ML20203F404

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Requests Comment from Interested Parites on Technical & Regulatory Aspects of Proposed GL Re Yr 2000 Readiness of Computer Sys at Npps.Comment Period Expires 980302
ML20203F404
Person / Time
Issue date: 02/04/1998
From: Bangart R
NRC OFFICE OF STATE PROGRAMS (OSP)
To:
GENERAL
References
NUDOCS 9802270295
Download: ML20203F404 (6)


Text

-

FEB 0 4 f338 STATE LIAISON OFFICERS STATE PUBLIC UTILITY COMMISSIONS PROPOSED GENERIC COMMUNICATION; YEAR 2000 READINESS OF COMPUTER SYSTEMS AT NUCLEAR POWER PLANTS The Nuclear Regulatory Commission (NRC) is proposing to issue a generic letter to all holders of operating licenses for nuclear power plants, except those who have permanently ceased operations and hava certified that fuel has been permanently removed from the reactor vessel, to require that all addresses provide certain information regarding their programs, planned or implemented, to address the Year 2000 problem in computer systems at their facilities, in particular, addressees are being asked to provide written confirmation of implementation of the programs, and written certification that their facilities are Year 2000 ready and in compliance with the terms and conditions of their licenses and NRC regulations. This information is being requested under 10 CFR 50.54(f).

The NRC is seeking comment from interested parties on both the technical and regulatory aspects of the proposed generic letter presented under the Supplementary Information heading.

Enclosed for your information is the notice of opportunity for public comment. The comment period expires on March 2,1998.

Further information on NRC and U.S. Government activities concerning the Year 2000 issue can be found on the NRC Homepage at http://www.nrc. gov /nrc/ news / year 2000.html.

OrynalS ed By RICHARD L@BANGART Richard L. Bangart, Director Office of State Programs

Enclosure:

As stated

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- WASHINGTON, D.C. 30646 0001

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STATE LIAISON OFFICERS STATE PUBLIC UTILITY COMMISSIONS PROPOSED GENERIC COMMUNICATION; YEAR 2000 READINESS OF COMPUTER SYSTEMS AT NUCLEAR POWER PLANTS The Nuclear Regulatory Commission (NRC) is proposing to issue a generic letter to all holders of operating licenses for nuclear power plants, except those who have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel, to require that all addresses provide certain Information regarding their programs, planned or implemented, to address the Year 2000 problem in computer systems at their facilities, in particular, addressees are being asked to provide written confirmation of implementation of the programs, and written certification that their facilities are Year 2000 ready and in compliance with the terms and conditions of their licenses and NRC regulations. This information is being requested under 10 CFR 50.54(f).

The NRC is seeking comment from interested parties on both the technical and regulatory aspects of the proposed generic letter presented under the Supplementary Information heading.

Enclosed for your information is the notice of opportunity for public comment. The comment period expires on March 2,1998.

Further information on NRC and U.S. Government activities conceming the Year 2000 Issue can be found on the NRC Homepage at http://www.nrc. gov /nrc/ news / year 2000.html.

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t fli Richard L. Bangart, Director Office of State Programs

Enclosure:

As stated

i 4498 Federal Jtegister/ Vel. 63, No.19/ Thursday, January 29,1998 / Noticos

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oATas: Comment period expires March greater environmental impact need not NUCLEAR REQULATORY be evaluated. As an alternative to the COMMISSION 2,1998. Comments submitted after this date will be considered if it is practical proposed exemption, the staff Proposed Generic Communication; to do so, but assurance of consideration considered denial of the requested Year 2000 Reediness of Computer cannot be given except for comments exemption. Denial of the request'would Systems et Nuclear Power Plants received on or before this date.

result in no change in current environmentalimpacts. The (MA0134)

A:casssts: Submit written comments ENC uclear Regulatory h

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U.S. Nuclear Regulatory Commission, g

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ACTION: Notice of opportunity for public Mail Stop T6-D69, Washington, DC Alternative Use of flesources comment.

20555-0001. Written comments may l

also be delivered to 11545 Rockville This action does not involve the use amamYt The Nuclear Regulatory Pike, Rockville, Maryland, between 7:45 of any resources not previously Commission (NRC) is proposing to issue am to 4:15 pm, Federal workdays.

8 considered in the " Final Environmental a generic letter to all holders of Copies of written comments received Statement Related to the Operation of operating licenses for nuclear power may be examined at the NRC Public Limerick Cenerating Station Units 1 plants, except those who have Document Room,2120 L Street, N.W.

and 2," dated November 1973.

permanently ceased operations and (Lower Level), Washington, D.C.

have certified that fuel has been pon FumTHER wonnaATioN CONTACT:

Agencies and Persons Consulted permanently removed from the reactor Matthew Chiramal, (301) 415-2845.

vessel, to require that all addnssees setmmy womasATm In accordance Wth its stated policy,d ido comin information regarding 1998, the staff consulte on!anung with the vivania State official Mr.

pmgr p

address the Year 2000 2000 Readiness of Computer Systems at David I

. e Bureau of Radiation (Y2K) problem in computer systems at Nuclear Power Planta their facilities. In particular, addressees Addressees n i o ments on, regarding the cgn t o ofimp ent o of the All holders of OPer..ing licenses for environmentalimpact of the proposed e

action. The State official had n programs, and written certification that nuclear power plants, except those who

comments, their facilities are Y2K ready and in have permanentl ceased o erstions ae com liance terms and Finding of No Significant Impact p

, en y rnov fro t en or i

vessel, Based upon the environmental regulations. This information is being assessment, the Commission concludes requested under to CFR 50.54(f).

Purpose that the pioposed action will not have The NRC is seeking comment from The U.S. Nuclear Regulatory a significant effect on the quality of the interested parties on both the technical Commission (NRC)is issuing this human environment.

and regulatory aspects of the proposed generic letter to require that all Accordingly, the Commission has generic letter presented under the addressees provide the following Supplementary Information heading. In information regarding their programs, determined not to prepare an this regard, the NRC encourages the planned or implemented, to address the environmental impact statement for the industry to propose a viable alternativ3 Year 2000 (Y2K1 problem in computer q

proposed action.

For further details with respect to the d ng tN n c

i ple Intati of e ss ssu an to the '(n rmation proposed action, see the licensee a letter $C that licensees are effectively programs, and (2) written certification dated December 23,1997, which is addressing the Y2K problem L, that the facilities are Y2K wad and in t

available for public inspection at the computer systems at their facilities.

com liance with the terms an Commission's Public Document Room.

Such an altemative could consist of a con itions of theirlicenses and NRC l

The Gelman Building. 2120 L Street, voluntary initiative on the part of the re8"lations' NW., Washington, DC, and at the local nuclear powerindustry to obtain public document room located at the licensee inputs and communicate its Description of Circumstances Pottstown Public Library,500 High tindings to the NRC.

Simply stated the Y2K computer Street, Pottstown.PA 19464.

The proposed generic letter has been problem pertains to the potential Dated at Rockville, Maryland, this 23rd day endorsed by the Committee to Review inability of computers to correctly Generic Requirements (CRGR). Relevant recognize dates beyond the current of January 1998.

information that was sent to the CRGR century, i.e., beginning with January 1, For the Nuclear Regulatory Commission' will be placed in the NRC Public 2000 and beyond. The problem results Bartholomew c, Buckley, Document Room. The NRC will from computer hardware or software Senior Project Manager. Profect Directomt' consider comments received from that uses two-digit fields to represent 1-2. Dmsion of Reactor Projects-l/II. Offsce interested parties in the final evaluation the year. lf the Y2K problem is not ofNuclear Reactor Regulation of the proposed generWetter.The corrected, computer systems will be

[FR Doc. 9&-2179 Filed 1-28-98; 8 45 aml NRC's final evaluation will include a unable to recognize the change in

    • uwo coos rseo-oM review of the technical position and, as century and will mistaad "00," for the appropriate, an analysis of the valuel year 2000, as 1900. The Y2K problem impact on licensees. Should this generic has the potential to interfere with the let'er be issued by the NRC,it will proper operation of any computer become available for public ir spection system, any hardware that is in the NRC Public Document Room.

microprocessor based (embedded

Federal Register /Vol. 63 No.19/ Thursday, January 89,1998 / Notices 4499 schware), and any softwan or database incorporated recognition of the Y2K function of a structure, system or at nuclear power plants. As a concern in the updated Standard component and (2) degrade, impair, or consequence, there is a risk that affected Review Plan (SRP), NUREG-0800, prevent operability of the nuclear plant systems and equipmant will fail to Chapter 7. " Instrumentation and facility.

function properly Control," dated Aufor staff review of

.ust 1997, which N####"

has a filed,proble'm is urgent because it The Y2K contains guidance non negotiable dead!!ne, computer based instrumentation and Diverse concems are associated with This matter requires priority attention control systems.

the potentialimpact of the Y2K problem because of the limited time remaining to At the Nuclear Utilities Software on nuclear power plants because of the assess the ma6nitude of the problem,its Management Group (NUSMC) Year variety and types of computer systems associated itschnical and cost risks, and 2000 Workshop, an industry workshop in use. Some of the concerns are the (1) l' 4 resource availabihty, and to implement held in July 1997, nuclear power plant scheduling of maintenance and programs that will achieve satisfactory licensees described their Y2K programs, technical specification surveillance resolution.

and gave examples of areas in which requirements,(2) use and application of Existing reporting requirements under they addressed Y2K issues in e der to -

programmable logic controllers and to CFR part 21, to CFR 50.72, and 10 ensure the safety and operabit of their other commercial off the shelf software and hardware,(3) o control systems, (4)peration of process CFR 50.73 provide for notification to the plants on January 1,2000. Some of the performance of NRC staff of deficiencies, non-issues discussed were the (1) evaluation conformance and failures, such as the of the impact of the Y2K problem on engineering calculatlons, and (5)

Y2K problem in safety related systems.

plant equipment (2) assessment process collection of operating and post.

To date, the NRC staff has not identified involved in the identification of Y2K accident plent parameter data.

nor received notification from licensees affected components, vendors, and Some ve:ciors have taken such or vendors of digital protection systems interfaces,(3) development of Y2K sctions as pladcg information on the (e g., Westinghouse, General Electric, testing strategies, and (4) identification Internet chem 63 which of their Combustion Engineering, Foxboro, of budget needs to address the Y2K Products are Y2X compliant, and how Allen Bradley, or Frematome/ Babcock & problem.

the vendor is addressing the Y2K Wilcox) that a Y2K problem exists with The Nuclear Energy institute (NEI) problem with respect to specific safety related initiation and actuation met with NUSMG and nuclear plant products, including products purchased systems. However, problems have been utility representatives in August 1997 to by their nuclear power plant customers.

identified in non safety, but important, formulate an industry wide plan to When addressing some of the particular computer based systems. Such systems, address the Y2K issue. On October 7, issues associated with the use and primarily databases and data collection 1997, representatives of NEl and application of software,it has been processes necessary for plant operation NUSMG met with the NRC staff to found that even if the application has no that are date driven, may need to be discuss actions NEI was taking to help apparent date manipulation algosithms, modified for Y2K compliance. Some utilities make their plants " Year 2000 it may still be affected by a Y2K related examples of systems and computer ready." NEI was preparing a framework problem. For example, a subroutine that equipment that may be affected by Y2K document with guidance for utility use date stamps the header information in problems follow:

in readying for the Year 2000. The archival tapes regardless of the rest of framework document makes a the content of the tape may be affected.

Security c mputers distinction in terminology between in addition, although individually Plant process (data scan, log. and alarm) and. Y2K readiness"("Y2K Ready"is several systems may be "date safe." the fr y s s\\em's Pa am i

Dt Putm defined as a computer system or integrated operations that the systems Ee n

Radiation monitoring systems application that fles been determined to support may be vulnerable to the Y2K Dosimeters and readers be suitable for continued use into the problem. Further, there are potential Plant simulators year 2000 even though the computer impacts from the operating system Engineering programs svstem or application is not fully Y2K supporting their instrumentation communicanon systems Comoliant) and "Y2K compliance" system's application software and from Inventory control systems

("Y2k Compliant"is defined as sub programs (such as calibration and surveillance and maintenance tracking computer systems or applications that data recording / reporting) associated

' D * '

accura'ely rocess dateltime data with the main application software.

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(including ut not limited to, One application which is common to To' alert nuclear power plant licensees calculating, comparing, and sequencing) all power reactor licensees is the link to the Y2K problem, the NRC issued from,into and between the twentieth between plant computers and the NRC's Informatica Notice (!N) 96-70," Year and twenty first ( enturies, the years Ersergency Response Data System 2000 Effect on Computer System 1999 and 2000, and leap-year (ERDS). This application performs the Software," on December 24,1996. In IN calculations). NEl/NUSMG !ssued the communication and data transmission 96-70 the staff described the potential framework document NEl/NUSMG 97-function which provide near real time problems that nuclear power plant 07," Nuclear Utility Year 2000 data availability to NRC and state competer systems and software may Readiness" to all licensees in November incident response personnel during encounter as a result of the change to 1997. The document recommends declared emergencies The NRC is the new century and how the Y2K issue methods for nuclear utilities to attain currently performing Y2K related may affect NRC licensees, in IN 96-70 Y2K readiness and therel'y ensure that upgrades to ERDS which will maintain the staff encouraged licensees to their facilities remain safe and continue the same cammunication protocol as the examine their uses of computer systems to operste within the requirements of current system with the exception that and software well before the turn of the their license. The scope of NEl/NUSMG either 2 digit or 4 digit year fields will century and suggested that licensees 97-07 covers software, or software-be accepted. Those licensees that consider actions appropriate to examine based systems or interfaces, whose anticipate changes to their ERDS link and evaluate their computer systems for failure (due to the Y2K problem) would should allow Nme in their schedules for Y2K vulnerabilities. The NRC staff also (1) prevent the performance of the safety retesting their systems. NRC contractors

4500 Federal Regiter/V:1, 63, N3.19/ Thursday, January 29,1998 /N:tices will support requests for testing on a requirements and the chane properly inbrmation will enable the staff t.

  • first come, first served" basis.

documented.

verify that each nuclear powerp! ant licensee 18 imp ementing an eflective l

NEl/NUSMG 97-07 suggests a strategy

  • Wd R"Ponse plan to address the Y2K problem and for developing and implenenting a la order to gain the necessary provide for safe operation of the facility cuclear udlity Y2K program. The assurance that addressees are effecuvely 'before January 1,2000, and is in stategy recognizes management, addressing the Y2K problem and are in compliance with the terms and
  • implementation, quality assurance, compliance with the term and conditions of their license (s) and NRC i

regulatory considerations, and conditions of their licenses and NRC regulations. The following NRC documentauon as the fundamental ngulations, the NRC staff requires that regulations are a basis for this request:

q elements of a successful Y2K project.

all addressees submit a written response e to CFR 50.36," Technical

)

The document contains additional Specifications," paragra ph (c)(3),

to this generic letter as follows:

guidance for these funlamental (1) Within 90 days of the date of this

" Surveillance requirements," and clements. The recommended pneric letter, submit a written nsponse parograph (c)(5)," Administrative components for management p}anning indicating whether or not you have controls." These relate, respectively, to requirements relating to test, calibration, an manakement awanness,nsors ip pro}ectleadership, pro}ect (ursued and an continuing to ursue a or inspection to assure that the 2K readiness program as ou ed in s

o jectives, p'roject management team.

NEIINUSMC 8747'II are n t necessary quality of systems and management plan, project te orts, conforming to the NEl/QSMG componen9 % maintained, and to interfaces, resources, oversig t, and guidance, pnsent a brief descri tion of provisions relatin to management, quality assurance. The suggested phases the pmgram(s)that have alread been procedures, reco keeping, and review 1

cf implementation are awareness, initial C mP eted, an being conducte, or are and audit necessary to assure operation l

assessment (which includes inventory, planned to ensure Y2K readiness of the of the facility in a safe manner, i

computer systems at our facility (les).

10 CFR 50.47," Emergency plans "

categorization, classificadon.

This response shoul!addass the paragraph (b)(8), which re..es to the b

kss (incjuding v'endor evaluation, uti3ity-program's scope, assessment process, provision and maintenr.e of adequate j

sm t e a le assess t

and plans for corrective actions emergency facilities and equipment to I

and schedules).

support the emergency responses.

cwned or supported softwere (including testink,eting your Y2K e Appendix B to 10 CFR Part 50, 4

i cvaluauon, interface evaluation', Y2K (2) Upon comp Criterion m," Design Control," requires remedial planning), remediation rogram, or,in any event, no I

readiness fuly 1,1999, submit a writtert that design control measures shall testing and validation, and notification.

liter than The quality assurance (QA) measures response confirming that your facility is provide for verifying or checking the apply to project management QA and Y2K rsedy and in compliance with the adequacy of design, such as by the implemaatation QA.

terms and conditions of your license (s) performance of design reviews, by the Regulatory considerations include the and NRC regulations. In addition, the use of alternate or simplified performance of appropriate reviews, response should contain a status report calculational methods, or by the reporting requirements, and of work remaining to be done to performance of a suitable testing documentation. Docum3ntation of Y2K, complete your Y2K program, including

program, program activides and results includes completion schedules. ("Y2K Ready"is
  • Appendix B to 10 CFR Part 50, Criterion XVD," Quality Assurance documentation requirements, project defined as a computer system or Records," requires that sufficient rnanagement documentation, vendor application that has been e'etermined to records shallbe maintained to furnish documentation, inventory lists, be suitable for continued use into the evidence of activities affecting quality.

checklists for initial and detailed year 2000 oven though the computer The records are to include, among assessments, and record retention. NEl/ system or application is not fully Y2K NUSMG 97-07 also contains examples Compliant. "Y2K Compliant" is defined others, operating logs and results of of various plans and checklists as as computer systems or applications reviews.

NE:/NUSMG 97-07, when properly calculating, comparing and sequencing) which relates to the provision and implemented, will present an from,into and between the twenueth maintenance of licensee links to the appropriate approach for licensees to and twenty first centuries, the years Emergency Response Data System.

in addiuon, the following address the \\,2K problem at nuclear 1999 ar.d 2000, and leap year requirements from Appendix A to 10 power plant facilities-calculstions.)

CFR part 50, "Ganeral Design Criteria in the course of implementing the Address the written reports to the for Nuclear Power Plants", also provide Y2K readiness program, problems could U.S. Nuclear Regulatory Commission, a basis for the request: (in the statement be identified that potentially impact the Attention: Document Control Desk, of consideration (SOC) for the licensing basis of the plants in certain Washington, D C. 20555-0001, under cases, license amendments may be oath or affirmation under the provisions amendment to 10 CFR part 50 which needed to address the probtem of Section 182a, Atomic Energy Act added Appendix A,"GeneralDesign resolution. Licensees should submit 1954, as amended, and 10 CFR 50.54(f).

Criteria for Nuclear Power Plants,"

such license amendments to the NRC an in addluon, submit a copy to the Published in the Federal Register on a timely basis. The utility Y2K readiness appropriate regional administratdr.

February 20,1971, the Commission noted that the general design criteria programs and schedules should have BacAfit Discussion added as Appendix A to Part 50 the flexibility to accommodate such an eventuality. In addition, licensees are This generic letter only requests establish the rninimum requirements for reminded that any changes to their information from addressees under the the principal design criteria for water-facilities that impact their current provisions of Section 182a of the coole,:1 nuclear power plants similar in licensing basis must be reviewed in Atomic Energy Act ol1954, as amended, design and location to plants for which accordance with existing NRC and to CFR 50.54(f).The requested construction permits have been issued 1

Foileral Regleter/V:1. 63, NO,19/ Thursday, January 29,1998 /N;tices 4501 by the Commisalon. Principal design Nuclear Regulatory Commission (NRC) available for publicinspection and criteria utablished by an applicant and take acdon with regard to Envirocare of copying at the NRC Public Document accepted by the Commission will be Utah,Inc. (Envirocare). The Petitior,tr Room,in the Gelman Building,2120 h incorporated by reference in the requests that the NRC:(1) Conduct an Strwt NW., Washington, DC 20555.

construction permit. The SOC also notes imme<1 late investigation ofissues raised Deted at Rockville Maryland, this 16th day that in considering the issuance of an in the Petition and immediately of lanuary 1998.

operating license under part 50, the suspend Envirocare's NRC license:(2)

For the Nuclear Regulatory Commission.

Commission will require assurance that conduct an investigation of possible cul). Peperieue, thne criteria have been satisfied in the criminal violations of section 223 of the detailed design and construcuon of the Atomic Energy Act of 1954, as amenced py,,,,,, pff,,,,f y,,j,,, y,,,7j,j g,j,,7

)

end sofeguards.

facility and any changes in such critaria (tha Act):(3)immediately suspend are justified.It should be noted that a Envirocare's !! cense with the State of (FR Doc. 96-2178 Filed 1-2s-98. B 45 aml

)

proposed Appendix A to 10 CFR part 50 Utah,under section 274)(2) of the Act; was published in the Federal Register (4) investigate the adequacy of the State on July 11,1967, and the comments and of Utah agreement state program t sugge:Uons received in response to the Protect whistle blowers;(5) contact each RAILROAD RETIREMENT BOARD notice of proposed rule making and current and former Envirocare employee Proposed Collection; Comment subsequent developments in the personally, on a confidential basis, to R89ueet technology and in the licensing process advise them of their rights to inform the 1

have been considered in developing the NRC of urrafe practices and violations, susesAM: In accordance with the general design criteria.)

to inform them of the protections requirement of Section 3506(c)(2)(A) of e Appendix A to 10 CFR part 50, available to them, and to ask them if the Paperwork Reduction Act of 1995 General Design Criterion (GDC) 13.

they have any information which they which provides opportunity for public

" Instrumentation and control," which wish to disclose, on a confidential basis comment on new or revised data addruses the provision of appropriate or otherwise; and (6) order a special collections, the Railroad Retirement instrumentation and controls to monitor independent review of Envirocare's Board (RRB) will publish periodic and control systems and variah!es relatlonships with its employees, along summaries of proposed data collections.

during normal operation, anticipated the lines of the review ordered by the Comments Are Invited On s sia is or t is re ue t,the (a) Whether the proposed information co dition a p priats o ens adequate safety.

Peutioner states that Envirocure's collection is necessary for the proper

  • Appendix A to 10 CFR part 50 CDC employee-related practices and performance of the functions of the 19 " Control room," which requires the contractual provisions constitute a agency, including whether the vi la provision of a control room from which NRC, tion of 42 U.S.C. 5851 and the information has practical utility:(b) the s whistle blower protection accuracy of the RRB s estimate of the actions can be taken to operate the nuclear plant safel regulations under Parts 19 and 40 of burden of the collection of the
  • Appendix A to to CFR part 50, GDC Title 10 of the Code of Federal information:(c) ways to enhance the 23 " Protection system failure modes."

Regulations (i.e., to CFR 10.16,19.20, quality, utility, and clarity of the an 40.7). Specifically, the petitioner information to be collected: and (d) which uires that the system $ hall be designefrotection to fall into a states that current and former ways to minimize the burden related to safe state or into a state demonstrated to Envirocare employees who have the collection of information on r vided to governmental authorities respondents, including the use of

[nf rmation adverse to Envirocare s be acceptable on some other defined automated collection techniques or basis' interests fear for their lives and the lives other forms of information tecimology.

Dated at Rockville, Maryland, this 23rd day of their families, should theiridentities of January 1998.

become known to an officer of 8 an urPm dabnahn For the Nuclear Regulatory Commission.

Envirocare. The petitioner also states Collection Jack W. Ree.

that certain provlsions in Envirocare's Withholding Certificate for Railroad Acting Director. Division o/ Reactor Program standard employment contract prevent Retirement Monthly Annuity Payments:

Mo nogement. Office of Nuclear Reactor its employees from disclosing to the OMB 3220-0149.

Regulation.

NRC information concerning unsafe The Internal Revenue Code requires

[FR Doc. 98-2182 Filed 1-28k-98. 8.45 am) practices and violations under the NRC all payers of tax liable private pensions anuno coor nn.ew heense and threaten them with severe to U.S. citizens to: (1) Notify each financial penalties in the event of a recipient at least concurrent with inhial disclosure.

withholding that the payer is, in fact, NUCLEAR REGULATORY The request for an investigation and withholding benefits for tax hability and COMMISSION the suspension of Envirocare's NRC that the recipient has the option of license is bein treated pursuant to 10 electing not to have the payer withhold, p,

CFR 2.206 of t e Commission's or to withhold at a specific rate:(2) 1869) regulations. The request has been withhold benefits for tax purposes (in Envirocere of Utah,Inc.; Notice of referred to the Director of the Office of the absence of the recipient's election Receipt of Petition for Director's Nuclear Material Safety and Safegaards. not to withhold benefits); and (3) notify Decision Under 10 CFR 2.206 As providad by 6 2.206, appropriate all ben-ficiaries, at least annually, that action will be taken on this petition they have the option of changing their Notice is hereby given that by petition within a reasonable time. By letter dated withholding status or elect not to have dated December 12,1GJ7, Mr. Thomas January 16,1938, the Director denied benefits withheld.

B. Cochran. Director of Nuclear the petitioner's request for immediate The Railroad Retirement Board Programs, Natural Resources Defense action concerning Envirocare's NRC provides Form RRB-W4P, Withholding Council (NRDC) requested that the U.S.

license. A copy of the petition is Certificate for Railroad Retirement

.