ML24197A111

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Letter Regarding Denying Reimbursement for Service the NRC Did Not Perform in a Satisfactory Manner
ML24197A111
Person / Time
Site: Aerotest
Issue date: 07/10/2024
From: Slaughter D
Aerotest
To: Jennifer Golder
Document Control Desk, NRC/OCFO
References
Download: ML24197A111 (1)
v • d • e


Text

AEROTEST OPERATIONS, INC.'

3455 FOSTORIA WAY

  • SAN RAMON, CA 94583 * (925) 866-1212
  • FAX (925) 866-1716

, July 10, 2024

Jennifer Golder Acting Chief Financial Officer U.S. Nuclear Regulato1y Commission Office of the Chief Financial Officer Division of the Comptroller Labor Administration and Fee Billing Branch Mail Stop T9 850 Washington, DC 20555-0001

RE: Cherish K. Johnson, CFO NRC letter dated April 30, 2020, to Dr. David M \\

Slaughter, President of Aerotest Operations, Inc denying reimbursement for service the NRC did not perform in a satisfactory manner ( or according to NRC regulations and procedures) (ADAMS #ML21056A317)

Ms. Jennifer Golder:

I am again requesting reimbursement for service the NRC did not perform in a satisfactory manner (or according to NRC regulations and procedures).

Since the April 30, 2020, letter was issued NRC OIG has issued 2 Investigation Reports and 1 Audit Report that support my reimbursement request for services the NRC did not perform in a satisfactory manner ( or according to NRC regulations and procedures).

  • OIG 021-012 "Aerotest Memorandum" dated 8/17/22 with is included as an attachment to letter dated October 5, 2023, addressed to Senators Lummis and Padilla and cc'd to NRC Commissioners (Hanson, Baran, Wright, Caputo, and Crowell), NRC CFO (Howard K Osborn and NRC Deputy General Counsel (Marian Zober). (ADMAS ML24058A360) e OIG 021-016 "Special Inquiry Report on the NRC's Oversight of the Research and Test Reactor Program" Issued September 29, 2023 (ADAMS
  1. ML23272A039)
  • OIG Aduit #24-A-07 "Audit of the U.S. Nuclear Regulatory Commission's Safety Inspections of Class II Research and Test Reactors" issued April 11, 2024 (ADAMS #ML24102A254)

In response to OIG 21-016 "Special Inquiry Report on the NRC's Oversight of the Research and Test Reactor Program" the NRC issued a written response dated February 2, 2024 (ADAMS #ML24017A135) and held a meeting on February 22, 2024, with the

Aerotest Operations, Inc Reimbursement Request Page 1 of 8 RTR's. Here are excerpts from NRC'sresponse which again support my reimbursement request for services the NRC did not perform in a satisfactory manner ( or according to NRC regulations and procedures).

e In the NRC Commission meeting on February 22, 2024, the NRC staff stated" The general requirement for regulation of RTRs is described in Section 104c of the Atomic Energy Act of 1954, as amended (AEA), which inherently acknowledges this lower risk and the important role ofRTRs, by requiring the Commission to impose only such minimum amount of regulation as necessary to protect public health and safety, promote common defense and security, and permit the conduct of widespread and diverse research and development. The NRC inspection program for RTRs follows this direction in that the program applies a graded approach to the frequency and scope of inspections commensurate with the risk posed by the facility, to ensure that reasonable assurance of adequate protection of public health and safety and the environment is maintained."

  • Also, in the February 22, 2024, meeting Josh Borromeo, Branch Chief, Non Power Production and Utilization Facility Licensing Branch, presented NPUF regulatory program and risk-informed implementation oflicensing and oversight.

His slide "Foundations of Safety" indicated that the NRC Oversite (which inspections are part of) confirms compliance with license and regulations. He mentioned NUREG 1537, which was published in 1996 as their guide to licensing RTR's.

  • Josh Borromeo stated the "NRC guidelines for the frequency of inspecting an RTR is based on power levels. (NRC Inspection Manual Chapter 2545-08 quoted below). He also added the program was flexible and the NRC could adjust the inspection frequency based on performance deficiencies identified."
  • Josh Borromeo also indicated a possibility that the financial charges to non university reactors as "being unfair" and are being reevaluated. He was talking about the algorithm used to assign NRC fees being *odious given that the small number of reactors that remain

The NRC Inspection manual provides us with the following additional information.

  • NRC Inspection Manual Chapter 2545-08. "Class II RTRs are less than 2 megawatts and are inspected bi-annually."
  • NRC Inspection Manual Chapter 2545-7.02 NRC inspectors perform a basic mission in determining whether a licensee's R TR is acceptably safe and meets current regulatory requirements and commitments."

What actually transpired at Aerotest Operations:

  • Areotest Operations, Inc (AO) a 250-Kilowatt TRI GA reactor which per Inspection Manual 245-08 is a Class II RTR and should be inspected bi-annually.
  • NRC Inspected AO annually from 1996 -2012 AO (Table 1)
  • AO had the same inspector from 1998-2020 (22 years)
  • Looking at the publicly available inspection reports on AO, I could not find any identified performance deficiencies in their inspection reports to warrant the

Aerotest Operations, Inc Reimbursement Request Page 2 of 8 increased inspections. Which goes against the Inspection Manual 2545 and Section 104c of the Atomic Energy Act of 1954.

  • The conditions found at AO are more a result of quality of NRC oversight not the frequency.
  • Unlike most other RTR's AO is billed for all services and must pay for each hour the NRC's spent on those inspections, travel, reports. etc. Given the substandard conditions of the reactor and license when transferred in 2017, effective services were not rendered by the NRC, but AO was charged, and AO paid those bills.
  • The actual reactor and operations did not match the public records available at the NRC. I used those public records in the due diligence that convinced me of the viability of the reactor operation and business.
  • When I took over control of AO reactor that AO's License and Technical Specifications were out of date, they were not within current regulations and did not follow NUREG 1537 guidelines. Even if you disregarded the written condition of the governing documents, License/TS, the actual operating manual, and procedures were antiquated and did not necessarily satisfy current regulatory obligations.

o For example, before 2012, a commonly cited fuel inspection procedure by the NRC inspector did not even exist. (Section IV of the Procedures Manual entitled, "Critical Assembly and Power Calibration Procedures,"

last reviewed May 16, 2002" ADAMS (ML022480411) dated 9/6/02) o Lack of modem written license and TS and up-to-date operational manual and procedures represented a potential minefield of future violations if the antiquated wording and circumstances that have been accepted in the past by the NRC are interpreted differently by this same agency.

o The prior licensee failed to keep License and TS in compliance with current regulatory requirements; while for this class of reactor it is not required to update the TS regularly, however AO's operating manual and procedures are required to comply with current regulations. This did not happen.

  • The Inspector failed to identify the licensee did not meet the current regulatory requirements, which is part of their basic mission when inspecting the licensee. The inspector inspected the Licensee for 22 years and was aware that License and Technical Specifications were written in 1965-1968 and the short coming of the operating manual and procedures.
  • In 2019 AO, a small business, was forced into decommissioning their reactor because of the NRC cost and timeline to bring AO's License/TS, the actual operating manual, and procedures into compliance with current NRC regulations.

AO paid the NRC whose mission is to determine whether a "licensee's RTR is acceptably safe and meets current regulatory requirements and commitments."

Here are some excerpts from the OIG report entitled Special inquiry into the U.S. Nuclear Aerates! Operations, Inc Reimbursement Request Page 3 of 8 Regulatory Commission's Oversight of Research and Test Reactor Program. * *

  • On Page 7. "The agency's RTR program failed to identify and address problems with the

NIST test reactor and other RTRs, specifically: (A) the NRC failed to identify problems with fuel movement, including precursors to later events; (B) the NRC's inspection practices often lacked direct observation of activities important to safety; (C) RTRs other than the NIST reactor experienced significant fuel oversight issues; and. (D) the agency's RTR program has not been substantively updated for at least two decades. and does not reflect the agency's risk-informed and safety culture positions.

  • The OIG's findings highlight future challenges for the agency's oversight programs for RTRs and advanced reactors." In Section III o "A. The NRC's approach to inspections at the NIST test reactor prior to the February 2021 event resulted in the failure to identify and address fuel movement problem areas that were potential event precursors. From 2016 through 2020, the NRC inspected NIST audit reports, fuel movement records, and fuel movement procedures that had indications of potential problems. However, the NRC failed to follow up on NIST audit committee reports identifying deficiencies with safety culture and operator training and requalification that contributed to the event. The NRC also failed to identify records that revealed unlatched fuel elements and procedures that lacked adequate steps to ensure fuel elements were latched."

o "B. The NRC's oversight ofRTRs lacked direct observation of activities important to safety. The OIG found that the NRC staffs routine inspections at NIST were scheduled primarily based on the annual frequency requirements stated in staff guidance documents. rather than by considering the timing of fuel movement or other planned activities that would have allowed inspections through direct observation. As a result, the NRC had not directly observed the fuel element latch checks following fuel movement at the NIST test reactor in the five years prior to the event.

An unlatched fuel element was the direct cause of the 2021 event."

o "C. The NRC's oversight practices were not unique to NIST and were implemented in the same manner at two other RTRs that experienced fuel issues. The OIG also found inadequate technical specifications and dated license bases that contributed to these fuel issues. Additionally, in one instance, the NRC failed to act for at least five years to address damaged fuel as described in NRC inspection reports."

o "D. The agency's RTR inspection program policy and guidance are outdated because they do not implement risk-informed approaches and safety culture elements. The last major revision to the safety inspection program was in 2004. Additionally, the 2004 safety inspection procedures underestimate the resources needed to complete all requirements that are defined in policy as "mandatory activities."

  • On Page 17: The OIG found that, between 2000 and 2010, NRC biennial inspections of Aerotest were inadequate. Specifically, the NRC did not perform direct observation of fuel movement and failed to adequately conduct oversight Aerotest Operations, Inc Reimbursement Request Page 4 of 8 activities related to damaged fuel, the facility's licensing basis, its ALARA program, and its technical specifications.

Here are some excerpts from the OIG memorandum Aerotest Investigation OIG case 021-01: * "The RTR inspector said that not acting sooner to report and resolve the stuck fuel

was his "mistake,' and that he should not have closed IFl-50-228/2005-201-02 until he had verified that the licensee completed its plan of action. He explained he was too reliant on "the experience of the project manager and the people above him" when deciding how to handle issues found during his inspections. The R TR inspector did not say why no violation was issued until 2013, except that the decision would have been a consensus judgement call. The RTR inspector said, "Typically. If one of these research reactors has a rod that is stuck or they are inspecting them and see a little damage of any sort, they just put it aside in storage and will not re-use it. This facility was very unique in that they did not do that.

So, they just operated with the damaged fuel. 11 He said that training and guidance could be improved. 11

Now let us turn back to Cherish K. Johnson, CFO NRC letter dated April 30, 2020, denying reimbursement for service the NRC did not perform in a satisfactory manner ( or according to NRC regulations and procedures) (ADAMS #ML21056A3 l 7)

e I. Untimely o AO reported the charges for service the NRC did not perform in a satisfactory manner ( or according to NRC regulations and procedures) is soon as it was discovered that NRC did not "perform their basic mission of in determining whether a licensee's RTR is acceptably safe and meets current regulatory requirements and commitments".

  • IL Improperly Assessed Fees o NRC did not perform their "basic mission of determining whether a licensee's RTR is acceptably safe and meets current regulatory requirements and commitments".

o The NRC billed for actual effort (in hours) expended by NRC Staff even though the NRC staff result did not meet "the NRC basic mission of determining whether a licensee's RTR is acceptably safe and meets current regulatory requirements and commitments".

o OIG 21-012 Memorandum clearly shows the NRC bill AO for NRC Staff time which they did not perform in a satisfactory manner ( or according to NRC regulations and procedures) o Josh Borromeo also indicated a possibility that the financial charges to non-university reactors as "being unfair" and are being reevaluated. He was talking about the algorithm used to assign NRC fees being odious

_given that the small number ofreactors that remain

  • III. Oversight was not inappropriate o The following OIG reports support the lack of effective or appropriate oversite by the NRC

Aerates! Operations, Inc Reimbursement Request Page 5 of 8 OIG 021-016 "Special Inquiry Report on the NRC's Oversight of the Research and Test Reactor Program" Issued September 29, 2023 (ADAMS #ML23272A039)

OIG Aduit #24-A-07 "Audit of the U.S. Nuclear Regulatory Commission's Safety Inspections of Class II Research and Test Reactors" issued April 11, 2024 (ADAMS #ML24102A254) o The general requirement for regulation of RTRs is described in Section 104c of the Atomic Energy Act of 1954, as amended (AEA), which inherently acknowledges this lower risk and the important role of R TRs, by requiring the Commission to impose only such minimum amount of regulation as necessary to protect public health and safety, promote common defense and security, and permit the conduct of widespread and diverse research and development. The NRC inspection program for RTRs follows this direction in that the program applies a graded approach to the frequency and scope of inspections commensurate with the risk posed by the facility, to ensure that reasonable assurance of adequate protection of public health and safety and the environment is maintained."

o Looking at the publicly available inspection reports on AO, I could not find any identified performance deficiencies in their inspection reports to warrant the increased inspections. Which goes against the Inspection Manual 2545 and Section 104c of the Atomic Energy Act of 1954.

  • IV. Fee-Policy Concerns not basis for relief o I am asking for reimbursement because services paid for, we not provided
  • V. Disputed Fees Unsupported o Please see responses to I. -IV. above

I am asking the NRC for reimbursement of fees and interest that AO paid the NRC from 1995 -2020 with interest calculated at federal funds rate plus 2% calculated annually (prior year balance plus1/2 of this year's invoices time the rate on 12-31 each year) in the amount of $6,603,602.38 (See attach tables 2 and 3). I will accept $4,603,602.38 as a credit toward future NRC Bills and $2,000,000.00 in Cash.

All information reference in ADAMS is included in this letter. If any additional information or clarification is required, please contact me at dmsraven@gmail.com or (801) 631-5919.

I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed on July 10, 2024.

Respectfully, Aerotest Operations, Inc Reimbursement Request Page 6 of 8 David M Slaughter, PhD AO President, Reactor Administrator, General Manager. NRC -RO and Manager CEO Nuclear Labyrinth LLC.

Enclosure:

Table 1 Tab le 2 Table 3

C C:

ALT : Document Control Desk U. S. Nuclear l{egulatory Commiss ion Washi ngton, D C 20555-000 I

Secretary of the Commission U.S. Nuclear Regulatory Commission Mail Stop 0-16 B33 Washington, DC 20555-000 1 Commissioners Christopher T. Hanson, David A. Wright, Annie Capu to, and Bradley R. Crowell

Brooke P Clark Deputy General Counsel U.S. Nuclear Reg ulatory Commission Office of the General Counsel Mail Stop 0-15 D-21 Washington, DC 20555-0001

Mcrrid, B. Gar land Attorney General U.S. Department of Ju stice 950 Pennsy lva ni a Ave nue. NW Washington. DC 20530-000 I

Via Email:

Cole La Croix (US Repre sentative Curtis Office) cole.lacroix (@,mail.house.gov

Andr ew Williams (US Senator Lummi s Office) Andrew Williams@lumimis.senate.gov

Aerotest Operations, Inc Re imbursement Reques t Page 7 of 8 Andrew Zack (US Senate Committee on Environment & Public Works Staff)

Andrew Zach@EPW.Senate.gov

Andrea Vasquez (US Representative Mark DeSaulnier Office)

Andrea. Vasquez@mail.house.gov

Nate Bentham (US Senator Padilla Office) Nate_Bentham@Padilla.senate.gov

Aerotest Operations, Inc Reimbursement Request Page 8 of 8 TABLE 1 Aerotest Inspections byNRC

Year Month Days Number Type of Inspection Inspectors/Approved by Ou PM Findings Adams 1994 January 3-11 94-01 Routine Leroy R Norderhaug, P.M. Marvin Medonca Quaills,/Robert J Plate 1996 April 22-26 96-01 Routine JB Nicholas AD McQueen/Thomas Marvin Medonca Level IV Violations - Control Gwynn access to high radiation areas and the vehicle access gate left open.

1997 June 3-4 97-201 Routine Marvin Mendonca/Seymour H Weiss Marvin Medonca ML20149E755/ML20149E783

1998 November 2-5 98-201 Routine CH Bassett/Seymour H Weiss Marvin Medonca Level IV Violation - missing information on shipping documents 1999 August 16-19 99-201 Routine CH Bassett/Ledyard B Marsh Marvin Medonca 2000 September 11-14 00-201 Routine CH Bassett/Ledyard B Marsh Marvin Medonca Transfer Issue ML003755637 2001 August 20-23 01-201 Routine CH Bassett/Patrick M Madden Marvin Medonca ML012500147 2002 August 26-29 02-201 Routine CH Bassett/Patrick M Madden Marvin Medonca ML022480411 2003 June 9-11 03-201 Routine CH Bassett/Patrick M Madden Marvin Medonca 2004 August 16-19 04-201 Routine CH Bassett/Patrick M Madden Marvin Medonca ML042380162 2005 April 25-28 05-201 Routine Craig Bassett, Kevin Witt/Patrick M Marvin Medonca ML05138438 Madden 2006 June 5-8 06-201 Routine/Safety Craig Bassett/Johnny E Eads Marvin Medonca ML061730163 2007 June 11-14 07-201 Routine Craig Bassett/Johnny E Eads Marvin Medonca ML071700653 2008 April 21-24 08-201 Routine Craig_Bassett, Phillip Young/Johnny E Marvin Medonca ML081230113 Eads 2008 April 23-24 08-202 safety Craig Bassett/Johnny E Eads Marvin Medonca ML081230034 2009 June 6-8 09-201 Routine Craig Bassett/Johnny E Eads Cynthia Montgomery ML091770065 2010 May 3-6 10-201 Routine Craig Bassett/Johnny E Eads Cynthia Montgomery ML101330004 2010 May 5-6 10-202 safety Craig Bassett/Johnny E Eads Cynthia Montgomery ML101330006 2010 November 8-10 10-203 Non Routine Craig Bassett/Johnny E Eads Cynthia Montgomery ML103340011 2011 August 15-17 2011-01 Routine Craig Bassett/Johnny E Eads Cynthia Montgomery ML112570060 2012 December 10-13 2012-206 Non Routine Craig Bassett/Gregory T Bowman Spyros Traiforos ML12361A147 2012 July 16-23 2012-204 Non Routine Craig Bassett/Gregory T Bowman Spyres Traiforos ML12213A001 2012 June 12-14 2012-202 Routine Craig Bassett/Gregory T Bowman Spyros Tra iforos ML12192A078 2012 June 13-14 2012-203 Security Craig Bassett/Gregory T Bowman Spyros Traiforos ML12192A096 2012 Sept 10-12 2012-205 Non Routine Craig Bassett, Gregory T Spyres Traiforos ML12264A000 Bowman/Gregory T Bowman 2013 December 18 Spyres Traiforos Level Ill violation issued ML13212A051 12/18/13 - TSl0.2 Fuel Violation 2006-present

7/10/2024 1 of 2 TABLE 1 Aerotest Inspections byNRC

2014 November 17-19 2014-201 Routine Craig Bassett, Kevin Hsueh, ""'.illiam Spyros Traiforos Level IV violation - late ML14351A262 Schuster/Kevin Hsueh medical exam 2014 November 18-19 2014-202 safety Craig Bassett, Kevin Hsueh, William Spyros Traiforos ML14335A576 Schuster/Kevin Hsueh 2015 August 17-19 2015-201 Routine Craig Bassett/Kevin Hsueh Spyros Traiforos ML15273A428 2015 August 18-19 2015-202 safety Craig Bassett/Kevin Hsueh Spyros Traiforos ML15257A331 2017 June 19-21 2017-2017 safety Craig Bassett/Anthony J Mendiola Spyros Traiforos ML17181A298 2020 August 10-12 2020-201 Routine Craig Bassett/Travis Tate Edward Helvenston Level IV Violation - TS12.1.5 ML20240A252 RSO Education 2020 August 11-12 2020-202 safety. Craig Bassett/Travis Tate Edward Helvenston Level IV Violation - ML20237F588 Background check not document 2023 June 27 2023-01 Routine Stephaine G Anderson, Michael M Jack D Parrott Level IV Violation - Failure M L24039A038 Lafranzo, Jack D Parrot, /Nathan A to route a neutron monitor fuguel to the electronics shop for adjustment and/or repair if meter is more than 20% off expected readings; Level IV Violation - Failure to implement the ARRR CFH Training; Minor Violation -

the Reactor Safeguards Committee failed to meet at least annually.

(Did not meet within 365 days or in Calendar year 2021)

7/10/2024 2 of 2 Aerotest Operations, Inc.

List of Payments to NRC Table 2

Date Num Memo. Amount

1995 Financial Statement 52,943.00 1996 Financial Statement 66,432.00 1997 Financial Statement 56,650.00 1998 Financial Statement 200.00 08/13/1998 1987 1998 ANNUAL FEE 47,750.00 08/13/1998 1987 FY 1999 PORTION 9,550.00 04/30/1999 3037 INSPECTION CHARGES ON LICENSE R-98 10,044.00 08/13/1999 3440 RESEARCH REACTOR FEES FY 1999 71,583.33 08/13/1999 3440 AUGUST EXPENSE 7,158.34 08/13/1999 3440 PREPAID FY 2000 7,158.33 2000 Financial Statement 74,987.00 02/04/2000 9 License R-98 Inspection 517.00 02/04/2000 9 Routine Inspection 2,585.00 2001 Financial Statement 18,394.00 08/08/2001 6016 Review of Part 50 Application 2,088.00 08/17/2001 6030 FY 2001 Annual License Fee 74,000.00 10/26/2001 6278 Review of Part 50 3,924.00 03/06/2002 6717 Routine Inspections 10,152.00 03/06/2002 6718 Review of Part 50 14,969.00 04/26/2002 6868 Review of Part 50 13,890.00 08/23/2002 7195 10/01/2001-9/30/02 71,400.00 09/19/2002 7257 Review of Part 50 14,985.00 11/08/2002 7416 Part 50 Application 16,651.00 03/17/2003 7766 Part 50 Application 14,804.00 05/06/2003 7879 Part 50 Application 13,463.00 08/01/2003 8165 Review of Part 50 7,987.20 08/01/2003 8166 Review of Part 50 8,923.00 08/20/2003 8209 FY 2003 Annual Fee 63,300.00 10/24/2003 8443 Review of Part 50 5,990.00 11/07/2003 8506 Review of Part 50 998.00 02/10/2004 8830 Review of Part 50 9,734.00 02/10/2004 8832 Part 50, License #R-98 8,892.00 04/20/2004 9072 Review of Part 50 9,625.00 07/13/2004 9323 FY ANNUAL FEE 2004 62,500.00 08/13/2004 9443 Review of Part 50 13,681.00 09/24/2004 9576 Routine Inspection, License R-98 11,904.00 10/21/2004 9682 Review of Part 50 $78.50 PM $10,707.40 10,786.00 03/08/2005 10123 Part 50 Routine 13,188.00 04/26/2005 10302 PM 8,792.00 08/08/2005 10618 Annual Permit Fee (License No. R-98) 59,500.00

7/10/2024 1 of 3 Aerotest Operations, Inc.

List of Payments to NRC Table 2

Date Num Memo Amount

08/08/2005 10619 PM 12,952.50 10/20/2005 10867 Routine Reactive Inspections 8,792.00 10/20/2005 10868 PM 13,090.00 02/07/2006 11207 PM 20,213.00 04/21/2006 11448 PM 17,466.00 08/10/2006 11731 FY Annual Fee 80,100.00 08/10/2006 11745 PM 13,632.50 10/23/2006 11967 PM 1,407.00 01/26/2007 12274 Part 50 Routine (9/17/06-12/23/06) 13,229.00 01/26/2007 1226\\5 Review of Part 50 $868/PM $7985 8,854.00 04/20/2007 12534 PM 3,341.80 07/26/2007 12852 PM 9,765.00 08/16/2007 12915 FY 2007 ANNUAL FEE 76,300.00 10/18/2007 13121 PM 16,506.50 10/18/2007 13122 Routine Inspections 18,445.00 02/04/2008 13472 PM 6,424.00 04/18/2008 13716 PM 8,772.00 07/22/2008 13977 PM 5,392.20 08/08/2008 14035 Routine Inspection 25,800.00 08/25/2008 14084 Annual Fee 76,500.00 10/17/2008 14248 Review of Part 50 6,129.40 02/09/2009 14592 PM 68,472.60 04/16/2009 14769 PM 74,018.00 07/23/2009 14999 PM 102,388.00 08/10/2009 15073 FY 2009 License R-98 Renewal 87,600.00 10/21/2009 15246 Review of part 50 17,136.00 10/27/2009 15251 Review of Part 50 $257/PM $476 733.00 02/08/2010 15526 Review of Part 50 $1028/PM $9354 10,383.00 04/27/2010 15708 Review pf Part 50 $17912/PM $6450.70 24,364.00 07/30/2010 15954 Routine/Reactive lnspections(3/28-7/03/10) 18,504.00 07/30/2010 15955 Review of Part 50$11950/PM $28038. 70 39,989.00 08/24/2010 15954 FY 2010 Annual Fee 81,700.00 10/25/2010 16090 Review of Part 50 $1150 / PM $12917.20 14,467.00 03/10/2011 16346 Inspection Report 28 hrs/ Transfer 18 hrs 15,151.50 05/31/2011 16467 License Transfer Fee 518.00 08/12/2011 16566 PM 17,096.59 09/16/2011 16620 Annual License Fee(10-01-2010-9-30-2011) 86,300.00 11/21/2011 16710 Inspection 58 hrs/over head 64.08 hrs 32,037.18 03/16/2012 16875 Review of Part 50 - PM 25,025.91 05/03/2012 16947 Inspection 68 hrs/safety 214 hrs/PM 16 hrs 86,030.49 08/24/2012 17119 Inspection 56 hrs/safety 234.5 hrs/transfer 43/pm 105.5 hrs 163,936.50

7/10/2024 2 of 3 Aerotest Operations, Inc.

List of Payments to NRC Table 2

Date Num Memo Amount

08/29/2012 17132 Annual Fee License R-98 34,700.00 08/29/2012 17140 Annual Fee R-98 34,700.00 11/14/2012 17238 Safety 165.50 hrs/Transfer 175.75 hrs/inspection 166 hrs 158,234.75 01/14/2013 17335 Cynthia Montgomery 6,198.36 02/27/2013 17399 Safety 48 hrs/Transfer 240 hrs/inspection 48 hrs 155,084.00 04/25/2013 17489 Safety Riview 115 hrs/Transfer 126.5 hrs/PM 121 hrs 99,325.00 08/05/2013 17636 Safety 90hrs/Transfer 73.25 hrs/ PM 101.75 hrs 72,610.00 09/06/2013 17673 Annual Fees 81,600.00 11/06/2013 17767 Safety Rievew 104 hrs/Transfer 82.50 hrs/PM 56.25 67,804.00 03/10/2014 17936 Safety Review 8 hrs/PM 5.36hrs 3,633.95 04/22/2014 18009 PM Changes 30 hrs 8,296.00 08/18/2014 18168 Indirect Transfer 126 hrs/PM 53.65 hrs 57,908.80 09/24/2014 18222 Annual Fees 84,500.00 11/18/2014 18296 Transfer 244.25 hrs/PM 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> 75,427.05 02/06/2015 18434 2014201/0500028 64 hrs and PM Charges 27.5 hrs 25,458.75 09/23/2015 18757 Docket #05000228 (Period 7/01/2015-09/30/2015) 83,500.00 05/26/2016 19118 NRG Fees 20,381.58 08/10/2016 19236 Proof of Financial protection/Transfer 108 hrs 30,680.64 09/06/2016 19267 ANNUAL FEE 81,500.00 11/04/2016 19357 Proof of Financial protection/Transfer 221.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> 62,965.33 02/17/2017 19516 QTR. 9/18/16 thru 12/24/16 (Part 170) 15,028.15 04/19/2017 19612 SRI Allocation Costs 11,797.80 07/26/2017 19772 LFB 17-4184 16,783.78 09/01/2017 LFB-17-5273 6/1 /17-9/30/17 81,400.00 10/25/2017 LFB 18-0411 6/25/17-9/30/17 10,662.54 01/23/2018 05000228 3,136.28 04/26/2018 05000228 12/24/17-3/31/18 27,529.53 07/19/2018 LFB 18-4924 Docket # 05000228 81,473.46 08/28/2018 LFB 18-5687 Per Small Business Form 526 850.00 10/25/2018 LFB19-0384 LFB19-0384 Docket #05000228 Small Business Fees 3,343.59 10/25/2018 LFB 019-0384 PM, Renewal, Start up, TS6.6 30,092.26 01/23/2019 LBF 19-1696 PM, Renewal, Start up, TS6.6 11,687.50 04/24/2019 LFB-19-3117 PM 3,781.25 07/19/2019 LFB-194096 LAR/OPR 2,887.50 08/14/2019 LFB-19-4890 Annual Fee 900.00 10/23/2019 LFB-20-0434 LAR/OPR 15;883.25 01/15/2020 LFB-20-1849 LAR/OPR (partial payment disbute $22,796) 1,251.00 04/21/2020 LFB-20-3811 LAR/ORP 23,726.25 09/17/2020 LFB-20-4504 Annual Fee 900.00 10/21/2020 LFB-21-0354 lnpection, LAR/ORP, PM 42,717.00 4,011,380.22

7/1.0/2024 3 of 3

.. I * +

Aerotest Operations Inc.

NRC overpayment interest Based on Federal funds plus 2%

Table 3

Interest Interest Year Fees Rate $ Total

. 1995 52,943.oq 52,943.00 i996.66,432.00 7.29% 6,280.99 125,655.99 1997 56,650.00 7.50% 11,548.57 193,854.57 1998 57,500.00 6.68% 14,869.98 266,224.55 1999 95,944.00 7.30% 22,936.35 385,104.90 2000 78,089.00 8.40% 35,628.55 498,822.45 2001 98,406.00 3.82% 20,934.57 618,163.02 2002 142,047.00 3.24% 22,329.64 782,539.66 2003 115,465.20 2.98% 25,040.11 923,044.98 2004 127,122.00 4.16% 41,042.81 i,091,209.79 2005 116,314.50 6.16% 70,801.01 1,278,325.29 2006 132,818.50 7.24% 97,358.78 1,508,502.58 2007 146,441.30 6.24% 98,699.53 1,753,643.41 2008 129,017.60 2.16% 39,272.09 1,921,933.09 2009 350,347.60 2.12% 44,458.67 2,316,739.36 2010 189,407.00 2.18% 52,569.45 2,558,715.81 2011 151,103.27 2.07% 54,529.34 2,764,348.42 2012 502,627.65 2.16% 65,138.30 3,332,114.37 2013 482,621.36 2.09% 74,684.58 3,889,420.32 2014 229,765.80 2.12% 84,891.23 4,204,077.35 2015 108,958.75 2.24% 95,391.67 4,408,427.77 2016 1:95,527.55 2.54% 114,457.27. 4,718,412.58 2017 135,672.27 3.30% 157,946.21 5,012,031.06 2018 146,425.12 4.27% 217,139.90 5,375,596.08 2019 35,139.50 3.55% 191,457.39 5,602,192.97 2020 68,594.25 2.09% 117,802.64 5,788,589.86 2021 0.00 2.08% 120,402.67 5,908,992.53 2022 0.00 6.10% 360,448.54 6,269,441.08 2023 0.00. 5.33% 334,161.21 6,603,602.28

Total 4,011,380.22 2,592,222.06 6,603,602.28

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