ML20059C849

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Comments on Proposed Rule 10CFR171 Re Exemption from License Fees.Requests Exemption from Fees for Physics Dept of Jackson Community College for Pu-Be Neutron Source License SNM-1171 Source
ML20059C849
Person / Time
Site: 07001228
Issue date: 10/12/1993
From: Hitchingham L
JACKSON COMMUNITY COLLEGE, JACKSON, MI
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR50859, RULE-PR-171 58FR50859-00025, 58FR50859-25, NUDOCS 9311020035
Download: ML20059C849 (2)


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October 12,1993 Secretary, U.S. Nuclear Regulatory Commission Attn; Docketing and Service Branch 11555 Rockville Pike Rockville, Maryland 20852

Dear Commissioners:

I respectfully request an exemption from fees for the Physics Department of Jackson Community College for our Pu-Be neutron source License SNM-1171.

Hopefully this request will be granted. However,if this is not the case I am afraid it will be necessary to relinquish the source. At that point I would request that the August 19,93 deadline be extended, Due to the fact that the notification was received sometime after August 6,1993. Jackson Community College, being an educational institution, was not in session at that time, thus I was not there during most of the month of August and was not aware of the deadline until August 25,1993 It is not possible for us to make an argument based on NRC costs due to not having data, or manpower in a two man department, to make an analysis upon which to base such an argument. However,it is difficult to believe that a fee of $3120 is justified for an inspection every 3-5 years, including the paper work required.

As a basis for granting an exemption, I would point out to the Commission that this source is used at a Community College only in the Physics Department to prepare materials for our laboratories. Our total supply budget of $3750 would barely cover this fee, and an increase in this budget is not possible under the College's current fiscal constraints, without an exemption we will have no alternative but to relinquish the source. Even though this will still penalize our Department and the College and remove an 9311020035 931012 PDR PR 171 5BFR50859 PDR BOARD OF TRUSTEtt

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JACKSON COMMUNITY COLLEGE JACKSON 2111 Emmons Road Jackson, Michigan 49201 COMMUNITY COLLEGE TEL (517) 787-0800. FAX (517) 789-1623

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educational experience from our students that they would probably receive at a four year College or University.

It additionally would penalize this Department and College from the stand I

point that in the last four years approximately $40,000 of donations and capital outlay monies have been spent on Nuclear Detection equipment to continue this part of our laboratory program, as well a $1000 to upgrade our ability to meet NRC source monitoring requirements.

The use of the source is minimal although it does enrich our program by allowing us to do a half-life experiment. The source is used to activate In115 to In118 which has a short half-life of 54 Minutes. The students investigate and determine the half-life in the laboratory. All physics students at every level do this experiment, so this involves approximately 250 students per year. This is the total function of the source. The source is in use only about seven days a year, and never removed from the howitzer as our license states.

I hope that you will allow us to continue this valuable experience for our students by granting the Physics Department and College an examption from j

fees, and look forward to notification of your favorable consideration of this matter.

1 Sincerely,

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  1. Lawrence A.Hitchingha

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