ML20238E036

Requests Comments on Encl Advanced Notice of Proposed Rulemaking on Below Regulatory Concern by 860929

ML20238E036
Person / Time
Issue date:	09/12/1986
From:	Dragonette K NRC
To:	Ryan Alexander, Bell M, Brenneman F NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), Office of Nuclear Reactor Regulation, NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20238E005	List: IA-87-506, Forwards Paper Requesting Commission Approval to Publish Advance Notice of Proposed Rulemaking on Disposal of Radwastes Below Regulatory Concerns,For Concurrence & Signature ML20238E004 ML20238E014 ML20238E018 ML20238E031 ML20238E036 ML20238E044 ML20238E048 ML20238E052
References
FOIA-87-506 NUDOCS 8709140073
Download: ML20238E036 (28)

Text

g _ _ _-

N/jt, F

[jd)f;4gc55'o g _

7 ,g gg y

b Note for: Robert Alexander, RES-Mike Bell, WM Faith Brenneman, NRR Richard Cunningham, FC Robert Fonner, OGC

. Sue Gagner, PA 7 hn Philips, DRR

/

Don Nussbaumer, SP From: Kitty Dragonette

Subject:

Review of draft ANPRM on below regulatory concern

. Since each of you have been involved in the policy statement on this

-topic and are familiar with the issues-involved, I would like to impose on you to review.a working draft of the package while I'm on a much delayed vacation. 1;{Wi{lg.6e_out"oftheoff[ ptember16-26]

and would appreciate any handwritten comments you may have by the 29th.- Feel free to call (7-4300) this week if you can give feedback that soon or as soon after the 29th as possible. (The}SECQieldati diNNNAfgand we will need to move quickly when I return.

Many thanks 8709140G73 970909 &

F PDR FOIA

- = _ - _ a

.~

, f .

"4 $ '

k[$  ;

. Q 6,, , ~ j

% .4 ,

U

. i y , l

': t/2MORANDUM FOR: Victor Stello, Jr. .

. i s .* Exec,Jtive Director for Operations 4

L John G. Davis, Director

~

FEOM:

Office of Nuclear Materisl Safsty end Safeguards O

SUNECT: ADVANCE NOTICE OF PROPOSEDMULEMAV18G RECfRDINs ,

w d RADI0 ACTIVE WASTE BELOW REGULATORY CONCERN hY ,

.a \ nclosed E for.your coheterrence and signature is a Conn.ission pa to '

N Km J- Cyrwa.4a.no G4apActn L ib forwartfan . vance notice of proposed rulemaking (AhPRM) on dis sal of radioactive waste beleg regulatory concern.

($R^b In the steff reavirements memorandum j to you dated Au s t' 12, 1986

}t.u ' Th SMf responding to SECY-86-204, the Commire. ion ('Lt4 D.nJ Peeted that 4 an ANPRN on@

p/

-54 The-polic $%

j this subje forwarded y-stetement tM he Connission V a poli state mervr yg t- ,

b approved for publication and usegincluded a connitment to[ssue in/ d C f d [ & # .3 N as App 6ndix 8

~

+,,- w(th ANPRMin90B e W SO S % days.)Thepolicystatementwaspublishedgugust29, 1986 4 The t SECY due cate asstg& mwn.C OlvU:cQ@ wet l' n

Octobe SfQfstL W +u rsquirementt-memoranuum 4.

1. d--ne4Mac4why explicitTdjrectiortsorh a k i k S;gis. h ]M.W N PR (M

' hNPRM questions to be proposed in the notist. We have listed questions to w

addres ,ssue ve,ry broadly,jas suggested by sorr.e of the comments on the ffCY.86-2043al. lots.. The quest 7 ens are also directed at the merits of iimited ruleading or other options such 35 sdditional 4

___.m_m . _ _ _ _ _ _ _ _ _ _ _

Recommended rewrite fo. Stello memo Enclosed for your concurrence and signature is a Commissian paper to forward to request Commission approval to publish an advance notice of proposed rulemaking (ANPRM) on disposal of radioactive waste below regulatory concern.

In the staff requirements memorandum (SRM) to you dated August 12, 1986, responding to SECY-86-204, the Commission requested that the staff prepare an ANPRM to be forwarded for publication. The Commission approved a policy statement for publication and use that included a commitment to issue an ANPRM within 90 days. The policy statement was published as Appendix B to 10 CFR Part 2 on August 29,1986 (51 FR 30839). The SRM directed that the staff prepare an ANPRM with a SECY due date of October 14, 1986, The SRM did not include any explicit directions or questions to be proposed in the ANPRM. We have listed questions to address the issue very broadly, as suggested by some of the comments on the Commissioner's notation vote response sheets for SECY-86-204. The questions are also directed at the perits of limited rulemaking or other options, such as additional (Pick up with ynur text) l 1

l

- / n eg 2xplicif

&%&b' i guidance only. No picp;;ed course of action is proposed or indicated

'$ d {

as preferred in order to solicit the broadest range of coment.

,e This Comission paper has been coordinated with the "i Rule # f4 e, NWit a v .Q C ;.d ";;;r t , Office of Administration) es,d the Offic 7&vis

e. 4 Research, .A State Programs, Public. Affairs, and Nuclear Reactor Regulation. The. )

Office of the General Counsel has no legal objection. No significant disagreement:s or issues-have been identified.

i John G.- Davis, Director Office of Nuclear Material Safety and Safeguards

Enclosure:

As stated i

.For: The Commissioners.

From: Victor Stello, Jr.

Executive Director for Operations

Subject:

Advance Notice of Proposed Rulemaking'on Radioactive Waste Below Regulatory Concern

Purpose:

To request Commission approval to publish an advance notice of proposed rulemaking regarding generic rulemaking on radioactive wastes that are below regulatory concern.  ;

Background:

Section 10 of the Low-Level Radioactive Waste Policy ,

Amendments Act of 1985 (Public Law 99-240) requires the NRC to establish standards and procedures for considering and acting upon petitions to exempt specific radioactive waste streams from

)

regulation if the radioactive content is below regulatory concern. 1

)

% requirement was met by means of a Comission policy statement b %% Lis S to FR PJ %

and staff implementation plan which were published in ederal N , R%; AD Register on August 29, 9 6 (51 FR 30839). po icy statement and plan were forwarded to' the C,omt sqn by SEC 4 6-204. In the staff @G l

/

requirements memorandum dated August 12,'986, from Samuel J. Chilk to Q

.- N .

Victor Stell t al in response to SECY-86-2047the Commission expreised s its desire to publish an advance notice of propos'ed.

Yl l rulemaking in addition to the policy statement. The policy statement %V i

' l l

j

l .

Background paragraph - Draft Comission paper

, Following the first complete sentence in the Background paragraph, please

. rearrange the remainder of the paragraph as indicated below.

In order to' satisfy this requirement, a policy statement and staff irolemen-tation plan (SECY-86-204) were forwarded to the Comission for approval on July 11, 1986. In the staff requirements memorandum dated August 12, 1986, in response to SECY-86-204, the Comission expressed its desire to publish.

an advance notice of proposed rulemaking (ANPRM) in addition to the~ policy statement. In accordance with the Comission's request, the policy state-ment was amended to indicate that an ANPRM would be published within 90  !

days. The policy statement and staff implementation plan were published -

in the Federal Register on August 29,1986 (51 FR 30839) as Appendix B to 10 CFR Part 2.

i

g

~

b{ l

'was-amended to indicate-that such a notice would be published within N /

90 days 'as directed by the Comissibn. s 7 4' i ANPR/A Discussion: An advance-notice-of-proposed rulemaking- is enclosed for your approval as, Enclosure A. The notice requests public comment on whether the NRC should proceed with a generic rulemaking on the issue f so, how should ofradioactivewastesbelowdrkulatorydbcernan the NRt ,, The AMP wou vMe be, published

--we. proceed. 4"hblis tien no later than Wednesday, November 26, 1986 pub li ca+1on e h re"4ced to meet the Commission's 90-day commitment.

The NRC, has gs (9rding j

\S w We-have received comenty the Comission policy statement 2* A  ; and staff implementation plan. Enclosure B provides an overview of

?;- the coments received to date. In general.... .

I N

Informal feedback from potential petitioners indicates interest,in

_- k '

preparidand submitting petitions. Interest

~

bas 1 6 e_xpressed by x - ther6 beeO OO 1 utility groups and a medical group. Although we. have not received. p 3 Mbmi Walb- ' s any petitiongo date, feedback has been positive. In view of the a

ct poienki C-amount of information the- petitioner is being asked to provide, we s

y did not expect petitioners to be able to respond this 'soon. -

f.c4%

Recommendation: That the Comission promptly approve publication of N

the proposed Federal Register notice in Enclosure A. Approval no later than November 12, 1986 is needed to assure publication within the 90-day comitment. j g g NOTE:

w ea aan l

]

. 1

[  ;

p j l'

RewriteN5.2 i l

)

l Informal feedback frpm potential petitioners--utility groups and a medical 1 a 4 group have/com\ rts 04 unicated with the NRC on this subject--indicates interest in l 6

,- preparing and-submitting petitions in the future. Althkoughtherehavebeen l .no petition submittals to date, probably because of the amount of information a petitioner is being asked to provide, the feedback from these interested i 9roups has-been positive.

i

J ]

l 1

i a., That the appropriate Congressional committees are being infomed' by a letter similar to Enclosure C.

b., That copies of the notice will.be distributed to all i a 'NRC  !

- Ce-1::f on licensees. . low-level waste compact  !

V Commissions _ and other_c' State officials, and other

//

interested persons by the Office of Administration in L coordination with the Office'of State Programs.

c. That the Office of Public Affairs will issue a public l

announcement similar to Enclosure 0.-

Victor Stello, Jr.

Executive Director for Operations

Enclosures:

A. FR Notice B. Overview of Coments C. Draft letter D. Draft announcement l

Contacts:

K. Dragonette, NMSS 427-4300 R. Alexander,~RES 443-7976 R. Fonner, OGC 492-8692- ,

l 4

i I

t l

l

h k e

f t

/

hh b h i

I

m -

a .,

4,.

.j^y QJt) hW n J., n u jfhhtJJ.

y h .f [7390-01]-

NUCLEAR REGULATORY COMMISSION 10 CFR parts 2 and 20 Radioactive Waste Below Regulatory Concern; Generic Rulemaking

.l

' AGENCY: Nuclear Regulatory Consnission.

I ACTION: Advance notice of proposed rulemaking.

\

. SyMMARY: Tpe Nuclear Regulatory Conmission (NRC) is considering

• Gewit cA utt4

=A r.t: tc its . regulations to address disposal of' radioactive.

K

~

wastes that contain sufficiently ' low quantities or concentrations of radionuclides that their disposal does not need to be regulated.

.The NRC has already published a policy statement providing guidance for filing' petitions for rulemaking to exempt individual waste stre ic rulemaking could provide a more efficient and effective means of dealing with disposal of wastes bel w regulatory e, pro posed (hl i tat i on o4 N f0I. 8C V. concern. Tht3ac(tonwouldsupplementtheearlierresponsetoa A 3 SintOnt M ) T mandate (5ECl'1n Ion 10 the Low)-level Radioactive Waste Policy Amendments Act of 3

1985 (Pub, L- . QQ-MO) -

M swavaffuGJ+

Ga M N #

ora ajheca w  %

W"1 Mvud

)

g .

' D DATE: The coment period expires (90 days after publication).

-Comments received after this date will be considered if it is practical to.do so but assurance of consideration may not be given except as'to comments received on or before this date.

ADDRESSES: Mail coninents to Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555. Attention: Docketing and Service Branch, or deliver comments to the NRC's Public Document Room,1717 H

- Street NW, Washington, DC between 8:15 a.m. and 5:00 p.m. weekdays.

i 50fl.FURTHER INFORMATION CONTACT: Kitty S. Dragonette, Division of

~

Waste Manag ,

ffice of Nuclear M terial Safety and Safe W. uards,dA W NC telephon (301 427-430 or Rober ' Alexa . Office of Research, g

telephone (301)423-7976, U.S. Nuclear Regulatory' Commission, Vishington, DC 20555.

SUPPLEMENTARY INFORMATION: On August 29, 1986, the NRC published a policy statement and staff implementation plan 'regarding expeditious handling of petitions for rulemaking to exempt specific radioactive

'l wastestreamsfromdisposalinalicensedlow-levelwastedisppsa(l3 C aA> W dL4 h 16 Ug pg 1j facility (51 FR 30839). Thesta#

polic@y staTEnientar and plari'A e in the i mpleme%kion 4

nature of regulatory guidance for implementing existing requirements  !

for rulecking petitions in 10 CFR 2.802. The documents describe the kind of information petitioners should file to allow timely l i

Commission review of the petition and the decision criteria that j l

should enable expedited action on petitions.  !

1 I

i 1

^

. Rewrite No. 3

'FOR FURTHER INFORMATION CONTACT: Kitty S. Dragonette, Division of Waste Management, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Comission, Washington, DC 20555, -Telephone: 301-427-4300; or Robert E. Alexander, Division of Regulatory Applications, Office of Nuclear'-

Regulatory Research, U.S. Nuclear Regulatory Comission, Washington, DC 20555, Telephone: 301-423-7976.

1

_3 [ ]

sq,ICi% M M W Commenters should consult th otice itself {or-ossistancosist-in formulating thoir comments on'this issue. However, the decision criteria listed.in the~

. policy statement are repeated here for the readers' convenience.

ordws ISi hauA)

- --W 1. Disposal and treatment of the wastes as specified in the

. petition'will result in no significant impact on the quality of the human environment.

- - % 2; The maximum expected effective dose equivalent to an individual

. member of the public does not exceed a few millirems per year for normal operations and anticipated events.

~~ ~ #

7 3. The collective doses to the critical population and general population are small. I i

4. The potential radiological consequences of accidents or equipment malfunction involving the wastes and intrusion into disposal sites after loss of normal institutional controls are not ,

significant.

5. The exemption will result in a significant reduction in societal Costs.-

4

6. The waste is compatible with the proposed treatment and disposal options.

l 1

S i E ]

' 7. The exemption is useful on a naticaal scale. i.e., it is likely to be used by a category of licensees or at least a significant portion of a category. .

8. The radiological properties of the waste stream have been characterized on a national basis, the variability has.been projected, and the range of variation will not invalidate supporting analyses.

CV

9. The waste characterization is based on dat\ on real wastes.

10. The disposed fonn of the waste has negligible potential for recycle..

11. Licensees can establish effective, licensable, and inspectable programs for the waste prior to transfer to demonstrate compliance.

12. The offsite treatment or disposal medium (e.g., sanitary landfill) does not need to be controlled or monitored for radiation protection purposes.

i

13. The methods and procedures used to manage the wastes and to assess the impacts are no different from those that would be applied to the corresponding uncontaminated materials.

14. There are no regulatory or legal obstacles to use of the proposed treatmtnt or disposal methods.

[

y e

4 hJ 1seAmo 53 @

'/

lhe policy statement and lan respon'ded to.the 6-month mandate in the-5fAff i rnple me ntaf ion - ,

Low-level Radioactive Waste Policy Amendments Act.of 1985 for the NRC L{

to establishistandards and procedures for.' expedited action on  !

l

petitions. However, the Commission realizes that a: generic' rulemaking on the issues associated with findings that wastes may be disposed of by exempted methods without posing an undue risk to public health and. safety would reduce the issues to be considered in individual rulemakings 'on specific wastes. Generic rulemaking'could also address the broader issues associated with:the lower end of the l low-level waste spectrum. The 6-month mandate in the et effectively precluded rulemaking as'an initial approach but the Commission can. l now consider .the niatter more. carefully. . The policy statement and staff implementation plan will be used in the interim while the Commission considers rulemaking in the area. Publicatiori of this

' notice should in no way discourage petitioners from making maximum j use of the option ~ for expedited rulemaking on specific waste streams.

l The.NRC requests public comment on the general question of whether and how to proceed on the matter of-slightly contaminated radioactive materials. The NRC also seeks public comment with respect to the following issues and questions. _ (In responding, conrnenters are encouraged to provide specific suggestions, the basis for suggestions g ,

offered.. and references or contacts which may be useful.)  % /-

~

• ~-- . _

,. $ q 4 1 (1) Should the decision criteria in the Commission policy .

statement be codified in-10 CFR Part 2 as requirements instead of guidance? ,

C J

~ '

(2) Should the criteria'be applied to a 1 itions for disposal

'of wastes that may be'below regulatory concern 3 not just those V

intended for expedited handling?

1 1

(3) Should the decision criteria in the Comission policy statement be quantified where possible and then codified in 10 CFR

'1

- Part 2 to facilitate processing petitions? - j i

'l (4) Should additional criteria be added or criteria deleted before they are quantified and codified?

(5) The Environmental Protection Agency (EPA) has issued advance S

on two aspects of the lower

~

notices of proposed rulemaking (ANPR end of the waste spectrum. In its ANPRM on low-level wastes (48 FR

. / 39563 August 31,1983), EPA asked for comments on how to address wastes which do not need regulatory control to protect the public. In

/ its ANPRM published June ik86 (51 FR 22264), EPA requested comments on standards for residual activity in buildings and soils of .

y 82AbuMA)

In vi-

\

facilities being decommissioned. ^' the EPA's authorities) {

s Le w =d-responsibilitiesgand resources dictated fragmented efforts in ]

this area, how should NRC proceed while minimizing conflicts or j duplication of efforts? How can NRC help EPA obtain the resources and priorities needed to approach the issues more generically while not delaying the needed decommissioning ,eleted standards? How can f EPA be encouraged to use its Federal Radiation Council authority on a 1

)

I timely basis?

4

- - 1

E b' (6) Are there other national or. international activities that l

NRC should encourage or support that could negate or minimize the need for'further NRC action?. i (7) Should the NRC take an entirely different approach than that reflected in the policy statement and develop amendments to 10 CFR Part 20? For example, should NRC develop a risk or dose value that would represent generic regulatory cut-off levels for wastes? Should  !

the NRC try to establish concentrations or quantities that are below-regulatory concern regardless of the form or disposal circumstances?

1 (8) .Should amendments be developed for 10 CFR Part 20 that would allow individual licensees to independently determine which wastes are below regulatory concern without specific NRC approval? If so, tha#

should NRC develop and validate computer codes wMeh licensees would v i have to use to demonstrate compliance with a generic below regulatory  ;

concern risk or dose value? What documentation and reporting requirements should be included in such amendments?

(9) Should amendments be developed to facilitate approval of specific requests from individual licensees? For example, should NRC develop factors that must be considered in licensee proposals for y dealing with slightly contaminated materials? Should NRC identify factors that licensees may consider in such proposals?

l (10) How can NRC most effectively address the potential for exposures of members of the public from multiple practices or sources i

l

(

~

.c Lthat are.each below regulatory concern,(e.g., trash and: consumer

n ..

6-

} ,

products .to s'anitary landfills) 7 (11) Should NRC_' develop additional' guidance instead of

.rulemaking?y If so :what guidance would be most helpful?

t #

10 CFR V LIST OF SUBJECTS .IN Part 2: Administrative-practice and procedure, Antitrust,L Byproduct material, Classified information, Environmental protection .

Nuclear materials, Nuclear power plants and reactors, Penalty, Sex discrimination; Source materiala Special. nuclear material, and aste' -

treatment'and disposal.

d

.l, D1f4t Part 20: . Byproduct material, Licensed material, Nuclear materials, Nuclear power plants and reactors, Occupational safety g c4/ and health, Packaging and containers, Penalty, Radiation protection, f

- . g Reporting and recordkeeping requirements, Special nuclear material. -l Source material, and Waste treatment and disposal.

Dated'at Washington, DC this day of , 1986.

For the Nuclear Regulatory Commission.

dET d O6h(MtL) ()-h%b ^nL44C/ [L() /

Sn fuug NcitTL J1 uaq/v i Meg L M.NM M, e

hM 6} M

Samuel J. Chilk, Secretary to the Commission. -

l rca t

7, ,,

.- s

• /

,- <... . / 07

,f fg Y.f u/ w "Cd4 s

a

rww---- , . - - , _ _ _ _

e f d

V b

L L

i I

f a'n c we op .a,4 1

)

0 61 it] $ % V1h l

- Y$15

)

l 1

i i

i ENCLOSURE C I

Dear Mr. Chairman:

1 1

The U.S. Nuclear Regulatory Comission (NRC) is publishing an advance notice of proposed rulemaking regarding radioactive waste below regulatory concern.

The NRC previously published a policy statement and staff implementation plan in response to the requirements of Section 10 of the Low-Level Radioactive Waste P.olicy Amendments Act of 1985 (Public sta4-implementobon weres as Rppand x T3 b 10CFR, Law 99-240).. Thestatementandplan[ published ust 29, 1986 (51 FR >c,p t 2, y 30839 aN1 hed standards and procedures for acting on petitions .

. for rulemaking on specific wastes whose radioactive content is low enough to be below regulatory concern. The rulemaking contemplated in the enclosed notice may facilitate action on future petitions or may be more generic in nature and would be supplementary to the Ac,t mandate in the 4aw.

The enclosed notice is being sent to the Office of the Federal Register ef0 publication. A copy of a public announcement to be released by the NRC on this matter is also enclosed.

l Sincerely, S

k John G. Davis, Director Office of, Nuclear Material Safety and Safeguardr

Enclosures:

1. Federal Register notice

2. Public Announcement l

l

k ,. e 5

i w H0 fos re T ,c a d d P ll 2 {f.3, \

}

l 4

1 1

1 J

i I

1

~

, 'RIN N0. AC35 PROPOSED AGENDA ENTRY l TITLE:

Radioactive; Waste Below Regulatory Ccncern; Generic Rulemaking CFR CITATION:

10 CFR 2; 10 CFR 20 ABSTRACT:

The advance notice of proposed rulemaking (ANPRM) seeks coments on the NRC consideration to amend its regulations to address disposal of radioactive wastes that contain sufficiently low quantities of radionuclides that their disposal does not need to be regulated.

The NRC has already published a policy statement providing guidance for filing petitions for rulemaking to exempt individual waste streams (August 29,1986; 51 FR 30839). It is believed that generic rulemaking could provide a more efficient and effective means of dealing with disposal of wastes below regulatory concern. This ANPRM would supplement the policy statement which was a response to Section 10 of the Low-Level Radioactive Waste Policy Amendments Act of 1985 (Pub. L.99-240). The public will be asked to comment on 14 questions.

(Also needed is a discussion of alternatives and costs to affected industry and to NRC)

TIMETABLE: ,

ANPRM (Date to be published)

ANPRM Comment Period Begin ANPRM Coment Period End Proposed Action for Division Review Office Concurrence on Proposed Action Completed Proposed Action to E00 Proposed Action Published Final Action Published

n,

' h,,. '-,\

er'!

\

• ^( l. 9,

, / n

~, y e <

l,', .

t ,

L; , .

3i ,

.. ' LEGAL AUTHORITY:

w

. p e <

To Be CompletAd by rulemakipp author

q 'J EFFECTS ON SMALL BUSINESS-AND'0THER ENTITIES

Yes or No t

AGENCY CONTACT: <

Kitty: S. ' Dragon,,stte _

Nuclear Regulatory Commission Office of Nuclear, Material Safety and Safeguards' . , _ . d >.

Washington, DC 20$50 s.

301 427-4300: i :i '.r

,. 9 si e \;

y<

e

}

1 5 i k hy c )

, i i

6

f. >

)

5 o

i j

?

k r

- i d

^

s

(

t 9

s

(4,M o ,

I

'. L ,

1 N K D rn f)ct cy, j gy.

o

@y e

W

/d 7 e

y ,a

~

ROUTING AND. . .TRAN$gliTAL ......... SUP initiets Dete h

occe symbol, room twmby, 70c gaan / N/- -

y '

d i 1..

ff ael A lm -

8 S. .

S.). .. .Xf4n f.M L n Y.$$ \

. h a et f t l

A. ...

tshhS 2,- Musx

{m Note and Retum e co.=rsetwa ror ca.r.nc. Prepare Wy

, wi For Correcten See Me As Requested . For Your Information $lgnature ,

Circulate irrvestigste I f .:

& Comment Jumity -

YUh coordineten mu ((*

. !, 24

[ k{

h Yh ti bd*tseet lN d r(n* q r VS / S s b A

? h s {w {g n f4 b ^

(scf' fan/d W 'f l.. S*

/

,gh ,

' # f' b ,p u hNI J -

Y / 4(_ mak,

/,o ,%p iw rt Oas, af($ RECORDs pisoftapprovals, e .ob,ed nces, des /

s concurre clearances, and similar actsons Room No. --Sidg.

00 NOT use this form )

(Name, org, symbol. Agency / Post Phone

'7 - fNo. m r u u (nov. 7-76) nxm m=

y o,y r m,a g. .n.=

cL

. m .m s . n,.u. m,,

5/6

~ - - - - - _