ML19242B829

Rescind Fy 2020 Annual Fee

ML19242B829
Person / Time
Site:	Aerotest
Issue date:	08/28/2019
From:	Slaughter D Aerotest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML19242B829 (1)

Text

AEROTEST OPERATIONS, INC.

3455 FOSTORIA WAY* SAN RAMON, CA 94583 * (925) 866-1212

• FAX (925) 866-1716 August 28, 2019 AEROTEST RADIOGRAPHY AND RESEARCH REACTOR DOCKET NO. 50-228/LICENSE NO. R-98.

ATTENTION: Document Control Desk NRC' s Chief Financial Officer U.S. Nuclear Regulatory Commission White Flint North 11555 Rockville Pike Rockville, MD 20852-2738

Subject:

Rescind FY 2020 Annual Fee Ladies and Gentlemen:

I am requesting that the annual fee for the fiscal year 2020 be rescinded for the reactor license R-98, docket number 50-228. Aerotest Operations, the license holder, declared cessation of operation on December 6, 2018. (The reactor has not operated since 2013.) The initial submission for the license amendment for fuel-possession-only was submitted on March 21, 2019 with additional supplemental information for inclusion submitted in written communications dated June 28 and August 14, 2019. The license amendment review is currently under way by the NRC staff(NRC letter dated July 30, 2019).

This request is supported by the language in 42 USC 2214 that state fees should be "for services or a thing of value" to the operating part 50 licensees; this belief is also reflected in the language found in 10 CFR 171.15(f). (ARRR is no longer an operational reactor.) Also, NUREG 1537-17.1.2 states. "If a non-power reactor is subject to annual licensing fees, the granting ofa possession-only license amendment also removes the basis for annual fees."

Aerotest Operations' intent is clear and has acted responsibly in seeking an amended license, thus, should not be penalized for NRC and Licensee review limitations.

Should you have any questions or require additional information regarding this submission, please contact AO President David M. Slaughter, Ph.D. at (801) 631 5919 or dmsraven@gmail.com.

I declare under penalty of perjury that the statements above are correct and truthful.

t"l~outv-- c:J 7* - - - - -

David M. Slaughter, Ph.D.

President, Reactor Administrator, Manager Aerotest Operations, Inc.

Cc Office of the Chief Financial Officer USNRC Post Office Box 979051 St. Louis, Mo. 63197