ML20175A088
| ML20175A088 | |
| Person / Time | |
|---|---|
| Issue date: | 07/09/2020 |
| From: | Clay Johnson NRC/OCFO |
| To: | Volk J AECOM |
| smh | |
| References | |
| Download: ML20175A088 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 9, 2020 Mr. John C. Volk, P.E.
Vice President AECOM 625 West Ridge Pike, Suite E-100 Conshohocken, PA 19428
Dear Mr. Volk:
On behalf of the Nuclear Regulatory Commission (NRC), I am responding to your letter dated June 9, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML20162A016), requesting to pay a 50-percent prorated fiscal year (FY) 2020 annual fee. You provided additional information to supplement your request on July 4, 2020 (ADAMS Accession Number ML20188A003).
In your letter, you note that AECOM removed all nuclear gauges from your location in Conshohocken, Pennsylvania and shipped them to Troxler for disposal. In addition, you state that you shipped three gauges in November 2019 and the last gauge in February 2020, and you were in the process of finalizing all documentation when the COVID-19 stay-at-home order in Pennsylvania took effect in March 2020. The NRC received your official termination request for license 37-19654-01 on May 20, 2020, and subsequently terminated the license on June 3, 2020. In the supplemental information you provided, you indicate that you did not have access to paper files in the office, and this prevented you from completing documentation that was required to terminate license 37-19654-01. You also describe VPN and network issues that you experienced during the stay-at-home order.
The NRC has an established procedure for waiving an annual fee upon termination of a materials license. This procedure is set forth in Footnote 1 of 10 CFR 171.16, Annual fees:
Materials licensees, holders of certificates of compliance, holders of sealed source and device registrations, holders of quality assurance program approvals, and government agencies licensed by the NRC, which provides as follows:
Annual fees will be assessed based on whether a licensee held a valid license with the NRC authorizing possession and use of radioactive material during the current FY. The annual fee is waived for those materials licenses and holders of certificates, registrations, and approvals who either filed for termination of their licenses or approvals or filed for possession only/storage licenses before October 1 of the current FY, and permanently ceased licensed activities entirely before this date. Annual fees for licensees who filed for termination of a license, downgrade of a license, or for a possession-only license during the FY and for new licenses issued during the FY will be prorated in accordance with the provisions of §171.17. If a person holds more than one license, certificate, registration, or approval, the annual fee(s) will be assessed for each license, certificate, registration, or approval held by that person. For licenses that authorize more than one activity on a single license (e.g., human use and irradiator activities), annual fees will be assessed for each category applicable to the license.
J. Volk Based on the provision above, when you hold a materials license during the current FY, fees are incurred irrespective of whether licensed materials are in use. The proration provision in 10 CFR 171.17(b)(2) provides that [l]icenses for which applications for termination or
[possession-only licenses] are filed during the period October 1 through March 31 of the FY are assessed one-half the annual fee for the applicable category(ies) for that FY. Thus, AECOM would be responsible for full payment of the annual fee for FY 2020.
Based on your unique set of circumstances, by which Pennsylvanias stay-at-home order did not allow you to access files in your office to finalize your termination request for license 37-19654-01, I am granting you an exemption from the requirement in 10 CFR 171.17(b)(2) to have filed the application for license termination by March 31 of the FY. Therefore, by granting this exemption, I have granted your request to pay a 50-percent prorated FY 2020 annual fee with respect to this license.
Please contact Mr. William Blaney at 301-415-5092 or Ms. Jo Jacobs at 301-415-8388 for any fee-related questions.
Sincerely, Cherish K. Digitally signed by Cherish K.
Johnson Johnson Date: 2020.07.09 13:42:45
-04'00' Cherish K. Johnson Chief Financial Officer
Letter: ML20175A088 Package: ML20162A015 Incoming: ML20162A016 *via e-mail CFO-0009 OFFICE OCFO/DOB/LFPT OCFO/DOB/LFPT OCFO/DOC/LAFBB OGC OCFO/DOC/LAFBB NAME WBlaney* JJacobs* JGibbs-Nicholson* M. Albert*NLO MBlair*
DATE 06/23/2020 06/23/2020 06/24/2020 07/06/2020 07/06/2020 OFFICE OCFO/DOB/LFPT OCFO/DOB OCFO/DOB DCFO CFO NAME ACRossi* RCAllwein* JEShay* BFicks* CKJohnson DATE 07/06/2020 07/06/2020 07/09/2020 07/09/2020 07/09/2020