ML19256A577
| ML19256A577 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 12/14/1978 |
| From: | Mowry W GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | Weiss D NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| NUDOCS 7901090044 | |
| Download: ML19256A577 (3) | |
Text
.
=
)
=y m.Lc.,c-
_- - _ =.
,~
=. = -
GENERAL ATOMIC COMPANY Po box 91(06 SAN DIEGO. CAUFCANIA W8 In Reply pty m ue December 14, 1978 f'*-ReferTo:
,696-1006
-~-.. ~,,, {, "'
.v
$ ~ ~ ~ _ R - ) 3]
- . :, D
--:8
~
Mr. Douglas Weiss
'-J---'*---
t r
License Fee Management Branch n_
Silver Spring Office l
3 Office of Administration Nuclear Regulatory Commission f....,.i" ' ' ' "
Washington, D.C. 20555 I
'?
l..
~. '... ~~-... __
Subject:
Docket 70-734; Fee Submittal re Contingency Plan.
'N w
Ref, a:
NRC letters dated September 29, 1978 and December 1, 1978.
b:
GAC letter dated September 19, 1978, re Contingency Plan, Ref. 696-797.
Gentlemen:
General Atomic Company (CAC) has received your letter, Ref, a, advising us to pay fees in the amount of $8300, presumably to cover the costs of the staff's review of our submitted contingency plan. We herewith submit under protest and without prejudice to our right to claim a refund of this or any future fees, a check in the amount of $8300.
The applicable control number is 10834.
General Aton!' Company, pursuant to a new regulation, was required to preparc a contingency plan in a specified format and submit such a plan for NRC re-view and approval. General Atomic was and is not an applicant requesting new authority or activity during consideration of the new regulation effecting con-tingency plans, nor are we requesting a license amendment.
Previously approved plans for coping with emergencies z ad physical protection of facilities contain-ing Smt, contained the essential elaments of the plan nov submitted in response e the new regulation. We believe ;1censees charged with compliance with new regulations should not be subject to the imposition of fees, or, at most, should be charged only the fee for administrative ame;.dments.
This revision of the regulation implementing a specific format for contingency plans coupled with exaction of a 7tossly excessive fee can only lead one to believe that the NRC staff has no found a way to self-perpetuate the bureau-cratic process unfettered by congressional control over its budget. Presumably licensees may now look forward to a plethora of other regulatory revisions which will also require a new or revised docu=ent submittal, each with a huge fee.
790109004 I
?~ / 3:7 i
e C
pn a
.1 -
. m s...
-w a s.
Douglas Weiss 696-1006 General /.tomic believes that a new applicant requesting NRC license has a=ple opportunity to consider the regulations in effect at the time and can corres-pondingly exercise the option of streamlining the various docu=ents required of an applicant to eliminate redundancies and overlapping. Existing licensees have no such opportunity in that their procedures and documents must be altered on a piecemeal basis as the modified regulations become effective. The staff's current interpretation of the applicability of fees in this case is highly sus-pect, and we request a formal interpretation by the General Co'insel.
Very truly yours, s
f/
j
!b 4 [8 ' (
-d William R. "cery Licensing administrator Nuclear Materials Control Division WiUl:hes
Enclosure:
Check for $8300.