ML19350C934

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Responds to Licensee 810205 Request for Review of NRC Invoice 211-81 Re Transportation Route Approval.Invoice Will Be Revised to Reflect 13 Manhours Expended for Review,Rather than 27.5 Manhours Initially Reported
ML19350C934
Person / Time
Site: 07000734
Issue date: 04/01/1981
From: Miller W
NRC OFFICE OF ADMINISTRATION (ADM)
To: Hogan J
GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
References
NUDOCS 8104100425
Download: ML19350C934 (2)


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UNITED STATES

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NUCLEAR REGULATORY COMM!SS:CN

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General Atomic Company (2

ATTN: M r. i.1 P. Hogan 4 " g ug D Senior Counsel a

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8 P.O. Box 81608

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San Diego, CA 92138 h--7.h /

wJ Gentlemen:

This refers to your letter dated February 5,1981, concerning the fee assessed by NRC Invoice No. 211-81 for review of a transportation route approval.

Your letter requested (1) the reasoning by which the NRC reached its decision to charge fees for route approval reviews as "special projects", and (2) details of the 27.5 man-hours expended in the review of your May 6, 1980 request for route approval.

The "Special projects" category in 1170.31 of the Commission's license fee schedule was designed to cover those applications or submittals which require review and approval by the NRC, for which a specific fee category would not be applicable. Because Section 73.37 of Part 73 required NRC staff review of route approval requests and, because the review would not result in an amendment to a specific NRC license, we determined at the time 573.37 became effective that the review of route approval requests would be subject to fees pursuant to fee Category 13, as special projects.

As stated in your letter, 5170.12(e) specifics that the fees for special projects are to be paid "when the review of the project is completed". As you are aware, fees for special projects are determined by the amount of professional manpower expended by the licensing staff to conduct the review, plus any contractual support services required.

Even though the review of your request was completed June 6,1980, the Licensing staff did not furnish us with the manpower data for the review until November 1980; consequently, there was a six-menth delay in notifying you of the fee due for the review.

In order to get the details of the 27.5 man-hours devoted to reviewing the route approval, we referred your request to Mr. George McCorkle, Physical Security Licensing Branch, Office of Nuclear Material Safety and Safeguards, because his office "rocessed the application and reported the review time involved.

Based on a reassessment of the 27.5 man-hours previously reported, Mr. McCorkle has new informed us that only thirteen (13) hours should be charged to the approval. The thirteen hours were associated with the research, preparation, coordination and finalization of the approval. We understand that the other hours related to follow-up and shipment monitoring activities which

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Mr. J. P. Hogan 2

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occurred after issuance of the approval, and to certain administrative costs which should not have been charged against the review. Based on this infor-mation, we have asked the NRC Office of the Controller to revise Invoice No.

211-81 to read $494 (13 m-hrs @ $38/m-hr).

We appreciate your bringing this matter to our attention and apologize for any inconvenience it caused. As a result, we have again emphasi:ed to the Licensing staff the importance of accurately reporting only the professional i

manpower actually expended in the review and processing of a licensee's request.

i Sincerely, William 0. Miller, Chief License Fee Management Branch Office of Administration

Enclosure:

10 CFR 170 i

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