ML19274E380
| ML19274E380 | |
| Person / Time | |
|---|---|
| Site: | General Atomics, 07000734 |
| Issue date: | 02/20/1979 |
| From: | Mowry W GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | Mccorkle G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7903230244 | |
| Download: ML19274E380 (3) | |
Text
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GENERAL AToWC COMPANY PO. Box 81608 SAN DIEGO. CAUFoANIA 92138 In Reply 17"I'553"O February 20, 1979 Refer To:
696-1028 Mr. G. W. McCorkle, Chief Physical Security Licensing Branch U.S. Nuclear Regulatory Cc==ission Washington, D.C. 20555
Subject:
10CFR73; Submission of Guard Training Plan: Dockets70-734; 50-89 and 50-163.
Dear Mr. McCorkle:
Recently the Cornission adopted new regulations affecting licensees whose activ-ities require physical protection pursuant to 10CFR73. Under the new regulations, paragraphs are added which require the submission of SECURITY GUAP3 TRAINING AND QUALIFICATION PLANS. Attached are copies of our plan as required.
Attached to this letter, docketed under 70-734, is a check in the amount of $8300 which your staff has advised us must accompany the transmittal. We presume that only one fee is necessary to cover the Commission's review of the plan which will eventually be incorporated as a section into our Physical Security Plan and apply equally to all of the subject licensed facilities.
By copy of this letter, the Division of Operating Reactors is also being noti-fled of our plans for Guard Training and Qualification. One copy each of the plan, however, is being submitted for each of our two reactor dockets.
General Atomic again expresses its concern with the Commission's policy of extr-acting fees to cover review of plans required by new regulation which are clearly the result of the Commission's upgrading its rules.
The Commission in adopting rules effecting fees made specific provisions for exempting from fees those cases where licensees made submissions to their plans which did not decrease their effectiveness. Similarly the Commission exempted suk issions which resulted from new Cecmission orders and regulatory improvements.
We be '.ieve that the submission of these additional plans clearly represents a Como'.ssion required change to licensing activities upgrading licensees physical protection standards and do not allow the licensees to engage in any new prev-iously unlicensed activity.
Within this framework, we believe the plan's review should be acceeplished without the extraction of fees. We remain concerned that through the implementation of such new regulations as mentioned above, each with its extracted fee places the Cecnission and its staff in a position of recommend-ing new regulations in part for the purpose of maintaining a funding level for its staff.
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G. W. McCorkle 696-1028 This, we believe to be in violation of guidance given by Congress through the Office Procedures Act and the justifications given supporting the Commission's rules implementing fees.
We look forward to the commission's specific justification whereby the fees continue to be extracted for each regulatory change which requires the addition of new information resulting from such upgraded practices.
Very truly yours, kw MUW
[ ifflimR.Mowry Licensing Administrator Nuclear Materials Control Division WRM:hes Attachments: Security Guard Training & Qualification Plan for General Atomic Company, 2/79 7 copies Check for $8300 cc: Director of Division of Operating Reactors U.S. Nuclear Regulatory Commission Washington, D.C. 20555 1 copy each for Docket 50-89 & 50-163 (w/o checks) 1 Plan for each Docket.
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No. 30198 / 7 GENERAL ATOMIC COMPANY REMITTANCE STATEMENT
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rv c;.e il0TICE T0 i!RC PUBLIC DOCUPEi1T ROOM The following item (s) are being withheld from public disclosure pursuant to the Atcmic Energy Act of 1954, as amended, and the Energy Reorgar.ization Act of 1974,
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