ML19321B087

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Forwards Safeguards Amend Fee for NRC Review of Physical Security Plan.Requests Reconsideration of Fee.Licensee Submitted Plan in Response to Regulatory Requirement & Was Not Applying to Amend License SNM-21
ML19321B087
Person / Time
Site: 07000025
Issue date: 06/12/1980
From: Remley M
EMVROCIE, ROCKWELL INTERNATIONAL CORP.
To: Weiss D
NRC OFFICE OF ADMINISTRATION (ADM)
Shared Package
ML19321B085 List:
References
80ESG-5748, NUDOCS 8007250588
Download: ML19321B087 (1)


Text

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g Energy Systems Group 8900 De Soto Avenue Canoga Park.CA 51304 Telephone:(213) 341-10C0 Rockwell TWX: 910-494-1237 Telex: 181017 InteinatiOnal June 12, 1980 In reply refer to 80ESG-5748 Mr. Douglas Weiss License Fee Management Branch Silver Spring Office Office of Administration U. S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Safeguards Amendment Fee, Docket 70-25

Dear Mr. Weiss:

Your letter of June 2,1980, indicated that our physical protection plan for special nuclear material of c 7derate and low strategic significance has been classified as requiring c. major amendment to License SNM-21.

Therefore, a major safeguards amendment fea of $8,300 is required as specified in Category 1A'of Section 170.3i of 10 CFR 170. A check in the amount of $8,300 payable to the U. S. Nuclear Regulatory Commission is enclosed in payment of that fee.

However, we wish to point out that our submission of the plan had been made solely in response to a new regulatory requirement and was not an application for any new authority or activity to be implemented under License SNM-21.

We believe that submissions to meat the requirements of new regulations should not be subject to the im;

/ tion of application fees for amend-ments to existing licenses.

We s. mit that the current interpretations of the applicability of license amendment application fees to this sub-mission is irregular, and we solicit review and reconsideration of the necessity for the enclosed fee.

Sincerely Lf M. E. Remley, Direqqor Health, Safety & Radiation Services gt

Enclosure:

Check No. 07116152 i

j 80 07250588