ML20045J116
| ML20045J116 | |
| Person / Time | |
|---|---|
| Site: | General Atomics |
| Issue date: | 07/13/1993 |
| From: | Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | Temper L NRC OFFICE OF THE CONTROLLER |
| References | |
| 67-2099, NUDOCS 9307230063 | |
| Download: ML20045J116 (3) | |
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CEN:RAL ATDANCS July 13,1993 67-2099 L
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ATTN: Ms. Leah Temper g
License Fee & Debt Collection Branch Office of the Controller U.S. Nuclear Regulatory Commission l
Washington, DC 20555-0001.
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Subject:
Invoice No. XT0468-93 dated July 6,1993 for Part 55 Services; l
Docket No. 50-00163; GA TRIGA Mark F
Reference:
Detail Quarterly Fee Billing Docket Report for.NRR' for the Period J
December 27,1992 - March 20,1993 (Run Date May 5,1993)
Dear Ms. Temper:
General Atomics (GA) has received the subject invoice. for $15,744 for Part 55
. services - replacement and requalification examinations and related items - for the period l
12/27/92-03/08/93, pursuant to 10 CFR 170.12(i) and 170.21.1. Pursuant to 10 CFR 15.31.
and 10 CFR 170.51, GA requests an extension of the payme. ? due date for the purposes ~ of appealing the invoiced amount. GA believes the invoiced amount for the services rendered to be excessive for the purpose of services related to the non-power reactor requalification exams conducted during this period.
During the period February 16-18, 1993, one NRC examiner, Mr. Patrick P.-Isaac observed the administration of six-year operator requalification ' examinations for five operators at GA's non-power reactor facility. During the seme period, GA requested - and
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Mr. Isaac conducted - an oral exam for one RO to SRO upgrade.' Grading of the examina-tions was also jointly conducted by the facility representative and the NRC_ examiner during his visit to the facility.
For the purposes of these requalification examinations, GA had exercishd its option to assist the NRC staff in the preparation and administration of the examinations. lAn NRC-examiner reviewed the exam prior to its conduct at 'the facility, and then observed as the examinations (written and oral) were conducted on February 16, 17 &:18, 1993. To that end, the GA facility representative had prepared the complete exam (both written and oral),
and submitted them to the NRC examiner for review and for the purpose of presenting them :
in an NRC format to the candidates (to simplify the latter for NRC staff, GA also submitted the examination content on a floppy disk-to the examiner). There were no changes of -
significance made by the examiner to the content of the examinations, which would have required a considerable expenditure of staff resources. GA, therefore, believes the 3.2 man. -
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o U.S. NRC, Office of the Controller July 13,1993 67-2099 Page 2 weeks of staff time spent on review and observation of these non-power reactor requalification examinations to be excessive based on the way these exams were prepared and conducted.
In GA's estimation, the following is a level of staff effort it believes to be justifiable related t administering the subject exams:
Review of GA prepared examination 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> g
SRO upgrade exam preparation 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Examiner at GA facility for conduct 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> of examinations, including travel Post exam review and document preparation 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Total 52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br />
$ 6,396.
52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br /> at $123/ hour Therefore, based upon a comparison of the referenced report and GA's estimate of the effort required by NRC staff for the subject exams, the invoice is believed to be excessive by an estimated amount of $9,348 ($15,744 less $6,396). Pursuant to 10 CFR 170.51 and the information presented in the invoice, GA hereby requests a review of the subject invoice and an extension of the 30 day period to allow resolution. Please direct any questions you may have to the undersigned at (619) 455-2823 or to Dr. Junaid Razvi at (619) 455-2441.
Very truly yours, Keith E. Asmussen, Director Licensing, Safety and Nuclear Comphance JR/KEA:shs
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