ML20045H621
| ML20045H621 | |
| Person / Time | |
|---|---|
| Site: | University of Michigan |
| Issue date: | 07/01/1993 |
| From: | Burn R MICHIGAN, UNIV. OF, ANN ARBOR, MI |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR21662, RULE-PR-170, RULE-PR-171 58FR21662-00589, 58FR21662-589, NUDOCS 9307210050 | |
| Download: ML20045H621 (2) | |
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Nuclear Reactor Laboratory "d
P The University of Michigan Mc Ford Nuclear Reactor Phoenix Memorial Laboratory cy M ~ 6 P 3 :4 7 2301 Bonisteel Boulevard inn Arbor, Micnigan 48109-2100 t313) 764-6220
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g Secretary
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. Nuclear Regulator:, Commission Att n: Docketing and Service Branch Washington, D.C.
20555 s ub.j e c t : 10CFR 170 and 171 Licensing Fees for Research Reactors uentlemen:
Within the last week, the University of Michigan was informed that university research reactors might no longer be exempt from fees associated with reactor relicensing, inspections, and operator licensing.
Prior to this, we had always been exempt.
While the Ford Nuclear Reactor at the University of Michigan would probably not shut down under the burden of routine licensing fees, they would impose a considerable hardship.
And, if we were forced to pay the entire cost of augmented inspections and enforcement hearings such as the one we were subjected to in 1992, we might be forced to shut down.
We are not a profit making operation.
We support research for the University of Michigan, for other universities and public institutions, and for industry. We have a fixed charge schedule based on cost recovery that is applied only to-industrial researchers.
University and public institutions can avail l
themselves of our services at no charge.
We have always sought to provide services that could not be.
obtained in any other way commercially.
We have never attempted to compete with industry.
For example, while the stnthesis of technetium-99m was developed in our laboratory, once that nuclide
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became of world-wide commercial interest, we did not attempt.to compet e wi+.h industry in producing it.
On the other hand, we do produce compounds that use isotopes of iodine because industry does not want to synthesize iodine due to-its short half-life and short shelf-life.
We have attempted to fill gaps where our services are needed and to be of benefit to society.
We are adequately supported by the University.
We are not under pressure to make money, and the income that we do receive goes toward upgrading our facility and to small research seed money grants.
j 9307210050 930701' PDR PR 170 SBFR21662 PDR'
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1993 t.lcensing Fees for Research Heactors The June issue of the Nuclear News has.an article that aelineates t
the types of services we provide.
However, the real issue for us is our basic purpose.
The 1954 Atomic Energy Act was passed to encourage nuclear research.
That is part of the reascn the Unn ers it y of Michigan decided to build a nuclear research reactor.
The Department of Energy provides our fuel at no charge.
-l In addition, some DOE funds are provided to encourage sharing of our f a c i l i '. y with researchers and to upgrade our instrumentativ.
Licensing fees will, in essence, take funds that are provided by l
one branch of the federal government to encourage research reactor operation and give them back to the federal government as a de facto way of discouraging research reactor opernt. ion.
The logic is difficult to understand.
One of our basic missions is to educate future engineer *.
If we and most of the other reactors in the United States are forced to
.hu t jawn. :na n y if not all nuclear engineering programs will disappear; where will the engineers come from^
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We are not writing criticize the Nuclear Regulatory Commission, 3
j t,u t to present our views on how this issue appears from the point i
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of vtew of reactor operators.
We request that you reconsider the decision to impose fees on research reactors and grant an l
l exemption to the rule.
If there are specific reactors that are I
competing wit.h private industry, we would support their being I
given a choice: stop the particular activity that is in I
competition or be subject to the same fees as a commercial d
reactor.
That choice also could be extended to fuel support by DOE.
Sincerely, f
[/1/ H Reed R.
Burn
>la n a g e r
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Commissioners Ivan Selin, Chairman Kenneth C.
Rogers James R.
Curtiss Forrest J.
Remick Gail de planque i
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