ML20248L463
| ML20248L463 | |
| Person / Time | |
|---|---|
| Site: | 07100827 |
| Issue date: | 03/17/1998 |
| From: | Funches J NRC OFFICE OF THE CONTROLLER |
| To: | Spencer G AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 9803230073 | |
| Download: ML20248L463 (6) | |
Text
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30e66-0001 o% ,,,g / -
March 17, 1998 f
Oceaneering intemational, Inc.
Solus Schall Division .
ATTN: George Spencer, RSO 11921 FMS29 Houston, TX 77041
Dear Mr. Spencer:
I am replying to your correspondence of October 7, October 22, and November 20,1997, regarding Quality Assurance Program Approval No. 0827 (QA 0827), invoice AM6365-97. QA 0827 was issued September 8,1995, with an expiration date of September 30,2000. QA 0827 was terminated by NRC on June 27,1997, based on NRC's rulemaking and you therefore believe no fees are due. For the reasons set forth below, the FY 1997 annual fee has been prorated; however, we must regretfully inform you that you also owe the annual fee for FY 1996.
The NRC published proposed rulemaking for public comment in the Federal Register on February 28,1994, which would, among other changes, modify the quality assurance 3
requirements for transportation. The final rule which was published May 28,1997, and became effective June 27,1997, adopted this change. As a result, a separate NRC QA program approval is no longer required effective June 27,1997. I have been advised that you were not >
on the mailing for either the proposed or final rule and therefore may not have been aware of I the revised regulation.
We similarly sent copies of our proposed and final FY 1996 and FY 1997 fee rules to all current NRC licensees; however, since you had not been added to the database at that time, you were not on the mailing lists for proposed or final FY 1996 fee schedules nor the proposed or final FY 1997 fee schedules.
Your November 20,1997, letter states: (1) we received no correspondence at all with regard to this program and certainly no notices of rulemaking or changing with regard to regulations pertaining to this program; and (2) had we known that this particular QA program was to be terminated, then, we would have made a determination to cancel, as we only carry type "B" packaging as a back up to our operations.
Annual fees are assessed to persons who hold a license on the first day of the fiscal year for which the annual fee is assessed. Since QA 0827 was issued September 8,1995, and was in effect until June 27,1997, you were subject to the annual fee for FY 1996, which began October 1,1995, and FY 1997, which began October 1,1996. You were not subject to FY 1995 annual fees. QA 0827 was not added to the database for billing purposes and therefore j you were not invoiced during FY 1996. Invoice AM6358-96 was issued November 30,1997, for
! the FY 1996 annual fee (the original invoice has not been mailed to you pending the results of this review.) We regret the administrative oversight which resulted in this delayed billing.
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. U. S. NUCLEAR REGULATORY COMMISSION l
1 FY 97 Annual Materials Fee Invoice Period 10/1/1996 - 9/30/1997
, 10 CFR 171.16 I
Invoice Date License Anniversary Month Invoice Number 03/18/98 September AM6365-97 TO: SOLUS SCHALL ATTENTION: RADIATION SAFETY OFFICER 11921 FM 529 HOUSTON, TX 77041
- Mark PAYMENT COPY with any billing address changes *****
License / Approval /
Registration / Code Annual Fee Certificate Number AA905 Category (s) Fee Amount 0827 ANN 10B (2 ) $ 500.00 TOTAL: $ 500.00 TOTAL INVOICE: $ 500.00 Amount Billed Represents 50% Proration If paid by Fedwire see attached Terms and Conditions. If paid by check, make check payable to the NRC (reference Invoice no.) and mail toi j
............................................. i U.S. Nuclear Regulatory Commission <=== This PO Box address is f License Fee & Accounts Receivable Branch <=== for receipt of payments i P.O. Box 954514 <=== only.
St. Louis, MO 63195-4514 For terms and conditions see attached.
Payment must be received within 30 days of the date of this invoice to avoid late charges.
Questionsx call 301/415-7554.
- PAYMENT COPY
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. I U. S. NUCLEAR REGULATORY COMMISSION i
FY 97 Annual Materials-Fee Invoice Period 10/1/1996 - 9/30/1997 1 10 CFR 171.16
- Invoice Date License Anniversary Month Invoice Number 03/18/98 September AM6365-97 .
TO: SOLUS SCHALL ATTENTION: RADIATION SAFETY OFFICER f 11921 FM 529 HOUSTON, TX 77041
- Mark PAYMENT COPY with any billing address changes *****
License / Approval /
Registration / Code Annual Fee Certificate Number AA905 Category (s) Fee Amount 0827 ANN 10B (2 ) $ 500.00 TOTAL: $ 500.00 TOTAL INVOICE: $ 500.00 Amount Billed Represents 50% Proration
!! paid by redwire see attached Terms and conditions. If paid by check, make check payable to the NRC (reference Invoice no.) and mail ton
........................................e....
U.S. Nuclear Regulatory Commission <=== This PO Box address is License Fee & Accounts Receivable Branch <=== for receipt of payments P.O. Box 954514 <=== only.
St. Louis, MO 63195-4514 For terms and conditions see attached.
Payment must be received within 30 days of the date of this invoice to avoid late charges.
Questions: call 301/415-7554.
- LICENSEE COPY
- U. S.
NUCLEAR REGULATORY COMMISSION j
FY 96 Annual Materials Fee Invoice Period 10/1/1995 - 9/30/1996 10 CFR 171.16 Invoice Date
............ License Anniversary Month 11/30/1997 .........................
September Invoice Number AM6358-96 SOLUS SCHALL h ATTENTION:
RADIATION SAFETY OFFICER 1441 PARK TEN BOULEVARD HOUSTON TX 77084 h
Mark THIS COPY with any billing address changes *****
License / Approval /
Registration / Ccde Certificate Number AA905 Annual Fee
.................. Category (s) 0827 .....
........... Fee Amount ANN ...............
10B (2) $ 950.00
\ TOTAL: $ 950.00 TOTAL INVOICE: $ 950.00 make check payable to the NRCIf paid by FedwireIf see .
paidattached by check, Terms and Conditi
...............................(. reference Invoice no.) and mail to:
U.S. Nuclear Regulatory Commission .............
License P.O. Fee & Accounts Box 954514 Receivable Branch <=== forof receipt payments<.== This PO Box add St. Louis, MO 63195-4514 <=== only.
For terms and conditions see attached.
date of this invoice to avoid Questions: late charges. Payment must be received w call 301/415-7554 PAYMENT COPY *
..=> To ensure accurate credit,
==> invoice with your payment. return this copy of the <-.
===> delayed if the invoice is not included. Processing may be<= .
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1 l U. S. NUCLEAR REGULATORY COMMISSION
! .. FY 96 Annual Materiale Fca Invoice g Period 10/1/1995 - 9/30/1996
! 10 CFR 171.16 l Invoice Date License Anniversary Month Invoice Number
............ ......................... ==............
11/30/1997 September AM6358-96 l SOLUS SCHALL ATTENTION: RADIATION SAFETY OFFICER i 1441 PARK TEN BOULEVARD HOUSTON TX 77084
- Mark THIS COPY with any billing address changes *****
License / Approval /
Registration / Code Annual Fee Certificate Number AA905 Category (s) Fee Amount 0827 ANN 10B (2) $ 950.00 TOTAL: $ 950.00 TOTAL INVOICE: $ 950.00 If ptid by Fedwire see attached Terms and Conditions. If paid by check, maks check payable to the NRC (reference Invoice no.) and mail to:
............................................. j U.S. Nuclear Regulatory Commission <=== This PO Box address is l Lic;nse Fee & Accounts Receivable Branch <=== for receipt of payments '
P.O. Box 954514 <=== only. -
St. Louis, MO 63195-4514 i
For terms and conditions see attached.
PLym nt must be received within 30 days of the dato of this invoice to avoid late charges.
Qus3tions: call 301/415-7554
- LICENSEE COPY
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Footnota 1 of 10 CFR 171.16 provides that th] cnnual fee is waiv:d when a licensa is t rminated prior to October 1 of ccch fiscal y;1r. Tha 1996 annual fee w1s wriv d for thosa licensees and holders of certificates, registrations, and sppro/als who either filed for termination of their licenses or approvals or filed for possession only/ storage only licenses prior to October 1,1995, and permanently ceased licensed activities by September 30,1995, and the FY 1997 fee was waived if a termination request was filed and the licensee permanently ceased licensed activity prior to September 30,1996. Since QA 0827 was not terminated within the timeframes provided, the stated provisions for avoiding FY 1996 and FY 1997 annual fees were not met. As provided in 10 CFR 171.17, licenses for which termination requests are filed during the period October 1 through March 31 of the fiscal year are assessed one-half of the annual fee.
Through telephone conversations with you and Diane Dandois of my staff, we were advised that you used the package in February 1997 when you had an offshore operation. We also leamed that your company would not qualify for small entity reduced annual fees.
Based on the information provided, the NRC: (1) acknowledges you received no communication with regard to the annual fees or the QA rulemaking; (2) acknowledges you may have terminated your QA program had you been advised of the annual fees since you only carried the type "B" packaging as back up; and (3) grants an extension of time to June 27, 1997, for purposes of receiving the 50 percent prorat!on of the FY 1997 annual fee. However, I find no basis to grant relief from the FY 1996 annual fee.
Invoice AM6358-96 (for which you recently recaived a past due notice) is due and the FY 1997 annual fee invoice AM6365-97 has been amended to reflect 50 percent proration.
Due to the complexities of this instant case and the amount of time it has taken to finalize our ,
reply, I will waive interest and late charges if psyment is received within 30 days from the date j of this letter, j l apolo0 !ze for the administrative errors which led to the delayed bill for the FY 1996 annual fee and the fee schedules not being mailed to you. Unfortunately, we are obliged by Federal debt collection law to seek payment for all sums owed the Federal government. If you have any further questions, please call Diane Dandois at 301-415-7544.
Sincerely, OrighalshnedbyJesse Funches Jesse L. Funches Chief FinIncial Officer i
Enclosures:
Invoice AM6358-96 i Invoice AM6365 97 (50 percent)
Distribution:
L. Tremper, OCFO License File QA 0827 D. Weiss, OCFO invoice Files: AM6358-96, AM6365-97 G. Jackson, OCFO OCFO/DAF/LFARB RF M. Messier, OCFO OCFO!DAF RF (DAF-7-193)
NUDOCS (ML-61) OCFO/DAF SF (LF-3.2.2)
PDR LF-98-5 DOCUMENT NAME: G
- see previous concurrence sheet w m. . - m \DAF7. 193 wm w c .co .*, q g r co m .ma % ,, c.w-crrres ocro/ ar/LFAns c occ n otro/ofoAr n otro a crog[ [
I NAME DBDandois TRothschild JTurdici PJRabideau JLrunches nArs 3/ 1hs 3 ,6 f,s 3)3,,f 3 f13f ,3 y f g,3 g OFFICHL RICJRD COPY