ML20043G830
| ML20043G830 | |
| Person / Time | |
|---|---|
| Issue date: | 12/04/1989 |
| From: | Holloway C NRC OFFICE OF THE CONTROLLER |
| To: | Skoczlas J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19330E503 | List:
|
| References | |
| FRN-55FR21173, RULE-PR-170 AD23-2-03, AD23-2-3, NUDOCS 9006210174 | |
| Download: ML20043G830 (2) | |
Text
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UNITED STATES y
NUCLEAR REGULATORY COMMISSION n
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DEC. 4 1988 MEMORANDUM FOR:
John A. Skaczlas, Jr., Chief Document Control Branch, IRM/DISS FROM:
C.' James Holloway, Jr., Assistant for "ee Policy and Rules, OC
SUBJECT:
EXTERNAL AND INTERNAL DISTRIBUTION OF PROPOSED REVISIONS TO 10 CFR 170 Enclosed is a copy of a letter notice to "All Parts 30, 40, 50, 61, 70, 71, 72 and 73 Licensees, Applicants and Reactor Vendors" which transmits the Notice of Proposed Rulemaking that was recently published in the Federal Register.
This notice relates to a proposed revision to 10 CFR 170 on license fees. The letter and notice have already been given to the Printing and Audiovisual Ser-vices Branch for reproduction.
They will provide 12,500 copies to your office within a few days in the "self-mailer, first class" form.
Please-take the necessary steps to have this letter and its attachment mailed to the following in a timely manner:
1.
The-external distribution should include:
a.
Utilitiesandvendors(11S) b.
Research and test reactors (11R) c.
Power plant managers (11M) d.
Vendors (11V) e.
NMSS-type licensees in the NMSS data base, including sealed-source device registrants f.
All Agreement States (CY) g.
AllNon-agreementStates(CJ)
.h.
Interestgroupsandorganizations(XI)
The address labels for category "e" above are being provided to Linda Stevenson by Maureen Moriarity and Steven Baggett.
2.
The internal distribution should include all branch chiefs and above in the following offices:
a.
Office of Nuclear Reactor Regulation b.
Office of Analysis -and Evaluation of Operational Data o
c.
Office of Nuclear Material Safety and Safeguards L
d.
Office of Nuclear Regulatory Research e.
Office of Governmental and Public Affairs i
f.
Office of the General Counsel g.
All regional offices 9006210174 900618 f
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. John A. Skoczlas, Jr.
2 h.
. Advisory Committee on Reactor Safeguards i.
Advisory Committee on Nuclear Waste j.
Atomic Safety and Licensing Board i
k.
Atomic Safety and Licensing Appeal Panel 1.
900 copies to the License Fee and Debt Collection Branch, MNBB 4503, for distribution as needed Your prompt attention in expediting this distribution is requested. Any copies remaining after distribution is completed should be sent to Glenda Jackson in i
MNBB 4503.
If there are any questions, contact me on x24301.
James o loway, Jr.
Assistant for Fee Policy and Rules, OC
Enclosures:
Ltr. Notice to Licensees with FR Reprint of Proposed Rule Revisions for 10 CFR 170 cc w/o encl:
R. Geris, ADM K. Shaw,-IRM L. Stevenson, IRM l
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INSPECTION & TECHNICAL SERVICES,INC.
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"A 800NO PATH TO QUAUTV" g g p3 :34 P.O. Box 80670
- Canton, Ohio 44708 Deceber 15, 1989
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l (216H534313 bckp.% t i. n.L snt.kr Secretary of the U.S. Ibclear Ragn1=t_
camd asion Attention: Ibcketing and Service Br DOCKET NUMBER g' f{ egg-Washington, D.C. 20555 PROPOSED RULE h
Subject:
- Proposed Rule Changes 10CFR-170 g g } }
Gentimen:
As a U.S.N.R.C. licensee us by-product materials covered under Schechle 170.31 (3) (0) with addi requir ments of Schedule 170.31 (10B),
SAM-SON IlcwtmG4 & TEGNICAL SERVICES, INC. herewith protests the proposed increases in fees as released.in your proposed rules coverea under Voltane 54 #230 dated Friday, December 1,1989 of the Federal Registar.
Our reasons are very basic, in that these increases far surpass any irbrma, Federal, local or otherwise that we are aware of. As a by-product material
- user, are proposing increases in license applications in excess of ~3007.,.
r a in excess of 1007., and acmendments wwdmately '907..
It is inposs-ible in private industry to escalate prices for goods and/or services on a percentage basis as intended in this proposed rate change.
In the private sector, we do not feel that the U.S.N.R.C. has the right to pass on to us the burden for acc
- dating persomel, etc. that has been declared surplus by the reduction in !bclear Power Plant construction.
Further, I an sure that these increases are not consistent with the GramF Rudnan policies that the Defense Department, as well as other branches of Goverranent are <==11ed to work within said guidelines. Finally, we feel such increases are " unfair to small business entities" and herewith request -
that these proposed revisions will be recinded..
Respectfully sulzultted,-
SAM-SO4 INSPICTI
& IECHNICAL S"dRVIGS, INC.
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, PD' Corporate Radiation' Safety Officer U.S.N.R.C. License No. 34-25890-01 cc: Ralph Regula, Wngressann - 16th District Stel:jh
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Secretary P
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U.S. Nuclear Regulatory Commission Washington, DC 20555 i'
ATTENTION: Docketing and Service Branch
Dear Secretary:
I as writing in response to the proposed revision of fee schedules:
l Radioisotopes:1,1 censes and Topical Reports of the Nuclear Regulatory L
commission 10'CFR part 170 published in Volume 54, Number 230 of the Federal Register.
y We object-to some of the fee changes.
I do not object to increases, recognizing inflation, hits everyone, but our organisation must now pay the
-j penalty.through dramatic rises.
The licenses' issued pursuant to human use of bi-product material,"iiource material, or special nuclear material in sealed sources: contained in teletherapy devices are an example.
I understand-that the renewal has ' Jumped-from $350 to $660 and-amendments have more than doubled from $120 to.$350.
Further, I do not-think that non-routine inspections under the same section warrant such a large differential between routine inspections.'
Non-routine are listed at $1,500 and routine are listed at $950.
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With respect to other licenses issued pursuant to_the same parts (30, 35, 40, 'and 70), renewal is listed at a higher amount than the application for a new license.
The renewal is listed at-$860, and the= application at $590.
Were these numbers accidentally reverned? Further, the asendment is listed at-
$350.
I am not sure how you can justify such a high price.. Non-routine inspections _in this section are awtraordinarily high at $1,200, compared to routine inspections at $860.
What is there about a non-routine inspection that ' Justifies such a differential? The NRC has successfully made the process so complex that both trying to set fees and understand fees that are set are both difficult tasks.
I strongly rec-nd reconsideration of these high fees. Particularly in the non-profit section where services are provided for the good of the public.
I-am not sure why the Nuclear Regulatory Coassission feels it is so important to cost shift the licensee.
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- l Thank you for the' opportunity to commant on the proposed rules,
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Sin y,
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i th M. Baab Vice President EPS:lah
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