ML20137R402

Comments on Proposed Rev to 10CFR35 Re Human Use of Byproduct Matl.Cost Data Used for Present Fee Schedule for FY77 & Out of Date

ML20137R402
Person / Time
Issue date:	09/16/1982
From:	Miller W NRC OFFICE OF ADMINISTRATION (ADM)
To:	Webb Patricia Walker NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20136D915	List: ML20136D909 ML20136E266 ML20136E272 ML20136E278 ML20136E295 ML20136E318 ML20136E323 ML20136E492 ML20136E705 ML20136E879 ML20136F099 ML20136F109 ML20136F154 ML20137Q526 ML20137Q531 ML20137Q538 ML20137Q545 ML20137Q557 ML20137Q566 ML20137Q572 ML20137Q579 ML20137Q585 ML20137Q596 ML20137Q605 ML20137Q644 ML20137Q655 ML20137Q660 ML20137Q671 ML20137Q682 ML20137Q688 ML20137Q690 ML20137Q692 ML20137Q695 ML20137Q697 ML20137Q705 ML20137Q710 ML20137Q715 ML20137Q719 ML20137Q721 ML20137Q724 ML20137Q726 ML20137Q734 ML20137Q742 ML20137Q747 ML20137Q760 ML20137Q766 ML20137Q777 ML20137Q783 ML20137Q791 ML20137Q796 ... further results
References
FRN-50FR30616, RULE-PR-35 NUDOCS 8509230500
Download: ML20137R402 (2)

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t UNITED STATES jfpnprog}o ,, NUCLEAR REGULATORY COMMISSION

p, WASHINGTON, D. C. 20555 2;  ;

%, / September 16, 1982 MEMORANDUM FOR: William Walker, NMSS FROM: William 0. Miller, Chief License Fee Management Branch, ADM

SUBJECT:

COMMENTS - PROPOSED REVISION TO 10 CFR 35 ON HUMAN USE OF BYPRODUCT MATERIAL We have reviewed the subject staff paper which we recently received and have the following comments:

1. Memo to Commissioners - P. 7, listed under the primary benefits of the proposed license structure and review process, item 4 states "more accurate cost recovery than under the current fee structure." We feel that this statement is misleading in that it implies that the current fee structure is not accurate. The cost data used for the present fee schedule is out of date since it was provided by NMSS for FY1977; however, that does not make it inaccurate. As you know, a revised proposed sched-dule is now before the Commission for their consideration. If approved this schedule would update the costs based on FY1981 professional staff hour data provided by NMSS.

2. Enclosure 3 - P. 11 (a) The proposed rate of $56 per hour was used for NMSS in some of the calculations. The NMSS professional rate, based on FY1981 actual cost data is $58 per hour.

(b) The amount shown ($108,750) in the 2nd paragraph as costs to be recov-ered under the current schedule should be changed to read $103,750.

(c) The last paragraph on page 11 and the first paragraph on page 12 indicates that under the proposed Part 35 rule that the total cost for processing new applications, renewals and amendments is $73,000.

We are unable to determine how the cost figures for renewals and amendments were determined. We note that $200 per case appears to have been included in the totals for travel costs. It is current Commission policy not to recover the cost of professional staff time actually spent in travel to or from the site. These two paragraphs also imply that when the Part 35 is revised not only will the turnaround time for applications be reduced but also the koj92j500850906 33 SOFR306gs pyg

2- SEP 16 1sa2 professional processing time will also be different from that which NMSS reported for SECY 81-615 which is now before the Commission for approval. At the time the proposed revision to Part 35 is im-plemented, it will be necessary to adjust the application, renewal and amendment fees charged to medical institutions to reflect any decrease in professional staff hours required to process applica-tions under the revised rule.

3. We suggest that a reference be added to Item 26, Form 313MH to read as follows:

"10 CFR 170, Section 170.31."

h 0.N &

Williarr 0. Miller, Chief License ?ee Management Branch Office of Administration l cc: P. Norry  ;

M. Springer l

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