Aerotest Letter from the Chief Financial Officer Regarding Additional Information for the Fees Assessed Under to Aerotest Operations, Inc. (Aerotest) within Invoice Number Lfb 22-0346ML21344A033 |
Person / Time |
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Site: |
Aerotest |
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Issue date: |
01/03/2022 |
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From: |
Clay Johnson NRC/OCFO |
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To: |
Slaughter D Aerotest |
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smh |
References |
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LFB 22-0346 |
Download: ML21344A033 (3) |
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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
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARML22215A1522022-07-21021 July 2022 Aerotest Radiography and Research Reactor - AO RAI Responses for Decommissioning Plan 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 ML21181A1232021-06-22022 June 2021 License and TS Amendments ML21147A0602021-05-19019 May 2021 Response to RAI 28 and 29 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 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 ML20248H4602020-08-28028 August 2020 Inc - List of Explanations, Changes, and Justifications for Raj CFH Training and Requalification Program ML20098D4152020-03-26026 March 2020 Aerotest Radiography and Research Reactor, Response to NRC Staff Request for Additional Information (Redacted Version) March 26, 2020 ML19184A1122019-06-28028 June 2019 License and TS Amendments ML18303A2912018-10-24024 October 2018 Aerotest Radiography and Research Reactor Response to RAI-ORP-7 ML18240A1412018-08-22022 August 2018 Response to Request for the Small Entity Fee Adjustment ML18068A1632018-02-28028 February 2018 Response to Request for Holding Information from Public Disclosure, Non-Proprietary Chapter 15, USAR ML17363A3032017-12-20020 December 2017 Aerotest Operations, Inc. - Submittal of Response to Request to Supplement the License Renewal Application ML16319A1322016-11-0101 November 2016 Aerotest Operations, Inc., Response to Generic Letter 2016-01 Regarding Monitoring of Neutron-Absorbing Material in Spent Fuel Pools ML16313A1582016-11-0101 November 2016 Aerotest Operations, Inc., Response to NRC Generic Letter 2016-01 in Regard to Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools ML16294A2502016-10-10010 October 2016 Aerotest Radiography and Research Reactor Response to Request for Additional Information Regarding Opportunity to Supplement 2012 License Transfer Application ML16245A2302016-08-22022 August 2016 Pillsbury, Winthrop, Shaw, Pittman, Llp, Submittal of Response to Request for Additional Information Regarding Opportunity to Supplement 2012 License Transfer Application ML16203A1542016-07-12012 July 2016 Supplemental Response to Request for Additional Information Regarding Application for Change in Method of Providing Financial Protection ML16190A1732016-06-15015 June 2016 Pillsbury, Winthrop, Shaw, Pittman, Llp, Response to Request for Additional Information Application for a Change in Method of Providing Financial Protection ML16117A2592016-04-21021 April 2016 Response to Request for Additional Information Re; Opportunity to Supplement 2012 License Transfer Application 2022-07-21
[Table view] |
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January 3, 2022 Dr. David M. Slaughter President and Reactor Administrator Aerotest Operations, Inc.
32455 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 October 28, 2021 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML21307A125), which requests additional information for the fees assessed under §10 CFR 170.21 to Aerotest Operations, Inc. (Aerotest) within Invoice Number LFB 22-0346 dated October 20, 2021, for Docket No. 50-228.
In your letter, you note that, based on the hours reported in the invoice, NRC staff effort related to the review of Aerotests possession-only license amendment request (LAR) for the Aerotest Radiography and Research Reactor (ARRR), submitted by letter dated March 21, 2019 (ADAMS Accession No. ML19084A051), as supplemented, appears to be substantial through the pay period ending August 14, 2021, but little effort is reported during the remainder of the quarterly billing cycle (ending September 25, 2021). You state that it is not clear what the purpose of relatively short amounts of time (e.g., 1 or 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) expended over two week pay periods after August 14 is, and that it is also not clear if these short amounts of time represent one entry of time, or several shorter amounts of time over a pay period. You also state that you do not understand the purpose of the hours reported for Mr. Jack Parrott supporting the LAR review and request a description of Mr. Parrotts effort. Additionally, you state that you do not understand the overall status of the LAR review or progress toward its completion.
After consulting with the NRC staff, I am confirming that the staff time charges related to the LAR in Invoice Number LFB 22-0346 are valid. The hours reported through the pay period ending August 14, 2021, primarily relate to the NRC staffs review of the LAR supplement submitted by a letter dated June 22, 2021 (ADAMS Accession No. ML21181A123); updates to the draft LAR safety evaluation (SE) to reflect the information in the supplement; documentation of LAR open items; and NRC staff evaluation and discussion of options for resolving open items to complete the LAR review. The hours reported for the remainder of the billing cycle primarily relate to further NRC staff evaluation and discussion of options for completing the LAR review; further work to finalize the safety evaluation in preparation for concurrence review; and the NRC technical staffs support of the concurrence process. Consistent with the NRC policy, technical staff hours are billed to licensees; however, administrative staff, management, and legal reviews
D. Slaughter are not billed to the licensees. Hours reported for one staff member in any given pay period may represent any combination of time over one or more days within the pay period. The hours reported by Mr. Parrott reflect reviews of the LAR, draft LAR SE, and proposed possession-only license conditions and technical specifications to support NRC decommissioning branch concurrence on the possession-only license amendment, consistent with NRC processes for possession-only license amendments.
By a letter dated July 12, 2021 (ADAMS Accession No. ML21188A391), the NRC staff stated that it expected to complete its LAR review by December 8, 2021. The NRC provided its determination on the LAR by letter dated December 6, 2021 (ADAMS Accession No. ML21242A463).
For future inquiries regarding billing or request for additional information about the technical work being performed, please follow the established process for licensees and applicants to submit requests for information regarding fees assessed under 10 CFR part 170 by submitting NRC Form 527, Request for Information Related to Fees-For-Service (ADAMS Accession No. ML20104C055). NRC Form 527 includes detailed instructions and a process map. To submit a formal billing dispute, you must follow the process in 10 CFR §15.31, Disputed Debts, that became effective on August 20, 2021, when the FY 2021 Final Fee Rule went into effect. As stated in 10 CFR § 15.31(a), For any type of charges assessed by the NRC, a debtor may submit a dispute of debt within 45 days from the date of the initial demand letter. The debtor shall explain why the debt is incorrect in fact or in law and may support the explanation by affidavit, cancelled checks, or other relevant evidence. The dispute must be submitted to the Office of the Chief Financial Officer via the eBilling system, by email to FeeBillingInquiries.Resource@nrc.gov, or by mail to the Office of the Chief Financial Officer at:
U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, Attn: Chief Financial Officer. For debt disputes related to charges for 10 CFR part 170 fees, the debtor must complete and submit an NRC Form 529 with the required information.
For further inquiries regarding billing or request for additional information about the technical work being performed, please refer to the processes mentioned above; and for questions directly related to your license, please contact Mr. Edward Helvenston at 301-415-4067 or Edward.Helvenston@nrc.gov.
Sincerely, Signed by Johnson,Cherish ture: ckj on 01/03/22 Cherish K. Johnson Chief Financial Officer
Enclosures:
- 1. NRC Form 527
- 2. NRC Form 529 cc: Senator John Barrasso Senator Cynthia Lummis Senator Alex Padilla Representative Eric Swalwell R. Feitel, OIG E. Helvenston, NRR
ML21344A032 (package) ML21307A125 (incoming); ML21344A033 (letter)
OFFICE OCFO/DOC/LAFBB/FBT OCFO/DOC/LAFBB/FBT NRR/DANU/UNPL NRR/DANU/UNPL OCA NAME NAridi MLee EHelvenston JBorromeo DDecker DATE 12/10/2021 12/13/21 12/16/21 12/20/21 12/20/21 OFFICE OGC NRR/DANU DCFO/DOC/LAFBB OCFO/DOC OCFO/DOC NAME BHarris JBowen MBlair (KRiner for) DDAbate KDarling DATE 12/15/21 12/21/21 12/21/21 12/22/21 12/22/21 OFFICE DCFO CFO NAME BFicks CKJohnson DATE 12/22/21 12/22/21