ML20028C096
| ML20028C096 | |
| Person / Time | |
|---|---|
| Issue date: | 06/04/1982 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Ahearne J, Gilinsky V, Palladino N NRC COMMISSION (OCM) |
| Shared Package | |
| ML20028C092 | List: |
| References | |
| FRN-47FR52454, RULE-PR-170 NUDOCS 8301060428 | |
| Download: ML20028C096 (17) | |
Text
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JUN 04 BB2 MEMORANDUM FOR: Chairman Palladino Commissioner Gilinsky Commissioner Ahearne Commissioner Roberts Commissioner Asselstine FRO:1:
William J. Dircks, Executive Director for Operations
SUBJECT:
PART 170 LICENSE AND INSPECTION FEES - RADI0IS0 TOPE LICENSES This responds to the Commission's request for the staff to conduct a study to determine whether use of actual costs in establishing license and inspection fees for radioisotope licenses would have a significant economic inpact on a i
substantial number of these small programs.
Currently there are 23 categories of small licensed programs that use byproduct raterial, source material, and small quantities of special nuclear raterial.
Categories are determined largely by use of the material, e.g., industrial radiography, medical, oil well logging, etc.
Fees for these licenses are based on the average cost to process a neu license application, a renettal or amendment within a category of license or to conduct a routine inspection of a licensed progr w within t.
lict nrc catepry.
Economic impact of assessing fees based on actual cost.
The Staff examined the alternative of fees based on actual costs v. average costs for radioisotope applications and licenses and concluded that the use of actual costs in estcblishing fccs would have littic impact on these small programs.
The I
rajor difference would be that under an actual cost system, an applicant filing a complete application would pay a smaller fee than an applicant whose application was incomplete because less review effort would be required. Likewisc a licensee who operates in accord with the regulations and terns and conditions of his license should pay less in inspection fees. This would provide for greater equity and fairness in fee assessment. Many licensees (in commenting on previous fee schedules) have suggested that fees should be based on actual costs.
8301060428 821222 PDR PR 170 47FR52454 PDR
3 Chairman Palladino, et al Procedure for recording staff time.
1 Currently all license applications received by the Commission are assigned a docket number and are entered into the computer where their progress is tracked by mile-stones. However, the individual license reviewers in NMSS, in reporting the amount of time expended in the review of a license application, charge their time to two different systems.
For the large fuel cycle applications (e.g., fuel fabri-cation, uranium mills, etc.) the actual time expended is charged to the specific docket and fees are assessed based on the actual professional staff hours expended.
For the small materials program the professional staff in the Material Licensing Branch charges licensing review time to program codes and activity codes rather than to specific docketed cases. A program code identifies a specific category of license (e.g., industrial radiography), and the activity code further qualifies the effort as associated with a new license, amendment or renewal.
Similiarly an inspector charges inspection time to a category of license rather than to a specific docket number.
For the small materials program, this system supports fees based on average costs rather than actual costs. To assess fees based on the actual profes-sional staff hours expended would require both the licensing and inspection staffs to charge their review and inspection time to dockets on a case-by-case basis.
Administratively, greater effort would be required to charge professional staff review or inspection time to the individual docket. NMSS recommends against the use of actual costs in establishing a revised fee schedule based on their conclusion that actual costs would not increase collections, but would significantly increase the administrative burden on the NMSS technical staff because it would need to keep track of time expenditures on a case-by-case basis for more than 5,000 cases per year, each of which averages less than five (5) hours of review time.
Another factor which would add to the administrative burden is that the review of an appli-cation may be completed over several weeks or months while the reviewer waits for additiond mformtion requested from the applicant. To a lesser decree, fees based on actual costs would also increase the administrative burden for inspection.
Revised fee schedules.
Enclosed are revised licensing and inspection fee schedules which are based on average costs. compares current fees (FY 1978 Schedule) with fees necessary to recover current licensing costs. The table shows that licensing costs have increased for most categories of use.
Significant increases are found in charges for broad licenses issued to manufacturers and distributors of radio-isotopes and products or devices containing radioisotopes, e.g., radiopharmaceuticals, l
gauging devices, light sources, tagged compounds, etc.
Similiarly fees for broad licenses authorizing industrial R & D and medical treatment and research have increased significantly. Overall licensing costs for these more complex radio-isotope programs have increased 3 to 6 times.
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. 5 Chairman Palladino, ct al - -
The license fees shown in Enclosure 1 were determined by multiplying the average professional staff time required to process the three types of material license applications by the professional staff-hour rate. The average tine was derived fron computerized data input for calendar years 1951 and 1902, along with estimates provided by the senior technical reviewers who process these license applications. The average times, used in fee computation, are based on current radiation protection requirements, which have changed since the current fee schedule was developed in 1977.
Additional license fee categories have been added to the schedule to more clearly define the types of licenses for fee purposes. For example, broad licenses noa take considerably more tima to review than previously because of additional requirements.
For those fee categories where an insufficient number of applications have been reviewed to establish an average professional staff tina for review, it would be necessary to base the fee on actual costs.
As indicated above, once the average professional staff review time has been determined it is then multiplied by the professional hourly rate for !"iSS. compares FY 1978 inspection fees for radioisotope license; with current costs.
Currently fees are assessed for routine inspections only and the frequency for imposing charges is limited.
Under the revised schedule all inspections (routine and non-routine) would be subject to fees and would be isased on average costs.
As in licensing, there is a wide range of inspec-tion effort within the same category of license.
In developing the inspection fees for materials licenses as shown in Encloture 2. the senior technical staff determined the average professional staff tir rquired to coaduct routine and non-routine inspections of i ; ctust.d progrwx;.
Tne cycraga ti;.i2 was determined irca ccr..i> uter data for FY 1001. M tha firrt si: r.cnth: of FY 1992.
The inspection fee cctocories
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.'or each cm.ct.ory was i..Ji t.ipiied by Ln..oarly i.rciessiona6 rate fo; a.
(signed)T. A.Rehm
[
!!illiam J. Dircks Executive Director for Operations
Enclosures:
1.
Revised Table of License' Fees 2.
Revised Table of Inspection Fees i
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Current Proposed (Fees 3/78) Fees TYPE OF REVIEW FFE CATEGORIES l
i
.JIAL NUCLEAR MATERIAL C.
Licenses for possession and New License
$110
$230 use of special nuclear material in sealed sources Renewal 110 120 contained in devices used in industrial measuring Amendment 40 60 systems.
D.
All other special nuclear New License
$460
$350 material licenses, except licenses authorizing Renewal 460 350 special nuclear material in unsealed form in Amendment 110 120 combination that would constitute a critical quantity as defined in 1 150.11 of Part 150 which shall pay fees in accordance with Category lA.
SOURCE MATERIAL Usc of source material Neu License
$140
$60 for shielding.
Renewal 70 60 Amendr.mni 40 60 C.
All other source material New License
$140
$350 licenses.
Renewal 70 230 Amendment 40 120 8YPRODUCT MATERIAL A., Licenses of broad scope for New License
$460
$1,200 possession and use of by-product material issued Renewal 460 700 pursuant to Parts 30 and 33 of this chapter for process-Amendment 110 120 ing or manufacturing of items containing byproduct material for comriercial distribution to specific licensees.
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Current TYPE OF Fees Proposed REVIEW (3/78)
- Fees
..i._
.ATEGORIES_
BYPRODUCT 1%TERIAL (con't.)
B.
Other licenses for possession New License
$460
$460 and use of byproduct material ic ued pursuant to Part 30 of Renewal 460 460 this chapter for processing or manufacturing of items Amendment 110 120 containing byproduct material for commercial distribution to' specific licensees.
C.
Licenses issued pursuant to New License
$190
$1,400 E32.72, 32.73 and/or 32.74 of Part 32 of this chapter author-Renewal 150 1,400 izing the processing or manufac-ture and distribution of radio-Amendment 40 23'O pharmaceuticals, generators, reagent kits and/or sources and devices containing byproduct material.
l Licenses issued pursuant to New License
$190
$700 E32.72, 32.73 and/or 32.74 cf Pcrt 32 of this chapter Renewal 150 700 authorizing distribution of rediepic rcccuticch, gener-Amand=nt 40 120 ators, reugu a '.; a u.c/or sources or devices not involving processing of byproduct material.
E.
Licenses for possession and New License
$190
$230 use of byproduct material in sealed sources for irradiation Renewal 150 170 of materials where the source is not removed from its shield Amendment 40 120 l
(self-shielded units).
F.
Licenses for possession and New License
$460
$580 use of less than 10,000 curies 460 350 of byproduct material in sealed Renewal sources for irradiation of materials where the source is Amendment 110 230 exposed for irradiation purposes.
Licenses for possession and New License
$460
$2,300 use of 10,000 curies or more of byproduct material in Renewal 460 930 scaled sources for irradiation of materials where the source Amendment 110 230 is exposed for irradiation purposes.
LICEl4SE FEES ASSESSED PER All10N te m't.)
J Current Proposed TYPE OF (Fees) 3/78 Fees REVIE!i _
F
.ATEGORIES BYPRODUCT l%TERIAL (con't.)
E H.
Licenses issued pursuant to New License
$950
$580 subpart A of Part 32 of this E
chapter to distribute items Renewal 570 230 E
containing byproduct material which require Amendment 230 120 device review to persons exempt from the licensing requirements of Part 30 of this chapter.
I.
Licenses issued pursuant to liew License
$190
$290 subpart A of Part 32 of this chapter to distribute items Renewal 150 230 containing byproduct material or quantities of byproduct Amendment 40
'60 material which do not require device evaluation to persons exempt from the licensing requirements of Part 30 of this chapter.
Licenser isrucd pursuant to flew License
$950
$1,200 ]
2 v.
subcart B of Part 32 of this chihter tn distribute items Rc n c'.1" I 570 700 contcming byproduct nhwme 6 which require sealed source Amendment 230 230
and/or device review to persons generally licensed under Parts 31 or 35 of this l
chapter, except specific j
licenses authorizing redis-tribution of items which have been authorized for distribution to persons i
generally licensed under Parts 31 or 35 of this -
chapter.
K.
Licenses issued pursuant to liew Licens5
$110
$290 i
subpart B of Part 32 of this chapter to distribute items Renewal 110 230 l
containing byproduct material Amendment 40 60 or quantities of byproduct which do not require sealed 1/In addition to fee shown, applicant will be assessed source and/or device review an additional $460 for each device review.
to persons generally licensed under Parts 31 or 35 of this 2]In addition to the fee shown, an additional $1,600 chapter.
will be assessed for each device / product review and
$350 for each sealed source review.
l
A Current ~
TYPE OF Fees-Proposed REVIEW (3/78)_
Fees
. F _.
ATEGORIES BYPRODUCT K4TERIAL (con't.)
L.
Licenses of broad scope for New License
$190
$1,200 possession and use of byproduct material issued pursuant to Renewal 150 700 Parts 30 and 33 of this chapter for research and Amendment 40 120 development which do not authorize commercial distribution.
M.
Other licenses for possession New License
$190
$700 and use of byproduct material issued pursuant to Part 30 of Renewal 150 460 this chapter for resecrch and development which do not Amendment 40 120 authorize commercial distri-bution.
N.
Licenses which authorize New License
$110
$930 services for other licenses, except for leak testing and Renewal 110 930 traste disposcl pickup services.
Amendment 40 120 Licenses for Fyrroduct Mm License
$190,$46hl
$700 0
- m..v i i -; n o p. :- r n Part 34 of this cnapter for Renewai
- 150,
'6D '
700 E
industrial radiography 3/
Amendment 40, 110 230 operations.
F.
All other specific byproduct New License
$110
$230 material licenses, except those in the categories 4A Renewal 110 230 through 9B.
Amendment 40 60 1.
WASTE DISPOSAL B.
Licenses specifically New License
$1,100
$1,400 authorizing the receipt of waste byproduct material, Renewal 570 930 source material, or special nuclear material from other Amendment 570 350 persons for the purpose of packaging or repackaging the material.
The licensee will dispose of the material by transfer to another person 3/ Currently, there are two fee categories covering authorized to receive or radiography operations.
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dispose of the material.
m LICENSE FEES ASSESSED PER ACTION (con't.)
5 __
Current TYPE OF Fees Proposed
/
REVIEW (3/781 Fees FEE CATEGORIES WASTE DISPOSAL (con't.)
C.
Licenses specifically New License
$190
$930 authorizing the receipt of prepackaged waste byproduct Renewal 150 460 material, source material, or special nuclear material Amendment 40 120 from other persons.
The licensee will dispose of the material by transfer to another person authorized to receive or dispose of the material.
Licensesspecificailyauthor-New License
$1,100 4/
D.
izing the receipt of waste Renewal 570 4/
byproduct material, source material, and/or special nuclear material from other Amendment 570 4/
persons for treatment or disposal by incineration; packaging of residues resultine from incinerction; and tran5fer of packages containinc rcaidu m te
,ic.o
_no d...
p_._
to receive or dispose.of waste material.
WELL LOGGING 1.
A.
Licenses specifically New License
$460
$700 authorizing use of byproduct material and/or special Renewal 460 700 nuclear material for well logging, well surveys, and Amendment 110 170 tracer studies other than field flooding tracer studies.
$460 4/
B.
Licenses specifically author - New License izing use of byproduct material 460 4/
for field flooding tracer Renewal studies.
110 4/
Amendment 4/ Fees to be based on actual cost to process the application.
COMPARISON OF PRESENT VS. PROPOSED MATERIAL 5
- 6.. _
LICENSE FEES ASSESSED PCR ACTION (con't.)
Current TYPE OF Fees Proposed REVIEW (3/78)
Fees FEE CATEGORIES _
NUCLEAR LAUNDRIES 1
A.
Licenses for commercial New License
$460
$700 collection and laundry of items contaminated with Renewal 460 700 byproduct material, source material, or special nuclear Amendment 110 170 material.
HUMAN USE OF BYPRODUCT, SOURCE OR SPECIAL NUCLEAR MATERIAL
- f..
Licenses issued pursuant to New License
$300
$580 Parts 30, 40, and 70 of this chapter for human use of by-Renewal 270 350 product material, source material, or special Amendment 40 230 nuclear material in sealed sources contained in teletherapy devices.
Licenses of broad scope New License
$190
$1,200 issued to medical instito-tions or two or more Renewal 150 700 nhmicianc
- n not,t to P rts M
120 10, n, E,
.C t..J N' o f
/.a.2r.6.:n.
this chapter authorizing research and development including human use of by-product material, except licenses for byproduct material, source material, or special nuclear material in sealed sources contained in teletherapy devices.
C.
Other licenses issued New License
$190
$580 pursuant to Parts 30, 35, 40 and 70 of this chapter Renewal 150 580 for human use of byproduct material, source material, Amendment 40 230 and/or special nuclear material, except licenses for byproduct material, source material, or special nuclear material in sealed sources contained in tele-therapy devices.
COMPARISON OF PRESENT'VS. PROPOSED MATERIALS 1
LICENSE FEES ASSESSED PER ACTION (con't.)
.7_
Current TYPE OF Fees Proposed (3/78)
Fees FE'E CATEGORIES REVIEU__
CIVIL DEFENSE:
A.
Licenses for possession New License
$190
$290 and use of byproduct material, source material, Renewal 150 230 or special nuclear material 40 60 for civil defense activities. Amendment DEVICE, PRODUCT OR SEALED g
SOURCE SAFETY EVALUATION A.
Safety' evaluation of devices New License
$570
$1,600 or products containing by-product material, source material, or special 580 nuclear m'aterial, except Amendment reactor fuel devices and devices or products distributed to general licensees or persons exempt from the require-ments for a license pursuant to Ptrts 30, 40, and 70 of this chapter.
r 9
n f
<,1 s
--, Licence
$110
$350 g
sources contr.ining byproduct l
material, source material, i
$120 except:
(1) reactor fuel, Amendment (2) scaled source (s) distributed to general licensees or persons exempt from the requirements for a license pursuant to Parts'30, 40, and 70 of this chapter.
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PROPOSE 0 f3ATERIALS LICENSE INSPECTION FEES 1
Current TYPE OF F
Proposed (3h8) --
Fees INSPECTION
.'. -. CAT E GORI ES SPECI AL NUCLEAP. IMTERI AL Routine
$330
$210 C.
Licenses for possession and N
640 use of special nuclear Non-Routine N/A material in sealed sources contained in devices used in industrial measuring systems.
D.
All other special nuclear Routine
$780
$320 material licenses, except y
licenses authorizing Non-Routine N/A 370
'special nuclear nuterial in unsealed form in combination that would constitute a critical quantity as defined in
! 150.11 of Part 150 which shall pay fees in accordance with Category 1A.
.CE IMTERIAL
$460
$130 Routine C.
Use of source material
'or nhi nidi r.o.
llN!
yn n..Li~
Routine
$460
$370 C.
All other source material licenses.
Non-Routine N/AU 690 BYPRODUCT 1%TERI AL A.
Licenses of broad scope for Routine
$1,600
$ 950 possession and use of by-Non-Routine' N/All 1,000 product material issued pursuant to Parts 30 and 33 of this chapter for process-ing or manufacturing of items containing byproduct material for conmercial distribution to specific licensees.
1/N/A - Hot applicable, currently t ere are no fees for non-routine inspections.
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.m Current TYPE OF Pr osed INSPECTION _
(
)
b CATEGORIES _
BYPRODUCT 1%TERIAL (con' t. )
B.
Other licenses for possession Routine
$780
$480 and use of byproduct material N/Ay 900 issued pursuant to Part 30 of Non-Routine this chapter for processing or manufacturing of items containing byproduct tr.aterial for conmercial distribution to specific licensees.
Rou tine
<650
$640 C.
Licenses issued pursuant to 132.72, 32.73 and/or 32.74 of N
850 Part 32 of this chapter author-Non-Routine N/A izing the processing or manuiac-ture and distribution of radio-pharmaceuticals, generators, reagent kits and/or sources and devices containing byproduct ma terial.
Routine
$650
$370 Licenses issued pursuant to
~
532.72, 32.73 cnd/or 32.74 N'
530 Non-Routine N/A of Part 32 of this chapter authorizing distribution of radic,p!.arcaaet ct i s, gener-4
.C oltr[~ '
ULOrs, FEqth.
sources or devices not involving processing of byproduct traterial.
Routine
$390
$210 E.
Licenses for possession and E
320 use of byproduct material in Non-Routine N/A sealed sources for irradiation of materials where the source is not reroved from its shield (self-shielded units).
Routine
$390
$270 F.
Licenses for possession and E
580 use of less than 10,000 cu' ries N/A of byproduct material in scaled Non-Routine sources for irradiation of materials where the source is' exposed for irradiation purposes.
Routine
$390
$480 Licenses for possession and E
640 use of 10,000 curies or more Non-Routine N/A of byproduct material in scaled sources for irradiation of materials where the source is exposed for irradiation purposes.
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Current TYPE OF Fees Proposed (3/78)
Fees IriSPECTION i.
- ATEGORIES BYPRODUCT !%TERI AL (c,on't.)
Rootine
$390
$320 H.
Licenses issued pursuan'. to subpart A of Part 32 of this Non-Routine N/A 320 chapter to distribute items containing byproduct rraterial which require device review to persons exempt from the licensing requirements of Part 30 of this chapter.
I.
Licenses issued pursuant to Routine
$390
$210 subpart A of Part 32 of this N/AM 320 chapter to distribute items Non-Routine containing byproduct material or quantities of byproduct material which do not require device evaluation to persons exempt from the licensing requirements of Part 30 of this chapter.
Routine
$390
$320 J.
Licenses issued pursuant to N
320 subpart B of Part 32 of this 6ittribute items Non-Routine N/A e,
containing byproduc raz. Ler & I which require scaled source and/or device review to persons generally licensed under Parts 31 or 35 of this chapter, except specific I
licenses authorizing redis-tribution of items which have been authorized for distribution to persons generally licensed under Parts 31 or 35 of this r
chapter.
K.
Licenses issued pursuant to Routine'
$390
$320 subpart B of Part 32 of this Non-Routine N/A 320 chapter to distribute items containing byproduct material or quantities of byproduct which do not require scaled source and/or device review to persons generally licensed under Parts 31 or 35 of this' chapter.
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PR@ POSED FATERIAL5 LICENSE lh5PtLiIUN Ptti puu
- 6. j Current Fees Proposed Type 0.f Inspection (3/78)
Fees
- ATEGORIE5_
BYPRODUCT 1%TERI AL_ (con' t.)
L.
Licenses of broad scope for Routine
$390
$420 possession and use of byproduct material issued pursuant to
.Non-Routine N/A 530 Parts 30 and 33 of this chapter for research and development which do not authorize comercial distribution.
~ Routine
$390
$370 H.
Other licenses for possession and use of byproduct material N
420
!!an-Routine 11/A issued pursuant to Part 30 of this chapter for research and development which do not authorize comercial distri-bution.
N.
Licenses which authorize Routine
$390
$320 services for other licenses, E
320 except for leak testing and Non-Routine N/A waste disposal pickup services.
7
$ 530 Routine
$720, 980 O
Licenses for byproduct unr": ~ kstr
.wcu:nt 1:
Non-Ro u t.i ne H//,
i,200 Part 34 of this chapter ior industrial radiography operations.
P.
All other specific byproduct Routine
$390
$530 material licenses, except tion-Routine N/A 530 those in the categories 4A through 98.
f.
WASTE DISPOSAL _
B.
Licenses specifically Routine
$650
$1,000 authorizing the receipt of waste byproduct ma terial, Non-Routine N/A 740 source material, or special nuclear raterial from other persons for the purpose of packaging or repackaging the material. The licensee will dispose of the material by 2fCurrently, there are two fee categories covering transfer to another person radiography operations.
authorized to receive or dispose of the material.
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- n o r,anm e c, - m monm a a w, m
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Corrent TYPE OF Fees Proposed If15PECTIOil (3/78)
' Fees
[, ATEGORIES i!ASTE DISP 05#_ (con't. )
C.
Licenses specifically Routine
$650
$740 authorizing the receipt of N
prepackaged waste byproduct tion-Routine if/A 950 material, source material, or special nuclear material from other persons.
The licensee will dispose of the material by transfer to another person authorized to receive or dispose of the ra terial.
Routine
$650
$740 D.
Licenses specif,ically author-E 900 izing the receipt of waste f!on-Routine ti/A byproduct material, source material, and/or special nuclear raterial from other persons for treatment or disposal by incineration; packaging of residues resulting frca incineration; and transfer of packages containing residues to another person authorized a. a -7., t r d N,r w r wast.e r.aterial.
- l ELL LOGGIliG r
A.
Licenses specifically Routine
$520
$370 authorizing use of byproduct l
material and/or special tion-Routine 11/A./
370 nuclear naterial for well i
l logging, well surveys, and tracer studies other than field flooding tracer studies.
i B.
Licenses specifically author-
' Routine
$520
$320 izing use of byproduct material N
480 for field flooding tracer
!!on-Routine ti/A studies.
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4' PROPOSED 14ATERI ALS LICENSENtMCtnnaRnanc-m Current TYPE OF Fees Proposed INSPECTION (3/78)
Fees TEu CATEGORIES _
NUCL'$ 8 LAUNDRIES _
A.
Licenses for comnercial Routine
$590
$530 E
850 collection and laundry of Non-Routine N/A items. contaminated with byproduct raterial, source material, or special. nuclear ra terial.
HUMAN USE OF BYPRODUCT, SOURCE OR SPECIAL NUCLEAR MATERIAL Routine
$460
$530 Licenses issued pursuant to A.
E 850 Parts 30, 40, and 70 of thir Non-Routine N/A chapter for human use of by-product material, source raterial, or special nuclear material in sealed sources contained in teletherapy devices.
Routine
$460
$740 Licenses of broad scope E
800 issued to medical institu-Ncn-Routinc N/A tions or two or more physiriw pursuant to Parts
,q n.
39, 7
this chapter authorizing research and development including human use of by-product material, except licenses for byproduct material. source material, or special nuclear material in sealed sources contained in teletherapy devices.
Routine
$330,460]
$480 3
Other, licenses issued C.
pursuant to Parts 30, 35, Non-Routine N/AE 690 40 and 70 of this chapter for human use of byproduct l
material, source material, l
l and/or special nuclear l
material, except licenses for byproduct material, i
source material, or special 3] Private practice physicians combined with "other l
nuclear material in scaled medical" non-broad institutional licenses.
sources contained in tele-therapy devices.
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PROPOSEDMAT5RIALSLICENSEINSPECTIONFEES(CDH L'J Current TYPE OF Fees
' Proposed i
INSPECTION (3/78) _
Fees FE5LATEGORIES_
CIVIL DEFENSE _:
Routine
$200
$320 A.
Licenses for possession ll-320 and use of byproduct Non-Routine N/A material, source material, or special nuclear material for civil defense activities DEVICE, PRODUCT OR SEALED SOURCE SAFETY EVALUATION _
Routine No Fees A.
Safety evaluation of devices or products containing by-Non-Routine No Fees product raterial, source material, or special nuclear material, except reactor fuel devices and devices or products distributed to general licensees or persons exempt from the require-ments for a license pursuant to Parts 30, 40, and 70 of this chapter.
P.o u t.i n c na reer Scie ty < ctiu; tic:. - T sea'l e:
t,.
sources containing byproduci Non-Routine No Fees material, source material, or special nuclear material l
(1) reactor. fuel, except:
(2) scaled source (s) distributed to general licensees or persons exempt from the l
requirements for a license pursuant. to Parts 30, 40, and 70 of this chapter.
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