ML20134B933
| ML20134B933 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 09/13/1996 |
| From: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Timbers W UNITED STATES ENRICHMENT CORP. (USEC) |
| Shared Package | |
| ML20134B936 | List: |
| References | |
| NUDOCS 9609230235 | |
| Download: ML20134B933 (9) | |
Text
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September 13, 1996
~.
Mr. William H. Timbers, President U.S. Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817
Dear Mr. Timbers:
In accordance with the Atomic Energy Act of 1954, as amended, the Nuclear Regulatory Commission is issuing the initial certification decision a4 proposed certificates of compliance for the U.S. Enrichment CorporatioLto operate the two gaseous diffusion plants leased from the Department of Energy, located in Paducah, Kentucky, and Piketon, Ohio. As required by the Act, NRC will report annually to Congress on health, safety, and environmental conditions at the enrichment plants, beginning in 1997.
Enclosed are the Federal Beaister Notice announcing the certificate decision, the proposed certificates of compliance for each plant, and the associated Compliance Evaluation Reports.
Section 76.62 of NRC regulations provides that certain persons may file a petition requesting Commission review of the certification decision within 15 days of publication of the Federal Reaister Notice. Unless the Commission grants any petition or otherwise acts within 60 days of publication of the Federal Reaister Notice, the decision will become effective and final.
NRC intends to assume regulatory jurisdiction over the plants from the Department of Energy on March 3, 1997.
Questions may be directed to Merri Horn or Carl Sawyer at (301) 415-7192.
Sincerely, WWW Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards
Enclosures:
- 1. Federal Reaister Notice
- 2. Proposed Certificate of Compliance for the Paducah GDP
- 3. Proposed Certificate of Compliance for the Portsmouth GDP
- 4. Compliance Evaluation Report for the Paducah GDP
- 5. Compliance Evaluation Report for the Portsmouth GDP Docket Nos. 70-7001 & 70-7002 3g
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September 13, 1996 l
Mr. William H. Timbers, President U.S. Enrichment Corporation l
Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817
Dear Mr. Timbers:
In accordance with the Atomic Energy Act of 1954, as amended, the Nuclear Regulatory Commission is issuing the initial certification decision and proposed certificates of compliance for the U.S. Enrichment Corporation to operate the two gaseous diffusion plants leased from the Department of Energy, located in Paducah, Kentucky, and Piketon, Ohio.
As required by the Act, NRC will report annually to Congress on health, safety, and environmental conditions at the enrichment plants, beginning in 1997.
Enclosed are the Federal Reaister Notice announcing the certificate decision, the proposed certificates of compliance for each plant, and the associated l
Compliance Evaluation Reports.
Section 76.62 of NRC regulations provides that certain persons may file a petition requesting Commission review of the certification decision within 15 days of publication of the Federal Reaister Notice.
Unless the Commission grants any petition or otherwise acts within 60 days of publication of the Federal Reaister Notice, the decision will become effective and final.
NRC intends to assume regulatory jurisdiction over the plants from the Department of Energy on March 3,1997.
Questions may be directed to Herri Horn or Carl Sawyer at (301) 415-7192.
Sincerely, MapeP Carl J.
l ello, Director Office of Nuclear Material Safety and Safeguards
Enclosures:
- 1. Federal Reaister Notice
- 2. Proposed Certificate of Compliance for the Paducah GDP
- 3. Proposed Certificate of Compliance for the Portsmouth GDP
- 4. Compliance Evaluation Report for the Paducah GDP
- 5. Compliance Evaluation Report for the Portsmouth GDP
i 49360 Federal Register / Vol. 61, No.183 / Thursday, September 19, 1996 / Notices l
l
[ Docket Nos. 70-7001; 70-7002]
Regulations (CFR), establishing 42003; and under Docket No. 70-7002, requirements and procedures for the at the Portsmouth Public Library,1220 Notice of Certification Decision for U.S.
certification process. After NRC review Gallia Street, Portsmouth Ohio,45662.
Enrichment Corporation To Operate and consideration of public comments, Notice of receipt of the application
{
Gaseous Diffusion Plants and Finding the final rule was published on appeared in the Federal Register (60 FR of No Significant impact September 23,1994 (59 FR 42944). Part 49026) on September 21,1995, allowmg AGENCY: U.S. Nuclear Regulatory 76, Tenincation of Gaseous Musion for a 45-day pubbc comment period on l
Commissix' Plants,' m, cludes procedural the appbcation and noticing pubhc l
ACTION: Certification of gaseous requirements, generally applicable NRC meetmgs to solicit public input on the l
diffusion plants.
health and safety standards, technical certification. A second notice appeared safety requirements, and safeguards and in the Federal Register (60 FR 57253) on
SUMMARY
- ne U.S. Nuclear Regulatory security requirements specific to the November 14,1995, providing for a 45-l Commission is issuing a certification CDPs.
day pubbc comment period on the l
decision for the U.S. Enrichment DOE currently continues nuclear compliance plan. Public meetings were Corporation (USEC) to operate the two safety, safeguards, and security held on November 28,1995, at the Vern 8aseous diffusion plants (GDPs) located oversight of the GDPs. DOE retains Riffe Joint Vocational Schoolin at Paducah, Kentucky, and at Piketon, ownership of the facilities and will be Portsmouth, Ohio, and on Demmber 5 Ohio. NRC is also issuing a Finding of msponsible for eventual 1995, at the Paducah Information Age No Significant Impact (FONSI) decommissioning of the sites.
Park Resource Center in Paducah, i
concerning NRC's approval of the USEC subnN its initial Kentu4 Eleven comment leuers wem mitificati n 8PP cation on April 18, received. Comments received during the li h
- h Pf* Pared by the U.S.
D En 1995. NRC's preliminary review of the comment period. together with initiSI 8PP ication determined that it did transcripts of the public meetings, are l
submitted b USE Y
not adequately address the standards available in the PDR and the LPDRs, and FOR FURTHER INFORMATION CONTACT:
NRC had established for the CDPs and were reviewed and considered by the i
Ms. M.L. Iforn. Office of Nuclear Material Safety and Safeguards, U.S.
did not contain enough information for staff during the certification evaluation.
Nuclear Regulatory Commission.
NRC to determine compliance with 10 The staff responses to the public Washington, DC 20555, telephone (301)
CFR Part 76. Therefore, by letter dated comments are also available in the Pw May 5,1995, NRC formally tejected the and the LPDRs.
415--8126; Mr. C.11. Sawyer Office of initial application and notified USEC As required by the Energy Policy Act, Nuclear Material Safety and Safeguards, that it had to submit a revised NRC consulted with the U.S.
U.S. Nuclear Regulatory Commission.
application. NRC's decision to reject the Environmental Protection Agency (EPA)
Washington, DC 20555, telephone (301) application was not a determination that about certification. EPA did not identify 415-8174.
the operation of these plants was unsafe any significant compliance issues.
SUPPLEMENTARY INFORMATION:
m in noncmnpliancs.
The USEC Privatization Act.
USEC submitted a revised contained in Public Law 104-134, was
Background
certification application on September signed into law on April 26,1996.
The President signed li.R. 776, the 15,1995, and a revised. DOE-prepared Agong other provisions,it amended the Energy Policy Act of 1992 (the Act),into compliance plan on November 6,1995.
Atomic Energy Act requirement for an law on October 24,1992. The Act The application pacia,,e includes: a annual application for certification to mended the Atomic Energy Act of safety analysis report; a quality require instead a periodic application, 1954, to establish a new government assurance pmgram; technical safety as determined by the Commission, but corporation, the U.S. Enrichment requirements; an emergency plan; an not less than every five years. Also, as Corporation (USEC), for the purpose of environmental compliance status report; required by the USEC Privatization Act, operating the uranium enrichment a nuclear material control plan; a NRC and the Occupational Safety and enterprise owned and previously transputatim pmtectim plan; a Health Administration developed a
{or protection of classined matter; ahysical protection plan; a security p operated by the DOE. The Act provided that within two years after enactment of describing coordination of their the legislation, NRC would promulgate waste management pmgram; a regulatory activities at the GDPs to standards that apply to USEC's decommissioning funding program, ensure worker safety.This MOU was operation of its GDPs at Paducah, KY, environmental information; and a DOE-published in the Federal Register on and Piketon, OH, to protect public Prepamd compliance plan. The NRC August 1,1996 (61 FR 40249),
health and safety from radiological staff requested additionalinformation hazards, and to provide for the common and revisions to the mrtification certihcation Decision of the Director, defense and security. The Act directed application and the complianm plan, OfBcm of Nuclear Material Safety and S
rds the NRC to establish and implement an and USEC responded during the period v
annual certification process under froin October 1995 through August The NRC staff has reviewed the which the GDPs would be certifisd by 1996.
certincatim application and the DOE.
the NRC for compliance with these h applimtion and all related non-prepared compliance plan submitted by standards. For areas where plant Proprietary, unclassified supporting USEC, and concluded that. :n operations are not yet in compliance, ini rmation and correspondence are combination with certificate conditions, the Act provided for a compliance plan available for public inspection and they provide reasonable assurance of Erepared by the DOE. The Act also CDPying at the Commission Public adequate safety, safeguards, and i
Document Room (PDR),2120 L Street, security, and compliance with NRC s oN" Ik NW, Washington, DC 20555, and at the requirements. Therefore, the Director, Congre o the sta On February 11,1994 (59 FR 6792),
local Public Document Rooms (LPDRs), Office of Nuclear Material Safety and the Commission published for comment under Docket No. 70-7001, at the Safeguards (Director)is prepared to a proposed new Part 76 to Chapter I of Paducah Public IJbrary,555 issue a Compliance Certificate and a Title to of the Codejffederal Washington Street, Paducah, Kentucky, compliance plan approval for each
l l
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Federal Register / Vol. 61, No 183 / Thursday. September 19. 1996 / Notices 49361 plant.The staff has prepared a Federal Register Notice on the air and water emissions or any l
8PP cation or compliance plan under uncontrolled releases, or otherwise li ant h c.h provid d a is of e g 76.37. or provided oral comments at adversely affect the environment.
staff's evaluations, bases for certificate any meeting held on the application or The maionty of the issues or areas of approval. and responses to public c mP aance plan conducted under noncompliance identified in the l
comments. The proposed Compliance 6 76.39. may file a petition, not compliance plan involve activities bs Certificates and Compliance Evaluation exceeding 30 pages, requestmg renew l,SEC to upgrade plant programs.
Peports are available m the PDR and the f the Director s certification decision procedures, and equipment to conform LPDRs The petition nust be filed with 'he
'o applicable NRC requirements.
The Amtial certificates will be issued Commission not ater than 13 dass arter Contmued operation under existing l
for an effective penod of approx 2mately Publication of this Federal Register plant programs and procedures, by 2 years, with expiration dates of N tice Any Person described in this itself, will not have a negative impact o l
December 31,1998. This is consistent Paragraph may file a response to any the level of effluents from plant l
with the new provision in Public 1 sw Petition for review, not to exceed 30 operations or otherwise adversely affect f l
104-134, the USEC Privatization Act.
Pages, within 10 days after the filing of the environment.
- h aded (c)(2) of the petition. Unless the Commission The only issue identified with regard '
l be omic Energy ct so b
grants the petition for review or to plant programs and procedures that
t for an annudafe P,lication otherwise acts within 60 days aAer the may relate to the quality of the y,,gg,,, gP g,
publication of this Federal Register environmentis, Environmental h"I"""Mi y]P t),
Not1@ hidal deim b Tmdhg Pmdes** for b Padumh ss f
Peri certificate application or compliance plant. This compliance plan issue will L
but not less than wery Eve plan will become Analcif no petition is ensure that all environmental data will Y'he steneuwes that two years is a remived within the designated 15-day be evaluated for trends to identify long-period, the Director willissue Anal term changes in the environment that Cepliance Certificates.
ma result from plant operations. The ce fica com ance two years signi6 cant progress will be made in Finding of No Significant impact at 6 p r
i a
implementing plant improvements As specified in 10 CFR 5 51.22(c)(19). data for any unusual results that might specified in the compliance plan.
an environmental assessment is not indicate an increase in radiological i
Therefore, uSEC will remtve an required for the certificates of releases from the Paducah Plant or in l
exemption from the requirements in compliance, themselves. However, the the dose to members of the public. The I
$$ 76.31 and 76.36 to submit an annual associated compliance plan describes staff finds the current practices to be application for certificate renewal in how and when the plants will be acceptable until new procedures are 1997. USEC will be required to 61e an brought into compliance with NRC established,in accordance with the application for renewal of the requirements in instances where plant procedure upgrade program, to certificates of compliance oy April 15.
compliance is lacking at the time of evaluate all environmental data for 1996.
certification. The staff has prepared the trends.
The requiresnents in $$ 76..*l1 and following environmental assessment on Plant equipment upgrades should -
76.36 for an annual appucation wer*
the compliana plan:
better ensure confinement of UF 8 and other effluents during normal and l
based on the previous statutory Environmental Assessmet*
accidental conditions, and, therefore, requirement for an annual application, will maintain or reduce the levels of which has been superseded. Derefor*
Identification of Preposed Action
- effluents from plant operations. The the exemptions from these requirements
& p H & is b p d staff has examined the two specific are justified under 5 76.23. which of the compliance plan associated with items of nonempliance that relate to specifically allows the NRC to grant certification of the GDPs. Afiorize theproving the effluents:"HEPA Filter Sy such exemptions from the requirements compliance plan would aut for both the Portsmouth and Paducah of Part 76 as it determines are GDPs to operate for a limited period P ants, and "High. Volume Ambient Ain l
authorised by law and will not endanger before achieving full compliance with Samplers" for the Paducah plant.
life, property, or the common defense, NRC's '*9uirements' Not all High Efficiency Particulate A and are otherwise in the public interest.
ne exemptions meet these criteria.
The Needfor Action (HEPA) filters have in-place efficiency Treasidea of= "" '- Authority Section 1701(d) of the Atomic Energy Performana testing in accordance wit)
Act of 1954, as amended b the Energy American National Standards Institute he certiflates of compliance will Pohey Act of 1992, states t at the GDPs Standard N510. Although the failure o become e5ective and the NRC will may not be operated by the Corporation the HEPA filters to perform properly assume regulatory authority over the unless the NRC "* *
- makes a.
could affect airborne radionuclide GDPs on March 3,1997, following a determination of compliance * *
- or emissions, no significant environment releases to the ambient air have been transition period. His transition period approves a plan...for achieving will give USEC time to revise compliance." Thus, NRC approval of the detected,in over ten years, that were attributed to HEPA filter failure. As I
Proadures and train mployees on the compliance plan is necessary to meet l
approved application. DOE will the requirement specified by the statute. reported in the USEC Environmental continue regulatory oversight dun,ng the Compliance Status Report, the transition period until NRC assumes EnvironmentalImpacts of the Action maximum dose to a member of the jurisdiction.
The staff has evaluated all the public from radionuclide air emission c mP ance plan issues with regard to for the Portsmouth plant in 1994 was li e"-
' Te Petiden Iw Review their environmental impacts. Individual 0.006 mSv (0.06 mrem) and for the USEC or any person whose interest issues or areas of noncompliance were Paducah plant in 1994 was 0.0016 mf may be effected, and who submitted evaluated to determine whether they (0.016 mremp, both well within the El written comments in response to the could produce any changes to routine 1 mSv (10 mrem) limit in 40 CFR Part
.,s '
i 49362 Federal Register / Vol 61. No 183 / Thursdar September 19. 1996 / Notices l
I
- 61. The staff concludes that the "HEPA Finding of so Significant Impact Filter System Testing" noncompliance On the basis of this assessment the will not significantly affect the quality staff has concluded that environmental of the bu=an environment.
impacts that would be created by this Although the new high. volume air action would not be significant and do sampling system has been in operation not warrant the preparation of an at the Paducah plant since August 1995.
Environmental Impact Statement.
+
sufficient data to establish the Accordingly,it has been determined capabilities of the system and to that a Finding of No Significant impact establish baseline radionuclide is appropriate.
concentrations at the station have not The Environmental Assessment and been completed. Data from the new the documents related to this proposed j
high volume air sampling system will action are avdlable for public help conArm the accuracy of data on inspection and copying at the i
annual radionuclide air emissions.
Commission's PDR and LPDRs.
Howow, since mad =um doens from l
Paducah annual radionuclide air Deted at RackvilleMland, tMs 2 day l
of september 1ees.
I seleases have been in the range of 0.0016 mSv (0.016 miem), well within For the Nuclear Regulatory Commission.
te A regulatay limit, the M g
g,,,,,,g,,y,,,'y,,,,,, y,,,,,,g,,,,7 concludes that the unavailability of data from the new high. volume air sampling j
system will not significantly affect the IFR Doc. es-240t9 Filed 9-to-96; 8:45 am)
I l
quality of the human environmeot.
"'8"***'*-'
More detailed information on the staff's evaluation is contained in the i
Compliance Evaluation Reports, which have been placed in NRC's PDR and in j
the 1.PDRs located in Paducah, t
Kentucky, and Portsmouth, Ohio.
Alternatives to the Proposed Action j
The proposed action to approve the compliance plan, along with the approval of the certi6 cation application.
would authorir.e USEC to continue operations of the CDPs under NRC regulatory oversight.
The "No Action" alternative would be to withhold approval of the compliance plan. Under this alternative, the GDPs would be shut down, or would continue to operate under DOE regulatory oversight until compliance is achieved.
Agencies and Persons Consulted in reviewing the certification application and compliance plan, and in
~j accordance with the Energy Policy Act of 1992, the staff consulted with EPA.
EPA did not identify any major concerns associated with the certification action or approval of the compliance plan.
1 Conclusion Based on the foregoing anaessment, the NRC staff concludes that the environmental effects of approving the compliance plan will be insignificant.
The staff believes that the compliance plan is sufficient to ensure that, during the interim period of noncompliance, plant operation related to areas of noncompliance will not significantly affect the quality of the human environment.
s
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DRAFT PROPOSED PAGE OF PAGES U.S. NUCLEAR REGULATORY COMMISSION l
CERTIFICATE OF COMPLIANCE l
FOR OPERATION OF GASEOUS DIFFUSION PLANTS Pursuant to the Atomic Energy Act of 1954, as amended, Title II of the Energy Reorganization Act of 1974, as amended (88 Stat 1242), and Title 10, Code of Federal Regulations, Part 76, and in reliance on statements and j
representations heretofore made by the applicant, a certificate is hereby j
l issued. This certificate is issued to certify that operation of the Gaseous l
Diffusion Plant identified in No. 5 below is in compliance with the standards set forth in Title 10 Code of Federal Regulations, Part 76, " Certification of Gaseous Diffusion Plants." This certificate shall be deemed to contain the conditions specified in Section 183 of the Atomic Energy Act of 1954, as amended, and is subject to all applicable rules, regulations, and orders of the Nuclear Regulatory Commission now or hereafter in effect and to any conditions specified below.
l I
i i
- 1. CERTIFICATE NUMBER 2.
REVISION NUMBER 3.
EXPIRATION DATE GDP-1 0
December 31, 1998 4.
ISSUED TO m====i um.o 5.
FACILITY AND LOCATION i
United States Paducah Gaseous Diffusion Plant Enrichment Corporation Paducah, KY 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 6.
DOCKET NUMBER 70-7001 i
l
- 7. CONDITIONS a io m een u.. pe.w =w a casmu. new=.
m ana.= is a====i up= nanne w.
w 1
8.
The United States Enrichment Corporation shall conduct its operations in accordance with the statements and representations I
I contained in the Certification Application dated September 15, 1995, and revisions dated January 19, 1996, May 31, 1996, July 26, 1996, August 1, 1996, and August 12, 1996, and in the Compliance Plan submitted July 12, 1996, July 15, 1996, July 18, 1996, and the revision submitted August 1, 1996.
9.
The United States Enrichment Corporation shall conduct its operations in accordance with the Technical Safety Requirements that are contained in Volume 4, Revision 5 of the Application dated August 1, 1996, as modified by Revision 6 o' the application dated August 12, 1996.
Changes to the Technical Safety Requirements shall require NRC approval prior to implementation.
10.
This Certificate of Compliance shall become effective on March 3, 1997. The NRC shall assume regulatory jurisdiction from the Department of Energy at 12:01 AM on March 3, 1997.
I I
DRAFT U.S. NUCLEAR REGULATORY COMMISSION PAGE_OF_ PAG 13 CERTIFICATE OF COMPLIANCE GDP-1 i
coun== m i
SUPPLEMENTARY SHEET 70-7001 I
w==en t
i i
i 11.
The Unites States Enrichment Corporation is hereby granted the 7
special authorizations and exemptions in Chapter 1, Section 1.8 of j
the Safety Analysis Report, Revision 5.
1 12.
The United States Enrichment Corporation is hereby granted an exemption from the requirements in 10 CFR 76.31 and 76.36 i
requiring submittal of a renewal application for the year 1997.
The next renewal application shall be filed by April 15, 1998, i
i FOR THE NUCLEAR REGULATORY COMMISSION Date:
By:
Office of Nuclear Material Safety and Safeguards Washington, DC 20555 l
40 s
I DRAFT
~
PROPOSED PAGE OF PAGES U.S. NUCLEAR REGULATORY COMMISSION CERTIFICATE OF COMPLIANCE FOR OPERATION OF GASEOUS DIFFUSION PLANTS Pursuant to the Atomic Energy Act of 1954, as amended, Title II of the Energy Reorganization Act of 1974, as amended (88 Stat 1242), and Title 10, Code of Federal Regulations, Part 76, and in reliance on statements and representations heretofore made by the applicant, a certificate is hereby issued. Thip ?ertificate is issued to certify that operation of the Gaseous Diffusion Pla:i identified in No. 5 below is in compliance with the standards set forth in Title 10 Code of Federal Regulations, Part 76, "Certifation of l
Gaseous Diffusion Plants." This certificate shall be deemed to contein the conditions specified in Section 183 of the Atomic Energy Act of 1954, as amended, and is subject to all applicable rules, regulations, and orders of the Nuclear Regulatory Commission now or hereafter in effect and to any conditions specified below.
- 1. CERTIFICATE NUMBER 2.
REVISION NUMBER 3.
EXPIRATION DATE j
GDP-2 0
December 31, 1998 4.
ISSUED TO mane== Ant =. i 5.
FACILITY AND LOCATION United States Portsmouth Gaseous Diffusion Plant Enrichment Corporation Piketon, OH 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 6.
DOCKET NUMBER 70-7002 7.
CONDITIONS This condicais is eumthaural upon Aalfllfug the,equiremens of 10 CFR Pa,t 76, as applicable. mui the emihixus bekm.
8.
The United States Enrichment Corporation shall conduct its operations in accordance with the statements and representations contained in the Certification Application dated September 15, 1995, and revisions dated January 19, 1996, May 31, 1996, July 20, 1996, August 1, 1996, and August 12, 1996, and in the Compliance Plan submitted July 12, 1996, July 15, 1996, July 18, 1996, and the revision submitted August 1, 1996.
9.
The United States Enrichment Corporation shall conduct its operations in accordance with the Technical Safety Requirements that are contained in Volume 4, Revision 5 of the Application dated August 1, 1996, as modified by Revision 6 of the application dated August 12, 1996.
Changes to the Technical Safety Requirements shall require NRC approval prior to implementation.
10.
This Certificate of Compliance shall become effective on March 3, 1997.
The NRC shall assume regulatory jurisdiction from the Department of Energy at 12:01 AM on March 3,
- 1997, a
DRAFT
=
U.S. NUCLEAR REGULAlDRY COMMISSION PAGE_OF_PAGES CERTIFICATE OF COMPLIANCE GDP-2 c.,*.= m SUPPLEMENTARY SilEET 70-7002 p=im mener 11.
The United States Enrichment Corporation is hereby granted the special authorizations and exemptions in Chapter 1, Section 1.8 of the Safety Analysis Report, Revision 5.
12.
The United States Enrichment Corporation is hereby granted an exemption from the requirements in 10 CFR 76.31 and 76.36 requiring submittal of a renewal application for the year 1997.
The next renewal application shall be filed by April 15, 1998.
FOR THE NUCLEAR REGULATORY COMMISSION Date:
By:
Office of Nuclear Material Safety and Safeguards Washington, DC 20555 i
t
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