ML19332D367
| ML19332D367 | |
| Person / Time | |
|---|---|
| Issue date: | 04/10/1987 |
| From: | Surmeier J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rich Smith NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| Shared Package | |
| ML19332B436 | List: |
| References | |
| FRN-54FR49763, RULE-PR-170 AD23-1-13, NUDOCS 8912010078 | |
| Download: ML19332D367 (5) | |
Text
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O APR 101987 1
MEMORANDUM FOR:
Ronald M. Smith, Attorney i
Division of Rulemaking & Fuel Cycle Office of the General Counsel o
- FROM:
John J.:Surmeier, Acting Director Planning and Program Analysis Staff, NMSS-l
SUBJECT:
ColNENTS ON PROPOSED REVISION OF PART-170 We appreciate the briefing you gave us on'the proposed revision.
In response to your March 10, 1987 memorandum and items discussed during the briefing, NMSS has the following comments:
1 1.
Regional. Involvement p
L We suggest that the Regions be given the opportunity to comment on the proposed rule.
The Uranium _ Recovery Field Office:of Region IV will have to be involved in the process of gathering / analyzing historical data on uranium recovery to support this new. rule.
All five regions issue materials licenses; NMSS will take the lead in gathering / analyzing historical data for-this area.
1 2.
Flat' Fees for Materials Licensing During the March 19, 1987 meeting, you mentioned $2,000 arbitrarily as the-1-
threshold.
Such an approach for " full cost" vs. flat fees for materials l
licensees seems reasonable, provided that there are not too many material u
licensing cases-in the " full cost" categories.
The large number of l-material licensing actions-(about 6,000 per year) would make it very
-difficult to. keep accurate records of time spent:on each individual E
licensing action.
If $2,000 is the cutoff, it appears that " full _ cost" would. apply principally to large-irradiators (Category 3G). The numb 6r of licenses in this category is small enough that the licensing staff could j
be expected.to keep accurate-records.- We, hope-that whatever the threshold l
is,- it should be high enough-that only a small percentage (e.g.,1-5 l
percent) of material-licensing actions are subject to full cost.
l Please' note that the phrase describing Category 3G is broad enough to include not only the negacurie irradiators which might appropriately be charged " full cost," but also taletherapy-units with 12,000 Curie cobalt-60 sources used to irradiate various items (e.g., animals, bio-logical samples, etc.).
Consideration may need-to be given to revising the descriptive phrase for Category 3G to ensure that it covers only the
" service" irradiators or adding a new category specifically for " service" irradiators.
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g20go7s891129 170 MISC PDR 7
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- Ronald M. Smith 3
APR 101987 given by NMSS staff, application filed in a Region, etc.).or may n 6.
Fees for transportation quality assurance reviews (Category 10F)
NMSS recommends that QA reviews for transportation packages be changed
. from actual. cost to-flat fees.
require 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of staff time; we feel the administrative burden ofThe m discretely capturirig and reporting this' time may exceed the amount we 1
collect.
We suggest the'following labor rates be used to calculate the fees:-
a.
~ New use QA program for use and maintenance only - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
b.
. New QA orogram for use, maintenance, design and fabrication -
6-8 hours.
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Renewals / Amendments of QA program - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
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