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Category:Letter
MONTHYEARIR 05000228/20230012024-02-0505 February 2024
NRC Inspection Report 050-00228/2023-001, Disputed Cited Violation and Minor Violation Revised, EA-23-118
ML23279A1062023-10-0202 October 2023
Response to Violation 05000228/2023001-001B
ML23255A0342023-09-0909 September 2023
Response to Violation 050-00228/2023-001-00lA
ML23255A0362023-09-0909 September 2023
Response to Inspection Report 050-00228/2023-001
ML23219A1882023-08-24024 August 2023
NRC Inspection Report 05000228/2023001, and Notice of Violation
ML23187A0562023-07-0101 July 2023
Radiation Safety Officer Change Update
ML23187A0582023-07-0101 July 2023
July 1, 2022 Thru June 30, 2023 Summary of Changes, Tests, and Experiments
ML23157A0662023-05-24024 May 2023
Letter from David Slaughter, Aerotest Operations, Inc. Inadequate Oversight of Non-Power Reactor OIG Case No. 21-012 and Requested Payment for Damages Caused by the Nrc'S Inadequate Oversight
ML22361A1022023-02-24024 February 2023
Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities
ML22340A0062022-11-16016 November 2022
Reference Documents from Decommissioning Plan
ML22215A1522022-07-21021 July 2022
Aerotest Radiography and Research Reactor - AO RAI Responses for Decommissioning Plan
ML22187A0852022-07-0101 July 2022
Inc - July 1, 2021 Thru June 30, 2022 Summary of Changes, Tests, and Experiments
ML22152A2522022-06-28028 June 2022
Request for Additional Information on Review of Request for Amendment to Approve Decommissioning Plan, Arrr (License No. R-98, Docket No. 50-228)
ML22060A2602022-03-21021 March 2022
Change in NRC Staff Project Management Responsibility for the Aerotest Radiography and Research Reactor
ML22040A1992022-03-0909 March 2022
Examination Confirmation Letter No. 50-288/OL-22-03, Reed College
ML22025A2002022-01-20020 January 2022
Amendment to AO Decommissioning Plan Submittal Letter Dated July 20, 2021, Agencywide Documents Access, and Management System (ADAMS) Accession No. ML21230A304
ML21307A3242022-01-12012 January 2022
Request for Supplemental Information for Decommissioning Plan, Arrr (License R-98, Docket 50-228)
ML21344A0332022-01-0303 January 2022
Aerotest Letter from the Chief Financial Officer Regarding Additional Information for the Fees Assessed Under to Aerotest Operations, Inc. (Aerotest) within Invoice Number Lfb 22-0346
ML21361A0472021-12-21021 December 2021
Response to December 6, 2021 NRC Pol Issuance; the Licensee and Its Reactor Safeguard Committee Request a Reasonable Opportunity to Review and Address Short Comings of the Draft Licensee and Technical Specifications Along with the Draft Sa
ML21242A4632021-12-0606 December 2021
Issuance of License Amendment No. 6 to Facility Operating License No. R-98 for the Aerotest Radiography and Research Reactor with Partial Denial of Amendment Request
ML21307A1252021-10-28028 October 2021
Letter Regarding Charges Billed
ML21209A5192021-07-20020 July 2021
Aerotest Radiography and Research Reactor, Response to NRC Letter Dated July 12, 2021 (ML21188A391)
ML21230A3042021-07-20020 July 2021
Decommissioning Plan Submittal (Redacted)
ML21147A3732021-07-19019 July 2021
Correction of Letters Regarding Closure of Confirmatory Action Letter No. NRR-04-003 and Review of Physical Security Plan
ML21188A3912021-07-12012 July 2021
Inc. - Revised Completion Date Possession-Only License Amendment Request for the Aerotest Radiography and Research Reactor Facility Operating License
ML21188A2162021-07-0101 July 2021
July 1, 2020 Through June 30, 2021 Summary of Changes, Tests, and Experiments
ML21193A0892021-07-0101 July 2021
Emergency Plan (Redacted)
ML21181A1232021-06-22022 June 2021
License and TS Amendments
ML21147A0602021-05-19019 May 2021
Response to RAI 28 and 29
ML21056A3172021-04-30030 April 2021
CFO Response to Aerotest November 11 2020 Letter
ML21126A1502021-04-28028 April 2021
License and TS Amendments
ML21098A1572021-03-31031 March 2021
Response to RAI CFH Training and Requalification Program- 3/30/21
ML21118A0252021-03-30030 March 2021
Confirmatory Order
ML21047A4682021-03-30030 March 2021
Request for Additional Information Possession-Only License Amendment Request for the Aerotest Radiography and Research Reactor Facility Operating License No. R-98
ML21034A6262021-03-12012 March 2021
Request for Additional Information Possession-Only License Amendment Request for the Aerotest Radiography and Research Reactor Facility Operating License No. R-098
ML21048A1392021-03-0505 March 2021
Acknowledgement of Letter Regarding Decommissioning Plan and Exercise of Enforcement Discretion
ML21004A0792021-01-0707 January 2021
Review of Physical Security Plan in Support of Possession-Only License Amendment Request License No. R-98
ML20345A0312020-12-28028 December 2020
CFO Response to Aerotest November 2020 Letter Re Lfb 20-1849
IR 05000228/20202022020-12-10010 December 2020
U.S. Nuclear Regulatory Commission Security Inspection Report No. 05000228/2020202 and Notice of Violation - Non-OUO-SRI (Cover Letter)
ML20332A0322020-11-18018 November 2020
Unable to Submit Decommissioning Plan by December 5, 2020 Due to COVID-19
ML20295A4242020-11-16016 November 2020
Notification of Mailing Address Change Regarding Submittal of Fingerprint Cards
ML20325A1762020-11-11011 November 2020
Response to NRC CFO, Letter Dated April 18, 2019 Re Reimbursement Request for Activities Associated with the Fees That Were Not Performed in a Satisfactory Manner
ML20325A1342020-11-10010 November 2020
Letter Disputing to Make Payment for Services That Are Not or Poorly Rendered
ML20289A4772020-10-23023 October 2020
Aerotest Response Letter from D. Slaughter Dated September 14, 2020 Docket 50-228
ML20304A1532020-10-21021 October 2020
Response to Notice of Violation
IR 05000228/20202012020-10-15015 October 2020
U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000228/2020201 and Notice of Violation
ML20276A2472020-09-28028 September 2020
Aerotest Radiography and Research Reactor - Updated Arrr Security Plan
ML20234A6312020-09-17017 September 2020
Request for Clarification Physical Security Plan Review - Cover Letter - (Public Version)
ML20248H4602020-08-28028 August 2020
Inc - List of Explanations, Changes, and Justifications for Raj CFH Training and Requalification Program
ML20177A2032020-07-27027 July 2020
Request for Additional Information Possession-Only License Amendment Request to Use Certified Fuel Handlers for the Aerotest Radiography and Research Reactor Facility Operating License No. R-98
2024-02-05
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Text
Docket 50-228 October 23, 2020 Dr. David M. Slaughter President and Reactor Administrator Aerotest Operations, Inc.
3455 Fostoria Way San Ramon, CA 94583
Dear Dr. Slaughter:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your letter dated September 16, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20267A141). Your letter stated that you are continuing to dispute
$22,796 of the $24,047 in fees the NRC assessed to Aerotest Operations, Inc. (Aerotest) under 10 CFR §170.21 within invoice LFB 20-1849, dated January 15, 2020 (your letter stated that you are no longer disputing the remaining $1,251 in fees assessed in invoice LFB 20-1849).
Your letter stated the charges you continue to dispute are intertwined with an audit [in December 2019] that clearly failed its purpose and added no value. Your letter also requested that I separate the costs associated with the audit from other costs in the invoice. Finally, your letter suggests that a third-party mediator could assist us in finding a remedy for this invoice dispute.
Previously, you sent the NRC other letters, dated February 11, 2020 (ADAMS Accession No. ML20049A037), March 30, 2020 (ADAMS Accession No. ML20188A223), and June 24, 2020 (ADAMS Accession No. ML20188A222), which requested additional information regarding the fees in invoice LFB 20-1849 (including an estimate of the portion of the fees that is associated with the December 2019 audit), and also questioned the validity of those fees. I responded to your letters by letters dated March 13, 2020 (ADAMS Accession No. ML20073E318), and August 31, 2020 (ADAMS Accession No. ML20267A141).
In my March letter, I confirmed the charges in invoice LFB 20-1849 are valid, explained the activities associated with the charges, and discussed how the charges are determined. In my August letter, I again confirmed that all of the charges are accurate and valid, and additionally explained that I am unable to provide a more detailed estimate of the charges specifically associated with the audit because NRC staff tracks time processing any license amendment request by using a unique project code, but does not track time at the level of detail you requested. As previously noted, the NRC tracks staff charges for License Amendment Requests at the level of detail deemed appropriate to ensure proper validation and accurate assessment of charges and bills accordingly. Furthermore, in providing my final determination on your fee dispute, my August letter stated that as of the date of that letter, the invoice would be taken out of dispute status and payment would be due immediately.
My August letter also explained the reasons and justification for the December 2019 audit, and stated that NRC staff prepared for and conducted the audit consistent with NRC policy and
D. Slaughter guidance, and in response to Aerotests proposed activities. However, I note that, notwithstanding your perceived value of NRC staffs effort related to the audit, pursuant to 10 CFR 170.21, NRC staff time for reviews of research reactor amendments is billed on a full cost basis, reflecting the actual effort (in hours) expended by NRC staff in support of the review. As stated in your June letter, you are not disputing that [NRC staff] actually worked the time they charged.
Your letter included the statement, A remedy may be quickly found for the disputed amount if we allow a third-party to assist us in finding a remedy. There are no provisions within 10 CFR Part 15, Debt Collection Procedures, to allow for a third-party mediator to provide a remedy for an invoice dispute. Should you wish to avail yourself under any other provisions under 10 CFR Part 15, you should do so only in accordance with the provisions as stated.
In summary, I made a final determination on this matter in my letter dated August 31, 2020, and consider this matter closed. The invoice was taken out of dispute status on August 31, 2020, and debt collection procedures will continue in accordance with 10 CFR Part 15 for the outstanding amount.
Please direct any questions regarding the settlement of invoice LFB 20-1849 to Ms. Carly Nelson-Wilson of my staff at (301) 415-8147. For further questions regarding billing, please contact Ms. Kelly Riner of my staff at (301) 415-6246. Lastly, for questions about the technical work being performed as it relates to your license, please contact Mr. Edward Helvenston at (301) 415-4067.
Sincerely, Digitally signed by Cherish K.
Cherish K. Johnson Johnson Date: 2020.10.23 14:36:59 -04'00' Cherish K. Johnson, CFO Office of the Chief Financial Officer
SUBJECT:
RESPONSE LETTER TO AEROTEST DOCKET 50-228, DATED: October 23, 2020 Distribution:
Jawanza Gibbs-Nicholson, OCFO Kelly Riner, OCFO Carly Nelson-Wilson, OCFO Jo Jacobs, OCFO Jackie Jones, OCFO William Blaney, OCFO Greg Casto, NRR Geoffrey Wertz, NRR William Kennedy, NRR OIG DOC/RF ADAMS: Yes No Initials: MB Sunsi Review by: NA Publicly Available Non-Publicly Available Sensitive Non-Sensitive ADAMS: ML20289A477(Memo) ML20238B829(Pkg)
OFFICE OCFO/DOC/LAFBB NRR OCFO/DOC/FSOB OCFO/DOB/FBT NAME MBlair EHelvenston ELeGrand ARossi DATE 10/15/20 10/15/20 10/20/20 10/21/20 OFFICE OGC OCFO/DDOC OCFO/DOC DCFO NAME MClark DDAbate KADarling BFicks DATE 10/22/20 10/22/20 10/22/20 10/22/20 OFFICE CFO NAME CKJohnson DATE 10/23/20 OFFICIAL RECORD COPY