Text

PR-030,040,050,070,170 - 32FR03995 - Proposed License Fees for Facility Licenses and Materials Licenses
	ML23151A489
Person / Time
Issue date:	03/11/1967
From:	; NRC/SECY
To:	;
References
	PR-030, PR-040, PR-050, PR-070, PR-170, 32FR03995
	Download: ML23151A489 (1)
	v • d • e

{{#Wiki_filter:ADAMS Templ~te: SECY-067 DOCUMENT DATE: 03/11/1967

         !TITLE:       PR-030,040,050,070, 170 - 32FR03995 - PROPOSED LICENSE FEES FOR FACILITY LICENSES AND MATERIALS LICENSES CASE

REFERENCE:

PR-030,040,050,070, 170

32FR03995 KEYWORD: RULEMAKJNG COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete I

PROPOSED RULE MAKING Indepcr.c:e1:c. , .. ~nt:e _ ::., \Vashington, D.C. 20201. ,, ~- * :i co::::ncnts, preferably m qu!nv..:p!:c.1--*. 0n this p:-oposal. Com-lnr, license 1ss:.:nnce fee and annual fee payable each year after lsst:ancc of the opcrntmc: l!ccnse. No se;:,arate fees

                                                                                                        § ,10.31 I
                                                                                                           <fl Each ap;illcatlon !or a source ma-
                                                                                                                   ,\pplir,,lion, for ~pl'cir.c !ircn~c,,.

ments n':i~* :.,~ .. :com;).1:-:!cd by a mem- would be assessed for llcens!t)g o~ nuclear tcnal license, other than a license ex-orand..:m. or 011c: In st:j);:>OrL thereof. material L"1c!dcntal to the operation of empted from Part 170 of th!s cha;it.er, a facility, or for fac1llty o;:>erator li- and other than an appllcaLlon for* re-Dated: ::\:arc:1 9, lS.37. censes under 10 CFR Part 55. The filing newal or amendment of a license, shall JAM=s L. GODDARD, !cc would be payaoie in full at the time be accompanied by the fee prescribed m Comm:ssroncr o/ Food and Drugs. of filing the application.

Construction Part 170 of Lhis,cha;i:.cr.

iF,R. Doc.* G7-2788, Flied, Mar. 10, 1067; permit fees and operating license fees 8 ~8 a m.1 would be payable when the first author- 3. Section 50.30 of 10 CFR Part 50 ls 1zat1on ls recc-lved; i.e., the provL~ional amended by addmi: a new para:::raph Cd> con1.truction permit or opcratme license. to read as follows: Annual fees wot:ld be payable 1 year § ;;0.30 Filin,: of :ipplirn1ion5 for Ji. ATOMIC ENEaGY GOM~.1!SSION after the 1SSuance of any provisional operating llccnsc. or In the case of a ccn~c*, oath or nnir111:11ion. ( 10 CFR Ports 30, 40, 50, 70, 170 l fac1hty for which an opcratlnir llcenso has already been issued, 1 year arter* the Cd) Fll11.1g fees. Each appllcallon for FACILITY AND MATE~IALS LICENSES elTective date of Part 170 and annually a production or utilization facility li-thereafter. cense, including whenever a;>propriatc, Pr.iposcd Fees a. construction permit, other than a li-Materials license fees. Fees an,-pro-The Alomic Enerey Comm1ss1on Is poscd for specl!lc byproduct, source, cense exempted from Part 170 o! this p:-oposlnr: to est-'lbllsh fees !or facility and special nuclear materials licenses chapter, shall be accompanied by the fee const:i.1ctlon permits and operating li- Issued pursi.:ant to 10 CFR Parts 30, prescribed In Part 170 of this chapter. censes Issued 1::1der 10 CFR Part 50 and 32-35, ,;o, and- 70. For new llcenses, ap- No fee will be required to accompany an for specltic .)y ,)roduet. source, and s;:,e- plication fees would be payable at the ap;:,llcatlon for renewal, amendment or c!;i: ::uclear :nnterlals licen~es issued tune of filing of the applicat1on. An- termination o! a construction permit or, u:., ..*1 lu C?,l ?a: ts .30, 32-35, -10, and 70. nual fees would be.payable l year after operating license, except as provided in

      '.'.:e Co:~.r.1,.;:,1on ls proposing the es-        tho Issuance of the license, or ln case       § 170.21 of this chapter.
 .ao:1shment of fees fo:- 1t..s fac11ity and              of out.st.anding licenses, l year after the      4. Section 70.21 of 10 CFR Pait 70 ls materials licenses which it believes to                  effective date o! Part 170 and nnnually       amended by adding a new pararrraph (!)

be reasonable and compatible with the thereafter. ExcmpUons are provided Commission's respons1b1hty for !osterine to read as follows: for licenses for mat'e11al Incidental to the the devclop:ncm of nuclear energy. The operation o! a facU1ty, as Indicated § 70.21 1-'ilin;.:. fees are sc~ oi.:t. below m a proposed new above, for licenses for export or import Part 170. .-\mendmcnts to Pai ts 30, 40, only of byproduct, source, or special nu- (!) Each application for a special nu-50, and 70 1.0 r.::!lcct the proposed appli- clear matcrtals and for certain licenses clear material license, other than a li-cation f.hnrr fee rcqu,remcnts are also held by cdu~tlonal Institutions. cense exempted from Part 170 of this prO,)OSed. The fees would ap;:ily to Pursuant to the Atomic Ener{:'Y Act o! chapter, and other than an applica-sp.:-:1!\c licenses but not to general 1954, as amended, and the Administra- t1on for renewal or amendment of a licenses at the present time.' tive Procedure Act of 1946, as amended. license, shall be accom;:ianlcd by the fee The Commission ls proposing applica- notice ls hereby elven that adoption or prescribed In Part 170 of this chapter. tion flllnc: fees, license issuance fees, and

tho !ollowine amendments of 10 CFR

~ annual !ces for both !ac1llty and ma- Parts .30, 40, 50, and 70 and o! the fol- 5. Chapter I o! Title 10 o! the Code terials licenses. With respect to both lowing new 10 CFR Part 170 1s contem- o! Fede1-al Rem.ilo.tlons 1.5 amended by

 !aclllty and r.:aterlals llcei1scs, I! a single          plated. All Interested persons who de-        adding a new Part 170 to read as follows:
 ~;),>llcatlon cove1s more than one facility,             sire to submit written comments or             PART 170-FEES FOR FACILITIES AND c,: ::.1ss or licensed m:llcrial, only a sinelc          suggestions ln connection with the pro-a.)pllcation fc.cmptlona.

refunds would be made 1! the license ified. Coples of comment.s on the pro- 170.12 Pnymont or recs. terminates before the expiratlon of the posed rule may be examined at the Com-yea:*. Sc11r0uu: or FEr:.s mission's Publle Docwncnt Room at 1717 Fac1l1t11 license fees. Fees are pro- H Street NW., Washlnrrton, D.C. 170.21 Schedule or tees !or production anci
-,:i . ..:d for* a:l facility construction per- 1. Section 30.32 of 10 CFR Part 30 ls utilization raclllUes.
m:i.S .i.nd op~rating licenses under Part 170 31 Schedule or f.ees !or mnterlala li-amended by addlnrr a new para:::raph Cc) censes. 50 of the Commlsslon'1, rules and rei:ula-tlons. cxccp~ for llccnscs to ~xport to read as follows: ENFOIIC1:MCNT
!ac1htles and [or cerlam licenses held § 30.32 ,\pplicalions for ,pccific liccn5cs.
170.'ll Fnlluro by licensee *to pay annual by educational 1nstllut1ons. The follow- * * * * * !ecs. ing types of fees would be required: (l) A fee for filmg an application !or a (e) Each ap;:,llcatlon !or a byproduct AuntoRITY: The provlslona or this Part 170 construction pc:*mlt; C2l a construction material license. other than a J1censc ts.sued under sec. 601, 05 St!lt. 200; sec. 161, permit issuance fee, and (3> an opcrat-* exempted from Part 170 of this chapter,
G8 St:lt. 9-18; 4 2 u.s.c. 220,1-and other than nn application !or re- GENERAL PROVISIONS
, specific 11cen 5 o5 arc t:.s~cd t.o na:ned per-.
newal or amend:nent of n. license. shall son& upon npphc:.tlon.s !lied pur,uant to tho be accompanied by the fee prescribed in § 170.1 Purpo 5 r.
rcgul:i.Uons In ;>:,.:-UJ 30, 32-36, 40, so, nnd Part 170 of this chapter. The regulntlons In this part set out 70 or this chapte:. Genera.I licenses arc e!TccU\'o without tbo fihni: or nppllc:i.:loiu 2 s "
ec .. on 40 31

o f 10 CFR Part 40 1s fees charced !or llcenslnrr services ren-W1th the commtwon o: tho usuance ot a.mended by addlnrr 11.. new paraernph (!) dcrcd by the Atomic Enerl:'Y Commission, llcenlng documcr,t., to pa.rtlcular per,ona, to read as follows: ns authorized under Title V o! the In-FEDERAL REGISTER, VOL. 32, NO. 48-SATURDAY, MARCH 11, 1967
/
399G _P!WPOSE[? RULE MAKING - dependent Offices Appropnation Act of facility as defined by :paragraph Cl) of (2) Any material art1flclally ennched 1952 (65 Stat. sec. 290), and prQV1S1ons , thlS section. ' by any of the foregoing, but does not in-regarding their payment. (h) "Sealed source" means any by- elude source material.
§ 170.2 , Scope. product material that is encased in a , Ck) "Special nuclear material in capsule designed to prevent leakage 'or quantities sufficient to form a cntlcal Except !or persons who apply for or escape of the byproduct mate1ial. mass" means uranium enriched in the hold t11e ,hcenses exempted in § 170.11, (1) "Source materlal" means: isotope U-235 in quantities in excess of the regulations m this part apply to each * (1) Uranium or thorium, or any com- 350 grams of contained U-235; uramum person who is an applicant for or holder bination thereof, in any physical" 01* 233 in quantities m excess of 200 grams; of a specific llcense issued pursuant to chemical form or plutonium in quantities in excess of 200
Parts 30, 32-36, 40, 50, and 70 of thlS (2) Otes which contain by weight one- grams, or any combination of them in chapter. twentieth of 1 percent'(0.05%) or more accordance with the following formula:
§ 170.3 D~finitions. of (1) uranium, (u) thoiium, or (ill) any For each kind of special nuclear matenal, combination thereof. determine the ratio between the quan-As used in this part:
(a) "Byproduct mateiial" means any Source material does not include ~pedal tity of that special nuclear mateiial and radionct1ve mutcrial <except special nu- nuclear matenal. the quantity specified above for the same clear material) yielded In or made radio- (j) "Special nuclear ma.te1ial" means; kind of s:pecial nuclear ma.tertal. The
. active by exposure to the radlation in- Cl) Plutonium, uranium 233, uranium sum o! such rp.tios for all kinds of spe-cide:1'<-- to the process of :producing or enrich~d in the isotope 233 or in the iso- cial nuclear materials in combination util!z,nJ' special nuclear mateiials. tope 235, and any othErr material which (b) "Mat:erials license"* means a by- the Comm1ssion, pursuant to the provi- shall not exceed unity. For exampl:, the product matenal license' 1SSued pursuant s10ns of section 51 of the Act determmes following quantities in combination to Parts 30 and 32-36 of this chapter,. to be special nuclear ma.teiia.1 but does would not ex_ceed the llmitat!on and are or a source material licens'e issued pur- not inclu~e source material; or witbm the formula as follows:
suant to Part 40 of this chapter, or a 175 (grams contained U-235) 60 (grams U-233) 50 (guuns Pu) special .nuclear mateiials license issued
" 350 + . , 200 + 200 =l pursuant to Par'_ 70 of this chapter.
(c) "Nu9,l~ar reactor" means an ap- (1) "Testing facility" means a nuclear Avenue, Bethesda, Md.; or at German-paratus, other than an atomic weapon, reactor hcensed by the Commission un- town, M~. designed or used to sustain nuclejl,r fis- der the authority of subsection 104 c. of sion in a self-supporting chain reaction. the 4ct and pursuant to the provisions § 170.11 Exemptions,
, Cd) "Other production or utilization of § 50.21(c) of tb.13 chapter for opera- (a) Np a:pplication flllng fees, license facility" means a facility other than a tion at: fees, or annual fees shall be required for:
nU<;:lear react_or hcensed by tpe Qpmmis- Cl) A thermal :power level in excess of {1) A license authorizing the export filtlU unfl.!li' th§ !!.Uli1m1cy gf §@Qti!m.ll rn~ !Q mg!l'awatt!!; or gp,!y qf ~ produgtion or util,lzation or 104 of the Atonuc Energy Act of HIM, m A tlJ.fil'fi'l§.l lJ!JWei' l!Wlll L~ ~G@§§ of* flUllliWl .
as amended (the Act) and pursuant to 1 megawatt, 1! the reactor ls to contain! (2) A license auliiorlzlli.g the exporb
. the :provisions of Part 50 of this chapter. (1) A circulating loop through the coi*e only or import only of byproduct ma- ' (e) Power reactor means a nuclear in which the applicant proposes to con- tenal, source material or special nuclear reactor designed to produce electrical or duct fuel experiments; or material; heat energy lice~d by the CommisITT.on , (li) A Uqu1d fuel loading; or (3) A license authorizing the receipt, under the authonty of section 103 or sub- <m) An experimental facility in the ownership, possession, use' or production section 104b. of the Act ,and pursuant core 1n excess of 16 squai:e i.n,ches in of byproduct material, source material, to the proVlSions of § 50.21 Cb) or § 50.22 cross-section. or special nuclear material i0,c1dental to of this chapter. (m) "Utillza.tion facility" means any the operation of a production or utiliza- I (f) Production facility" means: nuclear reactor other than one designed tion facility licensed under Part 50 o!
Cl) Any nuclear reactor designed or or used primarily for the formation of this chapter, including a license under used primarily for the formation of :plu- -:plutonium or U-233 and any other equip- Part 70 of this chapter authonzing tonium or urapiwn 233; or ' ment or device determined by rule of possession and storage only of special (2) Any facility designed or used for the Comml.ssion to be a utilization facil- nuclear reactor material at the 51te of a nuclear for use as fuel in operation o! the separation of the isotopes of uranium ity within the purview of subsection 11 or the isotopes of plutonium, except cc. of the Act. . the nuclear reactor or at the site of a (n) '"Waste disposal license" means a spent fuel processing plant for prqcess1ng laboratory scale facillties designed or at the plant. used for experimental or analytical pur- license specifically authorizing the re- (4) A, construction :permit or license poses 'only; or ceipt of waste byproduct matenal, (3) Any facility design~d *or used for source mateiial or special nuclear ma- applied for, or issued to, a nonprofit ed-th'e processmg 'of 1 1rradlated materials of terial from other persons for the purpose ucational institution, which shows itself commercial disposal by land or sea to be, with resp~ct to the material or containing special nuclear mri,teiial, ex- burial. - facillty licensed or to be licensed, party cept (1) laboratory scale facilities de- to (1) a loan agreement administered by signed or used for experimental or ana- § 170.4 lntcrprclations *. the Commission's Division of Nuclear Ed-lytical purposes, and (il) facilities in Except as specifically authorized by the ucation and Tra.inmg, or (il)' a univerS1ty wlµch the only bpecial nuclear matenals Commission in writing, no interpretation reactor assistance contract with the contained in the 1n-adiated matenal 'to of the meaning of the regulations in this Commission. The exemption m this sub- , be processed are uranium ennchej in the part 'by an officer or employee of the paragraph shall not apply to a construc-isotope U.:.235 *and plutomum produced CoillIIl.16.Sion other than a written in- tion pennit or license for a facility or by the irradiation, lf the matenal proc- terPretatlon by the General Counsel will ma.tenal other than that referred to in essed cimtams not more than 10_. grams b'e recognized to be binding
upon the the loan agreement or univer51ty reactor of plutonium per gram of U-235 and has Commis8ion. assistance contract.
fission product activity not in excess of Cb) The Commission may, upon* appli-0.25 millicuries of fisslon products per § 170.5 Communications. cation by an interested person, or upon gram of U-235.
All communications concerning the its own initiative, grant such exemptions (g) Il,esearch reactor" means a nu- regulations in this part should be ad- , from the requirements of this part as it clear reactor licensed by the Commission dressed to the Director of* Regulation, determines are authorized by law and under the authorlty of subsection 104 ::. U.S. Atomic Energy Commission, Wash- are othe~ in the public interest.
of the Act and pursuant to the :provisions ington, D.C. 205-15. Commun1cat).ons of § 50.21 Cc) of this chapter for opera- may be delivered m person at the Com- § 170.12 Payment of fees. tion at a thermal :power level of 10 -meg- mission's offices *at 1717 H Street NW., (a) Application ,fees. Each applica-a.watts or less, and which 1s not a testing* Washington, D.C.; at 4916 St, Elmo tion for which a fee 1s prescribed in th 18 FEDERAL REGISTER, VOL. 32, NO. 48-SATURDAY, MARCH 11, 1967
,. ~ ~l, ,~ - \. , .. , ~ ~~
1
~-: -r~, " '-~ ,; - ./' ~: * /- , * ' . '. :!~ -~R ~~~-;~D~ RULE 1 M_AKING *' '~ '.' , . .'_ -, 399~
, ,.. , ,, 1 ,t , - \ .. - ,I
1 ' :...
1 l I ' , * ., - \ : '\ \ * , pa.rt_shall.,be aceompanied by~ r,emit- (c). ,;nnual fees. )uinual' fees *pre- eral Aviation Reguia,tions by adding- an:. *. - ,- ** tancein the full amount of the fee: No scr1:becl'in'this parl*are payable-, 1n the -airworthiness dlrective'applicable to a11*; *, applicatJ.dqn will '6e- ru;cep~ for filing or tciase 'of licenses outstanrt din'.!.g on the effec- ' J'an ._Avio'n -MosJ.el. PA-5 L11,e ,. Yesd' ts <: r ' . ,'., ,, processe prior to pa,~ent of, the ve. date. of thla pa , ' year after the ._eqmpped with an 8 gram CO. cartrt ie ; , -
,full amount specified. Applications for effective date o! this part and annually , (P/N 2200-525-16). The 8 gram*~ CO2 \ , >'.., -which no remittance -is received may be -',tb'.ereafter. In. th~ case of license's is-* cartridge does not pr-ov.lde the minimum .\
r~turned _to the applicant. 'All a.pplica-: sued after' the effective ~ate of this part,_ -9uoyancy requirements needep., f9~s~e .-* 1
- tion -fees will '.be ,charged: irrespective of annµal f~ -a.re .payable 1 iear after, the operation of, these life_ vests., To correct _ *-
the ,Commission's disposition' of the date of issuance of the license or pro.,.* this. deficierioy., the proposed. airworthi- *,,
, appllcatiori. or';a, witll.drawa.l off the' vihlonal operating llcense; 1f any, which:. ,ness directive would reqmre the removal '
1
'*--;::,** ~-
application. .. _,, , . ever 1B earller, ancr annually theteafter.' of the 8 gram COJ cartridge (P /,N 2200-
. (o). 'construction permit fees and op-' _ (d) Method of payment. fee pay- 526-lq) and the lnstaµation pf a 12'gri).,m erating lic_ense fees.. Fees for construe- ments shall be by check or money cvder- C!J, cartn~e (P/N 2200-525-21) _and,'a tion pernuts and operating licenses-are ,payable to the U,S. -Atomic Energy long1nfiatorcap-(*P/N2200-538-8). , - ,: ..,c. **," *pa.yabl~,wheI},'the ~rovisional construe- C.onimisslon. - . .. _ - . _ Interested persons are invited 'to pa'r- *, *
tlo~ permit 'or _provlsional operating ,;', *sCHE ULE P.. FEts - , ,_ , '* tic1pate 1n th'e makipg, of U;e proposed 1
*, - . ,
license, if, any, is- iss,ued. Othenvise, * , , * . P 9 -, ' . rule by submitting such wntten data, ;
*- - rfees 'are payaple when ,the construction-*§ 110:21
Schedule.pf (ees for production.* 'views, or.. arguµients as tj),ey may desire.*, . -,.
* * . 'permit <2,r,qperatµig license is issued. No and u9~tion facilities.,* , '
Communications sho~d identity

the, J.- , - _ .:-
-.' 2ro~onal 99~ct10~ pernl,lt or- pro- Applicants for construction permits or docket number !l,Ild be silbi;nitted J-n dup- .
visiona.l operatil).g license~ or construe---, _operating licenses !or productioIJ, or utlli; J,icate .to the Federal Aviation Agency, tion permit or operating license, as the , zation facilities and holders of construe- Office of the General Counsel, Attention*: case may' b;e, will be issued by the,Com- tion permits or operating licenses *for, Rules Docket,. 800 .Independence Avenue ,
-* mission Ul'/,til the* ,tun amount of *the-fee production or utilization facilities, i;baj_l f:iW,, Washington, D.C. 20553, 'All. com-
I,' prescribe?, in thJ,s ~ has been pa.id.. ' pa,y*th!i following fees: I * -_ '.

munica'tions received on. or b.efo:r;e April '
. ,/ / ., . - , ,. . . *_ . - *_ _ -
10, 196,7, will be, cqnsidered *by the Ad-Foolhly (thermal megawatt values rehf: to ~ u m C(II)IIClty lip- appllontuiu lot Oonlltrnot>On hoome loo

the proposed*

Fee ror flhni:, Operating ministrator before taking -action. UJ)On rule. The- proposals con-'
/-~~,:~ ~::
1 : '*'
* , ,.,- -phod!ororatatodrn*tbe'pernutorlloo~)
con~~* ~ t r e e ~~a:;; _ tained m'th18 notice.may~ change9, u;i
. ,,' _ _ . . , , the light of comments received. All com- -... . '. .. , (l) Power ~tor:' , ., * ,,' r _ *,
_

_ ,

_ , * . men ts will be ,avrulable, both before !l,lld,
, . ,. ,- , ..,'gP to 1~ 1>h;r(tl 0 - ' - - - - - - - ' - - - - - - - - - - - - - - - - - - - - - - - - , - - - . : ** Si, roi '< ver 1, *to 1,500 :1,hr(t)______________________________ , 2,600 ~12,000 18, ooo *,1,soo "after the-closing date !qr comments, 1n ,~700 the ,Rules Do_ck~t for* ex~tion by * :I** '1 ** , *_ ;(2) ;
88
~~~6%-~w(tl---.---------------*-- 7 -------s----- 2,600 21,ooo .,_ 800 interested persons. , * ~_/![,
** :- * - , -. up to 16 Mw(t) ___. _ : ___________ '--~-------"---- soo 2, ooo - 700 * . Tbia amen!1ment is proposed under the * *1
. , (8) ri.~;% }~~t:w----*---:..,..~----;-*********-**,*-,:--, 800 3, ooo 1, ooo authority of sections 3!3 (a), . 601, and ,;* : 1, 1 . ; ,. * -Up to >1Iw(tl .. ------------------*--- 1-~---------- 300 1;000 '300 603 of*the Federa,,l Aviation Act of 1958. *, '*" ,: ,:
300 I, 600 (49 U ,SC
. * ' , 'Over l to 6 Mw(tt-*.'..----,-------*--------------------- ffil *
1364(a.) *'1421

1423),. I*, '*..*, ".;~ 'i:!i
, " 1 Over 6Mw(t) _______ ;__: ________*__ _c__________________
... - , _:.. ((I Other,produotlou or utlllmtlon faclhtyi ____ _.________ _,_ _____ .:_ __ * * ,
800 1,600
*
1 2,000 -

500 '
-6. ooo ~ . , 2, ooo.
In, CQI181deratio:g. of the, foregoing, it
- *
is proposed to amend § 39.13 of Part 39
,1 l .
Amendments i-oon'crng capacity shall not entitle t1Kn1pphcnut to a partial rn!und of any lee; apphoatiom !o<' \ of the Federal* Aviation ,Regulations* by*_ . '.:,1 11
.amendmonts moreasing capao,ty ton hlgher*fee category will not be accepted for filrng 1lille8!I accompwued*by th&* adding the "ollowing presoqbed roo Jess the amount already pa,.d, : ., ,. ,- * , , ~ , _ new: , a1rw . o'rthin ess - ,r * *
1* -
' § '170:31. Schedolo o( fees, ~or ~at"1'i11ui* ... ': '* 1 .' **
1 ENFoR~ . '__ directive: . :\ ' ' ' , :, ; I
-} c ~ , * - P ~ AVION. Applies to Moo.el PA--6 Lite * ,, :, , J- : , - * * , ,. , * *. § lJ0.41 Failure hy.Jicensee to pay ~- : , vest4_ equlpped,with an-8 gram 00. car-, , - '.', ',i' .. * , AppJ4cants for materials licenses ,and nual fees. , . : * *:, * . trldge (P/N 2:100-5215-lli). ,
_ *,: - * ":'\
-*.hol~ers, 0 ! ,mat;erials 1:J.censes*.ahall_,,pay
In any ,case where .'the Comm1aaion . Oompluinoe reqwred ,Within,30 days a!ter' - i :1;i;."*
'the !ollq~ing fees:_ ,, _ , ,* ' , finds that a licensee baa failed topa.y the ~the effective' date o! th!B' Ab, unless already U :- t *Bami)JU 07 MilEBuLs,f,f= ~ r applicable :annual fee* required 1ri *this accomplished. ' -. ' J,, '~~ f,;'. --~----:--....,-,,-,--*-~~~----,--* part, the Con:im!ss1ori may SUBPend *or
To insure adequate rue vest buoyaz;i.oy, * . ,
. , * ' .,*- ' , removethe8gramCO,oartrid'ge (P/N2200-, .*.:*; ,, Oategoryofmaterlall/ Apphoali9n Annual'fee revok~. th~ license 6,r may issue such '625-115) a.nd.J.nstall a. 12 gram oo, cartrtdge, ., 1 , ,,: .. '*?
h9=8' * , *

iee . , or~er with, respect to -licensed _activities (P/N, 2200--625'--21) and a long, infia.tor cap *, , .. ::
1 1 ,1.All~torfulsll~ _ -c as,theCteoII1Dll:'5s1ondete1nrm1nesto_beap-,_ (P(/N-220~8-8). , - ; , * .... *.- . ;,!*: . .*:,,,.' _,- ,-, than 0 !l_ropria or neces!lary order to carry' Pan Avion Service Bulletin No.~~ dated . _
,'~~esf~~* outtheprovisionsof,thispatt Parts-30 _Sep~.15,1966,coverathiasubject.) - _ ,,. ** . *'*e'. - . ---~-IJ~ii--iiyjirodaci; . .,. None !25-00 32-36, 40,, 50,- and* 70- of tbi'.a chap~£ ' Issued~ W ~ n , D.C., on, March *. '. . . I : /t, 1,matenalisruodpur- . -~ ando!*theAct, --. * . - 3,_1967.- * *,"*:;.*;
:. , '/ ,~t;J°~ 0P~~t; :- *_: _ (Seo. 161: 68 stat. 948; 42 u.s.o. :1201; .seo. JAMBS F. RunoLPH, ~
i ,_ :*.
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*I' A'IDMIC ENERGY COMMISSION I' /J.o CFR PAR'IB 30, 4o, 50, 70, 17rj] I j*
Proposed License Fees for Facility Licenses
'and Materials Licenses 'Ihe Atomic Energy Connnission is proposing to establish fees for facility construction permits and operating licenses issued: . under 10 CFR Part 50 and for specific byproduct, source, a_nd ape.-
cial nuclear materials licenses issued under 10 CFR Parts 30, 32-35, 40 and 70. I I , I -':. ]
I
. I' . .:* 'Ihe Commission is p~opoaing the* establishment of fees for its ' I *facility and materials licenses which it believes to be reasonable ,: i .'
and compatible with the Commission' a reaponaibili ty for fostering . * .. ,:
. *.-.J I 'I the development of nuclear energy. 'Ihe fees are set out below-in \., *.::
a proposed new Part 170. Amendments to Parts 30,. 4o, 50 and 70 ~~ to reflect the proposed application fil:lng fee requirement's are
*I *1 also proposed. 'Ihe fees would apply to specific licenses but not I
to general licenses at the present time.* i
'Ihe Commission is proposing application filing fees, license I
I issuance fees, and annual fees for both facility and materials 1 1 licenses. With respect to both facility and materials licenses,: t.'- I if a single application covers n:ore than one facility, or class
. ~ Specific licenses are issued to named persons upon applications filed pursuant to the regulations in Parts 30, 32-36, 40, 50 and 70 o~ this chapter. General licenses are effective without the.
filing of applications with the Commission or the issuance of I\,
licensing documents to particular persona.
I I I I
of licensed material, only a single application fee need be paidt However, 'if more than one license is issued in response to an ap~li-1 cation, the applicable fees for each license will be assessed. License issuance and annual fees for both facilities and materials would be deemed as assessed for licensing services to be performed I by the Connnission and paid for at the beginning of the year in wh~ch_.
.they ~re rendered. No refunds would be made if the license termit nates before the expiration of the year. I Facility License Fees. Fees ar~ proposed for all facility con'struction permits and operating licenses under Part 50 of the I
Commission's Rules and Regulations, except for licenses to export facilities and for certain licenses held by educational institutions.
'Ihe follow~ng types of fees would be required: ( 1) a fee for filing
an application for a construction permit; (2) a construction permit:~ ..
1 I' issuance fee, and ( 3) an operating license issuance fee and annual ; _*
.. I fee payable each year after issuance of the operating license. No separate fees would be assessed for licensing of nuclear material incidental to the operation of a facility, or for facility operator.'..
licenses under 10 CFR Part 55. ,'!he filing fee would be payable in full at the time of filing the application. Construction permit fees and operating license fees would be payable when the first authorization is received; i.e., the provisional construction permit or operating license. Annual fees would be_ payable one year after the issuance of any provisional operating license, or
- 2 \
in t.hc case of a facility for which an operating license has already been issued, one year after~the effective date of Part 170 and annually thereafter. Materials License Fees. Fees are proposed for specific by-product, source, and special nuclear materials licenses issued pursuant to 10 CFR Parts 30, 32-35, 40 and 70. For new licenses,* application fees would be payable at the time of filing of the application. Annual fees would be payable one year,.after the issuance of the license, or in case of outstanding licenses, one year after the effective date of Part 170 and annually thereafter. Exemptions are provided for licenses for material incidental to the operation of a facility, as indicated above, for licenses for export or import only of byproduct, source, or special nuclear ma-terials and for certain licenses held by educational institutions. I Pursuant to the Atomic Ehergy Act of 1954, as amended, and the Administrative Procedure Act of 1946, as amended, notice is hereby given that adoption of the following amendments of 10 CFR Parts 30, 4o, 50 and 70 and of the following new 10 CFR Part 170 is contemplated. All interested persons who desire to submit written connnents or suggestions in connection with the proposed amendments and regulation should send them to the Secretary, U. s. Atomic Energy Connnission, Washington, D. Co 20545, within 6o days after publication of this notice in the FEDERAL RIDISTER. Comments received after that period will be considered if it is practicable to do so, but assurance of consideration cannot be given except as to comments filed within the period specified. Copies of com-ments on the proposed rule may be examined at the Commission's Public Document Room at 1717 H Street NW., Washington, D. C.
1. Section 30.32 of 10 CFR Part 30 is amended by adding a new paragraph (e) to read as follows:
§ 30.32 Applications for specific licenses.
(e) Each application for a byproduct material license, other than a license exempted from Part 170 of this chapter, and other than an application for renewal or amendment of a license, shall be accompanied by the fee prescribed
... in Part 170 of this chapter.
2. Section 40.31 of 10 CPR Part 40 is amended by adding a new paragraph (f) to read as follows:
§ 4o.31 Applications for specific licenses.
(f) Each application for a source material license, other than a license exempted from Part 170 of this chapter, and other than an application for renewal or amendment of a license, shall be accompanied by the fee prescribed in Part 170 of this chapter.
3. Section 50.30 of 10 CFR Part 50 is amended by adding a new paragraph (d) to read as follows:
H 50.30 Filing of applications for licenses, oath or affirma-tion. I (d) Filing fees. Each application for a production or utilization facility license, including whenever appro-priate, a construction permit, other than a license exempted from Part 170 of this chapter, shall be accom-pa:hied by the fee prescr~bed in Part 170 of this chapter:* No fee will be required; to accompany an application for renewal, amendment or termination of a construction permit or operating license, except as proVided 1n H 170.21 of this chapter. I '
'I
-4. Section 70. 21 of 10 CFR Part 70 is amended by adding a new * * * ' paragraph (f) to read as follows: H 70e2l Filing. (f) Each application for a special nuclear material license;* other than a license exempted from Part 170 of this I chapter, and other than an application for renewal or ' I. I amendment of a license, shall be accompanied by the fee prescribed in Part 170 of this chapter. 5o Chapter 1 of Title 10 of the Code of Federal Regulations is amended by adding a new Part 170 to read a.s folJ.ows: 5
. _ PART 170-FEEB FOR FACILITIES AND MATERIALS LIC:ENSED **;. UNDER THE A'IOMIC :ENERGY ACT OF 1954, AS AMENDED GENERAL P:OOVISIONS Sec.
170.1 Purpose. 170.2 Scope. 170.3 Definitions. 170.4 Interpretations. 17q.5 Communications.
~70.n Ex:emptions.
170.12 Payment of Fees SCHEDULE OF FEES 170.21 Schedule of fees for production and utilization facilit~es. 170.31 Schedule of fees for materials licenses. ffiFO RC EMENT 170.41 Failure by licensee to pay annual fees. AUTIDRITY:
The provisions of this Part 170 issued under sec. 501, 65 Stat. 290; and sec. 161, 68 _Stat. 948; 42 u.s.c. 2201.
GENERAL PIDVISIONS B 170.1 Purpose. The regulations in this part set out fees charged for licensing services rendered by the Atomic Energy Commission, as authorized under Title V of the Independent Offices Appropriation Act of 1952 (65 Stat.§ 290), and provisions regarding their payment. I I,
§ 170.2 Scope.
Except for persons who apply for or hold the licenses exempted in e 170.11 of this part, the regulations in this part apply to
*each person who is an applicant for or holder of a specific license issued I,>UI'Suant to Parts 30, 32-36, 4o, 50 and 70 of this chapter.
s 170.3 Definitions. As used in this part (a) "Byproduct material" means any radioactive material
*** J (except special nuclear material) yielded in or made radioactive by exposure to the radiation incident to /
the process of producing or utilizing special nuclear materials. (b) "Materials license" means a byproduct material license issued pursuant to Parts 30 and 32-36 of this chapter, : I or a source material license issued pursuant to Part 4o I of this chapter, or a special nuclear materials license'. issued pursuant to Part 70 of this chapter. ( c) "Nuclear reactor" means an apparatus, other than an , atomic weapon, designed or used to sustain nuclear fission I
\
I
in a self'-suppcrting chain reaction. (d) "Other production or utilization facility" means
\.'
I a facility other than a nuclear reactor licensed by I I the Commission under the authori"lzy' of sections 103 or i I I lo4 of the Atomic Energy Act of 1954, as amended ( the
. Act) and pursuant to the provisions of Part 50 of this chapter.
(e) "Power reactor" means a nuclear reactor designed
. to produce electrical or heat energy licensed by :the Commission under the authority of section 103 or sub-section lo4 b. of the Act and pursuant to the provisions of IHI 50. 2l (b ) or 50. 22 of this chapter. ' ' * .r
( f) "Production facility" means :
.,,I (1) Any nuclear reactor designed or used primarily I I
for the formation of plutonium or uranium 233; or .\ (2) any facility designed or used for the separation i of the isotopes of uranium or the isotopes of plutonium, except laboratory scale facilities designed 1 or used for experimental or analytical purposes only;, or (3) any facility designed or used for the processing of irradiated materials containing special. nuclear material., except (i) laboratory scale facilities designed or used for experimental or ana~tical purposes, and (ii) facilities in which the only special nuclear materials contained in the irradiated material to be processed are uranium enriched in the isotope U-235 and plutonium produced by the irradia-
.J tion, if the material processed contains not IJX)re than 10-6 grams of plutonium per gram of U-235 and has fission product activity not in excess of 0.25 millicuries of fission products per gram of U-235.
I ,
* (g) "Research reactor" means a nuclear reactor licensed by the Commission under the authority of subsection lo4 c.
of the Act and pursuant to the provisions of 6 50.21(c). of this chapter for operation at a thermal power level*.,..-, of 10 megawatts or less, and which is not a testing facility as defined by paragraph (1) of this section.
\ ' ',\.' I (h) "Sealed source" means any byproduct material that is encased in a capsule designed to prevent leakage or*
escape of the byproduct material. (1) "Source material" means: (1) Uranium or thorium, or any combination thereof, in any :physical or chemical form or (2) ores which contain by weight one-twentieth of one percent (o.05~) or 100re of (i) uranium, (ii) thorium or (iii) any combination thereof. Source material does not include special nuclear material. (j) "Special nuclear material" means: (1) Plutonium, uranium 233, uranium enriched in the isotope 233 or in the isotope 235, and any other* . material which the Commission, pursuant to the pro-visions of section 51 of the Act, determines to be special nuclear material but does not include source material; or .,*" I (2) any material artificially enriched by any of ' I the foregoing, but does not include source material. - *, '-. '* * ....
*., t (k) "Special nuclear material in quantities sufficien~.
to form a critical mass" means uranium enriched in the isotope U-235 in quantities in excess of 350 grams of / contained U-235; uranium 233 in quantities in excess of 200 grams; plutonium in quantities in excess of, 200 grams, or any combination of them in accordance with the following formula: Fbr each kind of special nuclear material, determine the ratio between the quantity of that special nuclear material and the quantity specified above for the same kind of special nuclear material.
'Ihe sum of such ratios for all kinds of special nuclear ,1' materials in combination shall not exceed unity. Fbr I
I j
. II ... ' ' i '
I - l,
example, the following quantities in combination would not exceed* the l~tation and are within the formula as follows: 175 (grams contained u-235) 50 (grams U-233)
+ -------- +
350 200 50 (grams Pu) C 1 200* (1) "Testing facility" means a nuclear reactor.licensed* by the Commission under the authority of subsection 104 c. of the Act and pursuant to the provisions of 6 50.21(c) of this chapter for operation at: I (1) A thermal power level in excess of 10 megawatts; I
,_ \
or / (2) a thermal power level in excess of 1 megawatt, if the reactor is to contain: (i) A circulating loop through the core in which
*I the applicant proposes to conduct.fuel experiments; II I
or .,:.' I (ii) a liquid fuel loading; or i I '. (iii) an experimentaJ. facility in the core in excess of 16 square inches in cross-section. I
' I I
I , I 1 **
(m) .Utilization facility" means any nuclear reactor other than one designed or used primarily for the formation of plutonium or U-233 and any other equipment or device determined by rule of the Commission to be a utilization I
facility ~ithin the purview of subsection 11 cc. of th~

I I
Act.
. *1 I
(n) "Waste disposal license" means a license specifica.J.ly authorizing the receipt of waste byproduct material,
. , source material or special nuclear ma.terial from other persons for the purpose of connnercial disposal'by land or sea burial.
§ 170.4 Interpretations. Ex:cept as specifically authorized by the Commission in writ~,, no interpretation of the meaning of the regulations in this p4*; *:(/i:'-'... *, \.: .* 1*. by an officer or employee of the Connnission other than a written** ***.
I interpretation by the General Counsel will be recognized to be \* . *
\*
binding upon the Connnission. !, § 170.5 Communications. All communications concerning the regulations in this part should be addressed to the Directo~ of Regulation, U. s. Atomic Energy Commission, Washington, D. c. 20545.* Conmnmications may;
'I be delivered in person at the Commission's offices at 1717 H Str¢et, I
I NW., Washington, D. c.; at 4915 St. El.too Avenue, Bethesda, Maryland; or at Germantown, Maryland. I
I
, ' I
§ 170.11 Exemptions.
(a) No application filing fees, license fees, or annual fees: shall be required for: (1) A.license authorizing the export only of a production or u~ilization facility; (2) a license authorizing the export only or:import only of byproduct material, source material or special nuclear material; (3) a license authorizing the receipt, ownership, possession, use or production of byproduct material, source ~terial,
*J or special nuclear material incidental to the operation of a production or utilization facility licensed under Part 50 of this chapter, including a license under Pa.ft 70 of this chapter authorizing possession and storage only of sp,ecial nuclear material at the site of a nuclear* .. /'
reactor for use as fuel in operation of the nuclear i '
. I reactor or at the site of a spent fuel processing plan~
for processing at the plant. (4) A construction permit or license applied for, or issued to, a non-profit educational institution, which shows itself to be, with respect to the material or I
,i I , ,I facility licensed or to be licensed, party to (1) a loan* 'I agreement administered by the Commission's Division of Nuclear Eliucation and Training, or (11) a university reactor assistance contract with the Commission *. 'Ihe .. , l exemption in this subparagraph sha.11 not apply to a I construction permit or license for a facility or material I
other than tha't referred to in the loan agreement or !.
,I university reactor assistance contract. '
I I j
l (b) 'lhe Connnission may, upon application by an interested s '
person, or upon its own initiative, grant such exemptions f'rom the requirements of this part as it determines are authorized by law and are otherwise in the public interest. S 170~12 Payment of fees *
.,., (a) Application fees. Each application for which a fee is ',.*
prescribed in this part shall be accompanied by a remittance ' in th@ :full a.mount of the fee, No application will be accepted for filing or processed prior to payment of the full amount; ' specified. Applications for which no remittance is receivep. " I ,1 '.,' ~', t ', / may be returned to the applicant. All application fees will ,, *.
1 * , ..
I 1
* 'I be charged irrespective of the Connnission's disposition of* \.'.
the application or a withdrawal of the application. (b) Construction permit fees and operating license fees. Fees for construction permits and operating licenses are I I payable when the provisional construction permit or provisional
'\ . I *. I operating license, if any, is issued. Otherwise, fees are I payable when the construction permit or operating license is issued. No provisional construction permit or provisional . I - 14 i *. I I .. \ *1 I I
'.' 'i operat~ng license, or construction permit or operating license,* , I as the case rm:y be, will be issued by the Commission until the full amount of the fee prescribed in this part lias been j paid.
(c) Annual fees. Annual fees prescribed in this part are payable, in the case of licenses outstanding on the effective ;
. j,.. ' *'
date of' this part, one year after the effective date of this ,\ l I '
~ ' 'I *, L ,*'
I ,
part and annually thereafter. In the case of licenses issued * :*: *; -: i
* - *i l '- -;
I 1 ,
after the effective date of this part, annual fees are pay- *. ,: .*.:. , _ '\*:::. <*.:,.:
.,.. able one year after the date of issuance of the license or ~
provisional operating license, if' any, whichever is earlier,
'\/:',:- ,,, ':j... :' .
and annually thereafter. I.,..-..... .- '
'/ ,.:* ' :\"i,~'...' :*
(d) Method of payment. Fee payments shall be by check or~ , - * :.
,1* ....
money order *pay~ble to the u. s. Atomic Energy Commission *. '
/'
SCHEDULE OF FEES
'* § 170.21 Schedule of fees for production and utilization facilities
Applicants for construction permits or operating licenses j'
for production or utilization facUities)and holders of construc-tion permits or operating licenses for production or utilization * .. 1 ', ' ** ' ,,' J faciJ:tt;ies shall-pey the following fees:
. . .i,,
I ,

15 - I:.,,
I '
I Facility (Thermal megawatt values refer to the maxi- Fee for Filing Operating I mum capacity applied for Application for License *1 or stated in the permit or Construction Construction Fee & I I license)* Pennit Permit Fee Annual Fee i I (1) Power Reactor I Up to 1000 Mw(t) $2,500. $12,000 $ 1:,8oo > I,, I Over 1000-1500 Mw(t) 2,500 18,000 2,700 Over 1500 Mw(t) 2,500 27,000 3,800 -I I I (2) Testing Facility I Up to 15 Mw(t) Boo 2,000 700 *1 Over 15 Mw(t) 800 3,000 1,000 ( 3) Research Reactor Up to 1 Mw(t) 300 1,000 300
°".'er 1-5 Mw(t) 300 1,500 400 Over 5 Mw(t) 300 2,000 500 ., ~ -':. I* /
(4) ,, Other Production or ,) Utilization Facility 1,500 5,000 2,000
,I
Amendments reducing capacity shall not entitle the applicant to a partial refund of any fee; applications for amendments increasing: * * *'
capacity to a higher fee category will not be accepted. for filing* \,;* unless accompanied by the prescribed fee less the anx,unt already*,'.:,*: : paid. , *, . " *.i
'/ ' § 170.31 Schedule of fees for materials licenses.
Applicants for materials licenses and holders of materials:*. * \ licenses shall pay the following fees: I SCHEDULE OF MATERIALS LICENSE FEES I I. Category of Materials License At_1plication Fee Annual Fee
1. All materials licenses other than licenses in categories 2, 3, 4, and 5:* None
- 16 \ ' \
Category of , Materials License Application Fee Annual Fee
2. Licenses for byproduct material issued pursuant to 10 CFR Part 33 or pursuant to an application described in~ 35.ll
I (e) of 10 CFR Part 35. $100.00 $ 50.00 ,'
3. Licenses for byproduct material of,100,000 curies or m::>re in sealed sources used for irradiation of materials. 500.00 100.00 Licenses for special nuclear material in quantities sufficient to form a critical mass. 300.00 .' ,:100.00 Waste disposal licenses specifi-cally authorizing the receipt '
of waste byproduct material, I * ,I' source material or special nu- ;, ::*. ,I clear material from other persons
for the purpose of commercial I disposal by land or sea burial. 500.00 .200.00.

If a license falls within m::>re than one category of categories
, *I I
2, 3, 4, or 5, the license shall be deemed to fall within the I category for whic~ ~e fee specified is .the highest.*, ~ .* .. I*, ',
, , I
I
, \ ,J I
17
' \!
ENFORCEMENT s 170.41 Failure by licensee to pay annual fees.
In any case where the Connnission finds that a licensee has failed to pay the applicable annual fee required in this part, the Commission may suspend or revoke the license or may issue such order with respect to licensed activities as the Commission determines to be appropriate or necessary in order to carry out the provisions of this part, Parts 30, 32-36, 40, 50 and 70 of this chapter and of the Act. \ (Sec. 161, 68 Stat. 948; 42 u.s.c. ?201; sec. 501, 65 Stat. 290) Dated at Washington, .D. C. this eighth day of March 1967. FOR THE ATOMIC ENERGY COMMISSION W. B. McCool. Secretary 18 -
LISBON ROAD
LEW ISTO N, ME .
MOLYBDENUM AND TUNGSTEN PRODUCTS PLEASE REPLY TO BOX 1041
Z I P 04240 LEWISTON , MAINE , U . 5. A .
TEL AREA 207
784- 5478 CABLE ADDRESS . " ELM ET "
April 11, 1967 DOCKETED US!AEG APR 13 1967 Secretary, fflce of tfle Sei:reta,y
u. S. Atomic Energy- Commission Pcb/lc l'ra~edlags Washington, D. c. 20545 Attention: Mr. W. B. McCool Gentlemen:
In compliance with your March 13 notification to .A.EC Licensees, we are submitting hereon our comments in conjunction with the proposed es-tablishment of license fees which we have interpreted, places our usage and storage under Category l of Materials License at an annual fee of $25.oo. As your records will reflect, our !EC License STB-171 (as recently renewed on 2/14/67), permits us to retain a 200 lb. maximum quantity of the #104 thorium nitrate crystals for storage in our plant at any one time. The above is necessary as a standard raw material requirement for production usage. We believe that due to our limited storage and usage; you will wish to review this matter and exempt us from this annual fee in deference to the larger consumers of this product. We further believe that after full evaluation of this matter, you will find this request to be a fair and equitable request. Awaiting your prompt reply and thanking you for your review in this matter, I
remain, Very truly yours, PRL/rt
ADDRESS ALL CORRESPONDENCE TO: P. 0. Box 2078 La Jolla, California 92038 [ Beckma n:J 1NsTRUMENTs , 1Nc . SH A RP LA B OR A T O RIES D IVISI O N 11388 SORRENTO VALLeY ROAO . SAN DIEGO , CALIFORNIA, TELEPHONE: (714) 453-2 300 April 10, 1967 The Secretary U. S. Atomic Energy Commission OCKETED Washington, D. C. 20545 USiAEC
Subject:
11 AEC Proposed Schedule of Fees for PR 13 1967 Licenses 11 , dated March 10, 1967 Office of the Secretary Public ProCl!edlngs
Dear Sir:
Co I favo r the general principal that users of government serv, ,.. c.,,__....,"" wil I ing to pay reasonable fees cove ring the government's costs. But I object to certain provisions in the proposed schedule which I feel will discou rage the wider application of isotopes . Such discouragement will in the long run conflict with AEC's charter to produce maximum benefit to the pub I ic from the applications of atomic energy, wi II reduce the government's income from sale of isotopes, and, incidentally, also reduce I icense fee income. Specifically, I object to the fee schedule proposed for Category 2 ( 11 Licenses fo r byproduct material issued pursuant to 10CFR Part 33 or pursuant to an application desc ribed in 35. lle of 10CFR Part 35 11 ) . This category applies primarily to new and small users of radioisotopes . These users are the very ones most likely to develop important new applications of isotopes. These small users also represent the new growth markets of education, private medicine, smal I industry, and local government. The proposed fees, $100 for the application fee and $50 for the annual renewal fee, will prove sufficiently burdensome to eliminate many new and smal I users of isotopes . A $100 application fee vi rtually guarantees the permanent economic impractically of truly low cost mass applications of isotopes . Perhaps a lower application fee could be set for nominal quantities of byproduct material , say, fo r example, up to 10 millicuries per license. Admittedly, the proposed $100 application fee is not prohibitive for most current isotope applications which no rmally require a n in itial equipment invest-ment of several hundred dolla rs. However, I view the $50 renewal fee as very bu rdensome to many, onerous to most , and a costly nuisance to all isotope users . At the very least, let ' s eliminate altogether any annual renewal fee for isotope users in Category 2 . Failure to do so wil I, in my opinion, significantly hinde r the spread of isotope applications in the pub Iic interest.
[ eeckmanJ U. S. Atomic Energy Commission April 10, 1967 Page 2 To aid in your evaluation of my comments, let me say that I am President of Sharp Laboratories Division of Beckman Instruments, Inc. As such, I am responsible for the development of Beckman 1 s line of nuclear instrument-ation for laboratory measurement of radioactive samples. I received my professional training at Harvard University where I received my Ph.D. in Nuclear Chemistry in 1954. I have 13 years of nuclear experience, discovered the first long-lived isotope of Titanium, and have published numerous papers on isotope applications. Currently, I am a member of the AEC Advisory Committee on Isotopes and Radiation Development. Sincerely yours,
'fi~{l:,dapJ Rdaman A. Sharp, President Sharp Laboratories Division Beckman Instruments, Inc.
RAS:gjr cc: John Kuranz Frank Low
oocnr NU MBEr? . . . PROP.O ED ,. Et R- 3090,170
,'ld,so, PUERTO RICO NUCLEAR CENTER OPERATED BY UNIVERSITY OF PUERTO RICO FOR U. S. ATOMIC ENERGY COMMISSION A DDRESS REPLY TO :
Radiotherapy and Cancer Division Puerto Rico Nuclear Center Caparra Heights Station San Juan, Puerto Rico 00935 April 7, 1967 Secretary U.S. Atomic Energy Commission Washington, D .C. 20545
Subject:
Proposed rule making proposing the establishment of license fees for facility construction permits and operating licenses and for specific byproduct, source, and special nuclear material Iicenses.
Dear Sir:
The only comments we wish to submit on the proposed license fees is that non-profit institutions supported by public and private charity should be exempted from such fees . These fees would place an additional burden on an institution, such as ours (Dr. I. Gonz6lez Marttnez Oncologic Hospital), which already finds it very hard to meet its financial obligations from year to year. W\ttO.*M. M. Palacios de Lozano DOCKETED ~ Physicist OSAEC rsc APR 13 1967 fflce of the SecrelalJ
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PROCESS VALVE & EQUIPMENT CO.
'Wlan11/acfu,er6 ' Repn6en.faliue 4517 BIOOICPARIC ROAD CLEVELAND, OHIO 44134 DOCKETED April 7, 196 7 USi.lEC APR 12 1967 Secretary Office of the S crnta,y United States Atomic Energy Commission Public Fr.;m~lngs Wasn ington, D. c. 20545 Subject : Notice of Proposed on License Fees
Dear Sir:
We have received a copy of your March 13 , 1967 Notice to AEC Licensees concerning proposed establishment of license fees for facility construction permits and operating licenses issued under 10 CFR Part SO and for specific byproduct, source, and special nuclear materials licenses issued under 10 CFR Parts 30, 32-35, 40 and 70. We would like to go on record as opposing the charging of fees for the possession of this type of equipment since we feel that these fees are not in the best interest of the Industry or the Government. Some of the reasons for our opposing these fees are as follows:
1. The charging of fees for the possession of byproduct material cannot help but have an adverse effect on the indus t ry. This adverse effect won't be so much from the size of the fee, which is nominal, but will just discourage people from us ing this type of equipment. Government red tape is not too palatable when it is free. If you have to pay to get involved in it, we think the people would object strongly.

2. The fee will discriminate against the small user. Since it is a flat sum, regardless of installations, it obviously has a quite different effect on the man who has one gage and the man who has a hundred gages.

3. When sales are lost because of the fee, they will normally be lost in the 1 and 2 gage orders. This is just where the most work has to be done. Most of these 1 and 2 gage orders are people who are just getting into the stage of trying nuclear gaging. Charging a fee wi ll probably get these people out of the mood before they ever get fully into i t.

4. Initiating a fee for the services of the AEC would be similar to initiating a fee for the Public Health Service, or the U.S.
Department of Agriculture County Agents. The object is protection of the entire population and the cost of this should not have to be borne by any specific user. Very truly yours , PROCE,27VALVE & EQUIPMENT COMPANY R.J.Benson:ps J \ ~~~ - ~
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~um nf JHlimris SU PE RI N T ENDEN T @fft.c.e of tq.e ~up.eritmnh.ent of Juhli.c ~nstrnrlinn ~ JJlinBfi.e!h 62 706 April 10, 1967 Secretary United States Atomic Energy Commission Washington, D.C. 20545
Dear Sir:
The notice to AEC Licensees of March 13, 1967, has been received. This is to inform you that in my opinion the establishment of a license fee of any sizable amount for AEC Licensees would be detrimental to the Radiological Monitoring program in Illinois. It is my belief that only a small percentage of our monitoring instructors would renew their licenses. I urge you to take no action that would weaken the Radiological Monitoring program of this country. Very truly yours, {!r?,~
c. P. Goodwin, Coordinator Civil Defense Adult Education CPG:sj cc: Col. Robert Ritz
INSTRUMENT SALES INC. MANUFACTURER'S REPRESENTATIVES 709 BETHLEHEM PI KE PHILADELPHIA, PA. 19118 POST OFFICE BOX 4361 CHESTNUT H IL L 7- 7389 April 7, 1967 CKE TED OOAEC Director of Regulation u.s. Atomic Engergy Commission PR121967 Washington, D.c. 20545 fflce of the Secretary Publlc Prmatlings
Reference:
License Fees Gentlemen: We have received your communication concerning your proposal to establish license fees for AEC licenses. We feel that this fee is completely out of order and shbuld not be put into effect . To,begin with, it imposes a hardship on the customer because nuo:lear gaging is difficult enough now to sell to the customer and will be only more difficult if a licensing fee is established. In addition to that, the organ-ization who buys one gauge must spread the cost of that fee over the one gauge while a larger organization using a multiplicity of gauges would be able to pro-rate it over a larger number of gauges . This is not fair to the small user of radiation equipment. Government regulation when it is free is difficult enough to live with but when we have to pay to have Government regulation, this becomes unpallat-able . It has been nzy- understanding that the purpose of the Atomic Engergy Commission is to regulate the usage of isotopes and that they have not been involved in the fostering of their use. In the regulation of the use of isotopes, I wholeheartedly agree because if regulation is not imposed, it would probably result in a great deal of difficulty . The fostering of the use of isotopes has been done by private manufacturers as far as I can see , as opposed to the Atomic Engergy Commission . I sincerely hope that this licensing fee is not put into effect because it will definitely impose a hardship on our customers and potential customers to which they should not be subjected . Very truly yours,
- DEL I NSTRUMENT SA1/4E~~.
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RECEIVrn 1967 APR 12 P.M 8 53 U.S.AH'MIC EN RG Y COMM. m: l 1 .rnRY MAIL & R* v:*JS ECTION
00.Ci'ET. NUMBE~ PR~ *.S*, P.ROPOSED RULE .. i o, l?O STATE OF ILLINOIS Ill EAST MONROE STREET SPRINGFIELD, ILLINOIS 62706 TEL.A . C . 217- 525-7660 COL . DONOVAN M . VANCE STATE DIRECTOR April 10, 1967 Secretary, U.S. Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
With respect to the proposal for establishing a $2 5. 00 fee for specific Atomic Energy Commission Byproduct Material Handling Licenses, this Agency desires to make the following comments and recommendations. AEC Licenses are in the hands of sixty-five political subdivisions in Illinois to permit selected, qualified personnel to teach the Office of Civil Defense "Radiological Monitor Course" in support of the Federal Radiological Defense Program and Federal Community Fallout Shelter Program. Most of these Radiological Monitoring Instructors are unpaid, dedicated volunteers. It is extremely difficult to enlist the services of these people and get them to attend the OCD, RMI Course, to apply for the license, and to train the necessary number of monitors. To add a requirement for payment of $2 5. 00 fee for a training license will, undoubtedly, cause many to drop out of the program. Training radiological monitors is a never ending program and a difficult one at best. The number of qualified RMI' s available, even after five years of effort, is still far below the operational requirement of the State of Illinois and we believe the establishment of license fees will contribute to the failure of this program. The small amount of money derived from this fee would be offset by the personnel driven out of the program. In addition, Illinois needs a minimum of 519 Trained Radiological Defense Officers (RDO's) and Assistant RDO's. A prerequisite for RDO training is completion of "Radiological Monitoring for Instructors" (RMI) training. It is our belief that this program designed to me et Federal requirements for RDO' s will also be hampered by the establishment of license fees by the Atomic Energy Commission.
It is, therefore, recommended that Atomic Energy Commission Byproduct Material Handling Licenses granted by AEC to users for training Radiological Monitors for Civil Defense purposes be exempt from the requirement to pay a fee for the license as proposed by the Commission. Sincerely, D. M. Vance Director DMV:RSR:dg
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THE MASSILLON STEEL CASTING COMPANY 577 OBERLIN AV E. , S .W. *M A SSILLON , OHIO 44 6 4 6 *PHONE: T E MPLE 2- 7451 MANUFACTURERS OF April 6 , 1967 CARBON AND ALLOY STEEL CASTINGS C OM PLETE P A TTER N S H OP Mr. W. B. McCool, Secretary U.S. Atomic Energy Commission Washington, D.C. 20545 Gentlemen: Ref. - Change of rules to establish fees for facility and materials licenses. The Commission's responsibility for fost e ring the development of nuclear energy can best be served by continuing the program under the present appropriation system. It is our feeling licensing fees of facility and use of materials at this time would deter the development and progress of new users, as well as the furtherance of uses by present licensees. We realize that perhaps the Commission has spent a great deal of time and consideration to reach this decision, but we, in the use field, do not believe that any roadblocks should be put in the way of f ull use and continued development of nuclear energy. We would suggest that at least a period of five years be considered before such a licensing program be undertaken. Very truly yours, THE MASSILLON STEEL CASTING COMPANY HCB:bw
/4 ~/t~ 1 Harold C. BingJ fy--
President and cc: Honorable Frank T. Bow General Manager House Office Building Honorable Stephen M. Young Senate Office Building Honorable Frank J . Lausche DOCKETED S enate Office Building USiAEC APR 1 1 1967 "WE SHA LL NOT BE LIAB L E FOR A N Y S P EC I A L . IN D IRECT OR CONSEQU E NTI A L DA M AGES. NO CLAIMS OR EXPENSE ON MATERIALS FURNISHED WIL L BE ALLOWED UNLESS AUTHORIZED I N WRITING . ALL CREDITS ALLOWED ON DE F ECTIVE CASTINGS ARE ON A REP L ACEME N T BASIS. ALL AGREEMENTS SUBJECT TO STRIKES ANO ABI L ITY TO OBTA I N M ATER I A L OR CARS . OT H ER CONTINGENCIES BEYOND OUR CONTROL WI L L EXCUSE DE L AY OR PER M I T US TO CANCEL ANY CONTRAC T OR P AR T THE REOF. UN L ESS O TH ERW I SE ARRANGED. A LL PR I CES AR E SUB JE CT TO C H ANGE WIT H OUT N OT I CE . "
~ate of 05eorght DIVIS I ON S S TATE P A T ROL DRI V ERS LIC ENSE COLONEL R . H. BURSON DIRECTOR LT . COLONEL LEWIS G. BELL DEPUTY DIRECTOR ~ epartment of Jublit ,afetl? CRIME LABOR ATORY SAFET Y EDUCA TION ACCIDENT REP ORT I NG SAFETY RESPO NSIBILITY P. 0. BOX 14:$6 BUREAU OF I N V E STIGATION MOTOR VEHICLE IN SPECTION ~tlnnta , Oi.e.orgia 30301 GEORGIA POLICE AC ADEMY April 5, 1967 DOCKETED IIS!AEG Mr. Harold L. Price Director of Regulation United States Atomic Energy Commission Washington, o. c. 20545 Tuar Sir:
We are in receipt of your publication with reference to proposed license fees for specific byproduct sources under 10 CFR Parts 30, etc. We note that you specifically exempt educational in-stitutions. We are wholly in favor of this exemption but believe exemption should also be made for facilities operated by all tax supported institutions. We see no point in transferring state taxes to the Federal treasury in the form of license fees. This certainly decreases the spirit of cooperation between Federa~ and state agencies and is likely to initiate retribution in the form of state licenses for Federal agencies located in their various jurisdictions. Therefore, it is our opinion that redistribution of tax monies between Federal and state goverrurent through the nedium of license fees is a pointless and potentially useless procedure and sets a dangerous precedent. I hope you will consider the above comments in your final regulations for fee establishnent. aboratory LBH/mb
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0 OKLAHOMA CIVIL DEFENSE SEQUOY A H - W ILL R O GERS B U ILDING S POST OFFICE BOX 53365 CD OKLAHOMA CITY, OKLAHOMA 73105 DEWEY F. BARTLETT DON F . GU IER Governor State Director 405 JA C K S O N 1 - 2481 April 7, 1967 DOCKETED USAEC Mr . Harold L. Price Director of Reg ulations U.S. Atomic Energy Commission Washington, D.C . 20545
Dear Mr . Price:
Re f er ence is made t o your notice of Proposed Rule Making dated March 13, 1967 , and which would impose fees for byproduct materials licen s es under 10 CFR, Part 170. We would like to take this opportunity to comment on the proposed fees for handling 30mc cobalt 6 0 and/or any other similar isotopes that might be needed i n the teaching of the Radiological Monitoring Course and the calibration of those instruments . We believe that this or any other fee is completely unreason-able for these courses are being taught primarily to help save the lives of our people. Many of those being taught are federal employees having responsibilities under executive orders . It would amount to charging a fee for preparing our country to defend itself . We believe that any fee that might be imposed on these licenses would seriously jeopardize the entire Civil Defense Radiological Training Program. The majority of our licensees are volunteer i nstructors and in many cases require consider-able encouragement to continue with the program for they are giving up their spare time in most cases to handle this program. The State of Oklahoma very definitely opposes this or any other licensing fee for training materials to be used in preparing our people for s urvival . Sincerely, D/r:t. ~
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REC[IVED 1967 APR 10 PM 12 0 I U.S.ATtH ICENER GY COt-': >1. f,ZGUI tT0R Y MAIL & REC0,,u.3 3E CTION
30, 40, SD,
- 7 1!), (70 PROPOSED RULE JONATHAN J. YOBBAGY, M. D.
DIRECTOR DI' RADIOLOGY ST, JOHN HOSPITAi. ANO GILL MEMORIAL HOSPITAi. STEUBENVII.LE, OHi 43952 noc11.EHD AMHERST 4 - 1631 USlEC APR 111967 office of tlle secnWJ April 8, 1967 l'\;IIIIC~ lil&S Mr . Harold L. Price Director of Regulation United States Atomic Energy Commission Washington, D.C. 20545
Dear Mr . Price ,
This is in response to your letter of March 13 , 1967 , The proposal of fee for licensees for radioactive material is most unj ust to the individuals holding license permits for these radiactive elements . Most of this benefit as you know goes to the patient and to the institution . Therefore , to further tax the individuals capabilities seems most unfair . I had written the commission sometime ago pe rtaining t o the problem of allowing individuals to becooe licensed who were unqualified . This was found to be unjust at that time , as it is at this time . Only those indivi duals who are aware of the consequences as well as the benefits of these materials should be per:nitted to hold licenses . It appears that nany individuals must have exercised this 11 open door" policy, and therefore have no doubt burdened the commission with applications and duties . I would be most anxious to know what our annual fee would be . I shall state to you the licenses that I hold at the present time .
1. License No . 34- 4041-1 (167),
This is for radioactive isot opes - diagnostic and therapeutic .
2. License No . 34- 6578-1 (F?Ol .
Cobalt Teletherapy .
3. License No . 34-4041-2 (C66).
Office of Civil Defense . Should the tariff be of a magnitude that it would not be reasibJe to bear, and in the face of general heavY taxat ion that is present , I am sure that myself and others may have recourse to consider the prudence of the licenses , I am most anxious to hear from you in a reasonably short time advising me as to what the fee would be for my licenses . Sincerely yours, JJY: del o~dr/ttl~ ;:7~ J f l / ~ JON THAN UY~GY,M. D~
INDIAN A BLOOMINGTON , INDIANA 47405 S TUDE N T HEALTH SE R V I CE 600 N. JORDAN A V ENUE April 7, 1967 Mr. Harold L. Pri ce Director of Regulations U.S. Atomic Energy Corrnnission Washington, D. C. 20545
Dear Mr. Price:
Indiana Univ ersity, Bloomington Campus, is currently licensed pursuant to Title 10 CFR, Part 33. The introduction section, headed "Materials License Fees" states that "Exemp-tions are provided * . *
for certain licenses held by educational institutions." In Section 170.11(4) it is indicated that these exemptions apply only to institutions with loan a greements administered by the Corrnnissions Division of Nuclear Education and Training or university reactor assistance contract with the Corrnnission.
This is to request clarification of the proposed law as it applies to our university which operates under Byproduct Ma terials License issued pursuant to Title 10 CFR , Pa rt 33. Sincerely, DOCKETED USIAEC
,~-~f~ / Chairman, Radiolo gical Control Corrnnittee nk APR l 11967~
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FAIRFAX COUNTY HEALTH DEPARTMENT 3750 OLD LEE HIGHWAY FAIRFAX, VIRGINIA 22030 IN COOPERATION WITH THE PHONE, CRESENT 3 -20!5 0 STATE DEPARTMENT OF HEALTH Apr i 1 10 , 196 7 Secretary U.S. Atomic Energy Commission Washington, D.C. 20545 Re: Notice to AEC Licensees dated March 13, 1967 Through: Dr. Kennedy f l(
Gentlemen: Your notice regarding proposed fees for AEC licenses, invited comments. I wish to state that if it is the intention to charge
$25 minimum fees to all licensees, including county and state personnel who use radioactive sources in teaching Radiological Monitoring under the Civil Defense Program, then some consideration should be given to such an exception.
If I have misconstrued the meaning of the notice, I would appreciate a clearer explanation. Thank you for any advice you may give us in clearing up this question. Very truly yours, DOCKETED
~ ; CC~---fi;;,,_ USIAEC J.W. CI ayton Regional Sanitarian JWC/ak
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Dear Congre**- Irwin:
~~ ~~?tf .. . . ..
I ** writh1 to eall your attention to tlMt encl01ecl 11otla* to AtGale-,- ... '~'/I- i'- * ; Ener11 Coaisllaa Lie**** propo1ln1
UeenH fee adledule fn ti. ~ * */,,, ,* *, **1-;
of byproduct ndloactiv1 llotop*** As with eYffY article pullll__. *ta : f'f;. , *, Federal ReRhtel' Jt -i)eeo... very unclear wtt.tber the pNpOSed fee* woa14 app1* f\ ~,::~. to possessors of
A.P..c. licenses for purely aedlcaJ . , purpo**** I aa al.. * **,::..;:~*
ing a s*ll introductory paaphlet about the growth of ndloactlve _..,ta* _, ,*.
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of the increasing wide dils-inatlon of centers where radloacttft Mcll*l 4.t*p. Aosis can be perforaed. I aa particularly intere1ted in avoidln1 * ,_....,... where it ii api,lied to th* aedical u1e1 c,f radioactivity. - ;_;. I started the first w11 unit for radioactive dlao,0111 l* a, ffln_..,__,. anv of the hospitals had established their own dtagnotiltic *l*** I ddal l . ,, would have been 1011ewhat dissuaded froa attnptlng to ettabll.sll * .,..,,attn aedical tmit, if additional fMS had been applied by the AtOlllc en-., c-.t** ston. The A.E.C. is *.tumtn1 over IIU'Ch of the nplatatlon f A. a.c. II to states and it 1ee>>s a little bit_Ulbi~ous for thn to agala * * .,.., to *--11 a Federal LiceaseA fee !lchedule. / M far as tu wedical usage of ndioactivity are conc*med* the Atoalo ~ Conission inspects th* units very periodically, to deteratne wbetbeT proper .,a,!et1 :, --,,. precautions are belna eaployed. It exerts no other di net or tl\dtrect flmctt *ta ,; the aedical field, and it is for this rea1011 that I teol an - addltl** 1 fn IC.,lule
vould stiffle the growth of what 11 ono of the -lllOlt futest ll'Olfl*1 bn.Dcbes ef aedicine. '

I am also sending a copy of ~his letter to the Secretary of the V. s. A.toatc ener~y Collfflission, Washington, D. c., 2054S f ith warmest personal regards, I reaain.
1 Yours sincerely, Willia P. Bckhardt* Jr** N. D. WFP.:amh dictated but not read or signed.
STATE OF NEW MEXICO l
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.OSED RULE W \ ?0,170 EXECUTIVE OFFICE OF THE GOVERNOR OFFICE OF CIVIL AND DEFENSE MOBILIZATION P. C . BCX 4277 DAVID F". CARl3C OOVERNOR SANTA FE 87 60 1 A LB ERTA M I L L E R D IRECTOR April 4, 1967 OCKE1d U EC Mr. Harold L. Price Director of Regulations PR 101967 U.S. Atomic Energy Commission ffice of the Secretary Poblic Proceedings Washington, D. C. 20545
Dear Mr. Price:
Reference is made to your notice of Proposed Rule Making dated March 13, 1967, and which would impose fees for byproduct materials licenses under 10 CFR, Part 170. Insofar as this would effect licenses for possession and use of Office of Civil Defense Radiation Training Source Sets, CD V-784 (30mc cobalt 60) and/or civil defense instrument cali-bration units, we stand in firm opposition to the proposed rule. We recognize the administrative load you encounter in pro-cessing applications, maintaining records, etc. On the otherhand, these licenses pertain solely to training radiological monitors and maintenance of their instruments in order to provide an emer-gency capability for the protection of the citizenry. The licensees are volunteers with the exception of a relatively few professional civil defense employees who are required to use the byproduct material in the course of their duties. It is felt that the proposed fee would bring monitor training to a virtual stand still in New Mexico and would be a serious impediment to the radiological defense effort. Taking cognizance of paragraph 170.ll(b), Part 170, you might want to give consideration to automatic exemption for all civil defense affiliated licenses. Thank you for the opportunity to comment on this matter and for any consideration you can extend to us. Sincerely, q~~ ALBERTA MILLER State Director AM/raf cc: OCD Region V
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*", , [) , "' .7d,l./d, 511, ST A TE OF MICHIGAN P.ROP.OSED RULE * . - 7P, 170 CONSERVATION COMMISSION WATER RESOURCES ROBERT C. McLAUGHLIN COMMISSION Chairman GEORGE ROMNEY, Governor JIM GILMORE CARL T. JOHNSON Chairman E. M. LAITALA DEPARTMENT OF CONSERVATION GEORGE F. LIDDLE AUGUST SCHOLLE Vice Chairman RALPH A. MAC MULLAN, Director HARRY H. WHITELEY B. DALE BALL GERALD E. EDDY April 4, 1967 ALBERT E. HEUSTIS, M .D.
JAMES V. MURRAY LYNN F. BALDWIN 200 Mill ST., LANSING 489 13 Tel. 373-3560 Secret ary, U. S. Atomic Energy Commission Washington, D.C. 20545 Attention: Harold L. Price Director of Regulations Re: Proposed fees for facility and materials licenses. Gent l emen: With respect to the proposed rules published in the Federal Register March 11 , 1967 (32FR3995), we have a materials license for 250 millicuries of tritium (H3) for an electron capture detector in a laboratory instrument . As we understand the proposed rules, the annual license fee for the preceding use would be $25 per year. Could such a use qualify for an exemption under paragraph 170.ll- 4b and if not would you consider a change in the proposed rules to exempt government agencies which have in their possession some minimal amount of nuclear materials as specified by you from the payment of the license fee? Very truly yours, DOCKETED WATER RESOURCES COMMISSION USsAEC 1/ ,/ ~ (~~ Oem~ng Executive Secretary RWP:ms
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t:""t,~,- . . ,!,. _ ' !" " ' ** r *.- *n l~ *.1.t. \:... 1 .. i.1--- .\;;.'(_} .10,fl},Sf, PROPOSED R LE ** i \- 74,119 A MEMBER OF NORT H C ENTRA L ASS OC IATION OF COLLEGES AND SE C ONDARY S C HOOLS Broken Arrow Senior High School 808 EA S T COLLEGE PHONE : 748-7434 BROKEN ARROW, OKLAHOMA 74012 H. K. RAGSDALE , PRIN C I PAL JOE w. ROBINSON. Ass 'T. PRIN C IPAL April 4, 1967 OCllfHl BSlEC PRl O 1967 U. S . Atomic Energy Commission t office o11he Secre1ary Washington, D. C. 20545 ilblic Proceedings Gentlemen: Most license holders of type 35- 11456 - 1 hold these as a public service to the community in which they 1 ive . If I am re.quired to pay a fee for this license, I will not renew mine . I recommend that license holders that p rovide a com-munity service do not pay a fee .
~7=u¥ Christie By-rd Radet Office-r Broken Ar-row Civil Defense
co.ci:r:r r,;~ rrnrn 3a,qo, s-o, THE LANCASTER GENERAL HO-I Lancas ter, Pa. '1f>07'. AL PJWP.OSED RULE pR-14', 170 DEPAR T MENT O F R ADI O L O GY WILHELMINA S. SCOTT, M. D. PAUL W. EYLER, M. D., DIRECT O R OF DEPAR T MEN T ANDREW W. KOCH, M. D . EMMETT M. COOPER , M. D. Duane C. Goldman, M.D . April 3, 1967 Secretary, United States Atomic Energy Commission Washington, D.C. 20545
Dear Sir:
This letter is in comment to the Notice to AEC Licensees, March 13 , 19 6 7
We have a Byproduct Material License for the use of isotopes in diagnostic nuclear medicine . Part 170.31 states that we will be billed under Category 2 of materials license for a $50.00 fee annually .
Plans are drawn to add a new wing to our hospital contain-ing a 60 Co therapy unit so we assume that this will have to be licensed, for a fee, and an annual fee for use will be levied . Ultimately such fees are always born by the patient. Whether or not this can be traced directly to the individual patient ' s hospital bill, the financial support of a community hospital is carried in the main by its patients. The overhead of operation of nuclear medicine and radiation therapy departments is quite high already because of the cost of radioactive isotopes, instru-ments and physical plant . President Johnson has commented with concern about the rising cost of medical care, especially hospital charges . It is quite inconsistent for the President to plead for economy just as a government Commission levies fees which can only raise costs, particularly when the overhead in the medical specialties affect-ed , is already so high . Sincerely, DOCKETED Paul W. E ~~;J___..M. D. IIS!AEC ;vl /) , ~
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R_ ., w*. Koch/2 M. D. _g___ ,~-<-f-~~/,L I --u...( . D
~ett M. Co6per, M. D. -~c~~
Duane C. Goldman, M. D. EMC:pkr
t..,C(*-UJ.1,A IO }=-~(>> J UNITED STATES . *.- ") J &(c,..o,so ATOMIC ENERGY COMMISSION :* *: - ~: ~ ~ ~ 7 eJ I7 u WASHINGTON , D.C . 20545
John A. Pr 1l Cbalrman. Depar

t of Biology 11.1.nthr Collep k Bill, th C.solina 29730
Dear Hr . fre n:
Thank you for 7our lettar of April 3, 1967 to the ecret x7 c nttng on the Comml*ion'* ropoe 1 to eatablieh fee1 foy facility and teriele ltcen**** Your c ntt he ken nottd and "111 receive careful e eiaration rior* to tald further action on the pt: . d l'Ule. tncerel your,, GHald L . RuttGOa Ghief Prosr eel*tanee Br ncb Dtvi11on of di tin Protection tandard*
UNITED STATES ATOMIC ENERGY COMMISSION WASHINGTON , D .C . 2054 5 Mr . John L . wln Vie* heei4nt an Treaeurer Rue er* vat raity v Brun.ewtct. w Jereey 08903 Dear Mr . Dlu Thank you for y ur letter of Aprtl 4, 1967, to the
tery c-nt1Bg oa the Commiteion'* ropoa 1 to eetoliah feet fo~ facility d terial lie na***
Yeur commaate he* tea noted an will nceive c reful con,1derat1on rlor t taking furt r action on the pr ed rul*~ incerely yovr,, ald L. &tou, Chief fro r Aa1l1tance ranch Dtvteion of 8441 ti ProtectiOA tandar
e FRANK T . MOORE, M.D. AKRON CITY HOSPITAL DIRECTOR MARKET AND ARCH STREETS FREDERICK A . RUOF F , M . D .
WILSON D . REES , M.D. AKRON, OHIO 44309 HAROLD G . N I EMEYER, M.D. FRANKLIN H . SWENSON, M. D. DEPART MENT OF ADELBERT A . KOSTENSKY, M .D. RA D IOLOGY A ND N UCLEAR ME DICINE AUSTIN H. KUSTER , M . D . THEODORE E . SOPP RADIATION PHYSICIST 6 April 1967 Secretary, u.s. Atomic Energy Conunission Washington, D. c. 20545 Gentlemen: In regard to the Commiaeion 1 s notice, AEC PROPOSE.S SCHEDULE OF FEES FOR LICENSES, dated March 10, 1967 I would like to submit the following canment. It is my strong belief that radioisotopes being used for medical diagnosis or therapy whether by an individual physician or an institution should be exempt frcm any licensing fee. Sincerely y'!)rs, Fd~~ F. H. Swenson, M.D. Department of Radiology Division Radiotherapy and Nuclear Medicine bw
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-- *****- ,. .. ') 1 u, 'f ~ so p;:~-~ ;*:_: 2 _.~ ?v, 1 , 0 RADIOLOGISTS OF AKRON AKRON CITY HOSPITAL AKRON . OHIO 44309 PRACTICE LIMITED TO RADIOLOGY AND NUCLEAR MEDICINE FRANK T . MOORE . M.D.
DIRE C TOR FREDERICK A . RUOFF . M . D . WILSON D. REES . M .D . HAROLD G . NIEMEYER . M . D . FRANKLIN H . SWENSON . M . D . AUSTIN H . KUSTER . M . D . ADELBERT A . KOSTENSKY . M .D . THOMAS R . HATHAWAY. M.D . 7 April 1967 Secretary U.S. Atomi c Energy Commission Washington , D.C. 20545
Dear Sir:
Notice has been received of the Commission's proposal of a shedu le of fees for licenses for the use of isotopes. I believe the following comment is pertinent. The application f ee and the annual fee proposed would certai nly increase the cost in the medical use o f isotopes. Understandably, this will increase the cost to the patient . It is my belief that radio-isotopes being used in medical diagnostic procedures and in therapy should be exempt from any licensing fees. Sincerely yours , ASSOCIATED RADIOLOGISTS OF AKRON
- ~~ l l/LA_ oa-n_.
Frank T. Moore , M.D. gg
~ , ORDNANCE o,v,s,oN - .~.. . . **-- *.-
SHER IDAN S TREET, R ICH MOND, IND IANA 47374, TELEP H ONE : (3171 962- 5511 6 April 1967 Se cretary U. S. Atomic Energy Commission Washington, D. C. 20545 Subject : tomic Energy Commission Proposed Facility and Materials License (10 CFR Parts 30 , 40, 50 , 70 , 170)
Reference:
Atomic Energy Commission letter dated 13 March 1967 Gentl emen : Avco Ordnance Division has reviewed the subject proposed Facility and Materials License fees and requests specific clarification in regards to Section 170 . 11, exemptions, subparagraph 3, as this would relate to Section 170 . 21 , schedule of fees, subparagraph 4 and 170 . 31 schedule of fees for material licenses , subpar agraph 1. The reason for clarification is ne cessitated due to the fact that the Ordnance Division currently has a valid Source Materials License as issued under Docket No. 40- 6304 , Controlling License No. SMB- 103 , expiration date March 31, 1968 . As we review the proposed regulation , it would be our interpretation that this specific license would fall in the exemption category; and therefore , no application or annual fee would be applicable . However, the other sections sighted above could well be used to determine a fee applicable to the license . It would appear that this type of application and annual fees would be rather difficult to allocate to various government contracts . Specifically, in as much as the license fee would be prorated over the number of government prime contracts held by a private contractor without due regard to actual usage analysis . We would appreciate your r eply to these comments. If we can be of further assis tance, please contact the undersigned . Very truly yours , AVCO ORDNANCE DIVISION flt?~ A. P . Program ng ger APM/lr Inf o copy to: D. Abramowitz R. A. Mace A DIVISION OF AVCO CORPORATION
"! , tm A C:::-410 (1-ol) \.
___,. . SOURCE fi11lTEilIJ!L LICE IS Pursuant to the Atomic Energy Act of 1954, and Title 10, Code of Federal Regulations, Chapter 1, Part 40, " Licensing of Source Material," and in reliance on stateme nts and representations here tofore made by the licensee, a license is hereby issued authorizin g the licensee to receive, posse ss and import the source material de signated below; to use such material for the purpose (s) and at the place(s) designated below; *and to deliver - or transfer such- mat~riaLfo persons authorized . to receive it in accordance with the regulations in said Pai:-t. This license s]lall be deemed to con tain the conditions specified in Section 183 of the Atomic Energy Act of 1954 and is subject to all applicable rule s, regulations, and orders of the Atomic Energy Commission, now or hereafte r in effe ct, including Title 10, Code of Federal Regulations, Chapter 1, Part 20, "Standards for Protection Against Radiation," and to any conditions specified below. Licensee 3. License No .
1. Name Avco Co rporation S1113-103 Ordnance Division 4. Expiration Date

2. Address Richmond, Indiana March 31 1968 S, Docket*No .
40-6304
,1

6. Source Material 7. Maximum quantity of source material which J licensee may possess at any one time under ij Thorium and uranium this license Fifty thousand (50,000) .
~J,l. "'-..1 1----- - -- - - - - - - - - - - ~500 pounds of thorium magnesium alloy con-taining not more than 4% thor ium and -~ ounds- - of - -- uraniun.- ~ - - - - - - - - d~1*
1 CONDITIONS 8 . Authorized use (Unless otherwise specified, the authorized place of use is the licensee's address stated in Item 2 above.) For use in accordance with the procedures descri bed in the licensee I s application dated /'.Jarch 8, 1962 and supplements dated March 25 anc.l April 9, 1964 and March 19, .1965.
9. This license does not authorize chemica l processing such as milli_ng or pickli_ng of the thorium magnesium alloy.
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UNITED STATES ATOMIC ENERGY COMMISSION W A SHINGTON , D.C . 20545 March 13, 1967 NOTICE TO AEC LICENSEES Attached is a copy of a Notice of Proposed Rule Making published by the Commission in the Federal Register proposing the establishment of license fees for facility construction permits and operating licenses issued under 10 CFR Part 50 and for specific byproduct, sour ce, and special nuclear materials licenses issued under 10 CFR Parts 30, 32-35, 40, and 70.
The Commission is proposing the establishment of fees for its facility and materials licenses which it believes to be reasonable and compatible with the Commission's responsibility for fostering the development of nuclear energy. The fees are set out in a proposed new Part 170. Amendments to Parts 30, 40, 50 and 70 t o reflect the proposed application filing fee requirements also a r e propos ed. The fees would apply to specific licenses but not t o general licens es at the present time. The Notice allows 60 days for connnent by interested persons. Upon expiration of the comment period the Commission will review and evaluate the comments received in reference to the proposed amend-ments. Licensees are requested not to remit fees at this time. Further action by the Commission and republication in the Federal Register will be necessary before the proposed amendments are made effective. All interested persons who desire to submit comments in connection with the proposed amendments should submit them in writing within 60 days from the date of publication to the Secretary, U.S. Atomic Energy Commission, Washington, D.C., 20545. Comments received after that period will be considered if it is practicable to do so, but assurance of consideration cannot be given except as to comments fil ed within the period specified. Copies of comments on the propos ed rule may be examined at the Commission's Public Document Room, 1717 H Street, NW., Washington, D.C.
Enclosure:
Notice of Proposed Rule Making on License Fees
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(* .... ~. OPTI ONA.L F O RM N O . 10 MAY 19<<52 ED IT ION CSA FP MR (,1 CFR) 101-11.S UNITED STATES GOVERNMENT emorandum TO Chri s Henderson DATE: April 10, 1967
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FROM : Stanley T. Ro1finson, Jr. ~~
SUBJECT:
LICENSING FEES - PR 30, 40, 50, 70, 170 Attached is a letter from Congressman William J. Randall for whatever action is deemed necessary. This office has not responded in any way. Attachment cc: J. Hutton
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WM. J . RANDALL =~OP.Ci'.*ocsr - .;L;:E;-:s..:* ~- ,.. COMMI T T EES : 4 TH M ISSOURI D IST RICT [jl\ ~ AR M ED S E R V I CES G OVERN MENT O PERATIONS
~ongrcss of tbc Wnitcb ~tatcs 11,oust of l\epresentatibts m!la~bington. 39.<d:.
April 7, 1967 Secretary
u. s. Atomic Energy Connn.ission Washington, D, C. 20545
Dear Sir:
We are in receipt of a copy of the letter of March 30th, 1967, addressed to you by Joe M. Hopping, Ph.D., Assistant Professor of Chemistry, Central Missouri state College, Warrens-burg, Missouri. A duplicate of this correspondence is attached for your reference. Dr . Hopping seems to have sane specific and worthwhile objections, but I am not at all familiar vrith the proposals in question . Would you kindly look into this matter and furnish our office with a summary of the actions proposed and the possible outcome, so that we may have same information to pass along to Dr. Hopping? Your assistance is greatly appreciated. Sincerely, WJR:ew 4~ Wm. J . Randall Member of Congress Attachment
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1 Joe M. Hopping , Ph . D. Arrni ctant Professor of cc t Hon . . William J
Randall Chemistry M.o. ti-Qm Missouri

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[flt.~~ 530 .k.8. rikn {d~ ~ 9"eoua., . ! , ~ 6~603 April 4, 1967 Harold L. Price Director of Regulation United States Atomic Energy Commission Washington, D. C. 20545
Dear Mr. Price:
In reference to your letter of March 13, 1967, concerning the proposed fee for licenses under the "Atomic Energy Commission Act", we have no objections to the proposed fee structure on proposed rule making in conjunction with the Atomic Energy Commiss+/-on activity. Very truly yours, SISTER M. CANISIA, O.S.F. EDWARD T. MCGRATH Associate Administrator ETM: cu cc: P. R. Dirkse Dept. of Radiology
RECl:l 'ED 1967 AP-:: 0 /'.; 8 ,.. 5 L.. :;,!, Ti~'*li C EN Y C l1i . r .: ~tr_~* .... r:y MAI L & *,;__ .! ,..,.., .:-EC TIO,
DOCKET NU W3ER PR3tJ, 7 IHJ, S9<',
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HEADQUARTERS IOWA NATIONAL GUARD Office of The Adjutant General Camp COodge MAILING ADDRESS : P. 0 . BOX 616 DES MOINES , IOWA 5030 3 AGIA-RA.D~F 5-10 JEP/pj / 276-7383 5 April 1967 Secret ary, U. S. Atomic Ener 6J Commission Atomic Energy Commi s sion Washi ngton D. C. 20545
Dear Sir:
This office ha s a contract with t he Of f ice of Civil Defe nse to cali-brate all CD Radiolo gical i nstruments in t he St ate of Iowa . One of t he requirements of this contra ct i s to have an AEC Licens e f or t he possession of 30 curies of cesium 137 contained i n t he CD V 795 Calibr a tor, which is on loan from t he Of f ice of Civil Defens e . As t his pro gram is 100% Feder al Funded , it is f elt that all license us ed i n this and s i milar programs be exempt from proposed 10 CFR, Parts 30, 40, 50, 7, 170.l Facility and l'-:!at erials License s Propos ed Fees . FOR Tllli ADJ UT.11.HT G.c.;N1::..RaL
<;{or J 08~PH G. HAY COL G0 , Iowa AR.NG Ass istant Adj utant General OCKETED US4EC 7 1967 ffk:e of !he Secretary ubllc Proc"*'ir,gs
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pR. 10.11c, r:so, Vapuncich -SandePson & Brown - - DOCKET NU MBER P:ROP.OSED RULE TELEPHONE 252-6325 7t!J, 17() P.O. BOX 593 LABORATORIES 13 N. 32nd ST. _.J Billings Montana S'l/03 April 4, 1967 Secretary U.S . Atomic Energy Commission Washingto n , D.C. 20545
Dear Sir:
According to your new proposal to es t ablish license fees for nuclear materials, we as a laboratory in which we use an electron capture detector {with 250 millicuries of hydrogen 3 foil) a by-product material will be paying $25/year licen s e fee . We s ee no need for paying a license fee and object to charging laboratories {for testing usage only) this fee. Last year we analyzed 13 samples of milk and alfalfa for pesticide residues and realized an income of less than $350 for this work, in which we used the electron-capture detector. A charge of any amount for laboratory use I would consider ex\orbidant. I recommend that you exempt laboratory testing facilities utilizing nuclear material for test purposes from license fee charges. In addition the amount of tritium on the foil in our detector probably does not amount to $25 and we see no need to pay the AEC $25/ year for a $25 item. Thank you for considering our objections. Sincerely yours , Yapuncich, Sanderson & Brown DOCKETED Laboratories USIAEC APR 7 1967 ~,fj Offtce of the Secretary John G. Yapun cich Publlc Proceedings President SPECIALIZING IN CORE, WATER, GAS, CRUDE OIL , REFINED PETROLEUM PRODUCTS, AND FIELD ENGINEERING SERVICES
DOCKET NUMBER P*R., ~(}, vo, S'<>,
. P.OSED RULE ?t!J, (7 D ROGERS BROTHERS COMPANY FOOD PRODUCTS DIVISION March 3l, l967 Secretary U.S. Atomic Energy Connnission Washington, D.c., 20545 Sir:
Regarding the notice of proposed rule making concerning establishment of license fees for operating and special licenses. The annual fee of $25.00 for holders of materials licenses who have no more material than a gas chromatographic detector appears to be arbitrary and excessive. Additionally a pertinent question would be exactly what connection exists between materials license fees and a responsibility for fostering the develop-ment of nuclear energy? Sincerely, OCKETED OOAEC trator Quality Control APR 7 1967 / ba P.O. Box 2188 I Idaho Falls, Idaho 83401 I T elephone 208 522-0110 I TWX no. 910-977-5724
DOCKET NUMBER PR Jo,l/O,Sc,
- f.ROP.OSEO RULE I -?<J>, 170 STATE OF MICHIGAN DEPARTMENT OF PUBLIC HEALTH 3500 N. LOGAN , LANSING, MICHIGAN 48914 GEORGE ROMNEY, Governo r A LBERT E. HEUSTIS, M .D., Directo r April 4 , 1967 OCKETED U&4EC Harold L. Price APR 7 1967 Director of Regulation U. S. Atomic Energy Commission Washington , D.C . 20545 Dear Mr. Price The notice of proposed rule making published in the Federal Register with regard to license fees for facilities and materials under 10 CFR, Parts 30 , 32 through 35 , 40 and Part 70 , is of particular interest to the Michigan Department of Public Health and the State of Michigan. We have several questions with regard to these proposed rules.
1. Are governmental agencies exempted from license fees? If so, to what extent? For example , would a municipal power company applying for the construction of a reactor be exempt from such fees?

2. How does the fee schedule affect the agreement states? Will the compatibility of the state program depend on license fee charges?
What arrangements have been made with the agreement states? The answers to the above questions may have a bearing on the comments with regard to this matter made by the State of Michigan since legislation is under consideration amending the Agr eement Act 54. An early reply is requested . Very truly yours, DIVISION OF OCCUPATIONAL HEALTH frC ~-,- 'A~ D. E. Van Farowe, Chief Radiation Section DEV/ja "Equal Health Opportunity for All"
10 R- 3 ~, </0, s-o, DOCi\ET NUM BER fJW.P.OSEJ) RULE 7(), r70 HONIRON HONOLULU IRON WORKS COMPANY April 5, 1967 Secretary, United States Atomic Energy Commission Washington, D. c. 20545
SUBJECT:
AEC License Fee Gentlemen: As a representative of the Ohmart Corporation, manu-facturers of nuclear gaging equipment, and selling g~ges to small users, we feel that these license fees would retard the develop-ment of peaceful and constructive uses of nuclear energy devices. Most of our customers would become more reluctant to install gages if they were to be charged an annual fee of $25.00. Although the majority of developments in this field to date, have been made by governmental agencies, is it not the time to turn as much of the development over to private enter-prise as is possible? It would appear that this new license fee is to finance government developments at the expense of small companies. We feel that the governments only role should be one of inspection and policing and that for such services, a fee should not be charged. We hope that you will leave the develop-ment of new uses for nuclear energy to competitive private enter-prise rather than to a governmental agency which is only spurred on by "hot " or " cold 11 wars. Very truly yours, COMPANY a E. Cocker, OCIETEt P oduct Specialist, USAEC Machinery Department REC/mlg PR 7 1967 cc: Ohmart Corp. ffice at the Secretary Publlc ProcecUlngs Sen. Hiram Fong H c & s Sugar Oahu Sugar Olokele Sugar Div of Sewers - Honolulu Div of Finance - Honolulu P OS T OFFICE BO X 3140 / HONOLULU , HAWAII 9680 2 / TELEPHONE 512-011 / CABLE : HONIRON HONO L U LU Plants: Honolulu
Hilo, Hawaii

Jeanerette, Louisiana

Manila, Philippine Islands / Branches: New York City

Hawa i i

Philippines

Hong Kong
DO.Ci<ET rw*,wrn PR-; t,, qo, so, eROP.OSED RULE 1~,, 10 OLD DOMINION COLLEGE Norfolk, Virginia 23508 OFFICE OF THE PRESIDENT April 5, 1967 Secretary U.S. Atomic Energy Commission Washington, D.C. 20545 Dear Sir It has been brought to my attention, as an AEC Licensee, that consideration is being given to assessing a fee on colleges in connection with their use of nuclear material in their research and instructional programs. While the fee contem-plated is relatively small it would have considerable nuisance effect in making budgets, purchase orders, accounting, etc. an extra chore. It would also, of course, set the stage for much heavier assessments in the future. I do hope any charge may be avoided, but if it is deemed needed for control purposes would it be possible to exempt state-supported colleges? Such consideration is now being given to us on source and special nuclear material on loan from the Atomic Energy CoD1Dission. Your consideration of this request will be greatly appreciated. Very truly yours
~ -~;-::: ~~t President OCKETED USIAEC 7 1967
DOCKET NUMBER f.ROP.OSED RULE PR-JtJ,1/-8, s-o,
'Jt>, 17D 127 Bandel ier Avenue Los Alamos, New Mexieo 87544 April 4, 1967 Secretary U.S. Atomic Energy Commission Washington, D. c.
20545
Dear Sir:
The following are my comments on the proposal to es-tablish l icense fees for special nucl ear materials. As published in the Federal Register, March 11, 1967. My comments will be directed toward the requirement for a l icense in my particular case. I have a col l ection of the elememts, and to include the element uranium it was necessary to get a source material l icense. This is a l ot of bother for me and even ~ore for the AEC. Depleated uranium is very abundant now, the AEC is trying to find uses for it, but I can 1 t even possess a 3/4 11 x 3/ 4 piece of it without a l icense. At one time I knew someone who wanted uranium nitrate for coloring in ceramic glazes, the same problem, can't have it without a license. This material is not really dangerous enough to warrent all this attention is it? Many common chemicals on the open market are mu.ch more toxic than uranium. Thus my comments are. 1) If this establishment of fees goes into effect how about considering a change in the regulations concerning licenses? 2) If this proposal is defeated how about considering a change in the regulat-ions concerning l icenses? It may just be time for a re-evaluation of the requirements. Thank you. Sincerely, DOCKETED lJSiAEC APR Richard Niethammer
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4110 MOHAWK HOUSTON 16, TEXAS April 3, 1967 DOCKETED United States Atomic Energy Commission US!AEC Washington, D. C. 20545 Attention: Mr. Harold L. Price Director of Regulation Gentlemen: We are in receipt of your Notice of Proposed Rule Making, published by the Commission in the Federal Register, proposing the establishment of license fees for operating instructions. We feel that since this agency is a tax supported institution the charge for fees for licensing is not a just charge for the services rendered. We also appreciate the fact that with the ri~ing cost of today and increased demand on your budget you may feel this step is necessary. However, by the same token we, as a small business organization, are operating in a highly competitive field which normally requires us to bid our work for less than a reasonable profit margin. This is just another means of reducing our invest-ment. It is hoped that you will take into consideration the hardship to be worked on the small business man in regards to this proposed licensing fee. Yours very truly,
--,- :.:e MOBILE TES TING LABORATORIES, INC.
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- 4 H WIN T HROP COLLEGE THE SOU TH CA ROLINA COLL E G E FOR WOMEN* R OCK HI LL D EPART M E NT O F B I O LOGY April 3, 1967 Secretary, U.S. Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
Re: Proposed establishment of fees for facility and materials licenses. I feel two exemptions, each of which would apply under some circum-stances under the proposal as now written, should be somewhat broadened. Specifically, non-profit public and private educational institutions should have some degree of exemption other than that indicated in para-graph 170.11. The exemption should be great enough to cover quantities of isotopes which might reasonably be used for instructional purposes. An exemption for instructional purposes might vary according to the number of students involved or might be absolute. An alternative would be exemption of licensees whose basic license allowances were no greater than some multiple of the quantities for which no license is required. Another exemption which I feel should be specified as such and not simply covered by the loan provision is isotopes used for Civil Defense instructional programs. Sincerely, I\ Z-L CLrrt-11 John A. Freeman Q ~*,.. ~ Chairman JAF/dah DOCKETED llS.lEC
PR SENIOR HIGH SCHOOL ERIC CASSON, PRINCIPAL WEST L AFAYETTE, INDIANA
- DOCKET NUMBER PROP.OSED RULE JtJ,'1'1, SO, - 7o, ntJ April 4, 1967 Secretary of u. s. Atomic Energy Commission Washington
o. c. 20545
Dear Sir:
The Atomic Energy Commission is proposing a charge or fee for a special license to use radioisotopes. I have had a license to use small amounts of radioisotopes for seven years in high school experimentation. In that time I have taught scores of students proper handling and experimal use of radioisotopes. My fees charged would come out of my pocket, making it very difficult to continue research. A large user of radioisotopes or an institution can bear the cost of a fee , but I as a teacher would be hard pr essed to pay. This would be a definite hardship to my teaching. Yours sincerely ,
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Weldon L. Wi t ters Iliology Department WSW:bkp DOCKETED OOAEC APR Ofltce ef the SecrnarJ Pub'!-; rrr 1f-ln~
D0.CKET NUMBER pR*JIJ,'flJ, 'JO, PR0P.0SED RULE 7D, / 7O "rttysburg Qtnllrgr GETTYSBURG PENNSYLVANIA DEPARTMENT OF PHYSICS April 4, 1967 Secretary, U. S. Atomic Energy Commission Washington, D. C., 20545
Dear Sir:
With regard to the proposed fee for licenses, am I correct in reading this to mean that we would be charged $25 .00/year for the license covering our 1 curie Pu-Be neutron source? Thank you. Yours truly, ~
~~~'µvv, J. Richard Haskins Acting Chairman Department of Physics JRH/drc cc: Mr . Hoffman .,.
6 1967 ff lee. of the Secretary ubl1c Proceedings Br
RECEIVED 1967 APR 6 M1 11 I 4 U.S.l\ TOMI C ENERGYCOM. ,. rt-:::GUl. fJ OR Y MAIL & fiECOI\OS SECTION 4
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~PR 5 \967 "C7 Atomic Energy Commission Washington, D. C. 20545 Re : Doc ket No. 50-280 & 50-281 Attention : Mr. Peter A. Morris Director Division of Reactor Licensing Gentlemen : Your letter of March 27, 1967 , transmitting a copy of a Notice of Proposed Rule Ma k ing concerning license fees, has been received and is presently being reviewed. Our comments, if any , will be submitted at a later date. Your thoughtfulness in sending us this information is appreciated. Very truly yours , Vice President
REC EIVED 1967 APR 4 P.1 4 I 9 U.S.t.. T0MI C ENERGY CO>11
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{QEsT VI. NIA f,cIENCE ltjEAc- :as tl[ssocIATION A Sectio n of the We st Vi rginia Educa t i o n Assoc i a t io n
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Ll oyd G. Far i nash , Jr . 407 - 31 st Street Burnsville , W. V&. Vien na , We st Vi rg i n ia 26 10 1 Ma rch 30 , 1967 VICE PRES IDENT: Ge rl a nda V. Ama t o Box 105 Pemb e rt on , West Virg ini a 25905 EXECUTIVE SECRETARY - TREASURER: Rosa Cr a ig Box 775 Weston , West Vi rg inia 26452 Mr . H rold L. Price Dir e c tor of Regul a tion USAEC , Wa shing ton , D. C. 20545 De r Sir: Th nk you for y our n o tice to me of t h e pr opose d ru l e mak ing on licen se fe e s , a nd the in:ttit a. t i on to submit commen ts. I am not sure to wha t ext en t t his concerns me, si n ce I use my licenses on l y to te a c h s t ud ents b e g inn i n g r a d iati on study nd Civil Def ense Ra dia tion work . But if this d oes concern thi s field I c n only s y : I obtained my educ a t i on for t he pul?P o se o f diffusing inform tion to th e g ener 1 public who for the mo s t part will ~ e t it in no othe r wa y . To buy t h e isotope t cur r e nt pri c es , sinc e I no l onger r e c ei v e e non- lic ensed mounts fr ee from the g ov e r nment , uses 1 1 my fr ee c sh . If d d itiona l lic en e f~e r e t o b e 1 id up on p eop l e who re only pe rforming p ublic servic e with n o fin nci a l r emun er tion forsuch work , I sh a l l b e forc e d to let my licens e l a pse , a nd con s equently re si r n as r adi tion offic e r , ihich will lia v e t ha t re with no off i cer , for no one e l e h a s bothe r ed t o del v e d e eply into the prob l em in t h is are , or se ems inte r e sted in do i n g so . Sorry , but t ha t is t hew y i t is . As a singl e pe rs on , I p ya hi gh e r percent g e of fede r a l t x t h n f mily pe ople s i t is , with out p aying fu r the r for the p rivi l e ge of s e rving . Re sp ectfully your s , Cr a i g (1 I I
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Mr. Harold L. Price Director of Regulation United States Atomic Energy Commi Washington, D. C. 20545
SUBJECT:
Proposed Fees for Facility and Materials Licenses
Dear Sir:
Your letter of 13 March 1967 relative to the above matter has been received. It is our understanding that Section 170.11 of the proposed rules exempts Oregon State University from any fee payments since the University is a non-profit educational institution and is a party to a research reactor assistance contract with the Atomic Energy Commission. This contract is numbered AT(45 - 11) - 1953 and was entered into as of 3 March 1967. In addition to the above contract which supports the new TRIGA Mark II Reactor (License R-106) recently installed on the University campus, we operate a second reactor licensed as No. R-51. We assume that both of these facilities would be exempt. Your confirmation would be appreciated. Very truly yours, C. H. Blumenfeld Assistant to Director of Business Affairs CHB/hg cc: Hugh F. Jeffrey Chih Wang
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BARTON R. YOUNG, M.D. ROBERT B. FUNCH, M.D. JAY W. MAcMORAN, M.D. ROBERT A. BERNHARD, M.D. DEPARTMENT OF RADIOLOGY GERMANTOWN HOSPITAL PHILADELPHIA 44, PA. '\'\'ELLAND F. SHORT, M. D . RADIATION THERAPY AND ISOTOP ES ROBERT C. FRIED::.\fAN, ~I. D, JANET A. PARKER, M.D. MARYS, STRA:SG, M. D. April 3, 1967 Mr. w. B. McCool, Secretary U.S. Atomic Energy Commission Washington, D. C. 20545
Dear Mr. McCool:
It does not seem reasonable to me for the AEC to establish fees for its facility and material licenses because large sums of money are made available to the Commission yearly by our government. Establishment of license fees is another assessment by government and a form of regulation that is not warranted in my opinion. It is not clear to me whether a license must be obtained for each material that is being used, but obviously, if there are multiple licenses, the cost to a medical facility such as ours will be considerable. It is true that large companies will be able to pay the fees but the cost will be passed along to the public and the latter is already burdened heavily by taxes. Is not licensing just another tax? You can be sure that many of us have the utmost regard for the Commission's achievements in making available atomic energy for medical purposes, but I feel sure that all will share with me resentment if fees are charged for licenses. Very truly yours, r!?J~*rAr~1' Barton R. Young/ M. D. BRY/cmk
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Dear Sir:
This is to conment on the Atomic Energy Commission's proposed licensing fees as published in the Federal Register, March 11, 1967. We feel it is inappropriate for the Federal Government to charge non-profit educational institutions a fee to use radio-active materials. A large portion of our research funds are derived from Federal Grants and most of our instructional funds are from State appropriations. It would, therefore, appear that if your proposed licensing fees were adopted, institutions such as ours would pay them largely with either Federal or State monies. The diversion of any instructional or research funds is most undesirable, and this is particularly so in the present period of rapid expansion of the demand for a college education. We, therefore, register our disapproval of your proposed fee system if it is to be applied to those institutions, such as w Rutgers, who are engaged in non-profit educational programs . incerel t ohn L. Swink ice President and Treasurer
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Springfield, Illinois 62701 SPRINGFIELD March 31, 1967 Secretary United States Atomic Energy Commission Washington, D. c. 20545
Dear Mr. Secretary:
In response to a letter dated March 13, 1967 from Mr. Harold L. Price, Director of Regulation, in which the establishment of fees for AEC Licensees was proposed, we would like to offer our opinion for your consideration. We feel that the establishment of fees would be ill advised because the fees collected would probably not pay the cost of administering the program and collecting the fees, and, in the final analysis, would only serve to increase the cost to the patient. For this reason we would like to be on record as being opposed to the establish-ment of the proposed fee schedule. Respectfully submitted,
~~/.~
William L. Boyd Assistant Administrator WLB:st DOCKETED IISiAEG
UTAH RESEARCH & DEVELOPMENT CO., INC. 1820 SOUTH IN DUSTR IAL ROAD
SALT LAKE CITY, U T A H ~ 486-1301 29 March 1967 8ubridicrrv af f++l'E-R91',llc'l' E-E N-0-tl'+EE-RI-N6 ee-PtP01'1~
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Secretary U. S. Atomic Energy Commission Washington, D.C. 20545 Gentlemen: In response to your letter enclosing a copy of the Notice of Proposed Rule Making proposing the establishment of license fees for facility construction permits and operating licenses I we wish to submit the following comments for your consideration. We would be quite willing to pay a $100. 00 license fee should we get in 100 1 000 curies; however, $25 .00 seems high for a fraction of a curie in tracers and instrument calibra - tion sources. We suggest that a simpler, and hopefully free, lice nse system be maintained for sources which are just barely strong enough to require licensing at all. At present, the transition from no license required to procedures appropriate for licensing really dangerous objects is abrupt. Sincerely, UTAH RESEARCH & DEVELOPMENT CO., INC. William H. Clark Physicist WHC:fb OCKETED IJS!AEC 4 1967 Office of the Secretary Public Proc-)~ ilfS
CIVIL DEFENSE DEPARTMENT m*~K.~~ 44 Dunham St. PITTTSFIELD , MASSACHU S ETTS 01201 WILLIAM H . COONEY D I RECTOR March 31, 1967
Subject:
Proposed License Fees For Byproduct Material Secretary U.S . Atomic Energy Connnission Washington, D. C. 20545
Dear Sir:
With reference to the proposed Part 170 of Title 10, Code of Federal Regu-lations, we reconnnend that state, sector, and local Civil Defense Agencies be exempted from the requirement to pay application fees, license fees or annual fees for the receipt, ownership, possession, or use of byproduct material. Many Civil Defense Agencies use byproduct materials for the training of radiological monitors, and as internal calibration sources for remote area mon-itors. The Pittsfield Civil Defense Department, for example, owns a Victoreen Model A717A Gamma Sensing Element which is mounted on the outside of our C-D headquarters building. This permits us to monitor outdoor dose rates as high as 1000 R/hr. without exposing any of our monitors to the damaging effects of radiation. The ionization chamber is provided with a one millicure sealed source of Sr 90, which is used for calibrating the survey meter. As you undoubtedly realize, most local Civil Defense agencies operate on a very limited budget . Funds are not easy to obtain, and are never large enough to cover all needs. Any funds expended on license fees must therefore be di-verted from other budgetary needs. Under the circumstances, the imposition of application and license fees could have the effect of discouraging local civil defense departments from strengthening their defenses against fallout at a time when the federal government is attempting to improve these capabilities. It is our opinion that exempt ing all civil defense agencies from the re-quirements of the proposed Part 170 of 10 CFR would be in the public interest. Yours very truly, OCKETED IJS!AEC Paul F. Ast 4 1967 Radiological Consultant fffce of the Secretary /c Pullllc Prr.c* .1hs,
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TELEPHONE 247-9536 March 29, 1967 Secretary U. s. Atomic Energy Commission Washington, D.C. 20545
Dear Sir:
With reference to your proposed operating licenses fee under 10 CFR Parts 30, 40, 50, and 70, dated March 11, 1967, it is requested that exemption be granted to Civil Defense activities for t heir use of source material consisting of (1) CDV-784 Radiation Training Source Set with 6 5.0 me Cobalt 60 Sealed Sources . These Civil Defense Sources are used for public demonstrations and teaching activiti es and are con-sidered essential to this Government sponsored program.
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Col. USAF (Rtd.) Director, Civil Defense DOCKETED USAEC
DOCT(ET rW MBE.R PR 3a.lltJ, so. RROP.OSED RULE - 1t>, '10 au JOHN w. HURST, M. D. BLAIR MEDICAL CENTER 501 HOWARD AVENUE ALTOONA , PA. 16601 OFFICE HOURS BY APP01NTMENT TELEPHONE 943-8682 March 31, 1967 Sec r etary United States Atomic Energy Commission Was h ington, D. C. Gentlemen: Concerning the memorandum dated March 13, 1967, notice to A.E. C. Licenses concerning the proposed rule-making of license fees, I would be against the idea of annual fee system of any type. I can see the necessity of an application fee but not the annual fees. Sincerely yours, OCKETED USAEC n ~Hurst, M. D. APR 3 1967 Offtce of tile Secretary Pubtlc Proceedings JWH/tl
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- PROP.OSED RU LE 76 ,170 Education for Service CENTRAL MISSOURI STATE COLLEGE WARRENSBURG, MISSOURI 64093 March 30 , 1967 DOCKETED Secretary USl.4EC u.s. Atomic Energy Commission Washington, D.C. 20545 Re s Proposed License Fees, 32 F.R. 3995
Dear Sir :
I am in full sympathy with the current push to require users of federal services to pay for such services , pro-vided the tax payer ' s contributions are correspondingly reducBd . It seems , however , a bit much that a professor should pay twenty-five dollars per year for the privilege of using maybe two to five millicuries of one radioisotope in his research . This is particularly objectionable when the whole process of procurement and use is a trans - action between a private supplier and an individual . To repeat , I have no object i on to paying for services rendered , but in this ca se , what services? Bulk mailings of a half-dozen copies of inapplicable , unnecessary reg-ulations each year? The few minutes it takes a clerk-typist to fill in a renewal endorsement every other year? A once-in-a-blue-moon health physics inspection that is likewise unnecessary, and is unlikely to be conducted at all at an institution where one person is using tiny amounts of material? Finally , are your appropriations from general taxes to be reduced to match the income you anticipate from this new tax? If not , what ' s the purpose , other than to fatten your swollen bureaucratic till and broaden your empire? Not-;;/~ e M. Hopping, Ph . D. Assistant Professor of cc , Hon . William -J. Randall Chemistry M. C. from Missouri
- OwENs-lLLIN01s TECHNICAL CENTER - 1700 N. WESTWOOD 70,) 170 POST OFFICE BOX 1035 (D TOLEDO, OHIO 43601 ConPOIIATE RESEARCH March 30-, 196 7 OCKETED USiAEC The Secretary U.S. Atomic Energy Commission 3 1967 Washington, D. C., 20545 Oftiee of the Sew!*r:,
Public Pr~~ * * : s
Subject:
Notice of Proposed Rule Making published by the Commission in the Federal Register March 11, 1967, 32 F.R. 3995, proposing the establishment of license fees for facility construction permits and operating licenses issued under 10 CFR Part 50 and for specific byproduct source, and special nuclear materials licenses issued under 10 CFR Parts 30, 32-35, 40, and 70.
Dear Sir:
With reference to the proposed establishment of fees as described above, we wish to express our objections to this proposal. We consider that neither research nor industrial activities should require paid licensing from a Federal Agency whether the activities involve the use of radioactive materials or any other type of raw-material or product. Very truly yours,
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K. F. Spor~k KFS/jmc J
I DEPARTMENT OF THE ARMY UNITED STATES MILITARY ACADEMY WEST POINT, NEW YORK 10996 MADN-H Secretary U. S. Atomic Energy Commission Washington, D. C. 20545
Dear* Sir:
The United States Military Academy has the following material on loan from the Atomic Energy Commission for educational and training purposes (see Inclosure 1):
a. Twenty-five hundred (2500) kilograms of natural uranium as metal slugs canned in aluminum (License SUD-311).

b. Eighty (80) grams of plutonium as five (5) one-curie pluton-ium-beryllium neutron sources (License SNM-406).
Regarding your March 13 Notice of Proposed Rule Making con-cerning the establishment of license fees, our interpretation is that we would be exempt from payment of any fees under provisions of proposed paragraph 170, ll(a)( 4). Please confirm our interpretation. Sincerely, 1 Incl DONALD L. GEER Cy ltr 21Oct6 0 Colonel, AGC Adjutant General cc: DCSLOG D/ A Attn: Chief, PEMA Execution Div
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HARRISBURG , PENNSYLVANIA l'(/05 29 IARCH 67 Secretary, U.S . Atomic Energy Commission Washington , D.C. 20545
Dear Gentlemen:
This is an appeal to exclude nonprofit hospitals from paying an annual renewal fee We have a fairly active Isotopes De artment here at the Harrisburg Polyclinic Hospital and yet I am reminded by my hospital administrator that the Isotopes Department runs at a great loss financially. I think the annual fee will only add to the financial burden that an Isotope De artment of a community nonprofit hos ital must carry. I see no reason why a community hospital should not be pl aced in the same category as a university teaching center since we train our own isoto es technicans and have a formal course presented each year ~1ich is available to the interested Radiologic technicans in the area. Thank you for allowing me to comment on the Federal Register article of March 11, 1967, 32 F . R. 3995. Sincerely yours, Milton A. Friedlander, M. D . Chief Division of adiotherapy Harrisburg Polyclinic Hospital IAF sl
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DOCKET NUr,rnrn pR-Jfl/; PR0P.0SED RULE.__ _ _ _ Towson Baltimore Maryland 21204 VICE PRESIDENT-FINANCES GOUCHER COLLEGE 29 March 1967 Director of Regulation U.S. Atomic Energy Commission License Number 19-04740-01 Washington, D. C. 20545
Dear Sir:
A copy of your notice to Atomic Energy Commission licensees has been received and sent to the member of our faculty who is responsible for the use of radioactive material. The College currently uses for teaching purposes approximately $.13 worth of P32 . Will our license be sub.ject to the proposed fees and, if so, would we be eligible to apply for an exemption under section 170.11 (b)? DOCKETED USIAEC
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Phone 433-3371 IYlarch 28, 1967 IYl r. Harold L. Price, Director ofRegulation Atomic Energy Commission Washington, D.C. 20545
SUBJECT:
Your letter of 3/13/67 re: Establishment of license fees for Nuclear Sources Gent le men: We feel that if such a program were instituted it would work a hardship on ourselves and our customers. We are merely sales agents for a firm (The Ohmart Corp.) that manufactures industrial nuclear gauges for process measurement and control. So many of our customers in this area are comparatively small operators. This would make it more difficult to sell the gauges, and it would penalize the small users of such instruments. We surely hope that the proposed fee establishment will not be adopted. Sincerely, EQUIP IYIENT SPECIALTI ES CO . DOCKETED IJSIAEC RJC:ej
DOCKET NUMBER P.R0P.0SED RULE STATE OF NEVADA DEPARTMENT OF HIGHWAYS PR A,qo,'3'o,
, , l'/O DIRECTORS PAUL LAXAL T, GOVERNOR , CHAIRMAN HARVEY DICKERSON, ATTORNEY GENERAL WILSON MCGOWAN , STATE CONTROLLER URSON CITY, NEVADA 8970I ADDRESS ALL COMMUNICATIONS TO JOHN E. BAWDEN STATE HIGHWAY ENGINEER IN REPLY REFER TO SUBJECT March 28, 1967 Communications 940.25 r
Secretary U.S. Atomic En§rgy Commission Washington, D. C. 20545 L
Dear Mr. Secretary:
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DOCKET NUMBER PR ,o,tf.O, 50, fl.ROP.OSED RULE .. 7S, tzo AMERICAN NUCLEAR CORPORATION box 426 oo k ridge, tennessee phone 457-1234 March 29, 1967 OCKETED U. S. Atomic Energy Commission IJS!AEC Washington, D. C. 20545 AR 311967
Attention: Secretary
Dear Sir:
I have seen in Vol. 13 - No. 11, Atomic Energy Clearing House, the proposed Schedule of Licensing Fees, and would like to offer the following comments: While atomic energy as an industry has been growing in applications, knowledge, and participants for a number of years, it is still virtually a babe-in-the - woods * . . an infant when compared to all other major industrial efforts. As the industrial consumers' requirements change on a day-to-day basis, the nuclear oriented manufacturer, likewise, must be in a position to meet the changing needs of present and potential customers. For this reason isotopic containment capsules, source configurations, 'in-house' supply of isotopes, etc., will vary greatly as the industry developes new techniques, applications, and operating procedures. These changes require a great outlay of capital for Engineering and Research & Development on the part of the industrial manufacturer and contributes to the fact that the nuclear industry is not yet overall profitable to nongovernmentally supported companies. For this reason I do not approve of the proposed Schedule of Licensing Fees since I feel it will impose additional costs at a time when capital is most needed for growth and development of the industry. Further, I feel that some of the potential users of isotopes (many of the small, privately owned companies) will be discouraged from participating in an industry that has, although new, installed a program requiring fees additional to the already heavy burden of operating costs. This will hold particularly true of the small company who is interested in only a 11 trial run 11 of a nuclear process. The AEC has certainly done an excellent job in promoting the use of atomic energy and educating the public in the many benefits to
USAEC, - cretary - March 29, 1967 be derived from this new and exciting discovery. I do hope, however, that you r Commission will at least delay any form of fee installation until the nuclear industry is more accepted by the mass of industry that forms our Nation's economy, and until the nuclear industry - itself - is better established as a profitable network. Sincerely, AMERICAN NUCLEAR CORPORATION K. Wayne Graybeal \ President KWG:bc
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7!>, l?D Croswell-Lexington Community Schools Croswell, Michigan 48422 March 29, 1967 H. L. Price Director of Regulation US.At omic Energy Commission Washington, D.C. 20545 Dear Mr.fi.~
This is to be considered a constnuctive critieism of the proposed license registration and renewal fees, as invited by your recent notice . Our school system inaugurated a unit in radioisotope studies this year, and we obtained a license for a small uantity of P-J2 and I-lJl, for which we are paying 50.00 (approximately). Under the proposed fee system, as I understand it), we would be required to pay no initial registration fee, but would need an annual permit for which we would be charged $25.00. This is 'half what we pay for the isotopes. Our studies are for education~l purposes: training secondary school people in the properties and uses of this n~w area , but our budget is limited (as are most secondary school budgets). I would like to suggest, as an alternative, the payment of this fe e by NDEA to those schools whose budgets are limited; or perhaps setting a minimum value for the isotopes before the fee would be required, for it seems to me that a $25 .00 fee for $ 50.00 worth of isotopes is somewhat excessive. Thankk for the opportunity to express my opinion. DOCKETED '~ IJSi.A EC reeland teacher AR 311967 Office of file SecretaJJ Pl:blic *rnee"'11~gs
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STATE OF MARYLAND CIVIL DEFENSE AGENCY PIKESVILLE 21208 March 29, 1967 Secretary
u. s. Atomic Energy Commission Washington, D. c. 20545
Dear Sir:
Reference your Notice to .AEC Licensees, dated March 13, 1967, enclosing an extract from the Federal Register. Several political subdivisions in Maryland hold AEC licenses solely to support the Civil Defense Radiological Training Program. Making it mandatory to pay a fee to train volunteers would be a detriment to our Radiological Monitoring Program as well as Civil Defense in general. Therefore it is recommended that Section 170.11 of the pro-posed rule be changed to include licenses of sources used in radiological training in Civil Defense. Sincerely, Director
DOGf:ET NUM Brn n 34 L/(J, 5C P.ROP.OSED RULE i f\- 'lo , C70 Manufacturer, of : Powder Metal Pa r ts and Bear i n&s Carbo n and Me t al-Graph i te Brushes and Contacts Ne&at i ve Temperature Coefficient March 28, 1967 Resistance Un i ts United States Atomic Energy Commission Washington, D. C. 20545 Attention: Mr . Harold L. Price, Director of Regulation
Dear Mr . Price:
We received your notice to AEC Licensees of March 13, 1967, and would like to submit our comments which were invited with your notice . We can be very brief in our statements . If the fees mentioned in para.graph 170 . 31 listed on page 399'7 are put into effect, nearly all our applications of radioactive isotopes would be discontinued . Our work is such that we don't use these radioactive isotopes continuously but more on a standby basis . Therefore, long periods of time elapse when they are idle . Under these conditions we would look for competitive methods eliminating the use of radioactive isotopes because they would be more economical with the new fees. In other words, the purpose of the fees to "foster the development of nuclear energy" would be defeated . Very truly yours , KEr;:,;;ON C@Afrf~3/4, ocHTEU USAEC H.B . Sachse 1 AR311967 Research Director Ottlce of the secretary HBS/ecp ~blic Frocs~~lngs
F O UND E D 18~9 av KING KAMEHAM E HA IV ANO QU li: EN EMMA DIRECTORS DIRECTORS MRS . J . P . COOKE E. E. BLACK , PRESIDENT J . GARNER ANTHONY . VICE PRESIDENT A . L. Y. WARD , VICE PRES I DENT {foe f uttn 's MospHal CARTER GALT DO U GLASS . GUI LD MRS . C . J . HASTERT ALLEN C. WILCOX , JR . , VICE PRESIDENT KENNETH R . NU~SE , SECRETARY Jfonolulu 3, Jlamaii A , J , HEB E RT WILLIAM C . K EA WILLIAM E . AULL P . 0 . B OX 861 MRS . HAL LEW I S NATHAN F . BANFIELD , 3RD K. J.LUKE MORTON E . BERK. M . D . MALCOL"wi MAC NAUGHTON KE.NNETH F . BROWN MRS.T. W.C A RPENTER March 28, 1967 MASAJ I MARUMOTO ALEX SMITH M . B . CARSON Secretary United States Atomic Energy Conmission Washington, D. C. 20545
Reference:
Proposed License Fee for AEC Licensees
Dear Sir:
I wish to protest the proposal for the estal:iishment of license fees for the use of biproduct material as published in the Federal Register, March 11, 1967, pgs. 3995 to 3997. As I interpret the proposal, this would include licenses held by physicians for diagnosis and treatment of patients. The regulations would deter the use of byproduct material in medical applications particularly among young physicians just completing their training. It is this group of physicians who should be particularly encouraged to become licensed and take an active part in the extending field of nuclear medicine. The regulations would also deter physicians like myself who do not use isotope daily but who maintain an active interest and proficiency in nuclear medicine. I think there is a parallel in the internal revenue license fees for the use of narcotics in medicine. There is a license fee for commercial users but for medical use by physicians, the fee is kept at a nominal $1.00 RRK:en cc: Honorable Patsy Mink CKE J Honorable Spark Matsunaga USl; Honorable Hiram Fong Honorable Daniel K. Inouye AR 31 1967
00C1(ET NUMBERPR - 3eJ,'-W,S~, P.R0P.0SED RULE ']fJ, f 70 1400 South Luna Las Cruces, New Mexico 88001 27 March 1967 Secretary U.S. Atomic Energy Commission Washington, D.C., 20545 Gentlemen: With reference to the proposed rule wherein the policy of the Atomic Energy Commission is to be changed to provide for fees for certain licenses (10 CFR, Parts 10, 40, 50, 70, 170) . In your preamble to this proposed rule you stated" * *
which it believes to be reasonable and compatible with the Commission's responsibility for fostering the developnent of nuclear energy." I can't see how placing a $25 annual fee on Civil Defense volunteer radiological monitor instructors can help this cause.
Many Civil Defense radiological monitor instructors have taken on this work because of a sense of civic responsibility. I believe that if you cause them to pay $25 of their hard-earned money (none of which comes from Civil Defense), they will decide to let someone wealthier take on this job. Unfortunately, it is not the wealthy who generally have this sense of civic duty. If your reason in starting this fee system is an attempt to help pay for the administrative work, I might suggest a better scheme; at least as far as Civil Defense Radiological Monitor Instructors are concerned. Care-fully check each renewal for the license with the previous one for active participation in the Civil Defense Radiological Monitor Training Program. If the application shows no activity (item 9) for that year, charge them the $25 fee. After all, if there is no activity, your administrative work should be paid by those individuals who are not making effective use of your services. You might wish to be even more explicit in confirming the monitor training other than by appropriate entries in item 9 of the license application. This could be done by checking with the appropriate State Civil Defense Director or Radiological Defense Officer. Further, AEC regulations require that each Monitor Instructor maintain records of radi-ation received by each student he has trained. These records could be used for verification of training at the time of annual inspection by your Division of Compliance. DOCKETED USA£~
27 March 1967 I would propose that section 170.11 be modified to exempt all Civil Defense Radiological Monitors having licenses for Sealed Source Sets (CD V-778 Radiation Training Source Set) who indicate additional training during each year. I will appreciate your considering exempting qualified AND ACTIVE Civil Defense Radiological Monitor Instructors from your proposed fee system. Yours sincerely,
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CHARIES E. O'MEARA AEC License 30-11050-1 (F67) 2
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March 23, 1967 Mr. Harold Price Director of Regulations U. S. Atomic Energy Commission Washington, D. C. 20545
Dear Mr. Price:
In your March 13, 1967 letter you asked for comments regarding a proposed new license fee for facility con-struction and operating licenses. Our license is for, and probably will always be limited to, gas chromatographic equipment. For our tritium-coated foil used in the Argon ionization detector, we presume our category would be #1 with a license fee of $25.00 annually. Our Argon detector cost $225 (1967 quotation) and the tritium-coated foil cost $42.50 when purchased. The proposed annual license fee seems exorbitant for $300 worth of equipment. Very truly yours,
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J i/ M. Van Lanen JMVL:hd Director of Research cc: Dr. L. Stone DOCKEHD U$AEG
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(201) 442-3700 Department of Laboratories H. C . Pribor, M.D ._ Ph .D. Director S. M. Becker, M.D. W. R. Kirkham , M.D., Ph.D. Marvin Shuster, M.D. William Wilentz, M.D . March 27, 1967 J ames D. Hamm , Ph .D. W. Kozub, M.S. N. Cram, B.S. (Elect. Eng r.) Ldbordtory Manager Secretary U.S. ATOMIC ENERGY COMMISSION Washington, D.C. 20545
Dear Sir:
Permit me to register my objection to the establishment of license fees for atomic energy byproducts. As you know, many or most facilities utilizing these products do so at a financial sacrifice in order to extend these diagnostic agents to patient care. The licensing fee would only add to the hospital deficits. Thank you. Very truly yours, Marvin Shuster, M.D. MS:jt
, .... . ~ *( ,r, ~ Y3 4 c) 4 Y0 I -{ 70 -t-l?V .. " , .. *-J _L. ~~------- ~\!outing {ll:ffiil :!9efenst J\gtntg Cl!~euemu 28 March_, 1967 The Secretary U.S. Atomi.c Energy Commis.s.fon Washington, D.C. 20545 Dear Si.r ;
Reference i.s made to your Noti.ce to AEC Licensees of 13 March 1967 which. proposes. es.tabl i.s.hme.nt of li:ce.ns.e *fees..
rt your proposed change is corre.ctly foterpreted by thi.s. agency that those individuals or State Ci.vi:l De.fens.e Agenci.es., who are licens.ed to use the Office of Ci.v i l Defense Source Sets to train radi.ological moni.tors or cali.brate *OCD radiological

instruments, mus.t pay an annual licensi.ng fee ,
then th.e
Wyoming Civtl Defense Agency s.ta nds. oppos,ed to this proposal as concerns. Civil Defense Source Sets a~d Calibrators: *

W.e reason that training a group of volunte;ers. lo take certai_n actions duri.ng a nuclear attack th.at ts. in th_e publi_c interest as *well

as as.s.i.sti.ng w.ith. national s,urvival should not requi.re a fee to use public tools to accomplis.h thJ s. trai.ntng. More harm than good would come from s.uch action .
Instructors, i.n th.ts program would b.ecorne . . more. di.ffi.cult to procure. We agree witb the licensing program w.h.tch is. necessary for accountabi. l i.ty and pub li.c safety , however we do not agre.e w.i.th l evyi.ng fees. for OCD Source Set and OCD Calibrator l i censing. ** GOP /HAS/ jmw. c.c. Offi.ce of Ci. vi.l Defense, W.as.hi.ngton, D.C. Di.rector, Region Vl ; Denver, Colorado
DOCKETED 0$AEC MAR 30 1967~ 9 Office Pf !he Secretary l'ubftc Proc~~ings Branch Distribution : omal ft1 Suppl . tal ile ~'/ l~/77
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ALA M O ANA BUILDING i~~ :.,.{ : ~ :~:- : ., L ~l 7 t)I / 7 CJ 1441 KAPIOLANI BO ULEVARD HONOLULU , HAWAII 96814 March 25, 1967 Harold L. Price Director of Regulation U.S. Atomic Energy Comm.
Washington, ff.C. 29545
Dear Mr. Price :
I just received your MQrch 13, 1967 notice of proposed license fees and I could not help but feel caught in a web and feel that I was being taken advantage of, almost as though I might be dealing with charlatan. I'm sure you and the commission have no intent of this type of behavior but an impression of profiteering is immediately suggested. In my practive ~only portion dealing with your licensure eva-luation is that concerning a Strontium Bata-Ray applicator, a seal-ed source . An annual fee of $25.00 for the privilage of using this has no bearing on the economic value or degree of use, t he degree of supervision required, nor the evaluation of my application. I would personally consider any charge over and beyond $5.00 as most excessive. The Atomic Energy Commission as a whole has my sincere support. On the other hand monitory contributions in the past have been via federal tax and I see no reason why I should be required to support the committee's action over and beyond this merely because I make use of a strontium applicator GWH/ek DOCKETED OOAEC MAR301967 Office ot Ille Seeretay PuDl/c Praceedfngs Branch c..
RECElv-o b67 Ii~ 29 fiM 11 56 U.S.AT E CO . I ' . . MAIL u TION
WARTBURG DEPARTMENT OF PH YSICS A W Christian Lib era I Arfs - Founded 1852
DINSMORE INSTRUMENT COMPANY BOX 345 FLINT, MICHIGAN 48501 U.S. A. March 28, 1967
*Secretary, U.S. Atomic Energy Commission Washington, D. C. 20545 Gentlemen:
A 13 March notification from the Atomic Energy Commission, Harold L. Price, Director of Regulation, asks that any comments with regard to the proposed amendments for initiating a licensing fee be sent to this address. Our comments follow : We feel that since the Atomic Energy Commission is a division of the United States Government and is totally tax supported , that no license fees whatsoever should be initiated or charged by the Commission. The Commission itself was essentially set up as a Public Service Commission to guard and protect the welfare of the people of the United States from the misuse of and dangerous use of atomic energy materials. To make such a body , a tax collecting body as well adds a duty, considerable extra work, a much more massive payroll , and a function that does not properly belong to such a body. For the above reasons, we submit ~hat the addition of fees for such licenses and the collection of such fees should not be permitted to the Atomic Energy Commission . Very truly yours , DINSMORE INSTRUMENT COMPANY R. C . Dinsmore RCD/bw AREA 313 TELEPHONE 234 - 1605
PLANT LOCATION , 1814 REMELL STREET

MANUFACTURERS OF PRECISION INSTRUMENTS
WADDING - BATTING - MATTRESSES NON - WO V EN FABRICS
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.. DETROIT PITTSBURGH MILLS AND G ENERAL OFFICE S LOCKLAN D. CINCINNATI . OHIO 45215 March 28, 1967 Secretary U.S. Atomic Energy Commission Washington , D. C. 20545
Dear Sir:
We are opposed to the license fees proposed in your March 13, 1967 letter as we feel it would be detrimental to the industrial use of nuclear devices. Yours truly, TEARNS & FOSTER CO. C John C. Henning
~ /
Supt. Engineering & Maintenance JCH/ms DCKfTED US1AEC AR 3 0 1967 ALL AGREEMENTS ACCEPTED SUBJECT TO FIRES , S TR IK ES AND OTHER CONTINGENCIES BE YO ND OUR CONTROL . All quotations subj ec t to immedi ate acce ptance only.
COLORADO STATE !=""OR T COLLINS , COLORADO 80521 DEPARTMENT OF RADIOLOGY AND RADIATION BIOLOGY March 27, 1967 Secretary U. S. Atomic Energy Commission Washington, D . C. 20545
Dear Sir:
In regard to the proposal for facilities and materials license fees, the Section 170. 31 Category 1 fee would be somewhat restrictive for the small school where one or several small sources were used in laboratory demonstrations. I would suggest an initial fee of perhaps $25 to cover initial license issuanc e expense with renewal or amendment fees in the range of $5 to $10. Sincerely yours, Robert L. Watters, Ph. D., Chairman Radiation Safety Committee Colorado State University RLW:m ocKETE ustEC MAR 3 O 1967
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ST. PAUL, MINNESOTA 55101 221-2233 March Secretary U.S. Atomic Ehergy Commission Washington, D.C. 20545
Dear Sir:
This letter is in response to your NOl'ICE TO AEC LICENSEES dated March 13, 1967. The Minnesota Department of Civil Defense is opposed to the establishment of fees for licensure to possess and use Federal Office of Civil Defense radio active eo60 sources for Civil Defense training. Our reasons are as follows:
1. Licensees, recruited and trained over a period of fifteen years, are volunteers and not compensated for either qualifying for Byproduct Material License or for the training they themselves must receive.

2. Licensees are predominantly Science or Physics teachers norm.ally employed in the Secondary School Systems of the State. Their salaries are not com-parable to those paid people in industry or Federal Government.

3. The majority of Licensees maintain their eligibility only to be able to use the Cobalt 60 Source Sets ih conducting Civil Defense sponsored Radiological Monitor Training Courses. The majority of the instruc-tors are not compensated for this instruction.

4. Except where a single license hel d by a unit of government covers several users, the Licensee is commonly an individual.

5. Except for the large cities, the municipalities of the State will not and in many cases cannot legally s ecure such License.
I U.S. Atomic Energy Conuni.ssion March 28, 1967
6. The proposed Rule Making as set forth in your notice dated March 13, 1967, would in effect deny to the major portion of the State of ¥unnesota and its citizens the services of a licensed instructor to carry out the training required in the development of Local and State Radiological M.onitoring Systems.

7. The rule as proposed alludes to the development of Nuclear Energy. This does not apply to the develop-ment of Radiological Defense programs by units of local government in carrying out their Civil Defense responsibility in event of Nuclear War.
The Minnesota Department of Civil Defense hereby requests that exemption be granted from the fee payment requirements a: part 170 for licensees granted for use and possession of Co60 for Civil Defense Training purposes pursuant to 10 CFR JO. _Sincerely, 1 -7
. {/ tuL-t/
Aune Acting Director RVA.:F.SJ:c cc: OCDR-4
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R . .J . MARCOT T E. M . D . DIRECTO R March 28, 1967 OCl(E TED US!AEC AR 30 1967 fflce of the Secretary Secretary , ubllc Proc~~1l~gs U.S. Atomic Energy Commission, Washington , D. C. 20545
Dear Sir:
In regard to the U.S. AEC letter of March 13 , 1967 dealing with the establishment of licensing fees for users of byproduct materials, I submit the following comments: If one facet of the Commission's function is to promote the peaceful -uses of atomic energy , the charging of licensing fees opposes this function and tends to inhibit such uses. While one branch of the U.S. Government is publicly demon-strating great concern about the high cost of medical care , it is paradoxical that another branch should increase this cost further by initiating fees where none existed before. Any added cost of the hospital use of radioisotopes in diagnosis and therapy must be passed on to the patient. If the new Part 170 applies to pharma-ceutical processors of radioisotopes, then this will be additionally taxing since this inevitably will be reflected in increased cost of these products to the hospitals. On these grounds , I wish to register opposition fo the pro-posed Part 170. Very truly yours, Harold L. Chandler , M.D . Head, Radioisotope Unit, Mount Auburn Hos pital MEMBER CAMBRIDl3E COMMUNITY SERVICES SHARIN13 IN THE UNITED F'UND
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Area Code 717 March 27, 1967 Harold L. Price Director of Regulation Atomic Energy Commission Washington, D. o. 20545
Dear Mr. Price:
We have received your letter of March 13, 1967, in which you proposed to charge fees for the issuance of licenses, as well as the use of licenses, on an annual basis. while we are not opposed to the fee idea in principle, we are concerned about the addition of costs to our operating expenses. As you know, we compete with the European manufacturers in the manufacturing of watch dials; and, because of the labor costs in the United States as compared to those of foreign countries, we are already at a serious disadvantage, and any added costs just increase this disadvantage. I am under the assumption that our fee would be twenty-five dollars ( $ 25.00) per year; which, in itself, seems to be rather insignificant. we trust that you will take into consideration the problems of the domestic dial manufacturers when you set up your licensing fees. Yours very truly, Theo. R. Schwalm President TRS/tmw
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March 24, 196 7 Mr. Harold L. Price Director of Regulation
u. S, Atomic Energy Commission Washington, D, C. 20545
Dear Mr. Price:
I have just received your letter dated March 13, 1967, concerning the notice of proposed rule making and license fees for facility construction permits and operating licenses issued under 10 CFR Part 50, whatever this is. I just thought you might be inerested to know what an ordinary Radiologist's reaction is to your letter and to the ruling of the Atomic Energy Commission as published in the Federal Register, March 11, 1967. As an example, I would like to cite Part 170, under which are listed various numbers including section 170.1 entitled Purpose. If a relatively uninformed Radiologist such as myself reads paragraph 170.1 Purpose, I assure you that it means nothing. As an ordinary citizen and a taxpayer it would seem to me that such printing and explanations are entirely meaningless, and that if notices to AEC licensees are sent out, that perhaps some better or clearer explanation could be made. I know this letter sounds terribly sarcastic, but I just wanted you to know that for the ordinary individual receiving such a notice, at tax-payer's expense, certainly means little or nothing. I also realize that my inability to interpet the notice probably reflects on my poor intelligence, but I sincerely doubt if I am alone. Please forgive my personal remarks concerning your notice, I mean them only to be constructive if possible, so that any future notices might be more meaningful to me and others who may be just as unintelligent as I seem to be. ocHlE US1~EC HHR:gh AR 291967 Office o1 the secretary Public frO~e tngs
RECCiVEO 1967 MAR 28 PM '* I 6 U.S.A TGMIC ENERGY COMM. REG I I TORY . MAIL & *u;; ;; sc'CTION
\ A Department of the Municipal Government Evanston, Illinois LESTER C. BREITZMAN, Director MARTHA BAUMBERGER, Information Officer Fire Station #2 - 702 Madison Fire Station #1 - 909 Lake Street Phone: 475-7300 Phone: 475-3100 FALLOUT SHELTER March 23., l 9b7 Mr. Harold L. Price Di rector of Regulation
u. s. At©mic ERergy Conrnission Washimgron, o. c. 20545
Dear Sir:
Reference:
Your Notice to AEC Licensees. March 13, 1967 This office holds Byproduct Material License No. 12-9511-1* with Asst. Fire Marsl1lal Willard M. Thiel named as the Individual User. Present expiration date is September ":IJ, 1967. We would appreciate information as to whether or not a license of this type would be subject to the proposed license fee referred to in the March 13 Notice. Yours very truly,
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Martha K. Baumberger <::J c.0. I nfa-mation Officer otKE USAEC AR 291967 office of ttie SemtaJ'Y PubllC fro~* -*,, gs
LL c {1,. L(.S- 1 wy /z-£!,-ps DOCKET NUMBER PR 3 °1~ 0 1 :rv PROPOSED RULE 7 o, ! 7D WEST VIRGINIA METHODIST CONFERENCE HOSPITAL U . S. ROUTE 19 SOUTH P . O. DRAWER 1329 CLARKSBURG, WEST VIRGINIA ADMINISTRATION OFFICES March 28 , 1967 REPLY TO THE UNDERSIGNED
B. McCool Secretary Atomic Energy Commission Washington, D. C. 2054~
Dear Hr. McCool :
This is in reference to your notice to .AEC licensees dated 13 March, 1967 regarding the establishment of fees . J',zy" understanding is that relative to licensee the Atomic Energy Commission performs a service which is essentially one of protection to the public against contamination of various types by radioactive material . Since the services rendered primarily to the public rather than to the licensee, I feel that a fee imposed upon the licensee would not be justified . Revenues to maintain these functions of the Atomic Energy Commssion should come from general taxation or from the segment of the public that is particularly protected by the Atomic Energy Commission in this regard . If the Atomic Energy Commission is providing specific services to the licensee over and above those concerned with prdection of the public, then fees for these particularly services would be justified on an individual fee for service basis . Thank you very much for soliciting my opinion and for any consideration that you may give to it. Sincerely yours , f5,/~r1 ~
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~OSED RULE h- ?IJ_ ~ /70 MITCHELL, S. OAK. 57301 OTOLARYNGOLOGY AND OPHTHALMOLOGY OPHTHALMOLOGY 0 . J . MABEE, M. D. J . 0. MABEE , M. D.
March 24, 1967 rch 13, 1~7 Atomic Energy Commission Washington, D. c.
; published by
Dear Sirs:
!Stablishment operating How does this ruling apply to my status byproduct, under 10 CFR which involves only use and ownership of a strontium 90 applicator. for its ,e reasonable ,r fostering Si'l,cere ly, ,ut in a I / .,t,c..da.c? 1 (.; /l )n'2 ,/ / ~ l and 70 to tts also are .J udson o. Mabee , M. D. mt not to JOM:dk ~rsons. Upon CKETEo
eview and lJSiAEc ,posed amend-

his time.
'.4R 291957 the Federal fflce or th mts are made PqlJftr. f'r.*ec Secretary Bra* Uflffngs Ln connection Lting within , U.S. Atomic received after > do so, but
o comments 3 on the proposed
~nt Room, 1717 H ttaro.1a L * .t'rice Director of Regulation
Enclosure:
Notice of Proposed Rule Making on License Fees
. T tWMBER PR ](),II~ 5~
EROP.OSEl) RULE i' ... 1&.-i7o
IIIAEc PROPOSED RULE MAKING Ing license issuance fee and annual fee payable each year after issuance of the perating license. No separate fees ould be assessed for licensing of nuclear terial incidental to the operation of acilitv or for facility operator li-ses under 10 CFR Part 55. The filing
§ 40.31 (f) Each application for a source ma-terial license, other than a license ex-empted from Part 170 of this chapter, and other than an application for re-3995 Applica tion s for specific licenses.
newal or amendment of a license, shall would be payable in full at the time AR 291967 ling the application. Construction be accompanied by the fee prescribed in Part 170 of this chapter. fflce or the Secretary mit fees and operating license fees uld be payable when the first author- 3. Section 50.30 of 10 CFR P art 50 is Pubitc Proc~edtngs amended by adding a new paragraph (d) ation is received; i.e., the provisional onstruction permit or operating license. to read as follows: Annual fees would be payable 1 year § 50.30 Filing of applications for li-ATOMIC E after the issuance of any provisional operating license, or in the case of a censes, oath or affirmation. [ 10 CFR Parts 30, 40, , 170 l facility for which an operating license
has already been issued, 1 year after the (d) Filing fees. Each application for FACILITY AND MATERIALS LICENSES a production or utilization facility li-effective date of Part 170 and annually Proposed Fees thereafter. cense, including whenever appropriate, Materials license fees. Fees are pro- a construction permit, other than a li-The Atomic Energy Commission is posed for specific byproduct, source, cense exempted from Part 170 of this proposing to establish fees for facility and special nuclear materials licenses chapter, shall be accompanied by the fee construction permits and operating li- issued pursuant to 10 CPR Parts 30, prescribed in Part 170 of this chapter.
censes issued under 10 CFR Part 50 and 32-35, 40, and 70 . For new licenses, ap- No fee will be required to accompany an for specific byproduct, source, and spe- plication fees would be payable at the application for renewal, amendment or cial nuclear materials licenses issued time of filing of the application. An- termination of a construction permit or under 10 CFR Parts 30, 32-35, 40, and 70. nual fees would be payable 1 year after operating license, except as provided in The Commission is proposing the es- the issuance of the license, or in case § 170.21 of this chapter. tablishment of fees for its facility and of outstanding licenses, 1 year after the materials licenses which it believes to 4. Section 70.21 of 10 CPR Part 70 is effective date of Part 170 and annually amended by adding a new paragraph (f) be reasonable and compatible with the -thereafter. Exemptions are provided Commission's responsibility for fostering to read as follows: for licenses for material incidental to the the development of nuclear energy. The operation of a facility, as indicated § 70.21 Filing. fees are set out below in a proposed new above, for licenses for export or !,rnport Part 170. Amendments to Parts 30, 40, only of byproduct, source, or special nu- (f) Each application for a special nu-50, and 70 to reflect the proposed appli- clear materials and for certain licenses cation filing fee requirements are also clear material license, other than a li-held by educational institutions. cense exempted from Part 170 of this proposed. The fees would apply to Pursuant to the Atomic Energy Act of specific licenses but not to general chapter, and other than an applica-1954, as amended, and the Administra- tion for renewal or amendment of a licenses at the present time.' tive Procedure Act of 1946, as amended, The Commission is proposing applica- license, shall be accompanied by the fee notice is hereby given that adoption of prescribed in Part 170 of this chapter. tion filing fees, license issuance fees, and the following amendments of 10 CPR annual fees for both facility and ma- Parts 30, 40, 50, and 70 and of the fol- 5. Chapter I of Title 10 of the Code terials licenses. With respect to both lowing new 10 CFR Part 170 is contem- of Federal Regulations is amended by facility and materials licenses, if a single plated. All interested persons who de- adding a new Part 170 to read. as follows: application covers more than one facility, sire to submit written comments or or class of licensed material, only a single PART 170-FEES FOR FACILITIES AND suggestions in connection with the pro- MATERIALS LICENSED UNDER THE application fee need be paid. However, posed amendments and regulation if more than one license is issued in re- should send them to the Secretary, U.S. ATOMIC ENERGY ACT OF 1954, AS sponse to an application, the applicable Atomic Energy Commission, Washing- AMENDED fees for each license will be assessed. ton, D .C. 20545, within 60 days after License issuance and annual fees for GENERAL PROVISIONS publication of this notice in the FEDERAL Sec. both facilities and materials would be REGISTER. Comments received after 170.1 Purpose. deemed as assessed for licensing serv- that period will be considered If it is 170 .2 Scope. ices to be performed by the Commission practicable to do so, but assurance of 170.3 Definitions. and paid for at the beginning of the consideration cannot be given except as 170.4 Interpretations. year in which they are rendered. No 170.5 Communications. to comments flied within the period spec- 170.11 Exemptions. refunds would be made if the license ified. Coples of comments on the pro-terminates before the expiration of the 170.12 Payment or fees. posed rule may be examined at the Com-year. mission's Public Document Room at 1717 SCHEDULE OF FEES Facility license fees. Fees are pro- H Street NW., Washington, D.C. 170.21 Schedule or !ees for production and posed for all facility construction per- utilization facilities. mits and operating licenses under Part 1. Section 30.32 of 10 CFR Part 30 is 170.31 Schedule o! fees !or m aterials li-50 of the Commission's rules and regula- amended by adding a new paragraph (e) censes. tions, except for licenses to export to read as follows: ENFORCEMENT facilities and for certain licenses held § 30.32 Applications for specific licenses. by educational institutions. The follow- 170.41 Failure by licensee to pay annual ing types of fees would be required: (1) * *
fees .
A fee for filing an application for a (e) Each application for a byproduct AUTHORITY: The provisions of this Part 170 construction permit; (2) a construction material license, other than a license Issued under sec. 501, 65 Stat. 290; sec. 161, permit issuance fee, and (3) an operat- exempted from Part 170 of this chapter; 68 Stat. 948; 42 U.S.C. 2201. and other than an application for re- GENERAL PROVISIONS
, Specific licenses are Issued to named per- newal or amendment of a license, shall sons upon applications filed pursuant to the be accompanied by the fee prescribed in § 170.1 Purpose.
regulations in Parts 30, 32-36, 40, 50, and Part 170 of this chapter. 70 of this chapter. Genera.I licenses are The regulations in this part set out effective without the filing o! applications 2. Section 40.31 of 10 CFR P art 40 is fees charged for licensing services ren-with the Commission or the Issuance o! amended by adding a new paragraph (f) dered by the Atomic Energy Commission, licening documents to particular persons. to read as follows: as authorized under Title V of the In-
3996 dependent Offices Appropriation Act of 1952 (65 Stat. sec. 290), and provisions regarding their payment. § 170.2 Scope. Except for persons who apply for or hold the licenses -exempted in § 170.11, PROPOSED RULE MAKING facility as defined by paragraph (1) of this section. (h) "Sealed source" means any by-product material that is encased in a capsule designed to prevent leakage or escape of the byproduct material. (i) "Source material" means: (2) Any material artificially enriched by any of the foregoing, but does not in-clude source material. (k) "Special nuclear material in quantities sufficient to form a critical mass" means uranium enriched in the isotope U-235 in quantities in *e xcess of the regulations in this part apply to each (1) Uranium or thorium, or any com- 350 grams of contained U-235; uranium person who is an applicant for or holder bination thereof, in any physical or 233 in quantities in excess of 200 grams; of a specific license issued pursuant to chemical form or plutonium in quantities in excess of 200 Parts 30, 32-36, 40, 50, and 70 of this (2) Ores which contain by weight one- grams, or any combination of them in chapter. twentieth of 1 percent (0.05%) or more accordance with the following formula : § 170.3 Definitions. of (i) uranium, (ii) thorium, or (iii) any For each kind of special nuclear material, combination thereof. determine the ratio between the quan-As used in this part: tity of that special nuclear material and (al "Byproduct material" means any Source material does not include special nuclear material. the quantity specified above for the same radioactive material <except special nu-(j) "Special nuclear material" means: kind of special nuclear material. The clear material) yielded in or made radio-(1) Plutonium, uranium 233, uranium sum of such ratios for all kinds of spe-active by exposure to the radiation in-cident to the process of producing or enriched in the isotope 233 or in the iso- cial nuclear materials in combination utilizing special nuclear materials. tope 235, and any other material which the Commission, pursuant to the provi- shall not exceed unity. For example, the (bl "Materials license" means a by- following quantities in combination product material license issued pursuant sions of section 51 of the Act determines to Parts 30 and 32-36 of this chapter, to be special nuclear material but does would not exceed the limitation and are or a source material license issued pur- not include source material; or withiri the formula as follows: suant to Part 40 of this chapter, or a 175 (grams contained U-235) 50 (grams U-233) 50 (grams Pu) special nuclear materials license issued
350 + 200 + 200 pursuant to Par' 70 of this chapter.
(I) "Testing facility" means a nuclear Avenue, Bethesda, Md.; or at German-
<cl "Nuclear reactor" means an ap-paratus, other than an atomic weapon, reactor licensed by the Commission un- town, Md.
designed or used to sustain nuclear fis- der the authority of subsection 104 c. of sion in a self-supporting chain reaction. the Act and pursuant to the provisions § 170.11 Exemptions. (d) "Other production or utilization of § 50.21 (c) of this chapter for opera- (a) No application filing fees, license facility" means a facility other than a tion at: fees, or annual fees shall be required for: nuclear reactor licensed by the Commis- (1) A thermal power level in excess of (1) A license authorizing the export sion under the authority of sections 103 10 megawatts; or only of a production or utilization or 104 of the Atomic Energy Act of 1954, (2) A thermal power level in excess of facility; as amended (the Act) and pursuant
to 1 megawatt, if the reactor is to contain: (2) A license authorizing the export the provisions of Part 50 of this chapter. (i) A circulating loop through the core only or import only of byproduct m a -
<el "Power reactor" means a nuclear in which the applicant proposes to con- terial, source material or special nuclear reactor designed to produce electrical or duct fuel experiments; or material; heat energy licensed by the Commission (ii) A liquid fuel loading; or (3) A license authorizing the receipt, under the authority of section 103 or sub- (iii) An experimental facility in the ownership, possession, use or production section 104b. of the Act and pursuant core in excess of 16 square inches in of byproduct material, source material, to the provisions of § 50.21 (bl or § 50.22 cross-section. or special nuclear material incidental to of this chapter. (ml "Utilization facility" means any the operation of a production or utiliza-(fl "Production facility" means: nuclear reactor other than one designed tion facility licensed under Part 50 of (1) Any nuclear reactor designed or or used primarily for the formation of this chapter, including a license under used primarily for the formation of plu- plutonium or U-233 and any other equip- Part 70 of this chapter authorizing tonium or uranium 233; or ment or device determined by rule of possession and storage only of special (2) Any facility designed or used for the Commission to be a utilization facil- nuclear material at the site of a nuclear the separation of the isotopes of uranium ity within the purview of subsection 11 reactor for use as fuel in operation of cc. of the Act. the nuclear reactor or -at the site of a or the isotopes of plutonium, except laboratory scale facilities designed or (n) "Waste disposal license" means a spent fuel processing plant for processing used for experimental or analytical pur- license specifically authorizing the re- at the plant.
ceipt of waste byproduct material, !4) A construction permit or license poses only; or source material or special nuclear ma- applied for, or issued to, a nonprofit ed-(3) Any facility designed or used for terial from other persons for the purpose ucational institution, which shows itself the processing of irradiated materials of commercial disposal by land or sea to be, with respect to the material or containing special nuclear material, ex- burial. facility licensed or to be licensed, party cept (i) laboratory scale facilities de- to (i) a loan agreement administered by signed or used for experimental or ana- § 170.4 Interpretations. the Commission's Division of Nuclear Ed-lytical purposes, and (ii) facilities in Except as specifically authorized by the ucation and Training, or (ii) a university which the only special nuclear materials Commission in writing, no interpretation reactor assistance contract with the contained in the irradiated material to of the meaning of the regulations in this Commission. The exemption in this sub-be processed are uranium enrichel in the part by an officer or employee of the paragraph shall not apply to a construc-isotope U-235 and plutonium produced Commission other than a written in- tion permit or license for a facility or by the irradiation, if the material proc- terpretation by the General Counsel will material other than that referred to in essed contains not more than 10-*; grams be recognized to be binding upon the the loan agreement or university reactor of plutonium per gram of U-235 and has Commission. assistance contract. fission product activity not in excess of (b) The Commission may, upon appli-0.25 millicuries of fission products per § 170.5 Communications. cation by an interested person, or upon gram of U-235. All communications concerning the its own initiative, grant such exemptions (g ) "Research reactor" means a nu- regulations in this part should be ad- from the requirements of this part as it clear reactor licensed by the Commissio n dressed to the Director of Regulation, determines are authorized by law and under the authority of subsection 104 -~- U.S . Atomic Energy Commission, Wash- are otherwise in the public interest. of the Act and pursuant to the provisions ington, D.C. 20545. Communications of § 50.21 (c) of this chapter for opera- may be delivered in person at the Com- § 170.12 Payment of fees. tion at a thermal power level of 10 meg- mission's offices at 1717 H Street NW., <a) Application fees. Each applica-awatts or less, and which is not a testing Washington, D.C.; at 4915 St. Elmo tion for which a fee is prescribed in t-his
PRO POSED RULE MAKING 3997 part shall be accompanied by a remit- (c) A nnual f ees. Annual fees pre-tance in the full amount of the fee . No scribed in t his pa rt a re payable, in the application will be accepted for filing or
case of licenses outstanding on the effec-processed prior to payment of the tive date of this part, 1 year after the full amount specified. Applications for effective date of this part and annually which no remittance is received may be thereaft er. In the case of licenses is-returned to the applicant. All applica- sued after the effective date of this part, tion fees will be char ged irrespective of annual fees are payable 1 year after the the Commission's disposit ion of the da te of issuance of the license or pro-application or a withdrawal of the visional operating license, if any, which-application. ever is earlier, and annually thereafter.
( b) Construction permi t f ees and op- (d) M ethod of payment. Fee pay-erating license f ees. Fees for construc- ments shall be by check or money order tion permits and operating licenses are payable to the U.S. Atomic Energy payable when the provisional construc- Commission. tion permit or provisional operating SCHEDULE OF FEES license, if any, is issued. Otherwise, fees are payable when the construction § 170.21 Schedule of fees for production permit or operating license is issued. No and utilization facilities. provisional construction permit or pro- Applicants for construction permits or visional operating license, or construc- operating licenses for production or utili-tion permit or operating license, as the zation facilities and holders of construc-case may be, will be issued by the Com- tion permits or operating licenses for mission until the full amount of the fee production or utilization facilities shall prescribed in this part has been paid. pay the following fees : F ee for filing Operating F acility (thermal megawatt values refer to the maximum capacity ap- applicatio n for Construction license lee plied for or stated in the permit or license) 1 construction permit fee and an-permit nual lee (1) Power reactor: Up to1,000 Over 1,000toMw(t) 1,500 __ --- ---________ Mw(t) --------- ------ _______ _ $2,500 $12, 000 $1, 800 2,500 18, 000 2, 700 Over 1,500 Mw(t) ___ ____ __________ ___ ____ _______ ___ _______ ____ _ 2, 500 'Jfl,000 3,800 (2) T esting Up to facility : 15 Mw(t) __ _______ ______ ____________ _______ ___ _______ __ __ Over 15 Mw(t) ______ ____________ _________ __ ____ __ __ ___ _______ __ 800 2,000 700 800 3, 000 1,000 (3) R esearch Up toreactor: 1 Mw(t) ____ _________ ____ __________ __ ______ _______ __ ____ _ Over 1 to 5 Mw(t) ______ __ ______ ______________ __ __ _______ ______ _ 300 1,000 300 Over 5 Mw (t) ___________ ___________ ___ ____ ______ ___ ____ _______ _ 300 1, 500 400 300 2,000 500 (4) Other prod uction or ut!lization facility ____ ___ ______ __ ____ ________ __ 1,500 5,000 2,000 1 Amendments reducing capacity shall not entitle the applicant to a partial refund ol any lee; applications for amendments increasing capacity to a higher lee category wili not be accepted !or filing unless accompanied by the prescribed lee less the amount already paid,
§ 170.31 Schedule of fees for materials ENFORCEMENT licenses. § 170.41 Failure by licensee to pay an-Applicants for materials licenses and nua l fees.
holders of materials licenses shall pay In any case where the Commission the following fees: finds that a licensee has failed to pay the SCHEDULE or MATERIALS L ICENSE FEES applicable annual fee required in this part, the Commission may suspend or Category ol materials Application Annual lee revoke the license or may issue such license lee order with respect to licensed activities as the Commission determines to be ap-
1. All materials licenses propriate or necessary in order to carry other than licenses in categories 2, 3, 4, and out the provisions of this part, Parts 30, 5 1________ ___ __ ___ ___ None $25. 00 32-36, 40, 50, and 70 of this chapter
. 2. Licenses for byproduct material issued pur* and of the Act.
suant to 10 C FR (Sec. 161, 68 St at. 948; 42 U .S.C. 2201; sec. P art 33 or pursuant to an application de- 501, 65 St at. 290) scribed in ~35.11 (e) ol 10 CF R P art 35___ _ $100. 00 50. 00 Dated at Washington, D.C., this 8th
3. Licenses for byproduct day of March 1967.
m aterial ol 100,000 curies or more in For the Atomic Energy Commission. sealed sources used for irradiation of ma-terials ____ ____ ----- --- 500. 00 100. 00 W. B . McCOOL,
4. Licenses for special Secretary.
nuclear material in quanti ties su fficient [F.R . Doc. 67-2681 ; Flied, Mar. 10, 1967; to form a critical mass_ 300. 00 100. 00 8 :45 a .m .]
5. Waste disposal licenses specifically au thor-izing the receipt of w aste byproduct ma-terial , source material or special nuclear material from other persons for the pur-pose of commercial disposal sea burial__by ____
land______ or _ 500. 00 200. 00
- DOC~ET NUMBERpn 3{),1/tJ,SD, B.Ror.osE.D RULE K. 7e t 110 Maryland Office of Civil Defense County Office Building Area Code 301 Rockville, Maryland 20850 279-1251 March 23, 1967 CKETED IJ&JEC Secretary, AR 291967 US Atomic Energy Commission ttice _ot the secretary 111,c Procfadiffgs Washington, D.C . 20545
Dear Sir:
Reference is made to your notice to AEC Licenses, March 13, 1967, enclosing an extract from the Federal Register, March 11, 1967. While the proposed annual fee for category 1 type of materials license (Section 170.31) is relatively minor, I invite your attention to the fact that most local jurisdictions which hold such licenses for civil defense training purposes would find it inconvenient to pay a fee for renewal during the fiscal year immediately following adoption of the proposed rules. Their budgets are already, or will soon be, fixed and such budgets would not contain provision for license fees. Local jurisdictions, such as this county, hold licenses solely to support the civil defense radiological training program . We have no other radiological material or license for such material . A requirement to pay a fee for the purpose of training volunteers in radiological defense is inimical with the purpose and program of the whole civil defense program. This is to recommend that Section 170.ll(a) of the proposed rule be amended t o include licenses covering OCD radiation training source sets or commercial sources used in civil defense radiological training . Sincerely , 1/1#~ N. B. Wilson, Chief, Div . of Civil Defense
. CKET NUMBER PR-1D, '10, SO, . OP.OSED RULE \ '7()~ I~~
VETERANS ADMINISTRATION HOSPITAL LEXINGTON , KENTUCKY 40507 March 23, 1967 YOUR F I LE REFE RENCE : IN REPL Y REFER TO : 172
Mr. Harold L. Price Director of Regulation U.S. Atomic Energy Commission Washington, D.C. 20545
Dear Mr. Price:
Thank you for your Notice of Proposed Rule Making changes regarding A.E.C. licenses as published in the Federal Register 11 March 1967. I understand that these regulations do not now apply to our institution wiich is a nonprofit educational institution with an institutional license. In your request for comments, I would like to suggest that the annual fee schedule or renewal fee be changed from an annual basis to every two to five years to simplify bookkeeping. With kindest regards. OCKETED U&AEC SELBY, M. 0. adioi sotope MAR 291967 Office of the Secretary Public Proceedings Show veteran's /ult name and VA file number on all correspondence. If VA number is unknown, show service m,mber.
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DOCKET NU MBER po 30,tlO, 50, PROP.OSE.D RULE I\- ?IJ./-/7() KEITH J. SCHIAGER, PH.D. CERTIFIED HEALTH PHYSICIST 1321 LORY STREET , FORT COLLINS , COLO. 80521 (303) 484 - 0971 March 24, 196 7 Secretary U. S. Atomic Energy Commission Washington, D. C. 20545 Re : Facilities and Materials License Fees Gentlemen: After careful review of the proposed rule making pertaining to licensing fees, I would like to submit the following comments: The basic principle of charging fees for licensing services seems reasonable. Some of the proposed fee schedules appear to be disproportionate to the "services" (i.e. paper work rendered. For example, the bulk of the service is performed for new applications, with a lesser amount required for applications for amendments or renewals. The proposed schedule would require the same annual fee ($25) for a sealed cobalt-GO irradiator of less than 100,000 curies as for a specific byproduct material license of other types. The sealed source license, however, might require no amendments or renewals over a five year period, whereas a license for unsealed byproduct materials would require a renewal every two years, with any number of amendments possible between renewals. Therefore, over a period of several years, the same licensing fees would be assessed for both types of licenses even though one license may require several times more "service" than the other. The proposed fee schedule could be made more equitable if, instead of charging annual fees, an initial application fee was charged for each license and a smaller fee charged for amendments and renewals. For materials licenses in Category 1 of Section 170. 31 of the proposed rules, I would like to suggest an initial application fee of about $25 with a renewal or amendment fee of perhaps $15 . Fees for this category of licenses should be kept low so as not to discourage use of radioactive materials by small colleges, high schools and some individuals. Sincerely y ours, CKE ro ~kYL USiAEC Keith J. Schiager, Ph . D. '1R 291967 Health Physics Consultant ftlce or the Secret Ubl/c Proceedingsary KJS:smh lla.<iin.tion /1rotection consultation, an<l survc)is Gamma and X -my beam calibration Radiat ion sh ielding design certification Radioisotope sott1*ce leak testing
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WASHINGT O N AND LEE UNIVERSITY LEXINGTON. VIRGINIA, 244?1 0 DOCKETED DEPARTMENT OF PHYSICS IISAEC March 24, 1967 Mr. Harold L. Price Director of Regulation United States Atomic Energy Washington, D. c. 20545
Dear Mr. Price:
I welcome the opportunity to make a statement about the proposed A£C license fees. I represent a small physics de-partment which is trying to build up its educational and re-search facilities. At the present time we have a 2 curie plutonium-beryllium source which we use in a neutron howitzer for activation and neutron physics experiments for our nuclear physics course and for our elementary courses in physics and chemistry. I understand that the proposed license fee for this source would be 25 dollars annually. The department is presently building up its capacity to do research. We have a small grant which provides summer salary for faculty and student stipends for research work in the summer, when school is not in session. Much of my re-search experience has been in the field of nuclear spectro-scopy. It has been my hope that we could build up a small research program in the field of ganma- and beta-ray spec-troscopy. In addition I have done some work with the Mossbauer effect and am interested in the properties of low energy ganwna-ray transHions. In order to work in these fields it will i2 necessary for the department to be able to secure beta- and ga111na-ray emitters from time to time in greater-than-license-exempt quantities. Thus it will be necessary for us to secure a by-product license. This fee would be 100 dollars at the time of application and 50 dollars annually thereafter. While these amounts do not seem large in themselves they are a significant part of the budget of a small physics de-partment (1.5 % in our case). Unless the AEC wishes to limit the license holders to production facilities and big-time re-search groups with large budgets it seems ridiculous to im-pose this fee which probably will not cover the cost of ade-quate regulation and will seriously hamper the programs of small users of AEC licenses. Yours sincerely, W- ~ ~ W. Barlow Newbolt Assistant Professor of Physics
A DOCKET NUMBER <<pn 30.'/0,'>l), W, P.ROP.OSED RULE f\ - 18..-170 LANGSTON MEDICAL GROUP 1214 NORTH HUDSON STREET WANN LANGSTON. M . 0 . OKLAHOMA CITY 3 . OKLAHOMA GEORGE N. BARRY . M . 0. CAR D IOLOGY CARDIOLOG Y JOHN W . DEVORE . M . D . JAMES K . DEVORE . M. 0 . MeMATOLOGV GA.&TRO- NT ROLOGV JAMES A . LOWELL . M . 0 . ERf"rEST G . WARNER . JR .. M . D . PULMONARY D I SEASl!S N UROLOG V March 24, 1967 L CTRO NC PHA.L OGRAPH V DOCKETED U&AEC Mr. Harold L. Price U.S. Atomic Energy Commission Washington, D. C. 20545
Dear Mr. Price:
I have received the March 13, 1967 directive concerning proposed fees for facility and materials licenses from the Atomic Energy Commission. The Atomic Energy Commission is a tax supported institution. Those who will be paying the fees suggested are among the higher income groups who are paying the major federal taxes at present. The Commission setting up fees in effect is adding taxation on the basis of administrative regulations rather than by Congressional action. It has always been my understanding that the power of taxation lies with Congress and not with the administrative branch of government. It is, therefore, difficult to understand .the directive. Very truly your~ JWD/fl 52:.~M. D. ~ cc: John Jarman
DOCKET NUMBERPR -3t>,t/0,50, P.ROP.OSED RULE 10 <1-170 OCHSNER CLINIC 1S14 JEFFERSON HIGHWAY NEW ORLEANS, LA. 70121 CA BLE ADDRESS: OCHSCl-lNIC DEPARTMENT OF OPHT HAL MOLOGY R OBERT A. SC H IMEK , M. D , March 25, 1967 TELEPHONE: 834*7070 AREA CODE !504 JOHN F, FERRY , M . D . Secretary
u. s. Atomic Energy Commission Washington, 25, D. C. 20545
Dear Sir:
I would like to object to the proposed establishment of a license fee for sealed source units used in treatment of medical diseases and eye diseases. These are small units of limited application and necessity for further expense in maintaining these by private doctors would simply result in higher costs to patients. These higher costs would be significant because of the small number of patients and limited number of situations which a sealed source such as a strontium 90 applicator for eye diseases is used. Very truly yours, DOCKETED US'AEC
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ROBERT A. SCHIMEK, M. D. nb
DOCKET. NUMBER PR-3c,qo,s6', P.ROP.OSED RULE 1&<Hl0 C:1,"Y" C>F" S.A...G,lf'-JA...VV l'VIIC::HIGA.N lf'lhOI March 27, 1967 Secretary, U. S. Atomic Energy Commission Washington, D. C. 205h5 Dear Sir; Relative to your letter of Narch 13 , 1967, and the Notice of Proposed Rule Making, I would like to offer the following comments; 1 . As a Civil Defense instructor and C- D source set licensee , I would not be interested in paying any application fee or annual fee for the privileige of holding such license , since the license is held solely as a public service . I would return both the license and t he source set if any fee whatever were levied .
2. Paragraph 170 . 12 (payment of fees) wherein you state "all application fees will be charged irrespective of the Commission ' s disposition of the application or a withdrawal of the application, " sounds unreasonable . If the Atomic Energy Commission is in business to control and assist businesses and researchers I feel this "pay anyway" attitude conflicts with the helpful approach .
Your footnote 1 in the Schedule of Fees , needs a more equitable approach also . I am certainly left with the over- all impression the Commission is out for every penny it can ge t from licensees , while other Federal Agencies are playing the opposi t e game of " give away . 11 Isn ' t there some uniform philosophy by which the Federal Government could partially subsidize public and private activities without such extremes? Ve ry truly yours ,
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March 27, 1967 O: Kt. ED AIR MAIL U&4EC AR 291967 Secretary fflce of the Secretary Public Prcceedings U. S. Atomic Energy Commission Washington, D. C. 20545 Reference : Proposed Licensing Fees Specific Byproduct Material Licenses
Dear Sir:
Your letter dated March 13, 1967, signed by Mr. Harold L. Price, Director of Regulations, outlines the proposed fees which will be charged industrial users of byproduct materials. As a manufacturer of nuclear level gauges utilizing small sources of byproduct materials, am definitely against the proposed rule that would require licensees to pay application and annual fees. Instruments, Inc., since 1948, has pioneered the industrial use of nuclear gauges for controlling both liquid and solid levels in closed vessels. During these eighteen (18) years a substantial portion of our sales time was required to convince prospective users that the radioactive materials supplied would be safe with respect to their plant environments. It was particularly difficult to sell a chemical or food plant on the idea of using a nuclear level gauge, particularly in the years following World War 11. The much publicized fear of ionizing radiation immediately fol lowing Hiroshima created an atmosphere of fright among potential users. In more recent years we, along with other nuc Iear gauge manufacturers, have developed a field of instrumentation that is accepted by the major process plants throughout the U.S. The cultivation of a favorable climate to use radioactive materials in a process plant has not been easy. If the proposed rule outlined in the March 11, 1967 Federal Register is adopted, we will again be faced with an unfavorable climate in which to market our nuclear associated products. To substantiate our beliefs with respect to charging fees for specific licenses, I am attaching a copy of one of our customer's letters. The opinion of this user toward license fees is quite obvious--and negative
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INSTRUMENTS, INc. DIVISION OF NATIONAL TANK COMPANY Secretary--U .S. Atomic Energy Commission March 27, 1967 Page Two The explanation given for charging fees for byproduct material licenses seems extremely flimsy. I quote, "The commission is proposing the establishment of fees for its facility and materials licenses which it believes to be reasonable and compatible with the Commission's responsibility for fostering the development of nuclear energy
11

It is difficult for me to accept this statement as a valid reason for imposing fees since the development of nuclear energy for industrial use was certainly supported as much or more so by private industry than by the Commission.
I emphatically suggest that the proposed rules for establishing application and annual fees to use byproduct materials be dropped completely. Very truly yours, INSTRUMENTS, INC. Karl T. Ba I Vice President--Sales KTB/pw cc: Senator Fred R. Harris, Washington, D.C. Senator A. S. (Mike) Monroney, Washington, D.C. Mr. O. W. Graham , President, Instruments, Inc., Tulsa
DOCKET NUMBER PR-3~, l(o, 5°, P.ROP.OSED RULE 16 4--170 \ G D MARBLEHEAD LIME COMPANY A DIVIS I ON OJI' GENERAL DYNAM I CS CORPORATION March 23, 1967 lffi g@gnwg 1DJ MAR 27 \981 Mr. w. Darrell Hunt, Manager Nuclear Controls Department msmur.mrrs me. Instruments, Inc. P.O. Box 556 Tulsa, Oklahoma 74101
Dear Mr. Hunt:
We are using your Model 200HLFS GAMM-0 SWITCH and type B-20-06 source holders to sense lime levels in six coolers of our design, and contemplate a seventh installation. Your records should include de-tailed information on these applications. We would appreciate your advice as to the category of license that these installations will fall under, under the Atomic Energy Commission proposed new Facility and Materials Licenses Regulations, a copy of which is enclosed for your ready reference. If either the license fees, inspections, or regulations become excess-ive, the use of this type sensor can no longer be justified. We would therefore appreciate your comments on these proposed new rules. r - *_ . ..:~- - --~:~r~
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TULSA MEDICAL ISOTOPE LABORATORY 3 1 1 CO L UMB I A BU I LD IN G TU L S A, O K L AH O M A 7 4 1 14 RADI O IS O T O P E D IAGN O SI S ANO T H E RAP Y March 23, 1967 Secretary U. S. Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
Ref: 32 FR 3995 I am taking this opportunity to comment on the proposed rule pub] ished in the Federal Register concerning establishment of I icence/. fees. I should I ike to point out that these fees serve as a deterrent to small us e rs of by- p roduct materi a ls and would thus tend to discourage their more widespread use. It would furthermore become another overhead factor which would tend to exert further pressure on the upward tendency of med ical fees . Since both these considerations are in the pub I ic interest and since the Atomic Energy Commission functions primarily for the protection of the p ub I ic, it would appear reasonable to continue to defray the cost of operations of the Commission from the general tax fund. Sincerely yours,
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u. s. Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
I am writing in connection with the proposed establish-ment of fees for licenses as published in the Federal Register. In my opinion, the federal regularion of the production and use of radioactive isotopes is for the protection of the public welfare and the costs of this regularion should be derived from general funds rather than from licensure fees. Medical and industrial conditions call for rapid develop-ment of radio-isotope technology; federal regulations have had an effect of delaying development to some degree and licensure fees would add to this delaying effect. yours, Menard Ihnen, M. D. MI :jp
WEST VIRGINIA UNIVERSITY *
MORGANTOWN, WEST VIRGINIA 21515015 MEDICAL CENTER

SCHOOL OF MEDICINE DEPARTMENT OF RADIOLOGY March 23, 1967 tlCKEnD U&AEC Secretary AR 27 1967 U. S. Atomic Energy Commission fllce of the Sterefa'1 IC ~~d!ngl Washington, D. C. 20545
Dear Sirs:
This letter is written in response to Atomic Energy Commission (10 CFR Parts 30, 40, 50, 70, 170) Facility and Materials Licenses, Proposed Fees: Published in the Federal Reigster, March 11, 1967 (32 F.R. 3995). The proposed application fees and annual fees would undoubtedly bring in monies to expand the facilities of the Atomic Energy Commission. Let us take a look at the proposal from the applicants viewpoint. Excluding the commercial production and use of isotopes, most license applications pertain to research in development and use of isotopes from which no profit is derived per se. The proposed fees would add an additional financial burden to the already limited budget of these projects. We believe any additional revenue needed by the Atomic Energy Commission should come from reallocation of federal funds and not by additional taxation in this manner. The very nature of the proposal is contrary to the "Commission's responsibility of fostering the develop-ment of nuclear energy". Please transmit our objections to the proper committee as soon as possible. Thank you for your kind help in this matter. Sincerely y~ 4 Green, M.D. n, Radiation and Isotope Committee GGG:paw
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PresiJmt CHARI.BS P. ANDERSON, M.D. JEROME P. CAVANAGH, Mayor DeptJt'Y CommiSJion8f' DIANE Mel.ANH PLACE Medical SeNJi&es DEPARTMENT OF HEALTH Vice-President DAN A. DBMARB DIITROIT, MICHIGAN 48226 JAMBS J. MCCLENDON, MD. Depflt'Y Commissioner JOHN F. C.0TANT, M.D. Admimstrative Services 8801 John c. Lodge Freeway Pavilion l BERT F. DONLIN Detroit, Michigan 48202 Secretary lo she BoMd March 23, 1967 Mr. w. B. McCool, Secretary Re: Proposed Rule Making United Statea Atomic Energy Commission Facility and Materials Washington,D. c. 20545 Licenses- Proposed Fees (32FR 3995)
Dear Sir:
Although non-profit educational institutions are specifically exempted from fees for licensing of qualifying materials and reactors, it appears that no other classes of licensees are categorically exempted from such fees in the above mentioned proposed rule making. However, under paragraph (b) of section 170.ll, the commission may, upon its own initiative, grant such exemptions as it determines are authorized by law and are otherwise in the public interest. In our opinion it would be in the public interest to exempt non-profit organizations, such as units of government, educational institutions, and research laboratories, from fees associated with by-product material licaises, and we urge that the proposed rules be amended so as to plainly state such exemptions. Sincerely, John J. Hanlon, M.D., M.P.H. HEALTH COMMISSIONER 4£~v~ Associate Industrial Hygienist BUREAU OF :INDUSTRIAL HYGIENE VEL:hp
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GUNITE DIVISION e W H EELS - BRAKE D RU MS KELSEY-HAYES COMPANY CASTI GS Gunite Truck Steel Trailer ROCKFORD IL 61101 Duc t ile Specia l Eq ui pm ent March 21 , 1967 Director of Regulation, U.S. At omic Ener g y Commission, Washington, D. C. 20545 Dear Sir ; In regards t o y our NOTICE TO AEC LICENSEES of March 13 , 1967 , I would like to know if this fee that is being proposed w ould apply to our facility. Our license number is 12-02360-02. We hav e a (5) currie source used in the radiography (x - ray ing) of commercial heavy duty castings . DOUKEUD USIAEC
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- ATOM IC UNITED STA TES WASHI ERGY COMM! SS IO GTON, D.C. 20545 March 13, 1967 NOTICE TO AEC LICENSEES Attached is a copy of a Notice of Proposed Rule Making published by the Commission i the Federal Register proposing the establishment of license fees for facility construct ion permits- and operating licenses issued under 10 CFR Part 50 ad for specific byproduct, source, and special nuclear materials licenses issued under 10 CFR .
Parts 30, 32-35, 40, and 70. The CoIJLmission is proposing the establishment of fees for its facility and materials licenses which it believes to be reasonable and compatible with the Commission's responsibility for fostering the development of nuclear energy. The fees are set out in a proposed new Part *170. Amendments to Parts 30, 40, 50 and 70 to reflect the proposed application filing fe e requirements also are proposed. The fees would apply to specific licenses but not to general licenses at the present time. The Notice allows 60 days for comment by. interested persons . Upon expiration of the comment period the Commission will review and evaluate the co1UJ.~ents received in reference to the proposed amend-ments . Licensees are requested not to re..mit fees at this time . Further action by the Commission and republication in the Federal Register will be necessary before the proposed amendments are made effective. All interested persons who desire to submit comments in connection with the proposed amendments should submit them in writing within 60 days from the date of publication to the Secretary, U.S. Atomic Energy Commission, Washington, D.C. , 20545. Comments received after that period will be considered if it is practicable to do so, but assurance of consideration cannot be given except as to comments filed within the period specified. Copies of comments on the proposed rule may be examined at the Commission's Public Document Room, 1717 H Street, NW ., Washington, D.C.
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Harold L. Price Director of Re ulation
Enclosure:
Notice of Proposed Rule Making on License Fees
316 COLFAX AVENUE SCRANTON, PA. 18510 Center PHONE 717 - 347-5671 March 21, 1967 Mr. Harold L. Price Director of Regulation U.S. Atomic Energy Commission Washington, D.C. 20545
Dear Mr. Price:
I have reviewed your notice concerning AEC licen-sees and the proposed establishment of license fees for facility construction permits and operating licenses issued under 10 CFR Part 50. I would suggest that hospitals be exempt for the purposes of construction or annual fees in as much as they are non-profit; and in as much as the sole purpose of the radioactive material is for the care and treatment of per-sons who are physically ill. It is not clear in reviewing Section #170.11 Exemp-tions as to whether hospitals are excluded. I do notice that this section exempts non-profit educational institutions; I feel that, likewise, the non-profit hospital institution should be exempt. Yours truly, JLB:eb AR 24 1967 ffice of the Secretary Pabl/c Procce~filgs YOUR HEALTH IS OUR MOST IMPORTANT PRODUCT
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+no OHIO WESLEYAN UNIVERSITY DELAWARE, OHIO 43015 March 21, 1967 Mr. W.B.McCool, Secretary U.S. Atomic Energy Commission Washington, D.C. 20545 Dear Mr. McCool; With reference to the Proposed Ru.le Making involving the establishment of fees for by-product materials licenses, I would like to raise the point that in many academic institutions, the only utilization of radioactive material is for research and instructional purposes.
While the proposed $25.00 fee is not exorbitant, it may constitute an appreciable fraction of the annual budget for radioisotopes by some academic institutions. I would like to propose consideration of an amendment exempt-ing individuals and instututions from payment of this fee where such use is limited entirely to research and instruction *
Gordon Ogden 1 III of Botany cc: E. Shuck, -Vice-President for Academic Affairs Ohio W sleyan University DOCKETED OSIAEC
PHONE 486-5207 DIAGNOSIS AND INTERNAL MEDICINE NORMAN 0 . ROTHERMICH , M . 0 ., F. A. C . P. RICHARD L FULTON , M. 0 . . F A C P. WARREN W. Si.tlTH . M. D., F. A . C. P. VOL K. PHILI PS. M D., F. A . C. R WALDEMAR BERGEN , M. D. JOHN F. CONDON , M . 0 . BULENT JAJU LI, M . O . HOWARD W. MAR KER , M . O. 1211 DUBLIN ROAD (U S. ROUTE 33) Columbus, Ohio 43212 RADIOLOG Y TH OMAS E. FOX . M. D. March 22, 1967 HAROLD W. LO NG, M. D. Secretary u.s. Atomic Energy Commission Washington, D. c. 20545 Re: Notice to AEC Licensees concerning fees or facility construction permits and operating licenses and for specific byproduct, source and special nuclear materials licenses of 13 March 1967. Gentlemen: Your Commission feels that it is appropriate for you to establish fees for your licenses and you believe it to be reasonable and compatible with the "Commission's responsibility for fostering the development of nuclear energy". While it is my impression that nuclear energy would develop with or without your fostering it seems patently 11 11 obvious to me that you intend to require fees despite the objections of those from whom the fees are to come. To me the whole subject smacks of extortion, and if a non-Federal agency attempted to do this, the Justice Department would be swinging with all of the power of the Federal might to punish the of fender. Accustomed as I have become to living under various Federal protection rackets, I am sure I can knuckle under and pay to protect the small investment that I have made in time and money toward protecting my license to do radioiodine up-takes and give radioactive iodine therapy. I will discuss this, however, with my congressman and with a member of the Joint Committee on Atomic Energy whom I know, and make my posi-tion equally as clear as I have in this letter. Sincer ly yours, USAEC t, AR 24 1967 VKP/maf Office of the secretary PullllC ProceedlAP
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Secretary, U.S. Atomic Eaergy Commissioa Washingto D.C. 20545
Dear Sir:
In reference to your commwiicatio* dated March 1;, 1967 regarding fees for .E.C. licease holders, as a volunteer Civil Defense RADEF Officer I do not.feel I should be required to pay a fee for the respo sibility i:nvolveathe custody of a "source". If we were on salary or if we were paid to take care of these "sources" perhaps it would be more reasonable, but as log as we are doing this on a voluntary basis, it does :not seem fair we should be required to pay for the privilege of putting in all the time and effort necessary to properly dischars-e the duties attached thereto. CKETED USIAEC
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RADEF Officer AR 23 1967 Staples, Minnesota 56479 omce of the SeCr2tary License No. 22-11679-01 PubUc Prm!dlngs
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Borg-Warner Corporation ROY C. INGERSOLL RESEARCH CENTER WOLF AND ALGONQUIN ROADS, DES PLAINES, ILLINOIS 60018, PHONE 312 827-313!
March 21, 196 7 Secretary U.S. Atomic Energy Connnission Washington, D. C. 20545
Dear Sir:
I fail to see how license fees for by-product materials licenses 10CFR-30 foster the development of nuclear energy. No arguments were found in the "Notice to AEC Licensees" of March 13, 1967 to justify the imposition of license fees. The AEC is striving to have the states take over the health safety aspects of isotope use, which will relieve the AEC of these costs. Next, the states will institute license fees to cover the cost of their regulatory programs, too. It seems to me that the imposition of substantial license and inspection fees will stifle the research uses of radiotracers. Radioisotopes have limited use to start with; we only have one or two jobs a year which require the use of radioisotopes. A fair investment is required, too, for a radioisotope facility. License and inspection fees will increase this cost. It will be more difficult to justify a radiotracer facility for our limited research uses, if these fees are instituted. These license fees favor the large non-research users of radioisotopes. Their fee is more easily amortized, is less per unit of work done. The large routine uses of radioisotopes, for production and diagnostic purposes, would not be penalized as much by the proposed fees. The occasional use of isotopes on basic and applied research work would be discouraged by the additional costs. Very truly yours, tl/H?t( 6,ti~ C. E. Albertson CEA: lld
t UNIVERSITY o_:,.i'v{inmsotti COLLEGE OF MEDICAL SCI E NCES SCHOOL OF PUBLIC HEALTH* MINNEAPOLIS, MINNESOTA 55455 March 20, 1967 OCKETED U&AEC 1967 ) ffl'ce or the secretary Secretary &lie Procm1ags U.S. Atomic Energy Commission Washington, D.C. 20545
Dear Sir:
This letter is in response to your invitation for comment on a proposed schedule of fees to be charged for licenses by the Atomic Ener gy Commission. From the tone of the news release, dated March 10, 1967, there appears to be no doubt that a fee schedule will be established. The invitation for comment refers to the manner in which it shall be done. I question the whole concept of a fee schedule for the Atomic Energy Commission and would like to see the rationale which justifies the need for a fee schedule in the licensing pro gram. One of the important questions that comes to mind is, 11What are the implications of the fee schedule with regard to AEC-state agreements"? A fee schedule proposed by the Atomic Energy Commission appears to represent a step in the wrong direction with respect to plans purported to foster agreements between states and the AEC. It is difficult to re gard as a step in the direction of relinquishing responsibilities for the health and welfare of people to the states, The applications of radioisotopes and radiation-producing sources is still in a developmental stage, Consequently , the costs of programs justifiably may continue to be borne by the general taxpayer rather than specific licensees. I am puzzled by the proposal, because the income from fees is likely to be an extremely small fraction of the total budget of the Atomic Energy Commission. Financial assistance to the AEC seems an unlikely reason for instituting a fee schedule. Bookkeeping costs conceivably mi ght result in a net loss to the AEC. Why is a fee schedule needed?
The absence of justification for the proposal forces me to register opposition to it. Sincerely, Donald E. Barber Associate Professor DEB:cal cc: Dr. Conrad P. Straub Mr. Ralph 0. Wollan Mr. Don C. Fleckenstein
. CKET NUMBER n 30, LID, se, p ""JROPOSED RULE 1, - '70 + f1{)
li cvµ.L 9-.llL4.... l . Signed CLH OCH TED
U&lEC ARl 71967 I I 1 _ _ti I 1 3/ /6'1 I I 1
PR- 30, l/0,50, UNITED STATES l. l(ET NU MBER POSED RULE ?D '1-170 TOM IC ENERGY COMMISSION DOCKETED USiAEC
' WASHINGTON, D.C. 20545 March 13, lcJ::>7 NOTICE TO AEC LICENSEES Attached is a copy of a Notice of Proposed Rule Making published by the Commission in the Federal Register proposing the establishment of license fees for facility construction permits and operating licenses issued under 10 CFR Part 50 and for specific byproduct, source , and special nuclear materials licenses issued under 10 CFR Parts 30, 32-35, 40, and 70.
The Commission is proposing the establishment of fees for its facility and materials licenses which it believes to be reasonable and compatible with the Commission's responsibility for fostering the development of nuclear euergy. The fees are set out in a proposed new Part 170. Amendments to Parts 30, 40, 50 and 70 to reflect the proposed application filing fee requirements also are proposed. The fees would apply to specific licenses but not to general licenses at the present time. The Notice allows 60 days for comment by interested per sons. Upon expiration of the comment period the Commission will review and evaluate the comm~nts received in reference to the proposed amend-ments. Licensees are requested not to remit fees at this time. Further action by the Commission and republication in the Federal Register will be necessary before the proposed amendments are made effective. All interested persons who desire to submit comments in connection with the proposed amendments should submit them in writing within 60 days from the date of publication to the Secretary, U.S. Atomic Energy Commission, Washington, D.C., 29545. Comments received after that period will be considered if it is practicable to do so, but assurance of consideration cannot be given except as to comments filed within the period specified. Copies of comments on the proposed rule may be examined at the Commission's Public Document Room, 1717 H Street, NW., Washington, D.C. Harold L. Price Director of Regulation
Enclosure:
Notice of Proposed Rule Making on License Fees
C~ai~a~" Sea.Dar ci co Co:7:...~ ~ss ~o~e~ ~ o~ ~ so ~ Co~.:::i ss i o~e~ ~ao ~it Co~.::: ~ss~o~e ~ R22 ey Form AEC* 3lb (;1 ov. 11-53)
PROPOS ED RULE MAKING 3995 ing license issuance fee and annual fee § 40.31 Applications for specific licenses, Published in the FEDERAL payable each year after issuance of the operating license. No separate fees REGISTER, March 11~ 1967 (f) Each application for a source ma-would be assessed for licensing of nuclear terial license, other than a license ex-L-32 F.R. 3995 _/ material incidental to the operation of empted from Part 170 of this chapter, a facility or for facility operator li- and other than an application for re-censes under 10 CFR Part 55. The filing newal or amendment of a license, shall fee would be payable in full at the time be accompanied by the fee prescribed in of filing the application. Construction Part 170 of this chapter. permit fees and operating license fees would be payable when the first author- 3. Section 50 .30 of 10 CFR Part 50 is ization is received; i.e., the provisional amended by adding a new paragraph Cd) construction permit or operating license. to read as follows: Annual fees would be payable 1 year § 50.30 Filing of applications for li-ATOMIC ENERGY COMMISSION after the issuance of any provisional operating license, or in the case of a censes, oath or affirmation. [ 10 CFR Parts 30, 40, 50, 70, 170 l facility for which an operating license
has already been issued, 1 year after the (d) Filing fees. Each application for FACILITY AND MATERIALS LICENSES effective date of Part 170 and annually a production or utilization facility li-Proposed Fees thereafter. cense including whenever appropriate, Materials license fees. Fees are pro- a con'struction permit, other than a li-The Atomic Energy Commission is posed for specific byproduct, source, cense exempted from Part 170 of this proposing to establish fees for facility and special nuclear materials licenses chapter, shall be accompanie~ by the fee construction permits and operating li- issued pursuant to 10 CFR Parts 30, prescribed in Part 170 of this chapter.
censes issued under 10 CFR Part 50 and 32-35, 40, and 70. For new licenses, ap- No fee will be required to accompany an for specific byproduct, source, and spe- plication fees would be payable at the ap1;>lication for renewal, amendment or cial nuclear materials licenses issued time of filing of the application. An- termination of a construction permit or under 10 CFR Parts 30, 32-35, 40, and 70. nual fees would be payable 1 year after operating license, except as provided in The Commission is proposing the es- the issuance of the license, or in case § 170.21 of this chapter. tablishment of fees for its fa cility and of outstanding licenses, 1 year after the materials licenses which it believes to 4. Section 70.21 of 10 CFR Part 70 is effective date of Part 170 and annually amended by adding a new paragraph (f) be reasonable and compatible with the thereafter. Exemptions are provided Commission's responsibility for fostering to read as follows: for licenses for material incidental to the the development of nuclear energy. The operation of a facility, as indicated § 70.21 Filing. fees are set out below in a proposed new above for licenses for export or import Part 170. Amendments to Parts 30, 40, *
only ~f byproduct, source, or special nu- (f) Each application for a specia! nu-50, and 70 to reflect the proposed appli- clear materials and for certain licenses cation filing fee requirements are also clear material license, other than a li-held by educational institutions. cense exempted from Part 170 of this proposed. The fees would apply to Pursuant to the Atomic Energy Act of chapter, and other than an applica-specific licenses but not to general 1954, as amended, and the Administra-licenses at the present time. 1 tion for renewal or amendment of a tive Procedure Act of 1946, as amended, license, shall be accompanied by the fee The Commission is proposing applica- notice is hereby given that adoption of tion filing fees, license issuance fees, and prescribed in Part 170 of this chapter.
the following amendments of 10 CFR annual fees for both facility and ma- Parts 30, 40, 50, and 70 and of the fol- 5. Chapter I of Title 10 of the Code terials licenses. With respect to both lowing new 10 CFR Part 170 is contem- of Federal Regulations 1s amended by facility and materials licenses, if a single plated. All interested persons who de- adding a new Part 170 to read. as follows: . application covers more than one facility, sire to submit written comments or or class of licensed material, only a single PART 170-FEES FOR FACILITIES AND suggestions in connection with the pro- MATERIALS LICENSED UNDER THE application fee need be paid. However, *posed amendments and regulation if more than one license is issued in re- should send them to the Secretary, U.S. ATOMIC ENERGY ACT OF 1954, AS sponse to an application, the applicable Atomic Energy Commission, Washing- AMENDED fees for each license will be assessed. ton, D.C. 20545, within 60 days after GENERAL PROVISIONS License issuance and annual fees for publication of this notice in the FEDERAL Sec. both facilities and materials would be REGISTER. Comments received after 170.1 Purpose. deemed as assessed for licensing serv- that period will be considered if it is 170.2 Scope. ices to be performed by the Commission practicable to do so, but assurance of 170.3 Definitions. and paid for at the beginning of the consideration cannot be given except as 170.4 Interpretations. year in which they are rendered. No to comments filed within the period spec- 170.5 Communications. refunds would be made if the license 170.11 Exemptions. ified. Copies of comments on the pro- 170.12 Payment of fees. terminates before the expiration of the posed rule may be examined at the Com-year. mission's Public Document Room at 1717 SCHEDULE 01' FEES Facility license fees . Fees are pro- H Street NW., Washington, D.C. 170.21 Sch~dule of fees for production and posed for all facility construction per- utilization facilities. mits and operating licenses under Part 1. Section 30.32 of 10 CFR Part 30 is amended by adding a new paragraph Ce) 170.31 Schedule of fees !or materials 11-50 of the Commission's rules and regula- censes. tions, except for licenses to export to read as follows: ENFORCEMENT facilities and for certain licenses held § 30.32 Applications for spec ific licenses. by educational institutions. The follow- 170.41 Failure by licensee to pay annual ing types of fees would be required: (1) * * *
fees .
A fee for filing an application for a Ce) Each application for a byproduct AUTHORITY: The provisions of this Part 170 construction permit; (2 ) a construction material license, other than a license Issued under sec. 501, 65 Stat. 290; sec. 161, permit issuance fee, and (3) an operat- exempted from Part 170 of this chapter; 68 Stat. 948; 42 U.S.C. 2201. and other than an application for re- GENERAL PROVISIONS 1 Specific licenses are issued to named per* newal or amendment of a license, shall sons upon applications filed pursuant to the be accompanied by the fee prescribed *in § 170.l Purpose. regulations in Parts 30, 32-36, 40, 50, and Part 170 of this chapter. 70 of this chapter. General licenses are The regulations in this part set out effec tive without the filing o! applications 2. Section 40.31 of 10 CFR Part 40 is fees charged for licensing services ren-with the Commission or the issuance of amended by adding a new paragraph (f) dered by the Atomic Energy Commission, licening documents to particular persons. to read as follows: as authorized under Title V of the In-
3996 PROPOSED RUL E MAKING dependent Offices Appropriation Act of facility as defined by paragraph (I) of (2) Any material artificially enriched 1952 (65 Stat. sec. 290), and provisions this section. by any of the foregoing, but does not in-regarding their payment. (h) "Sealed source" means any by- clude source material. product material that is encased in a (k) "Special nuclear material in § 170.2 Scope. capsule designed to prevent leakage or quantities sufficient to form a critical Except for persons who apply for or escape of the byproduct material. mass" means uranium enriched in the hold the licenses -exempted in § 170.11, (i) "Source material" means: isotope U-235 in quantities in excess of the regulations in this part apply to each (1) Uranium or thorium, or any com- 350 grams of contained U-235; uranium person who is an applicant for or holder bination thereof, in any physicar or 233 in quantities in excess of 200 grams; of a specific license issued pursuant to chemical form or plutonium in quantities in excess of 200 Parts 30, 32-36, 40, 50, and 70 of this (2) Ores which contain by weight one- grams, or any combination of them in chapter. twentieth of 1 percent (0 .05 % ) or more accordance with the following formula: § 170.3 Definitions. of (i) uranium, (ii) thorium, or (iii) any For each kind of special nuclear material, combination thereof. determine the ratio between the quan-As used in this part: tity of that special nuclear material and (a) "Byproduct material" means any Source material does not include special radioactive material (except special nu- nuclear material. the quantity specified above for the same clear material) yielded in or made radio- (j) "Special nuclear material" means: kind of special nuclear material. The active by exposure to the radiation in- 0) Plutonium, uranium 233, uranium sum of such ratios for all kinds of spe-cident to the process of producing or enriched in the isotope 233 or in the iso- cial nuclear materials in combination utilizing special nuclear materials. tope 235, and any other material which the Commission, pursuant to the provi- shall not exceed unity. For example, the (b) "Materials license" means a by- following quantities in combination product material license issued pursuant sions of section 51 of the Act determines to Parts 30 and 32-36 of this chapter, to be special nuclear material but does would not exceed the limitation and are or a source material license issued pur- not include source material; or withiri the formula as follows: suant to Part 40 of this chapter, or a 175 (grams contained U-235) 50 (grams U-233) 50 (grams Pu) special nuclear materials license issued 350 + 200 + 200 pursuant to Par' 70 of this chapter. (c) "Nuclear reactor" means an ap- (I) "Testing facility" means a nuclear Avenue, Bethesda, Md.; or at German-paratus, other than an atomic weapon, reactor licensed by the Commission un- town, Md. designed or used to sustain nuclear fis- der the authority of subsection 104 c. of the Act and pursuant to the provisions § 170. 11 Exemptions. sion in a self-supporting chain reaction. (d) "Other production or utilization of § 50.21 (c) of this chapter for opera- (a) No application filing fees, license facility" means a facility other than a tion at: fees, or annual fees shall be required for: nuclear reactor licensed by the Commis- (1) A thermal power level in excess of 0) A license authorizing the export sion under the authority of sections 103 10 megawatts; or only of a production or utilization or 104 of the Atomic Energy Act of 1954, (2) A thermal power level in excess of facility; as amended (the Act) and pursuant
to 1 megawatt, if the reactor is to contain: (2) A license authorizing the export the provisions of Part 50 of this chapter. (i) A circulating loop through the core only or import only of byproduct ma-(e) "Power reactor" means a nuclear in which the applicant proposes to con- terial, source material or special nuclear reactor designed to produce electrical or duct fuel experiments; or material; heat energy licensed by the Commission (ii) A liquid fuel loading; or (3) A license authorizing the receipt, under the authority of section 103 or sub- (iii) An experimental facility in the ownership, possession, use or production section 104b. of the Act and pursuant core in excess of 16 square inches in of byproduct material, source m aterial, to the provisions of § 50.21 (b) or § 50 .22 cross-section. or special nuclear mat erial incidental to of this chapter. (m) "Utilization facility" means any the operation of a production or utiliza-(f) "Production facility" means: nuclear reactor other than one designed t ion facility licensed under P art 50 of (1) Any nuclear reactor designed or or used primarily for the formation of this chapter, including a license under used primarily for the formation of plu- plutonium or U-233 and any other equip- Part 70 of this chapter authorizing tonium or uranium 233; or ment or device determined by rule of possession and storage only of special (2) Any facility designed or used for the Commission to be a utilization facil- nuclear material at the site of a nuclear the separation of the isotopes of uranium ity within the purview of subsection 11 reactor for use as fuel in operation of cc. of the Act. the nuclear reactor or at the site of a or the isotopes of plutonium, except spent fuel processing plant for processing laboratory scale facilities designed or (n) "Waste disposal license" means a license specifically authorizing the re- at the plant.
used for experimental or analytical pur- !4) A construction permit or license poses only; or ceipt of waste byproduct matertal, source material or special nuclear ma- applied for, or issued to, a nonprofit ed-(3) Any facility designed or used for terial from other persons for the purpose ucational institution, which shows itself the processing of irradiated materials of commercial disposal by land or sea to be, with respect to the material or containing special nuclear material, ex- burial. facility licensed or to be licensed, party cept (i) laboratory scale facilities de- to (D a loan agreement administered by signed or used for experimental or ana- § 170.4 Interpretations. the Commission's Divisi-on of Nuclear Ed-lytical purposes, and (ii) facilities in Except as specifically authorized by the ucation and Training, or (ii) a university which the only special nuclear materials Commission in writing, no interpretation reactor assistance contract with the contained in the irradiated material to of the meaning of the regulations in this Commission. The exemption in this sub-be processed are uranium enricheJ in the part by an officer or employee of the paragraph shall not apply to a construc-isotope U- 235 and plutonium produced Commission other than a written in- tion permit or license for a facility or by the irradiation, if the material proc- terpretation by the General Counsel will maiterial other than that referred to in essed contains not more than 10-*; grams be recognized to be binding upon the the loan agreement or university reactor of plutonium per gram of U-235 and has Commission. assistance contract. fission product activity not in excess of (b) The Commission may, upon appli-0.25 millicuries of fission products per § 170.5 Communications. cation by an interested person, or upon gram of U-235. All communications concerning the its own initiative, grant such exemptions (g ) "Research reactor" means a nu- regulations in this part should be ad- from the requirements of this part as it clear reactor licensed by the Commission dressed to the Director of Regulation, determines are authorized by law and under the authority of subsection 104 '.:. U.S. Atomic Energy Commission, Wash- are otherwise in the public interest. of the Act and pursuant to the provisions ington, D.C. 20545. Communications of § 50.21 (c ) of this chapter for opera- may be delivered in person at the Com- § 170.12 Payment of fees . tion at a thermal power level of 10 meg- mission's offices at 1717 H Street NW., <a) Application fees. Each applica-a watts or less, and which is not a testing Washington, D.C.; at 4915 St. Elmo tion for which a fee is prescribed in this
PROPOSED RULE MAKING 3997 (c) Annual f ees . Annual fees pre-part shall be accompan ied by a remit-tance in the full amount of the fee. No scribed in th is part a re payable, in the application will be accepted for filing or
case of licenses outstanding on the effec-processed prior to payment of the t ive date of this part, 1 year after the full amount specified. Applications for effective date of this part and annually which no remittance is received may be thereafter. In the case of licenses is-returned to the applicant. All applica- sued after the effective da te of this part, tion fees will be charged irrespective of a nnual fees are payable 1 year after the the Commission's disposition of the date of issuance of the license or pro-application or a withdrawal of the visional operating license, if any, which-application. ever is ea rlier, and annually thereafter.
( b ) Constructi on permi t f ees and op- (d ) M ethod of payment. Fee pay-erati ng license f ees. Fees for construc- ments shall be by check or money order tion permits and opera ting licenses are payable to the U .S. Atomic Energy payable when the provisional construc- Commission. tion permit or provisional operating S CHEDULE OF FEES license, if any, is issued. Otherwise, fees are payable when the construction § 170.21 Schedule of fees for production permit or operating license is issued. No a nd utiliza tion facilities. provisional construction permit or pro- Applicants for construction permits or visional operating license, or constnic- operating licenses for production or utili-tion permit or operating license, as the zation facilities and holders of construc-case may be, will be issued by the Com- tion permits or operating licenses for mission until the full amount of the fee production or utilization facilities shall prescribed in this part has been paid. pay the following fees: F ee for filing Operating F acility (thermal megawatt values refer to the maximum capacity ap* application for Construction license lee plied for or stated in the permit or license) 1 oonstruction permit fee and an* permit nual lee (1) Power reactor: Up to 1,000 Mw(t) . . ...... ... . . . . .... ... ...*.. . .*... . .... ...... $2,500 $12,000 $1, 800 Over 1,000 to 1,500 Mw(t) * . *. . .... *.... . . ......*.**......... . .. 2,500 18, 000 2,700 Over 1,500 Mw(t) .. . .......... ...... . . ... *.*..*.*... ........*.. 2,500 'n,000 3,800 (2) T esti ng facility : Up to 15 Mw(t) .. ....... ....... . *..... .................... ..... 800 2, 000 700 Over 15 Mw(t) *..... . .... . . . . . . ... ... ....*.*....*. .........*.*. 800 3, 000 1, 000 (3) R esearch reactor: Up to 1 Mw (t) ............... ... .**. *. *. *........... . *...*..... 300 1,000 300 Over I to 5 Mw(t) ................ . . .... .... ........*.... . . ..... 300 I, 500 .00 Over 5 Mw(t) .... . . .... ........ . . . . . ........... *.*. ** ........ .. 300 2, 000 500 ({) Other production or utllization facility *...* . *................ ..**.. 1,500 5,000 2,000 1 Amendments reducing capacity shall not entitle the applicant to a partial refu nd of any lee; applications for amendments increasing capacity to a higher lee category will not be accepted for filing unless acoompanled by the prescribed lee less the amount already paid.
§ 170.31 Schedule of fees for materials ENFORCEMENT licenses. § 170.4 1 F a ilure by licensee to pay an-Applicants for materials licenses and nual fees.
holders of materials licenses shall pay In any case where the Commission the following fees: finds that a licensee has failed to pay the SCHEDULE 01' MATERIALS L ICENSE FEES applicable annual fee required in this part, the Commission may suspend or Category of materials Application Annual lee revoke the license or may Issue such license fee order with respect to licensed activities as the Commission determines to be ap-
1. All m aterials licenses propriate or necessary in order to carry other than licenses in categories 2, 3, 4, and out the provisions of this part, Parts 30, 5 *- ****** -*---* * * * **
None $25. 00 32-36, 40, 50, and 70 of this chapter
. 2. Licenses for byproduct material issued pur~ and of the Act.
suant to JO CFR (Sec . 161, 68 Stat. 948; 42 U .S .C. 2201; sec. Part 33 or p ursuant to an application de- 501 , 65 Stat. 290) scribed in §35.11 (e) of 10 CF R Part 35** ** $100. 00 50.00 Dated at Washington, D.C., this 8th
3. Licenses for b yproduct day of March 1967.
material of 100,<XMl curies or more i n For the Atomic Energy Commission. sealed sources used for irradiation of ma-terials . .......... . *.*. 500. 00 100. 00 W. B. McCex>L,
4. Licenses for special Secretary.
nuclear material in quantities sufficient [F.R. Doc. 67-2681 ; Filed, Mar. 10, 1967; to form a critical mass _ 300. 00 100. 00 8 :45 a .m .]
6. Waste disposal licenses specifically author*
izing the receipt of waste by product m a-terial , source material or special nuclear material from other persons for the pur* pose or commercial disposal by land or sea burial.. ...... ...** 500. 00 200. 00
RADIOLOGICAL SERVICE COMPANY INC. 35 URBAN AVENUE
WESTBURY, NEW YORK 11590

516 333-9797 March 14, 1967 Secretary U. S. Atomic Energy Commission Washington, D. C. 20545 Gentlemen:
Reference is made to the Atomic Energy Commission's proposed schedule of fees for licensing. I would appreciate your clarifying whether this proposed fee would be applicable to our company. We presently possess an agreement state (New York) license for disposal of radioactive waste material and also an Atomic Energy Commission license in the event we exceed the reciprocity section of Part 150. 20. Our existing license from New York State includes storage facilities and our A. E. C. license does not include this provision. We are particularly concerned that your proposed fee schedule does not include agreement state licensees and that there is a possibility agreement states may use this fee schedule. Therefore, since we may apply to various states for waste disposal licenses, we eventually would be subject to a fee of $500. 00 for each of 5 0 states or $2 5, 000 and an annual fee of
$10,000.
Since it appears that the Atomic Energy Commission is mainly concerned with waste disposal companies that have warehouse facilities within their jurisdiction, this fee schedule should not apply to companies that are under the jurisdiction of agreement licensing states. Sincerely yours, HG:ms "Specialists in Health Physics Services since 1952"
Radioactive Waste Disposal

Radiation Decontamination

Chemical Waste Disposal

Leak-Testing Sealed Sources

X-Ray Calibration

Nuclear Instrument Calibration
s, INC. RADIOLOGICAL SCIENCES AND SERVICES P. 0. BOX 602 CLEARWATER, FLORIDA 33517 AREA CODE (813) 446-6227 March 11, 1967 DOCKETED Secretary USilEC
u. S. Atomic Energy Commission
*l ashington, D. C. 20545 Ref: News release No . K-61
Dear Sir :
I am writing in regard to the Commissions' proposal to charge fees for licenses. In my opinion this is the worst thing that the Commission could do in attempting . to execute its basic mission, which is to develop the peaceful uses of Atomic Energy. In addition, it is unjustified--another form of taxation. The person who has to use radioactive materials would have no choice butto pay this fee. Persons using drugs controlled by the FDA do not have to pay a fee--why discriminate? A further example of discrimination would exist for individuals in states which now license use of radioactive materials. There can be no justification for these persons not haveing to pay a fee while their neighbor in the next state does pay. The Commission has had over 20 years of existence without fees. There has been enough criticism of the length of time it takes to get a license, the nit-picking types of information re-quired to get a license, and portions of 10 CF parts 20 and 30 without making us pay for it. I sincerely hope that the Commission will not take this step, for the reasons given above. Very truly yours,
~MQ~
Boone M. Bowen, President DYNATOMI~ INC. BMB :b
" I*
P£ --1193 (Date) i DOCKET .NUM!!ERPR Je,c,e,.~, to: .PJ?OPOSED *RULE , .- ?o, 170
. (d.~For npprop*r1_o tc ha ndlin& *.
Reply for Chairman*~ Siunature With or

without copies for
~mmiasioncrs -- For Information -
ifil~RKS _ _ _ _ _ _ _ _ _ _ _ __
Arnold R. Fritsch
.. *.: ....,. ..., . For the C~airman I,
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EVERETT '"!CKINL!;:Y DIRKSEN ** MINORITY LEADER
*1LLINOIS W, 1193 DOCKET NUMBER PR' - ~ft,W,,'it!J, PROPOSED RULE 18,llf DOCKETEI>
O&\EC The ~ionoro.olc Glc::ia T. Se aborg Chai r ,.1an Atoi,iic Energy Conu;iission i\'a shin g t on, D. C.
Dear ;. Ir. Chair man:
Aay consideration you can 3iv e to the f2cts set forth in t he c n c 1 o s e d c o JO 1,nm i c a t i o n s e n t t o y o u u n c.l c r cl a t e o f . Ap r i l l e b y the State of illinois will be appreciated. At your convenience I . would ap p reciate rccei~ing a re~ort as well as the return. of the enclosure ifter it has served its pur J? ose. Sincerely, Enclosure 1193-
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*.. ~ *~ - ~ * ,*',i April l O, 19 G7 Sccret-3 -:-1, V. S. Ator,,ic : .
2ncri;i-y Com;::1is s ion Vashi:-.g _ton, D. C. 20545 D0a: Sir:
"v\Ti~h rosp.::ct to t:10 p:oposc::l fo: cs~01ishL1g c. $25. 00 fo0 for specific J:.tor.1i.:::
Energy Cor::.:1issi0n i3yproduc t Ma toriti 1 Eandli;;-,g Lic2r.ses, this Age:--.cy dcsi_:~s to r:~c:~e th1;;; *following co.:1~ents nnd rccomr:'l0r:da tio:-,s. *
.* . AEC LiccnsGs are in t:1e hc.nds of six~*y-f.:.vo politic~l s~bdiv.isio::-.s i;*. ::::li::oi.s * .*: to perr:-.it sckctcd,* qualifi0d pe:son::cl to t02ch foe Office of Civil Dcfo::se * Ruciiological Mo:-.itor Course" **b s..i;:J~o:t of t}10 ?-202:c:l R~diolo0icc:l Do:'.:e:::s0 Progr~w c:.~-.d Fed~:-al Community Fdlou*, S:1oltcr P:ocr.:im. !v7ost of thGsG ~diolccic~ l Moni tori.1g Ins truc~o:;~ ~.-c u,1pc:id, dcdicQ tcd voh~ ** ~aers. ~t is 0:.trc:-,:cly difficult to .e:ilis t tho services of t1:cs0 people and get t:10:..1* to ~ tter.d the OCD, RMI Cou:se, to apply for foe licG:.1so, and to tr2i~ tt~ neccss.:.rf nu;:-.b0r of rr,onito:s. 'l'o ~ cid a rcquirc::1cr. i: for pa y::no~:.t of $2 5. 0 0 foe for c: ..*. trainil",<; licanse will, un.:!oubi:edly, cc1us0 r:,c:.ny to drop out of the prog-ra:.1.
Training rndiologic~l ~o:.:itor.s is .a never er:.dir,g progrc:.r:: c::.nd a diffic-.;lt or:0
. at best. The nur:1b0r of qudifi0d RMi's "'vailable, eve:n after five yc2.rs of . :. * .* *effor~, is still for b0lov1 t::c ope.c:tio~al rnquironent of the State of Hi:nois a~1d ** we .believe the. cstublishment of license fo.as wil*l contrfoute to the foib:e of this p:og.-:.m. The sir.all ar:-.ount of mo~1cy derived from this foe would be offset by the pcrson.1el driven out of the progrc.r:1.
fa 2.ddi ticn, Illi:::ois nacds a ninimum of 519 Trained Rc;ciiolo<:ioa 1 Dafonse O .:.:,c
*** "'* ' ;'"0'"') ,,.. -,..~ \*\.,1.,,1 ,,,..,a* J-~-..,
_.,;, '-l* r-~s{s**-:,.,.,l*
L4:.i,i~ ':"'>'i'Q's
\,.!...,I
r-~-:-.-.,..cuis'te A* ~..1.c::.;:J."" ,. J. ,::cor ;-Y,'-O
.\,.LI -i"-6 J.*J.44;,a is
--"'i"""'a co::1plo:io:1 of "R~diologica l ~onito:ing foi.* Instructors" (RMI} training. n: is our bd:ci tr..;'.i t this p:ogram dcsign0cl .to r.--.co: .?edcr~l ;cquircment.s for DO' s
'nili ~lso bo h.::::-.jerad by thc',cstabli.s~r.1ent of license foes b:,* tho A~c=-:~:.c E~*.c:0:; Cv:~*.:,1!..s Giovr. * ~
I* **** *

It is I therefore, *rGCO:iii1'\C:1dcd tl1ut Atomic :s~*.orgy Cori:~ission By!:>rccuct Iv:a tc ti.:: l Jfo~cili:.10 Lice~scs g.c:nted by .AEC to users for i::"2iriin,;; RZldioloc.:;ic~ l
?-.-!or:-~tors *for Civil Dcfonzc purpos0s bo c;.:c:npt fror.1 the roquir.0r,1~i1t to p~y a . fee fo1* th~ *l ice.1s e as p;opo~~d* ~r the ___~omr.-iission. * * ** **. *\' } ,: .. 1 .:*,1_ *. .. *' ...._,.,;, / .::*.: ; , *. \ ***. .* : n** ' ' .*"'c'*o- --LJ'.. t I.,
1 M. Vcr.ce * ** -: :
.. * , I. 4 ~
DMV:RSR:dg
-~.. ..' ...- ', .:'... * *\.
* * : : .. '1 .! * ~- ** _.. .... . . . . * ~. . ,*. ! ..
.; .
I * ,*
. , .1 *. :,::: . . _-,. ., *.. t '* ~ **.-*. ' '..,.- . . :'. ,, ' ... , . , ..*. . . .. ' ** i ... . .. * ' * ,*1 . -~*:-*.. .. *.. ., I ' ",
. , . .-?***,**
.. . ~
C*,*
-- -~
I
' ~ 1 .' * ' ;
I*
... . ... . ~ . .. :' .. ,* . . ~-:_. . . ' ,' * .** , ' \ *.* t ; .* .' ., *:**., '*
n,LINOIS RADIOLOGIC.AL DEFENSE DATA rn1:i.:J r.:..::i.tcriol *io a detailed nppct*t:io1'..l'.l, cnt of the Poclcrnl Guido.nee fo.:- ~/.D!::F otuff ~*nd monitor .:.ng ut..itioriD o.a zhow. :i.n Pa.rt E, Chapter 5,
( .
,~ocndix . 1, . of t~e Fadcrul Guiclc.
I Tot:.ul gonla for thrc(;? 'm.'.ljo:: opc~ntional nccoso iti0a oro shown no rollo~o: . I RADEF Off1CERS_ HOl'YITORS STATIONS Goals Acc. Go:.110 Acc. Goclu Acc. rllinois 9013 58,637 The sp.a.cz to the in:medintc right of the "Goa ls" column is for notatior. of 6,253 nccomrlishmcnta ( 11 Acc 11 ) . If a county ciuvelor.ii: figurco which differ free those nhown here by more* than 50%t the Sf:>CCi::i.c goo.lr; cct up by tha polit* icnl ?ubdivisiono concerned, should be carefully re;v:!.ewecl. Fro~ these figurecs data in Column II (total rc1/2uircmcnto) of tha proz:ra.m popcr (Section V B), can be <lct,n*m:f.n.ecl, Linc :..t:cm.:: 2, 3, *& 5 o:; that 1 Gection may be taken directly. Hoi.t ot:hai* 'i'i:e,.10 &1*0 de.pendant on the!:JO three und can be dqtcrmincd usin3 theoc thr~o 'k jor aeto pf duta ao c* busis £or calcula~ion.
Since public shclteru place u large drain on' thc supply of trained monitor$ the masnitude of thia requirement is r;ivcn by sho""1:!.ng the uumboi-of ohcltaro in the Phaao II final record sUlli!n.3.rics (Cat. 2*3).
SHELTERS CAPACITY
<.100 >100 Illino'ls 1,945 5,558 These shelterc src divided into those havinr; capacitiea of lcsa than 100 spaces (<.100) which should have_ three monitors and thoae with 100 spacaa or mor.c (>100) which should have five monitors,.
All of the above* infornultion luio been d~veloped down to county level * (county figurea include all politicnl subdi'-{iaiono within tho county 1 boundaries), The totals* of the individual county figures a.re equal co tha St4te figurea given tloova.
' Att(lchment F AL-6
COUNT'{
- SHELTEf(S;\-
Cnpl.lCi ty lLl.WO'lS RADEJ:' D/\TA RADr:F Ol1l?lCER Goll 1 a Acc.
*NON1'£0RS Goolo Acc.
STATIONS Goalo Acc.
-<100 >100
l. Adams 16 3ll 10 542 76

2. /\ lcxo.nrlcr J 8 5 1,.9 25

3. nond 3 0 6 149 35

4. no one 0 2. 5 114 26

s. 13rown 0 0 5. 96 24

6. Bureau 3 5 l) 414 95

7. Cnlhoun 0 0 s 92 23

8. Carroll 12 0 7 224 47

9. C.iss l 0 6 1147 36

o. Champaign 20 94 15 998 117

11. Christian 2 8 10 362 79

12. Clark 0 2 6 158' 37

13. Clo.y 2 6 7 204 42

14. Clinton 1 1 G 244 59

15. Coles 10 23 7 341 49

16. Cook 1,103 3,775 55 24,184 500

17. Crawford 0 3 7 191 44

18. Cumberland 0 0 6 136 34 19, De Kull:>. . 8 5 7 345 74

20. De Witt. 2 3 u 221 so

21. Douglas 1 l 7 188 45

22. Du Pago 50 74 15 960 110

23. Edgnr 0 s 8 245 55
/
24. Edwardo 0 3 s lll 24
*PHASE II FINAL RECORDED S'1.3'"'.MARY-CATEGORIES 2-8 FACILITIES Attachment F
- COUi ** J JTY snEL*r~ rtJ\DE? Oi7l'IC"Crt t-mrn~* . STATIO 'S c ~naci. Goalc Ace, Goalo cc. Goalo Acc. * < l('~ *> l OD
25. Ef fin~hnt? 2 5 8 231
so 26 . Fa ye tte 14 9 7 279 *43 2 7. 7 ord 4 2 8 258

59 2 7 1*.inklin 3 4 9 301 6C '
29 . Fult on 2 4- 13 394 92
30. Gallatin 0 0 6 120 3i

31. Greene
1 1 8 212 51
32. Grundy 2 8 7 214 42 I

33. Hamil ton . 4 4 .5 144 23

34. Hancock 1 2 12 357 gG
( ,-. 35 . - Rard i n 0 3 4 87 u "3 6 . Henders on 0 0 6 144 '36 3 7. *I cnry 7 12 10 335 76 38 . I-roquoio 3 l l l1 422 102 39 . Jacks on 7 41 8 450 ~56
40. Jasper 1 0 7 175 :43

41. Jeffo r oon 3 16 8 305 ,54

42. Jersey 3 *S 6 170
34
43. Jo Da.vicso 1 1 8 236 1157

44. Johnoon l .l 6 152 .' 36 45 * .lfone 68 lOl 13 1;073 ... *91

46. Kankakee 14 32 12 558 39 4 7
Kendall 2 l 6 147 I 34
48. KnoA 7 23 12 484 $1 49 . Lake / 77 "84,,
8 sr,1 54 Atts.cbme.ir; F AI.*6
COIJ!IT'f -
<100 SltCLTERS C1 1 p.:1c.l.l:y *>100 r1r..:mo1:;; I',/,DZf i),\ 'r.\
MD13f OFPIClm Goo ls ".cc. ce MONITORS Coale /Ice. STllTXONS C:onlo ,'cc.
50. La Salle 16 33 16 741 132

51. La.wrcn..:a 7 16 7 261 40

52. Lee 4 10 9 *1**' 68

53. tiviagoton 6 6 13 408 90 5L
Log.in 7 4 9 2H5 61 55, McDonough J 5 8 JlO 59 56, Melloney 7 8 8 293 58
57. McLean 34 46 17 852 130

58. Macon 29 57 7 54fl {~4

59. Macoupin 4 2 14 lHti 106 60, 11a.dison 49 90 14 l,005 102

61. Marion ,. 9 10 373 79

62. H11rshall l l 6 152 36 63, Nns on 0 1 7 185 *45

64. Ma r;sac 6 l 5 11 3 ,~

65. Menard 0 1 6 137 1)

66. Mel:cer 2 3 9 269 (i2 6 7. Nonroe 1 7 6 l78 35

68. Mon tgomery 2* 5 12 379 87 69 . ,Morgan 7 16 8 337 I 59 70, 1Houlti"io 4 8 7 212 if()

71. Ogle .) l 12 342 82*

72.
Peoria 36 108 11 940 73 73, Perry / 7 , 11 6 224 37 74 . Piatt 4 l 8 717 50 i~LL.achment p'
(l~-*
u COUtiTY
- s1 ti::-r:n:ns Cnpacil:y < J.00 . >10 0 11.'i,lllOJ:S R\DE11 !)/\Tit MD/ff Ol7ltY.CEl\
Go:'.llll
/\er.*
H01llTORS Goalo
... _ . ~
Acc. STi\TIOHS Goalo Acc. 7 'j, Pike 0 'l 12 337 03 76, Poro 0 0 5 96 21~
77. Puli:ink i" 1 2 6 137 31

78. l'utno.m 0 0 s 92 23

79. Rnncl olph 9 26 10 4"J7 70

80. Richland 1 4 6 159 J4

01. Rock I!llalld 42 137 !_\ l, 043 58

02. St. Clair 42 125 ll1 1.16J 103

03. St1linc 2 12 7 250 li6

84. Sc1ngamon 29 84 lJ 875 !12 05 . Schuylor 0 l 6 129 31

06. Scott 0 0 5 88 22 8 7. Shelby 0 4* 9 284 66

88. Sturk 0 0 s 116 29 89 . Stephcnoon 12 26 9 418
63 90 . Tazewell 2 7 9 29 7 64
91. Urlion 4 3 7 216 41

92. Vcnnilion ' 13 40 16 719 120

93. Wabash 7 4 5 . 121 20

94. Hn1:ren l 2 7 209 49

95. w.:rnhing'ton 2 1 7 199 47 l s. 7 235 48 ...

96. Wayne . *'
9 7. White 0 ,~ 7 204 46
90. Whi teside / 7 29 9. l~30 66

99. Will p 62 12 65'.) 73
Attachment:
F h l.- I,
~ .J ****
-,1 . *:. . ILLINOIS RADEF DATA ('5) -
COUNTY SHEL'i'ERS R,\DEF OJ!I!:LCI.m
\
l'.ONlTORS ST.6-..i'YONS C.np.:ieity Goa lo Acc. Go.'.llu M:c. Coo.le A_cc.
..: 100 : > l.00 100. Hillfom~on 15 20 7 345 l>O 101. W_nncba30 33 74 8 601 53
02. Woodfot'd 0 .3 8 215
50 Attachm-mt: F AL-6
OOCKH NUMBER PR---"°'~
. 7 ., I P-ROP.OSED llUU t!J,t~o . PJ? 1192 jl')ou~c of 1'tprc~cntatibc~
Rlasbiniiton, 31>.C. May 2 I I.'
, Con.:;ressional Liaison Officer Atomic Energy Commission Washington, D.C.
Sir: The attached conmnmication is sent for your consideration *
' Please investigate the statements contained therein and forward me *, .
the necessary information for re.- ply, returning the enclosed corre ..., ' 1* apondence with your answer. Yours truly, I I I I
~~Cu\Mll~ f...
JARMA. M. C. ; f? DOCKETED -
*OOAEC i *' I will dee apprec at. your , l:.
i careful consideration of Mr, i Dougherty's comments and will be I grateful for a report concerning 1*
this matter. i/..
*:I i i.I I . . *1
RETURN IN l"IVI! PAY8 TO fot. J\,nthong ~tt55pifal 801 N, W, DTH IITREltT
$kl11homa <llitg, 19kl11. 73102 DOCKET NUMBER PR '
P-ROP.OSfD RU!.E,..:_:..;..
*-~
2905 Windsor Place Oklahoma City:, Okla. April 28, 1967 DOCKETED EC Honorable Congressman John Jarman 2416 Rayburn House Office Building Washington, D. C.
Dear Congressman,
Re: Proposed rule making on License Fees by the Atomic Energy Commissioru, fr am Federal Register, March 11, 1967 As Chief Pharmacist for the leading voluntary hospital in Oklahoma, and anticipating becoming more and more involved in pharmaceutical use of radioactive agents, I wish to express my opinion that the setting up of a fee for licenses issued by the Atomic Energy Commission is unwarranted and that the expenditures of those licensees involved make such a fee unjustified. It seems there is an ever greater tendency for the Government or its agencies to take advantage of anyone it can rather than to make a genuine effort to practice economy and be of greater ser-vice to its people. I, therefore, ask that you do what you can to prevent this proposed rule making on License Fees from taking place.
\ ___.. --- - *--- - T]Q- 1191 ~
,. .. oocKET NUMBER PR*_3Affa,se, I .-; EROfOSED. kUl.£ 1
*- ',1*, 7~
J,ousc of l\cprcscntatibc1 Rlasblniilon, 39.C. Mo.y 2 196 7 r' . I *. r Congressional Liaison Officer I . Atomic Enerc;y Commission Washington, D.C. I Sir: ,,I I The attached connnunication -i I is sent for your consideration. Please investigate the statements contained therein and forward me r
'I the necessary information for re- It .*
ply, returning the enclosed corre-spondence with your answer. Yours truly, DtCIETED rYvvvv - Wl!Wt~ .. UUEC HN JA ,iAN M. C. MAY . 8 .1967 I wil ply a 1 re iate your _ careful con13idera. on of Dr. Coin' s ** comments and will be grateful for a report concerning this matter. l .
*JI I
I, 5 /tj/ f /
--t .: 5 !:>::._~ - ,Pf! - 1191
1 oo_* . NUMtlER pR'_~* ,'le,10 91J, PRO . . ED IWJ.£ ?d, '
,, . I** I l ' I I I
April 28, 1967 D1lCKElED USIAE.0 Mr. w. B. McCool, Secretary MAY 81967 U. S. Atomic Energy Commission Office of the secretarY Washington, D. c. 20545 bile PrtC'le~Ings
Dear Mr. McCool:
This letter is in opposition to the proposed establishment of fees for construction permita and operating licenses for users of radio- ' active materials. In my opinion, this would boa further detriment to the development of the peaceful uses* of atomic energy . As a medical doctor with a fairly large experience in the medical uso of these isotopes, it is my opinion that the clinical application of these isotopes both in diagnostic and therapeutic quantities has developed very slowly. One of the principal reasons for this slow development is, in my opinion, the difficult economic situation involved in the use. Throu gh out the country, those people most involved in nuclear medi-cine have pointed out that their financial experience in this pract i ce has been poor. In most cases, the practice of nuclear medicine can only be justified on the basis of scientific interest
~ or de si re to provide the patients with the benefits of nuclear medicine, or in aome cases as a hobby because of this poor financial experience. It is my opinion that the addition of a license fee, even though small, will further hinder the proper development of clinical application of radioactive isotopes. It is, of course, true that ultimately the patient will bear the expense of any additional cost.
So far, I have talked with nine or ten doctors in Oklahoma City who are concerned about this subject. Each of them is of the opinion
that a license fee at this time would be a hinderance of the proper development of the medical use of radioactive isotopes. *In our particular practice, I am sqr~ that . W~~ould go ahead and accept the fee and continue to use ihe radioictiy~ pharmaceuticals. How-ever I in some cas ea I know,- :tha t this would' be just another de te rren t
~ for a young doctor starting in practice and thinking about the p*ossi-bili ty of becoming a user of r_ adioactiyecpharmaceuticals.
*
l !U ud \*
1 l'{l\ 11" ; 1 -,
,(, **. I I\ I * ,j;.
s{!e~~ J '
c. a:/ctG.*o~
Chief of Radiology
,/;;,: ~ >' , r Jarman
CGC/mah cc The Honorable John J . "
O~ET NUMBER PR Jc, 7
'IV, 1 7 n~
P.ROPOSED RU.LE CJ t " THE UNIVERSITY OF WYOMING OFFICE OF THE PRESIDENT BOX 3434, UNIVERSITY STATION LARAMIE, WYOMING 82070 May 3, 1967 Mr. Harold L. Price Director of Regulation United States Atomic Energy Commission Washington, D. C. 20545
Dear Mr. Price:
Receipt is acknowledged of your letter of March 31 enclosing the proposal of the Atomic Energy Com.mission .to establish a fee schedule for construction and operation of nuclear facilities (Federal Register of March 11, 196 7). A key sentence in the proposal is: "Exemptions are provided ... for certain licenses held by educational institutions. 11 We trust that this exemption will be broad and will obtain should a decision be made to establish a fee schedule. The University of Wyoming holds two broad licenses, one covering operation of our Atomics International L- 77 reactor and the other covering general campus use of radioactive nuclides. The activities covered by these licenses are an essential part of our teaching and research programs. Financing them is expensive and requires continually expanding commitments. We feel that license fees would be particularly onerous in view of the fact there is already a heavy expenditure of funds in the nuclear area to comply with existing Federal regulations. Therefore, we should like to be on record as opposing fees for ACE nuclear licenses at educational institutions. Sincerely, H. T. Person Acting President
HESE!Vc.D t-67 MM Af1 I 47 U.S.,i T I11 C ENERGY CO~it1. Ii-~!! ..,,,.,..., y AIL & t. j,,., .... 'E TIO
OFFICE DOCf<O NUMBER poI\_- 1<'411
?~ O SO, OFFI CE CORAL GABLES, FLORIDA 33 134 .P.ROP.OS8) RUU . . ST. PETERSBURG, FLOR IDA 33733 P. 0 . BOX 1686 P. 0 . BOX 11771 PHON E: 305-446-01 3 1 PHON E: 8 13-862-4765 SHANNON ASSOCIATES, INC.
MANUFACTURERS REPRESENTATIVE PHONE 425-8520 1204 EAST CO LON IA L DRIVE P. 0 . BOX 61 71 ORLANDO, RORIDA 32803 May 4, 1967 ucuu, IMEC Secretary M~ 81967.., United States Atomic Energy Washington, D.C. 20545 ~ ...
., 111, s.etr,y
Dear Sir:
This is in response to Notice to AEC Licensees, dated March 13, 1967, inviting comments on the proposed establishment of fees for materials licens es. Shannon Associates, Inc., is a distributor of Edwards/Pyr-a-larm fire detection devices. Each of our devices contain a small quantity of Americium 241 and as such comes under the rules and regulations of the Atomic Energy Commission. We are a Specifie Licensee for the distri-bution of Edwards/Pyr-a-larm Fire Detection and market it throughout the State of Florida. Since our product is designed for life safety and property protection against loss from fire, it +/-s a most valuable device in the protection of our country's assets. We would have serious objection to the imposition of the license fee because of the added cost of doing business. We request that the Commission reconsider its proposal to impose the annual license fees for the type of material which we distribute. Sincerely, Ralph RBS: clb cc: Irve Mande - Edwards Co., Norwalk, Conn.
DOOl(ET NUMBER PR-30, tf o,10,
.MOPQSiO RUlE . 1d , f ?o /)
SYSTEMS SERVICE CO. INC. POST OFFICE BOX 6163 ( . , , ) ORLANDO , F LORIDA 32803 1204 EAST COLONIAL DRIVE, SUITE 3, AREA CODE 305 / 425-47 17 May 4, 1967 IOCHTE! 0$AEC Secretary United States Atomic Energy Commission Washington, D.C. 20545
Dear Sir:
This is in response to Notice to AEC Licensees, dated March 13, 1967, inviting comments on the proposed establishment of fees for materials licenses . Systems Service Company, Inc., is a distributor of Edwards/Pyr-a-larm fire detection devices. Each of our devices contain a small quantity of Americium 241 and as such comes under the rules and regulations of the Atomic Energy Commission. We are a Specific Licensee for the distribution of Edwards/Pyr- a-larm Fire Detection and market it throughout the State of Florida. Since our product is designed for life safety and property protection against loss from fire, it is a most valuable device in the protection of our country's assets. We would have serious objection to the im~ position of the license fee because of the added cost of doing business. We request that the Commission reconsider its proposal to impose the annuall license fees for the type of material which we distribute. cerely, ( r:LC:I(~ Kreiner JEK: clb cc: Irve Mande - Edwards Co.,Norwalk, Connecticut AN AUTHORIZED EDWARDS SYSTEMS DISTRIBUTOR
ttUUU ISl£C MAY 81967 Route 2, Box 1023 St . Charles , Illinois ' 60174 May 4, 1967 Secretary Subject - Prooosed ~ee for AEC License U.S . Atomic Energy Commission i*1ashington, D.C. 20~4') Reference - AEC Ryoroduct "License No . 12 - 11173-01 , incl . amendment No . 01
Dear .Sir:
Tn accordance with requirements set forth in the ~ederal Civil Defense Guide cover i ng Fadiolo~ical Defense for local communities, and In accordance with accreditation requirements established by the same ~ederal Civil Defense Guide for local Civil Defens e or ganizations, and In accordanre with requirements of the Illinois Emergency Preoaredness Plan as oromulgated by the Illinois Civil Defense Agency concerning local Radiological
Defense, Permit me to request that your office consider the effects of stch a proposed license fee uoon such a wide program of this s ort, especially when it is to be lari:;ely done with volunteer individuals of adequate technical competence to qualify for su ch license orivilege . To date, we have not heard of a single State which has accomplished its total R.adef requirements under existing imple -
mentation. And it is reasonable to supoose that imoosing such a license fee, either for application or renewal, will only further justify the foolish turn-down of this vital pro~ram in other communities which have none . In order to be adequately effective, every community must have not less than 3 qualified Radiolo~ical Defense individuals continually lir ensed in order to carry on an nnendinq tra*nin~ and r etraini ng oroPTam for present volunteer personnel and new volunteers and reolacements~ this has to be a continuous oroqram . Therefore , can it be oossiol e for your office to grant exemption to individuals or orpanizations which are enPa~ed in this phase of Civil Defense, at least for as long as this pnogram phase is a ~ederal requirement for tates and local communities to pursue? for the e, Car les Chodl, r . ~ J Asst . Director/Acting Rade. Officer St . Charles Civil Defense cc : Col. *
Lazar, IBMA.AC Russ Forkins l<'ile (2) - Annex C
e DOCKET NUMBERPR jt>,<10,so, P-R0P0S£D RULE - 7tJ ,J7O AMERICAN ATOMICS CORPORATION 425 SOUTH PLUMER AVE., TUCSON, ARIZONA 85719 622-4881 Aitay 1, 1967 AREA CODE 602 Mr. Harold L. Price Director of Regulation U. S. Atomic Energy Commission Washington, D. C. 20545
Dear Mr. Price:
We have received and read your "Notice to AEC Licensees" of lvbrch 13, 1967, relative to proposed fees. Our reaction is one of both surprise and dismay, since the investment that our customers have made in research and development of the use of radioisotopes is very substantial. The initial reaction of our customers to your cooperation in the licensing of the radioisotope Iight sources was good. It was apparent that your interest was that of assisting manufacturers in developing the use of these byproduct materials within the framework of regulatory controls which guided them to safe applications. We don 1t believe that your intentions are any different today, however, it does appear that the establishment of fees at this time could adversely affect the start of important research and development work of potential industrial users, even though the fees presently proposed are nominal. These comments are extended with the desire to offer you the reaction of potential users of the byproducts of atomic energy and one who believes that the more encouragement that is offered to industry to work with these radioisotopes, the greater wil I be the volume of safe use. Yours very truly, C. Victor Hanson, Jr. DOC.KE TED Vice President UStAEC CVHJr/kr
N011::.c~ ':~.: ..,:: ll'vW A.~:iJ l -i , :
'I' _;*! f
i-1!-i0J A:HJ31'-l3 ::rn:J1 v*s*n 0 ... /.!3:J]>J
DOCKET NUMB(~ pt)~30,<<II, SO, P(lOPOSfO - I\ ,7e, 179 SIMPSON COLLEGE FOUNOEO 1860 INDIANOLA, IOWA 5'011-5 May 4, 1967 Secretary U.S. Atomic Energy Commission Washington, D. C. 20545 Gentleman: This concerns the Notice of Proposed Rule Making on License Fees which I received in March. I have not been able to find, locally or in this vicinity, a copy of 10CFR Part 33 or 35 in order to see if and which proposed fee category applies to me. Therefore I shall assume that, if not category 2, at least category 1 would cover my situation and make comment below on that basis. There must be many of us who are not specialists in isotopes but who are interested in using these in our teaching, feeling that some understanding of this phenomenon is desirable for the major and non-major student alike. However, not always is the generally licensed quantity suitable for class use, and we find a somewhat more specific license convenient for several reasons. On the other hand, this is by no means so integral to our program that we are willing to bear fil!.Y cost imposed. In this specific case, it seems to me that even a twenty-five dollar annual fee would not only be unnecessary but a definite deterrent to wider use of isotopes. Since this educational function is a vital goal of the AEC, it would seem to be better to avoid discouraging those who are interested in the teaching use but not primarily involved in research uses with their more generous support. As a matter of fact, it is not at all clear from the material mailed out what reasons have prompted the proposal of a fee schedule. No strong and persuasive reasons have occurred to me in thinking over the proposal, and I would urge that the non-profes-sional (in the sense of not large scale) category of licenses be exempted from the proposed fees. Sincerely, OCl£T£D OOAEC f"t:~ CLM/ gm r
\ ., ~
AY 81967 Otttc, et flit Secrew, l'!Jtl'lr, "ri-..*A/*';3 a.-.:i... . ~/~-~,A)~~ Head, Dept. of Chemistry/* ,
~ OC*KET NUMBER PR-10,'ld,~ . -ROPOSED RULE 7D, 110 Phone (317) 634-2571 SAFETY CORPORATION 2716 East Michigan Street
P. 0. Box 11102 Indiana polis, Indiana 46201 SJ 1967 Secretary Atomic Energy Commission Washington, D.C. 20545 OCIE TEO ll&AEC
Subject:
Your Notice of March 13, 1967 AY 81~ 7 ftlq 4f tbt $Hreta,y Concerning License Fees ubllc Prot:l!dlng1
Dear Mr. Secretary:
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We hold specific license GL-221 and hold, store distribute the fire detectors manufactured by Pyrotronics, Inc., of Union, New Jersey. These devices incorporate using Americium Oxide 241 in the amount of 80 micro-curies. We feel this establishing of license fees is unfair for the follow-ing reasons:
1. Our particular radioactive source is very safe.

2. Our prime function in servicing these detectors is subsequential to the direct sale to the general licensee; that is, we do this servicing as a duty that is contingent on being a distributor of these devices.

3. Additional costs such as licensee fees will have to be passed on to the consumer.

4. Point 3 becomes much more important since the cost of protecting lives and property increases!!!

5. The State of Indiana is not an aggreement state at present and so our licensing is direct with you. This fee proposat if enacted, could be adopted in the four states on our boundry, greatly ballooning the basic licensee fee.
Your commission is concerned with the public health in this application. Our firm is concerned with fire safety with lives and property. There ar, very many other firms in the country with our same interest. Since our interests seem to parallel toward the public, please try to consider these things in your contemplation of this added cost to the public. Many thanks for your asking our opinion. SINCERELY, SAFETY CORPORATION dA-c~ *df'>>~ W. Fred Welch
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DOC~ NUM-8£R
- iRCWDsfo RUU Dayton Electronics Alarm and Sign*as 530 West Second Street BAidwin 4-5616 lETE D ~
Secretary United States Atomic Energy Commission AY 81967 Washington, D. c. 20545 "'~ *t the Ster., fc "-edt t-,
Dear Sir:
In answer to invited comments on the fees for materials licenses. We are a distributor of Pyr-A-Larm fire detection systems. Our devices contain a very small quantity of Americium 241 and as such comes under licensing of the Atomic Energy Commission. We are a Licensee for the distribution and installation of their systems and market them in the Megacity Area. Their devices are generally licensed for sale to the public. It is assumed that our specific license comes under Category #1 which would provide an annual fee of $25.00. The amount of the fee is not large, but we are "nickeled and dimed" to death by the various rating bureaus, city licenses, permits, and as a small business man this is another expense added to our cost of operation which must either be absorbed by our company or passed on to the subscribers for our services. Our industry is greatly in fear of pricing themselves out of the market in this country today. Our services are designed for the protection of life and property against fire, burglary, hold-up and the malfunction of industrial equipment. We feel that if we were not "hamstrung" by the various Government regulations, licensing, etc. that this industry would have one of the greatest possibilities of advancement in our country. We have serious objections to any license fee because of the added cost of doing business. As a small business organization we feel that the Underwriters Labora-tories fees are justified in our industry and are all that should be required, but we are burdened with license fees and inspection fees from Factory Mutual, F.I.A., Improved Risk Mutual, Fireman's Fund Mutual, Board of Fire Underwriters and dozens of other organizations which are leeching money from our company which could be better spent for new equipment and research to provide better service to our customers. Emerson M. Booher, President & General Manager EMB:hbb CC: Congressman Charles Whalen ~ h State Rep. Clara Weisenborn Senator Frank Lausche Mem~er ot - (Nf r State Rep. David Albritton Gov. James Rhodes NATIONAL BURGIAR ANO FlRE AlARM A.\)()CIATION, INC. Burglar, Fire and Hold-Up Alarms ~ Watchman's Reporting Stations Sprinkler Supervisory and Waterflow Alarms
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MILWAUKEE , WISCONSIN 53201

AREA CODE : 414

TELEPHONE: 276*9200 May 5, 1967 L P.f ~:J
~i~tli Secretary U.S. Atomic Energy Commission Washington, D.C. 20545
Dear Sir:
This will acknowledge receipt of your Notice to AEC Licensees dated March 13, 1967, wherein you invite comments on the proposed establishment of fees for materials licenses. The Johnson Service Company is a national distributor for Pyro-tronics, Inc., manufacturers of PYR-A-LARM, a fire detection device. We are holders of a specific license for the distri-bution and service of said detectors, which contain a small quantity of Americium 241. Although the amount of the annual fee proposed is not large, it is entirely possible that the Agreement States could conceivably follow the lead of the Atomic Energy Commission. Inasmuch as we operate in all 50 states, this would certainly then represent a considerable sum of money for the annual privilege of being so licensed. We respectfully request that the Commission reconsider its proposal to impose the annual license fee, or consider the possibility of exempting entirely the product as manufactured by Pyrotronics, thereby eliminating this specific requirement for licensing. Sincerely, JOHNSON SERVICE COMPANY
. Kammeraad son-Pyrotronics Co-Ordinator KJK/ns
GENERAL DYNAMICS Fort Worth Division P . 0 . Box 748, Fort W orth, Texas 76101
817 PErshing 2-4811 5 May 1967 WTW:er Misc.-FW#ll-22732 Secretary United States Atomic Energy Commission Washington, D. C. 20545 DOCIETE8
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Subject:
Proposed License Fee 81967
Reference:
(a) Notice to AEC Licensees Office *f tfte secni., GDFW Log 67/3965 Pallllc ,raett~IIICI Gentlemen: The Fort Worth Division of General Dynamics submits hereby its comments relative to the Notice of Proposed Rule Making published by the Atomic Energy Commission in the Federal Register proposing the establishment of license fees for facility c onstruction permits and operating licenses issued under 10 CFR Parts 30, 32-35, 40, 50, and 70:
1. Para. 170.3 (k) - def. of critical mass, for purposes of license fees , is too stringent.
It should allow for metallic impurities, hy-drogen ratios, etc.
2. Para. 170.12 (a) & (b) - application and permit fees should be at least partly refundable if the application is denied or withdrawn, or if con-struction is not completed for one reason or another.

3. The enforcement provisions appearing in 170.41 should be clarified to provide for at least a sixty (60) day notice to a licensee prior to the suspension or revocation of a license for failure to pay the applicable annual fee.
Very truly yours,
/ R. G.~ Smith Contract Administration Supervisor
00CKEY NUMBER I _:_-:_=:_~..;--- COMPLETE PROPERTY 72 5 W EST MAIN STREET BUSINESS PHONE 673-1416 PROTECTION SERVICES PEORIA . ILLINOIS 6160 6 AREA CODE 309 e FIRE DETECTION May 4, 1967
BURGLAR D ETECTI O N tUET£1 e SAFE Ile VAULT Secretary Ulltt TAMPERING United States Atomic Energy Commission Washington, D. C. 20545 8 1967 e H OLD-UP ALARMS lfflCltftlleSecnlllJ olllk "'cettlllP Re: AEC Proposed Rule Making e OPENING AND CLOSING SUPERVISION
Dear Sir:
e I NDUSTRIAL PR O CESS We wish to state our objection to the proposed establishment of fees for the SUPERV I SION handling of materials licenses in connection with our procurement and installa-tion of Pyr-A--Larm fire detecting devices. e FREEZ ER Ile R EF RIGE RATOR SUPERVISI O N The quantities of these units that we hand Ie are relatively smal I, seldom more e WATCHMAN than 10 at any one ti me or Iocati on - usual! y only 2 or 3. Even in much Iarger TOUR quantities, the very small amount of radiation in the aggregate is still relatively SUPERV I SION smal I. Furthermore, al arm installing companies purchase these units for the e SPRINKLER specific purpose of installation in single units at widely disbursed areas, immed-SUPE R VISION iately upon receipt of the equipment. e AUTOM O B I LE A L ARMS We could foresee that if licensing were necessary for us to handle this product or material, it would probabl y be necessary that we license in perhaps 3 or more e YACHTS Ile Iocati ons, si nee our service area geographically covers several states. Then, BOATS too, once a precedence has been set in the Ii censi ng of a product or equipment, e T R UCKS Ile such a procedure could be extended to a great variety of products or equipment. TRAI L E R S While the initial intent is to maintain adequate control over radio active devices , it, however, does not necessari Iy fol Iow that such a procedure would not be used e HOMES Ile LODGES by other agencies and for other purposes.
U L T R AS O NIC It is granted, however, that the initial concept of licensing radio active materials Ile ELECTRIC EY E D ETECTI O N is, in itself, a good one, but I believe that you should seriously consider just how far the AEC should pu rsue such control , particularly with units where infi ni tesimal e CLOSED CIRCUIT amounts of energy exist . Carried to an extreme point , one might presume that INDUSTRIAL TELEVISI O N timepieces having radium hands and numerals on their dials could also come under Ii censi ng consideration.
DIRECT WIRE CENTRAL STATION PROTECTION FOR ALL COMMERCIAL AND INDUSTRIAL REQUIREMENTS
United States Atomic Energy Commission May 4, 1967 Page Two I think you will find that there are a great many small companies in the business of providing life safety and property protection against loss from fire, a segment that is just as important as municipal safety and fire departments, and to impose a license on these concerns, would *not: be in the best interests of national safety. Sincerely yours, E. B. Oberlander EBO/ajb
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'*7£t !__70 Fyr*/?p*r Exclusi ve Distributors EXTINGUISHERS & SYSTEMS RECHARGING SERVICE PARTS . HYDRO TESTING CABINETS - HOSE WILLIAM J. ROEHL, INC.
4568 MANCHESTER AVENUE ST. LOUIS, MO. OLIVE 2-1066 63110 B DAVIS SAFETY EQUIPMENT FIRST AID KITS & SUPPLIES FLAMMABLE GAS DETECTORS BRASS GOODS TOXIC GAS DETECTORS FOAM COMPOUNDS PVR*6_n. RM. fll£ ANI SIIOKE ~ T I O N smw St . Louis, Hssouri. May 3rd , 1967 Secretary , United ~tates tomic Energy Commission
*,Jashington , D. C. 20545 .
Dear Sir~ This is in response to Notice to AEC Licensees dated March 13,1967 invit - ing comments on the proposed establishment of fees for materials li - cen ses. 11e as distributors for the Pyrotronics . Inc ., who are manufacturers of Pyr - A- Larm fire detection devices object to the imposition of the license fee , because we are a small business and operate in more than one (1) tate, thus increasing our costs of operation .
,le request that the Commission reconsider its proposal to impose the annual license fees for this type of material .
Very truly yours, 1
** ILLIAM J . ROEHL . INC . Distributors for PY OTRO ICS. I~C.
LFR/H DOUETED tl6ilEC
ALERT SAFEn CORPORATION
r::::x::::::I: R. R. # 2 F1nni119dale Rd. Pleasint Plains, Ill.
Are, Code 217 626-3871 525-7575 ' ~6 7 7 AUTOMATIC SPRINKLER SYSTEMS SMOKE DETECTOR SYSTEMS FIR E-LITE ALARMS May 2 , 1967
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ENG I N E ERING SE RVICE! FREE ESTIMATIESI Secretary United States Atomic Energy Commission Washington , D. C. 20545
Dear Sir:
As a holder of a Specific License from the A EC , we would like to register an objection to the charging of a licnese fee as outlined in your "lfotice to AEC Licensees , " dated March 13 , 1967 . We are distributors of fire safety equipment including Pyr - A-Larm , a device using Americium 241 and manufactured by Pyrotronics Inc ., Union, ff . J . The amount of Americium used is minute , and the volume of our business coming f rom this source is greatly disproportionate to the exis ting requir ements of r e cord keeping , wipe tests , etc . This fee would be but another burden added t o the already weighty burdens the small business firm has t o endure . If this f e e is cha rged , it may be multiplied many times by the 11 .A.greement States", who may like the idea themselves . We are asking for a reconsideration of t his p r oposa l an d recommend it be abandoned . Sincerely ,
/1 /{/ A:;pu'7'1~
RAL:al R. A. Lynch cc: Pyrotronics
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TEXAS NUCLEAR CORPORATION, A SUBSIDIARY OF NUCLEAR-CHICAGO CORPORATION 3 May 1967 Secretary
u. S. Atomic Energy Commission Washington, D. c~ 20545
Dear Sir :
As a manufacturer and seller of nuclear gauges to industry, the Nuclear-Chicago Qualicon and d/M gauges, I am strongly opposed to the establishment of license fees for industrial users. The AEC has always promoted the use of radioisotopes in research and industry but this proposed action can do nothing but harm the previous effort.
Nuclear gauges are.in competition with many other types of gauges for almost every a pp lication where they are considered. The radia-tion hazard aspect has always been difficult to overcome in the user's consideration. Even today, most food processing industries will not permit radiation gauges in their plants. App lication of annual fees and the attendent paper work will undoubtedly cause many industrial users to choose a non-nuclear gauge.
A further point is that if the AEC adopts a fee schedule, it is likely that the agreement states will follow the AEC example and further compound the work of nuclear gauge manufacturers in assisting customers to know and meet the total licensing requirement. While
the present licensing procedures are necessary, they are an extra cost burden f or the nuclear gauge industry which competitors do not share. Certainly, the burden should not be increased.
The nuclear instrument industry is going through a difficult time with many companies in financial straits. Some have merged with larger companies (RIDL), others are reducing o perations and selling of f divisions (TMC and Tracerlab), still others are in bankruptcy (EON). It is evident that the nuclear industry can do without further handicaps.
U.S. Atomic Energy Commission 3 May 1967 Page 2 From the above arguments it would appear that the stated reasons for establishing fees, "The Commission is proposing the establishment of fees for its facility and materials licenses which it believes to be reasonable and compatible with the Commission's responsibility for fostering the development of nuclear energy.", are not valid and that imposition of fees would result in just the opposite effect to that desired. yours,
.~,;?#/#/
arman, D1 r *e ctor al Division vg cc Senator John Tower Senator Ralph Yarborough Representative Jake Pickle
. wE.NA; M. JACKSON, CLIN TON P. ANOE:R SON, N . MEX. ALAN 81_~,. ~ . N CV . , RANK CMUR C H, 10.\HO £FI NES T GRVCNING, A LA S K A ' RANK C. MO SS , UTAH WASH . , CHAl , W THOMAS H . KU C Hl'L , CALIF, GO RD O N ALLOTT, COL O . LENO , JOA O ..,N, IOA H O
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CA RL HAYDEN , ARIZ . G £0RC E MCCOVERN, s. o ... re. GA YLORD N E LSON, WIS. COMMITT EE ON L EE M ETCAL,r, MONT . I NTERIOR AND INSULAR AFFAIRS JCFI AY T. V!:R KLER. ST AF"F D IRECTOR May 3, 1967 Honorable Gle nn T. Seaborg At omi c Energy Commission Washington , D. C.
Dear Sir:
The enclosed is respectfully submitted to you for every proper consiq~ration. Please pr ovide me with a report in duplicate, and return the enclosure to me with your response. HMJ: ch enc.
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DOCKET NUMBER PR 34'4~S&,, 29 April 196 7 PROPOSfD RULE ~ "id, /1° Secretary U.S. Atomi c Enerey Co~~ission Washington, D.C. 20545 t ;,.: f°,'_:: i°Q ,: 2*;C0_~_, r ,,
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Dear Sir:
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Your Notice to A.E.C. Licens es , date d 13 M.rch, 19 67, has just come to my attention. In this notice you advise of a contem-plated licen se fee and request comme nts. We arc distributors of Pyral arm ioniz a tion detecti on equipme nt which is manufa ctured by Pyrotronics I Inc. of Union, !lew Jersey. Althoueh we handle many oth er lines of equipment t his is the only one that r e quires s pecific licen~ing. Our princi pal concern, and that o f the Comm ission, I would expect, is that the end user be aff orded the best possible installation of this valu able life and property savine equip-men t. In this r egard the present requirements of testing and handling imposes a rathe r heavy cost on the user of this equi pmen t and tends to di s couraee its use. To add to this the cost of license fees by the Corrin ission and possibt, each individua l state would make the pur chase of this equipment more difficult for the averaee business to justi fy . The en d result is the failure of some businesses to properly protect their property and the lives of their employe e s. This should not be the objective of rovern~ent. I urge that you reexamine the reasons for considerine the pro-posed fees. At the same ti me I would request that your further review your standar-d reqµ i rerr.ents for ha_n dline; this equipment. Your favorable conside ration of these requests will be apprec-iated. Sincerely yours, ELECTRIC CO., INC. DOCKETED U&lEC Arthur Siegal, P.E. President 5 1967 AS:bh cc: Senator Henry Jac ks on
R t,t. VD 1967 14AY 4 PM 3 55 U.S c: M1C E, ER GY CCM M OFF ICE OF TH!: SECi', ETA.RY D. C. Of FIL'. [
DOCt([T NUMBER. PR '1,o1 ,tlo,5a, eROPOSED RUU
e' l1 D OFFICE OF CIVIL DEFENSE MOULTRIE COUNTY SU LLIVAN, :: ILLINOIS ~Ji 51 May 1st 1967 Secretary of U. S, Atomic Energy Commission Washington D. C. 20545
Dear Sir ,
Recently word has been recieved in this office that the U. S. Atomic Energy Commission plans to impose a $25 . 00 fee for the renewal of By Product Material liscenses , as we Un-derstand it this fee would apply to volunteer workers in civil defense as well as commercial users , we feel that in the case this is justified, but in the caseof civil defense workers who for the most part donate thier time and knowledge it is not . Several workers in our area feel they will have to drop out 0r which would impair our efforts in civil defense .
$* ()-.
We sinc erly hope that you will reconsider this fee s o that we may be able to keep our orginaz;rf William J. Doyle Diredtor Moultrie County Civil Defense OCXETED County Building USl£C Sullivan Illinois 61951 AY 4 1967
DOCf<ET NUMBER PR-Jo,'fO, ' 0 PJiOPOSE.O iUlf .1°, l10 Manufacturers' Representatives P. 0 . BOX 3708 Cable Address "MATTCABOT" HONOLULU, HAWAII 96811 PHONE 995-378 KET ED OOAEC 4 1967
!flee 1! the Secratary Public ~,me-ings May 1, 1967 Secretary United States Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
Subject:
Specific License Ca tagory 1!1 We have just learned that your activity is contemplating a license fee of $25.00 a year. As a small business man, this is another expense added to our operation, that in general increases the cost to the government, since 90% of our business is with government act-ivities. We request that the Commission reconsider its proposal to impose the annual license fee for this type of material that we distribute. 7Ji;/'@Ad-MATT CABOT & ASSOCIATES MC/jw
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~QPp~ RULE 7 v, t 7 o THE PENNSYLVANIA STATE UNIVERSITY 207 OLD MAIN BUILDING UNIVERSITY PARK, PENNSYLVANIA, 16802 Vice President for Research April 26, 1967 AY 4 1967 ETEO Otflca at Illa Sf01tarJ ,.111,c ~4/'!rs Secretary 1ruc:i
United States Atomic Energy Commission 5.
Washington, D. C. 20545 Subject : Notice of Proposed Rule Making
Reference:
Exemptions, Par . 170.11(4) Gentlemen: We strongly agree that the above referenced paragraph should be included in any rule that would establish license fees for Commission facility and materials licenses. The responsibility of nonprofit educational institutions to pro - vide a solid training base for the rapidly expanding nuclear industry is a continuing one. Commission support has been vital and necessary in supplementing Universities' sophi sticat ed and expensive nuclear research programs . The support provided has, in addition, accelerated curricula expansion by permitting edu-cational planning based upon more stable financial estimates . We feel that adoption of the proposed exemption will enable non-profit educational institutions to keep abreast of the research requirements of the nuclear industry. Sincerely yours, E . F. Osborn Vice President for Research EFO/NJP/z
, * * ' * ( l* J* (* April 26, 1967 Secretary United States Atomic Energy Commission Washington, D. C. 20545
Subject:
Notice of Proposed Rule Making
Reference:
Exemptions, Par . 170.11(4) Gentlemen: We strongly agree that the above referenced paragraph shoul.d be included i n a:n.y rule that would establish license fees for Commission facility and materials licenses. The responsibility of non1irofit educational institutions to pro-vide a solid training base for the rapidly expanding nuclear industry is a continuing one. Commission support has been vital and necessary in supplementing Universities ' sophisticated and expensive nuc1ear research programs. The support provided has, in addition, accelerated curricula expansion by permitting edu-cational planning based upon more stable financial estimates . We feel that adoption of the proposed exemption will enable non-profit educational institutions to keep abreast of the research requirements of the nuclear industry. Sincerely yours, E. F. Osborn Vice President for Research EFO/NJP/z cc : IN. J . Palladino Paul S. Roeder D. A. Ross
0000J NUMBER PR '30,l(C,SG,
PROPOSED RULE .. 'll>,l70 IRE EQUIPMENT INC. _.
DISTRIBUTORS F"OR NUCLEAR FIRE DETECTION 82 BROADWAY FIRE ALARM AND SYSTEM lcs JI S, IHC. CAMBRIDGE, MASS. 02142 TRowbridge 6-5100 May 1, 1967
~~ KEao liSIA.fC Sec r etary 3 1967 United St ates Atomic Energy Commission fflce of Ille secreia,y ru1111c llrlcmlngs Washington D. C. 20545
Dear Sir:
With r eference to Notice to A. E. C. Licensees , dated March 13lli , 1967 , we wish to submit our comments in connection with the proposed esta blishment of fees for material licenses . Fire Equipment Inc . is a distributor for Pyrotroni cs Inc . of Union, New Jersey . We transf er , install , service, and test Pyr- A- larm early detection devices that contai n a small amount of Americium 241 . We assume tha t our specific license s GL- 210 would come under Catagory #1 , stating that holders of material licenses shall pay an annual fee of $25 . 00 . We strongly object to the licenses fee, because in the course of our doing business , we could be ins talling devices in seve r a l of the New England s t a te s . If the Agreement Stat es should follow the lead of the A. ~ . C. in setting up fees on ma terial license s , a substantial cost could be imposed on a di st ributor protecting property and life with Fyr - k - l a r m devices . Our business be comes mo re complex and costly from day t o day with the a dditional devices and tools that must be furnished to provide the ul tima te in te ~ting t hi s device. If additional costs are l evied to the distributor due to licenses fees , it would cause increasing hardships and add to our cost of doing business . We re quest that the Commission reconsider its ' proposal to establish a fee for the type of ma terials wfuich we distribu te. Very truly yours, FIRE .r::~UI PEEl\-rr I NC . By: # tl.&,A_µU' D. A~Corra di DAC : Iv1IP Vice President - General Manager
A ~ET NUMBER- , 99,~,~, HARBISON-:LKER REFRAC;;;:E;uu,;;~;~; - 2 Gateway Center, Pittsburgh, Pennsylvania 15222 U C\J J--........._,_ C. D. GABOR CHIEF ENGINEER TE L E PH O N E * ( 41 2 ) 39 1
5200 T EL ET YPE ( 7 101 66 4

4347 May 2, 1967 Secretary U.S.Atomic Ene r gy Commission Washington D.C. 20545
Subject:
Fees for Atomic Ener gy Licensing
Dear Sir:
On behalf of our company, I wish to protest the proposed levying of fees on applications and licenses for the use of radiation type devices such as are now being used by industry for level controls , specific gravity measurements, etc. We have purchased a number of devices of this type from the Nuclear-Chica go Company and are now using them under A.E.C. 's specific licenses No. 13-11154-1 (G67) at Hammond, Indiana, No. 25-12123-01 at Ludington , Michigan, and state license No. 174 at Eufaula, Alabama. These devices have been very successful and we are very much "sold" on the use of nuclear energy for certain applications where other more conventional methods of control are not applicable. In view of the potential danger involved in the use of this type of equipment, it is certainly desirable that a central authority such as the A.E.C. have jurisdiction over the application and use of the material, and we agree that the issuance of licenses as a means of controlling such use is entirely proper . We do feel , however, that charging a fee for such licenses is not jus-tified. The regulation of the use of atomic energy is for the good of the country as a whole , and an agency supplying such regulation should not be depen-dent in any way on revenue from its activities. Development of the use of atomic energy should be on a free basis , subject only to such safety standards as are set up by the regulating a gency. For small users such as ourselves , the fee in-volved is not prohibitive, but is more of a nuisance than anything else. I am quite sure that it will cost the A.E.C. more than the amount of the fee involved to set up the system that would be required to collect and keep track of such fees. On the other hand , if the fe es were increased to a point where such book-keeping would pay for itself, the additional cost of the license could become a considerable factor in deterring the use of nuclear energy where it would otherwise be useful. We sincerely hope that the A.E.C. will see fit to simplify rather than complicate the licensing of atomic material and that the proposed levying o f fees will be dropped. Yourr;:;ry~rc_~ W. R. Cameron WRC:vh Electrical Superintendent cc: Mr. D. Muchler Mr. J. McIntyre Rice-Pittsburgh Co. Nuclear -Chicago Co. Pittsburgh, Pa. Des Plaines, Illinois
DOCtCET NUMBERPR '30.CfO,S~,
~QPOSW IUU - 7&, 17/J DEPARTMENT OF THE NAVY NAVAL ELECTRONIC SYSTEMS COMMAND BAILEYS CROSSROADS . VIRGINIA 22041 IN REPLY RE F ER TO ELEX-0516 9900 Ser 138 2 May 1967 FIBST ENDORSEMENT ON NAVSHIPYD SFRAN BAY LE'rl'ER 10330{lo8) OF 25 APRIL 1967 From: Commander, Naval Electronic Systems Command To: Director of Regulations U. S. Atomic Energy Coimnission Washington, D. C. 20545 Subj: Proposed License Fees For AEC Byproduct Material Licenses
1. Basic letter contains conments on subject proposal and is forwarded with concurrence for consideration.
Copy to: BUMED(Code 74) NAVSHIPYD, SFRAN BAY ii~ a. wrm,W!S OCXETED ~ d1re,c t1on USIAEC 3 1967
!flee of tftt Secretary llllc ~cee*1ngs
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PROPOSED RULf - - 11J, {70 SAN FRANCISCO BAY NAVAL SHIPYARD VALLEJO, CALIFORNIA 94592 IN REPLY REFER TO : 10330 (108) APR 2 5 1967 From: Commander, San Francisco Bay Naval Shipyard To: Secretory, U. S. Atomic Energy Commission, Washington, D. C. 20545 Via: Commander, Naval Electronics Systems Command (0516) Subj: Proposed Fees for AEC Byproduct Material Licenses; comments concerning Ref: (a) Notice of Proposed Rule Making, 32 FR 3955, published in Federal Register, II March 1967 I. The effect of fees proposed by reference (a) on this Command, and presumably on other Federal Iicensees, has been considered. It is concluded that, notwith-standing the merit of the intent of the proposal, its specific application to AEC Byproduct Material Licenses held by this activity is not economically feasible and therefore not in the best public interest. 2 . The total annual fees for the four licenses now held by this Shipyard would amount to only $125 maximum. The additional direct and indirect cost to the government for merely processing these fees will approximate this amount and .is not recoverable. Therefore, under the proposed Paragraph 170.11, it is sug-gested that the Commission consider exempting Federal licensees from the payment of subject fees. KE TED
~EC AY 3 1967 ftitt tf Ille Seci,tary 1',~flc IINc~~f.lnfs
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n 1c.HAR0 a . ,ws*E~ GA., CHAl"M A ~ET NUMBER gD,'#6,~ );R- 1184 JOHN f!'TENNI S, MIS S. MA .. OAIIIET CH~ ITH, MAINa tlT\JART SYMING TON . MO.
H ENftY M . JACKSON, WASH , STROM THURMOND, JACK MILLEft; IOWA a.c. MO.POSf.D auU...............~9.,.1"..c..,Z_.p SAM J . £PIVIN, JR. , N ,C , JOHN Q , TOWEfl , TEX, HOWARD W . CANNON, NEV, JAMES , PE.AftSON, KANS, ROBEftT c . *v"o, w . VA . PETEii H , DOMINICK , COLD. STEP'HEN M , YOUNG, OHIO DANIEL K, INOUYE, HAWAII TlfOMA8 J, MCINTYRE, N,H, COMMITTEE ON ARMED SERVICES DANIEL . R EWSTE" , MD, HAIUIY P, 9YIID, Jfl, , YA, WILLIAM H , DAftDEN, CHIEP' 011" STAl'f' CHAM.Ea** kUtaOW, CHIIE.P' CLEIIK April 26, 1967 Mr. Harold L. Price Director of Regulation Atomic Energy Commission Washington, D. C.
Dear Mr. Price:
Thank you for your letter .of April 24 in response to my inquiry concerning the Atomic Energy Commission's proposal to establish fees for licenses to use radio-isotopes. I appreciate your assistance in this matter and look for-ward to receiving wora of your final decision.
/
DKI:at DtCIETED USAEC 3 1967 ffllte If flit Secnb1J r, !1~ T-nC *11~p b& 1184
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SOURCE FOR ALL YOUR FIRE PROTECTION SINCE 1919 PORTABLE EXT I NGUISHERS 40 TERMINAL WAY CO:a & FOAM SYSTEMS PITTSBURGH , PA . 15219 FIRE HOSE & EQU I PMENT REPA I RING & RECHARGING PHONE 431-0700 AREA CODE 412 May 1, 1967 Se c retary United States Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
This is in regard to Notice to AEC Licensees, dated March 13, 1967, inviting comments on the proposed establishment of fees for materials licenses. we We as Distributors of Pyr-A-Larm Detection Devices, under-stand that these devices contain Americium 241 and this comes under the rule and regulation of the Atomic Energy Commission. We are licensed to handle this product on a non-fee basQs, at this time . We feel that we are doing a part in the detection of fire at an early stage with this device . The Pentagon would not have had a large fire in their computer area if they would have had this protection . We feel that $25 . 00 license fee is unfair to a small business like us and when these license fees start, they are always small and they have a way of growing . The next thing the State or Municipality will be requiring a license and before you know it, what small profit we make on the sale of these devices will be taken up in fees . I feel the Commission should reconsider its proposal to impose an annual license fee on small businesses like ours . Very truly yours , FIRE SAFETY SUPPLY COMPANY CKETED
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AY 3 1967 Ice tt lflt StQlllq l'lltltc ~~lf'la,ts
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- 8RQPOSf.O llUll_ - 7&cf70 STATI':: OF ILLINOIS CIVIL DEFENSE AGENCY 11 1 f:: AST M O NROE S TREET S P RINGFIELD, I L LINO I S 62706 TEL . ( AREA C G DE 217) S il 5 25-7860 COL . DONOVAN M.VANCE William L. Eisele, Coordinator S T ATE D I REC T OR Southwest Ill inois Mutual Aid Area P. O. Box J65, Belleville,Ill.6222(
May 1, 1967 ----- Telephone: AC 618-ADams 5-0055 II CH TED IJ&AEC Secretary U. s. Atomic Energy Commission Washington, D. C. 20545
Dear Mr. Secretary:
This letter is in regard to your notice issued March 13, 1967, wherein it is proposed by the Atomic Energy Commission to establish a license fee for each licensee of the Commissi on . This off ice is respectfully soliciting that you consider pr oviding licenses to all Civil Defens e Units , and Civil Defense Agencies free of char ge. We fe el that licenses held for Civil Defense purposes should be exempt fr om t his licensing charge for the foll owing reasons: Civil Defens e is nonprofit_, Organization used for the training of individuals to save lives in case of a nuclear attack on this country. It is necess ar y to ma i ntain a license with your Commi ssion in order to have use of a Source Set for trai ni ng purposes . There are no available funds to pay for licenses for this type of operation. It would hinder the Radiological Defense Program, on a local, State and national level. All the Radiological Monitoring Instructors serve on a volunteer basis . In view of the foregoing , it is hoped that you will reconsider your proposal to establish a license fee for each licensee of the Commission . FOR THE DIRECTOR Eisele DMV:WLE:vr cc: State Off ice
A OOCf(Ef NUMBER P-R- Jo, w,, ~o, W PRO.POSED RUU __ 'I E>, 110 Conducted by The Sisters
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601 N_W _ 9TH STREET e OKLAHOMA CITY , OKLAHOMA 73102 OCKETEI US.EC April 28, 1967 3 1967 Mr. W. B. McCool, Secretar y U. S. Atomic Energy Commission Washington, D. C. 20545
Dear Mr. McCool:
This letter is in opposition to the proposed establishment of fees for construction permits and operating licenses for users of radio-active materials. In my opinion, this would b e a further detriment to the development of the peaceful uses of atomic energy. As a medical doctor with a fairly lar g e experience in the medical use of these isotopes, it is my opinion that the clinical application of these isotopes both in diagnostic and therapeutic quantities h as developed very slowl y. One of the principal reasons for this slow development is, in my opinion, the difficult economic situation involved in the use. Throughout the countr y , those people most involved in nuclear medi-cine have pointed out that their financial e xp erience in this practice has been poor. In most cases, the practice of nuclear medicine can only be justified on the basis of scientific interest or desire to provide the patients with the benefits of nuclear medicine, or in some cases as a hobby because of this poor financial experience. It is my opinion that the addition of a license fee, even though small, will further hinder the proper development of clinical application of radioactive isotopes. It is, of course, true that u 1 t i ma t e ly th e p a t i en t wi 11 b e a r the e x p ens e o f any add i t ion a 1 cos t . So far, I have talked with nine or ten doctors in Oklahoma City who are concerned about this subject. Each of them is of the opinion that a license fee at this time would b e a hinderance of the proper development of the medical use of radioactive isotopes. In our particular practice, I am sure that we would go ahead and accept the fee and continue to use the radioactive pharmaceuticals. How-ever, in some cases I know that this would be just another deterrent for a young doctor starting in practice and thinking about th e possi-bility of becoming a user of radioactive pharmaceuticals. s~-~~
. G. Coin, M.D.
Chief of Radiology CGC/mah
~ NUMBERPR 30,1/0,5"0, BROPOS(D avu ~ 7tJ, 110 COMMONWEALTH OF PUERTO RICO
[J>uerto fRico Water rResources .JCuthority
&n 9uan. l/Juerto fRico CABLE ADD.RESS April 24, 1965 P. O. BOX 4267 PRWRA 00905 <<01, OIIEO AY 3 1967 The Secretary tflcttft11,a..,.,
U.S. Atomic Energy Commission ~ "-cee,11,a Washington, D. C. 20545 D e ar Sir: I refer to the AEC letter of March 13, 1967 stating that license fees are being considered for nuclear facility construction permits and operating licenses. I would like to point out that the fees will definitely be detri-mental to the development of commercial nuclear plants both in the United States and Puerto Rico. In the Commonwealth of Puerto Rico the capital investment on nuclear plants in the 450-500 MWe size range, is approximately 150% of the capital investment of a foss il fuel fired plant as disclosed by our bids for a nuclear plant opened last October 3, 1967. Prior to the obtainment of a construction permit, detailed stu-dies in the fields of geology, meteorology, environment, etc. , have to be performed which adds to the cost of the project. Personnel has to be trained to handle the operation of the plant in compliance with the AEC licensing regulations. These expenses plus construction fees and licensing fees and annual fees may make the proj-ects economically prohibitive for utilities to consider them. So far licensing services have been provided free of charge. Will the new fee offer additional services or benefits? I shall greatly appreciate your point of view on this question. Cordially yours,
~ u .CO /J Rafael V. Urrutia Executive Director
ooc<<ET NUMBER PR-30,Cf0,50, fROPOSE.O IOLE 7e, no
' *.\ R O8 E RT S H AW CON T RO L S COMPANY SANTA ANA FREEWAY AT EUCLID STREET ANAHEIM, CALIFORNIA AERONAUTICAL AND INSTRUMENT DIVISION 92803 ANAHEIM , AREA CODE 714-TELEPHONE !!3!!*81111 e LOS ANGELES , AREA CODE 213-TELEPHONE 628-5144 e CABLE ADDRESS-ROBERTSHAW May l, DOCKETEO U. S. Atomic Energy Commission IIS.CEC Washington, D. C. 20545 Attention: Secretary
SUBJECT:
Federal Register Publication of March 11, 32F. R. 3995 Facility and Materials Licenses Proposed Fees Gentlemen: The Robertshaw Controls Company, A & I Division of Anaheim, California, disapproves of the suggested proposal to establish fees to be charged to users of radio active by-product material. Those of us in the business of selling nuclear gauges to general industry in the United States have had difficulty in receiving general acceptance for nuclear gauging devices. Resistance to use of nuclear gauges usually results from false ideas the customer has regarding use of radio isotopes. Over the years we have gradually educated the customer to accept radio isotopes as common place sources of energy, and we are gradually making in-roads across all industries. In the past, the Atomic Energy Commission has offered assistance in various forms towards educating users of the benefits to be gained through the use of radio isotopes. The Commission also profits through revenues gained through the sale of radio isotopes to various processors. In short, the .Atom Energy Commission has profited in relation to the profits gained in the nuclear gauge industry in general. The assessment of a fee to a user of radio isotopes at this time, seems to be a direct attack against all the progress we have made in the last years. It makes our selling job more difficult, and in all probability will affect the. whole trend towards the use of nuclear gauges i n the United States. We strongly
ooocu NUMBER PR AERONAUTICAL AND INSTRUMENT DIVISION NQeou,o IUU U. S. Atomic Energy Commission May l, 1967 recommend that this proposal be withdrawn at this time. It is probable that the establishment of fees might be more acceptable in years to come after nuclear gauges per se have received greater acceptance. Such action taken at this time, however, is ill timed and would be extremely damaging to the industry. Thank you for your consideration on this vital issue. Very truly yours, T. A. Gray Product Manager Nuclear Products TAG:lg
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DOCKET NUMBER ,.A ,o, ""' 5-', PROPOSED RUl.£ l"'l{'-_719,(loTEL. 4 26 -7s11 i AR E A c DE 617 CABLE ADDRESS: ATOMLIGHT TELEX: 094-65B2 NEW ENGLAND NUCLEAR CDRP. 575 ALBAN Y ST R EET, BOSTON, MASSACHUSETTS O211B April 28, 1967 U.S . Atomic Energy Commission Washington, D. C. Gentlemen: With regard to your recent request for comments on the proposed licensing fee for radioisotope users, it is our belief that imposition of such fees would markedly inhi b it, and possibly reduce, the number of individuals and firms employing radioisotopes . We feel, therefore, that suc h fees would be detri mental to scientific an d industrial uses of radioisotopes . Yours truly, NEW ENGLAND NUCLEAR CORP . OCUlEI lliJEC AY 2 1967 Office ,t fire s.cr.., PuMlo FtoccMIICI lraacb Paul A . M cNulty UU> Sales Manager PAM: jcw
TRACE RLAB A DIVISION OF LABORATORY FOR ELECTRONICS , INC . 1601 TRAPELO ROAD
W ALTHAM , MASSA CHUSETTS 02154 AREA CODE 617 894 - 6600 DD C*IE fc o CABLE ADDRESS l.l&IEC LFE WALTHAM , M ASS MAY April 28 , 1967 Mr . Haro l d L. Price Director of Regulations U. s . Atomic Energy Commission Washington , D. C. 20545
Dear Mr . Price :
As you know , Tracerlab is perhaps the very first commercial company in this country to distribute radioactivity and rad i ation devices . We have been involved with regulatory procedures since their origin and are pleased that the AEC contin~es to solicit and be responsive to our comments . There has been a great deal of comment on the establishment of fees , and we generally agree with the various comments that we have seen , many of which have come t o us through our customers . In summary , they may be s t ated as follows :
1. Hospitals , schools , civil defense groups , and other non-profit institutions should be exempt from payment of fees .

2. This exemption should not lead to the establishment of higher f ees for othe rs.

3. The f ee s to be derived from the by- product licensees would hardly be worth the effort .

4. The various states will assuredly set up their own fee schedules , using without doubt different sets of criteria .

5. Many companies will be subject to different fees from vari ou s states , based on the commonly used twenty- day rule .

6. The $25.00 annual fee for a radioactive source worth $20 . 00 seems considerably out of line .

7. The fee for a waste disposal license is exorbitant in relation to the other fees , if it is to be applied to a licensee who does not maintain a burial ground but merely accumulates s ealed drums for re- shipment .
I, Mr . Ha;rold L. P;ric e
u. s. Atomic Energy Commi s si on April 28, 1967 We feel that there has been much improvement lately by industry in their attitude toward the hazards and difficulties associated with the use of rad i oactive materials .
This proposal , we feel, will not promote the improvement of this attitude. Very truly yours , p Rosen erg , Ph . D. ivis i on Manager Technical Products JR/ae
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1050 N . 38TH STREET
P. 0 . BOX 1546

SEATTLE, WASHINGTON 98103

206 ME 3-5300 29 April 1967 Secretary U.S. Atomic Energy Commission Washington, D.C. 20545
Dear Sir:
Your Notice to A.E.C. Licenses, dated 13 M.rch, 1967, has just come to my attention. In this notice you advise of a contem-plated license fee and request comments. We are distributors of Pyralarm ionization detection equipment which is manufactured by Pyrotronics, Inc. of Union, New Jersey. Although we handle many other lines of equipment this is the only one that requires specific licensing. Our principal concern, and that of the Commission, I would expect, is that the end user be afforded the best possible installation of this valuable life and property saving equip-ment. In this regard the present requirements of testing and handling imposes a rather heavy cost on the user of this equipment and tends to discourage its use. To add to this the cost of license fees by the Commission and possibly each individual state would make the purchase of this equipment more difficult for the average business to justify. The end result is the failure of some businesses to properly protect their property and the lives of their employees. This should not be the objective of government. I urge that you reexamine the reasons for considering the pro-posed fees, At the same time I would request that your further review your standard requirements for handling this equipment. Your favorable consideration of these requests will be apprec-iated. Sincerely yours, SELO ELECTRIC CO., INC. OCIE TED OOAEC Arthur Siegal, P.E. 11967 President Office If the Secnttary btlc llncee41np AS:bh cc: Senator Henry Jackson ELECTRICAL CONTRACTORS AND ENGINEERS
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oocaNuMsER P<<OP.fflm RULE PR-34WJ, s~ 7eJ, 170 MCLAUGHLIN GORMLEY KING COMPANY 0 133'.: 1715 S. E. FIFTH STREET e MINNEAPOLIS, MINNESOTA, 55414, U. S. A. CABLE "MACK" MINNEAPOLIS AREA CODE 612 TELEPHONE 331-1808 April 25, 1967 Mr. Harold L. Price Director of Regulation
u. s. Atomic Energy Commission Washington, D. c. 20545
Dear Mr. Price:
We received a notice to all Atomic Energy Commission licensees dated March 13 in regard to the proposal that a fee should be charged for licenses. The copy of the proposal that was submitted with this letter does not adequately show all the parts so that we are not sure whether licenses for the tritium foil used in the electron capture would come under this or not. We would be very much opposed to paying a fee of $25.00 to operate an electron capture GLC, and are wondering if this comes under the section 70 and 50 under the exemptions or not. This is the only reason we have a license is to use a GLC for analytical procedures and control procedures in our laboratory. Si( cerely your~,
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~ QP.OSED IUU 76J, l?o OKLAHOMA MEDICAL RESEARCH FOUNDATION 825 NORTHEAST THIRTEENTH STREET OKLAHOMA CITY, OKLAHOMA 73104 April 27, 1967 tclET£ UU£C Secretary AY 11967
u. S. Atomic Energy Connnission Washington, D. c. 20545
Dear Sir:
This letter is written in connection with the recently pub-lished notice in the Federal Register proposing the establishment of fees for appticants and holders of materials licenses. This institution, which is the holder of license #35-7464-3, would like to urge that nonprofit research institutions such as the Oklahoma Medical Research Foundation be specifically exempt from payment of the proposed fees. Any consideration that you can give to this reconnnendation will be greatly appreciated.
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Leonard P. Eliel, M. D. Vice President-Director of Research LPE:hh cc: Dr. Bradford, Secretary, OMRF Isotope Connnittee
RECHARGE AN PAIR SERVICE ON ALL TYPE ,E XTINGUIS S AND AUTOMATIC SYSTEMS CHERRY 6-2768 12 N . ONTARIO TOLEDO 2, OHIO April 28th, 1967 Secretary United States Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
This is in reply to Notice to AEC Licensees, dated March 13th, 1967, inviting comments on proposed establishment of fees for materials licenses. As Fire - X Associates, we are distributors for Pyr-A-larm Smoke and Fire Detection Systems. The detectors are the Ionization type and use a small amount of Americium
#124. To sell this equipment we have AEC license #GL204.
We are a small organization that handles this equipment on a commission basis. This Pyr-A-larm system is for safety and property protection against fire. It is a finished product and a valuable device in the protection of our country's assets. We feel that the establishment of this license fee is unjust and unfair. As a distributor of a finished product, as far as we are concerned, we feel this is no different than the sale of any other finished product in the United States. Pyrotronics Inc., the manu-facturer of the units, already carry a license to handle this, and as to the danger in-volved from these detectors, it is even less than the amount found in a wrist watch. Therefore, any further fee for license would be merely duplication. It is also our feeling that this new licensing fee by the Aton:i.ic Energy Commission would set a precedent which could be used by the state as well as the cities in which we do business. Therefore, we sincerely request that you reconsider this proposal for the type of material which we distribute. f'- Very truly yours, tCKElED FIRE-X ASSOC IA TES USl!EC 11967 ___,/~~ lfflce tf the Secretary Pubtlc Prtee~~l!lgS Tad Petrie TP/j cc: G. Clark COMPLETE LINE OF AUTOMATIC SYSTEMS PORTABLE EQUIPMENT FIRE HOSE FIRE DEPARTMENT SUPPLIES
000(£'r NUMBERPR ~,&10,s-o, CITY !- MARION P.Ra.P.OSED RULE - ?o, l10 OFFICI: OF CIVIL Dl:FENSE 1107 NORTH HIGHLAND STREET
MARION, ILLINOIS 62959 T. J. REDICKAS Telephone 993 -2323 Tw x 618-993-6790 DIRECTOR You r File Reference :
In Reply Refer To: 27 April , 1967 Secretary U. S . Atomic 1nergy Commission Jashine;ton , D. C. 20545 De&r Sir: In response to your inqui ry bS to personal views con c erning the licensine; fees planned by the A. E. C., I wish to express mine bS follows . Considering that the use of radioactive source sets by Civil Defense is exclusively directed toward public benefit , name l y , national er,ergency preparedness by training volunteers in monitoring &nd other essentia*l skills , &nd not for private personal gain , I believe that li c enses issued for the use of Civil Defense Training Sour c e Sets should be exempt of licensing fees . Sin c erely , , I FOR THE DIRECTOR Julian J . Leves , Training Officer
~ARION CITY - 'ITLLIAtSON COUNTY CIVIL DEFENSE JL/JJ
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PROGRESS THROUGH ELECTRONICS 828-2 163 14 GLENWOOD AVEN UE RAL EIG H, N. C. 833-2824 ENGINEERING - SALES - SERVICE COMMUNICATIONS - NURSE CALL - CLOSED CIRCUIT T . V . - INDUSTRIAL SECURITY - SMOKE DETECTION - FIRE ALARMS April 28, 1967 Secretary,
u. s. Atomic Energy Commission Washington, D. c.
Dear Sir:
This letter is in response to your notation to the Atomic Energy Commission Licensees, dated March 13, 1967, inviting comments on the proposed establishing of fees for its materials licensees. Naco Electronics Corporation is a contractor and distributor of Pyr-a-larm Fire Detector Systems and Devices. Each of these devices contains a smaJ.l amount of americium 241 and, as such, comes under the rules and regulations of the Atomic Energy Commission. We assume that our specific license comes under the Catogory One (l), which would provide for an annual fee of twenty-five dollars ($25). The amount of the fee is not large, however, this is another expense added to our operation, which must be passed on to our customers. Since the product is designed for life and property protection from fire, it is a mat valuable device in the protection of our country's assets. We would, therefore, have serious objection to the imposition of the license fee, because of the added cost of doing business. An even more serious objection can be implied by the fact that it is entirely possible that the agreement states will follow the lead of the Atomic Energy Commission, in imposing fees on material licensees. Since we operate, in many instances, in several states, if such procedure is followed we would be re-quired to -pay license fees to each of the agreement states, and the amount of fees imposed could be substancial. It is our feeling that this action, by the Atomic Energy Commission, will set a precedent, which will cause increased expense in distribution of life saving equipment. We, therefore, request that the Commission e==?T l
__ J
- Page 2 -
reconsider the proposed license fees, which cover the type of materials we distribute. Sincerely, NACO ELIDTRONICS CORPORATION B. L. Barker Vice President BLB/mbh
IXDfl ~ MBER PR jO, '10. SD, J F.!ROP.OS- Ull .
10, &10 Varian aeroGraPH 2700 mitchell drive/ walnut creek/ california 94598/ 415-939: 2400/twx 910-385-6301 formerly wilkens instrument & research , inc.
tCHTE IJQAEC 11967 April 27, 1967 lflce tf ttlt SeeretalJ bllc llnlcedlRga Secretary U.S. Atomic Energy Commission Washington, D. C . 20545
Dear Sir:
Subject:
Establishment of License Fees for Byproduct Materials Licenses (32 F. R. 3 995) We wish to comment on the proposed amendment to 10 CFR which provides for the estab-lishment of license fees for byproduct materials licenses. Among other products, our company manufactures and sells electron capture detectors incorporating a radioactive source. These detectors are used primarily in pesticide residue analysis, a project of vital importance which is supported largely by federal funds. The proposed annual license fee of $25 represents a substantial portion, about 10%, of the cost of an electron capture detector to our customers. Thus, assuming a five-year detector life, the sum of the annual license fees is about one-half the original cost of the detector. We believe this represents an undue burden on the customer. Indeed, the effect of the proposed license fee may well be to induce the research worker in pesticide analysis to seek other methods and equipment which do not involve radioactive materials. This is particularly likely to occur in universities conducting research under already strained budgets. Similar considerations apply to other research areas wherein radio-active materials are useful but not indispensable ; e.g., clinical research and therapy. We feel that the Commission should make every effort to ease the financial burden of conducting research, rather than adding to the cost by levying the proposed license fees. We can readily understand the Commission's intent in proposing the license fees for revenue purposes. However, we believe that whatever revenue is raised by this measure would be of small consequence when compared to the possible curtailment of important research projects involving radioactive materials. The Commission's stated purpose is to " foster the development of nuclear energy. u Surely, the chief effect of the pro-posed fees will be to hinder such development.
U.S. Atomic Energy Commission April 27, 1967 Page 2 For these reasons, we urge the Commission to reconsider its action in this matter. Respectfully submitted,
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~ QP.OSED RUU: ... 7~, 170 MANUFACTURERS OF AUTOMOTIVE, INDUSTRIAL AND CONSTRUCTION EQUIPMENT G ENE RAL OFFICES BUCHANAN PLANT PLANTS:
ZIP COD E BucHANAN, M.rcHIGAN BUCHANAN, MICH . 49107 BATTLE CREEK, MICH. Legal Department JACKSON, MICH. April 24, 1967 BENTON HARBOR, MICH. Secretary U. S. Atomic Energy Commission DOCIETED Washington, D. C. 20545 IIUEC Re: Atomic Energy Commission 10 CFR P arts 30, 40, 50, 70, Facility and Materials Licenses
Dear Sir:
Clark Equipment Company is a licensee affected by the proposed fee schedule, indicated above. We wish to object to the imposition of such license fee arrangement, as presently proposed. Primarily, our objection lies in the area of constitutionality of such fees. The relativel y large amounts charged, in many of the fee schedules, would indicate that the fee system is primarily designed for revenue production, rather than nominal charges for administrative and regul atory expenses. There is no question that if the fees are, essentially, a form of taxation, then only the House of Representatives and Congress would have the constitutional authority to levy such taxe s, nor could such rights be delegated to the Commission. (See Section 19 , Page 339, Volume 33, American Jurisprudence.) As a practical matter, aren't such large fees self-defeating ? It would appear that such large fees must be computed and absorbed in competitive bids, which the Government must ultimately pay. We sincerely hope that these objections will merit your thought-ful consideration. Sincerely yours, CLARK EQUIPMENT COMPANY
':--f.a-"ft'{', . B. Kenny JBK/Lgt Chief M e tall ist
OOC1Cfl NUMMRPR 3<<>, ~ ~ RUli .. 7&>, /70 PRINCE GEORGE'S COUNTY County Service Building, Hyattsville, Md. 20781 TELEPHONE: B64*7S00, B64
8121 ( 3D 11 COUNTY COMMIBSIONERB CI VI L DEFENSE AGEN CY G L A D Y S NOON SPELLMAN , CHAIR M AN R , HAL S I LVERS FR A N C I S B, FRANCO I S, VICE CHAIRMAN D I R E CT OR F R AN C I S J, ALU I SI JE SSE S, BAGGETT M , BAYNE BROOKE 26 April 1967 Secretary U. S. Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
With regard to the March 11, 1967, Notice of Proposed Rule Making, I offer the following comment: In Section 170.11, it is suggested that an ex-emption be added in the regulations as follows :
"No ... fee shall be required for:"
(a) (5) A license authorizing the receipt, possession, and use of 30 MC Cobalt 60 source-sets, or equivalent, for training purposes by custodians in bona-fide Federal, State, and Local Civil Defense organizations. Since the material is not for use by a profit-making organization, and represents a public use, the license fee would not appear to be applicable. Very truly yours, HAS/lf JJ~14L) Harold A. Siegel, Chief Radiation Defense copy: R. Hal Silvers, Director
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OOCtCET NUMBER P,R-10, <id, 50 PJlO'-OW> lUU . _~Deno UNIVERSITY OF COLORADO BOULDER. COLORADO PRESIDENT'S OFFICE April 24, 196 7 IUUrrt U&AEC APR27 1967 Secretary w. B. McCool frlc, ., tltt Sclte,J
u. s. Atomic Energy Commission "1Wlc ~lfllCl Washington, D. C.
Dear Mr. McCool:
This letter is written in regard to the proposed rule which would allow the AEC to charge license fees. We would suggest that educational institutions be exempted from the license fees. The University of Colorado has four AEC licenses. The by-product materials, source materials, and gamma irradiation licenses are all maintained for the research programs at the University. The research using radio-isotopes is funded through grants and contracts from the Atomic Energy Commission, National Science Foundation, National Institutes of Health, Department of Health, Education, and Welfare, and the Department of Defense and its service branches. The license fees would be an added cost to the University which would be paid out of the grant and contract overhead funds. The small fee, paid to one branch of the Federal government from funds provided by another branch, may exceed the cost of passing the funds through the several offices involved. Sincerely yours,
~~'3b3 Pittsfield, Illinois, April 25, 1967.
Secretary,
u. s. Atomic Energy Commission, Washington, D.c. 20545
Dear Sir:
I am a co-holder of byproduct material license No. 12-8146-1 Amendment No.l (B66), issued in the name of the Pike County Civil Defense Agency, Radiological Dep-artment, Pittsfield, Illinois, permitting the use of a Cobalt 60 source of 30 millicuries total to used in train-ing of instrument operators and instrument calibration purposes. Since I am a volunteer instructor using this source in the training of radiological monitors for the protection of all citizens, I protest the proposal to charge a fee for this license so long as it is used in the public service as a civil defense training aid. Yours very truly,
~~~ -
Eldon Frank, Deputy Director, Pike County Civil Defense Agency, Pittsfield, Ill. 62363
MADONNA HIGH SCHOOL 157 NORTH ROOT STREET AURORA, lLuNOIS 60505 e DOC1(ET NUMBER eROP.OSf.D RUU PR-~,q~,so, 1", 17D April 24, 1967 Secretary U.S. Atomic Energy Commission Washington, D.C. 20545
Dear Sir:
According to a notice dated March 13, 1967, you are proposing to establish a license fee which would affect licensees using the OCD Training Source Set. Personally, I would like you to reconsider such a policy. It would seem that with the limited funds now available for Civil Defense such a step would only curtail the work. I am sure that this is not a part of your plan. Perhaps this was merely an oversight and merely rewording your proposal would assist us. Please do not think that I am trying to infringe on an area that is beyond my control. I am very interested in Civil Defense work and I feel that those involved in it need encouragement in rather than opposition to their efforts. Anything you or the membe rs of your connnission can do for us will certainly be appreciated. Thank you. Respectfully, aocKEHB ltSilEC ~J,uf;;, ~-l>>,)/,~ APR 27 1967 Sister M. Cyriaka Woida, O.S.F. tfttlle 11 1M secr~tarJ hllllc f1r9e,9~i11P Radiological Defense Officer
reenville
College GREE NV ILLE, ILLINOIS. 62246 T ELEPHONE 66 4-1 8 4 0 April 24, 1967 Secretary
u. s. At mic Ener y C .mmi 3s ion Wa3hin t n, D. C.
Dear Sir:
Recently the Atemic Ene r gy C .m..misgi n sent an tice t e ch licen3ee pr p 3ing the establishment f license fees . It w uld seem that the pr pesed regul tin would mean that those having the o.c . D. training 3et3 w uld als* have t p y fee . It would seem s thou h licensees wh 3e primary interest 13 in Civil Defense should be exempt from these fees . I w uld ls like t pr test the charging f fees t licensees wh are c nnected with educ a ti n 1 instituti ns. Thank y u f r y ur c nsider tin.
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1}7(. Ralph J. Miller, Chai rman Department f Physics RJM/jms PR271967 tfflalftlleS--,
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LAW DEPARTMENT CA BLE ADDRESS USSCOLAW PGHPA April 25, 1967 DOClETEI UUEC APR261967 Office af tlle Secretary Publlc ,ne"'~lnp Secretary U.S. Atomic Energy Commission Washington, D. C. 20545 RE: Notice of Proposed Rule Making on License Fees rear Sir: Mr. Price's letter of March 13, 1967, requested that written comments pertaining to the proposed amendments be submitted within 60 days of March 11. The comments of United States Steel Corporation are primarily limited to the proposed fees as applicable to renewal applications. It is felt that with respect to Category 1 (Section 170.31) the imposition of an annual fee to the exclusion of an application fee does not properly reflect the Commission's responsibility as contemplated in the proposal introduction. With respect to this category it would appear that the actual work involved on the part of the AEC is small but that what work is involved is largely confined to the original application. It is suggested, therefore, that the $25 fee be used as an application fee with no annual fee being imposed on this category. It is also noted that proposed fees would not be applicable "to general licenses at the present time". Insofar as this implies that such fees are or might be contemplated in the future, exception is taken to their propriety _insofar as this type of license is concerned, either at this time or in the future. CWW:sjg
BROWN UN IVERS I T Y Provulence, Rhode Island
02912 April 24, 1967 OtCKETU Ulltc Secretary APR261967 Atomic Energy Commission fflceoftlleSecrew,
!Ille llr~dll!P Washington, D. c.
Subject:
Proposed Rule Making, Part 170-Fees Facilities and Materials Licensed Under The Atomic Energy Act of 1954, As Amended
Dear Sir:
We have read with interest the notice of proposed rule-making that you sent to us on March 13. It appears to us that the Atomic Energy commission has built into the proposed rules sufficient flexibility so that the commission may use judgment in applying the proposed fees to educational institutions holding licenses for research purposes. We at Brown would prefer t o see the regulation prepared so that materials license fees would not be required of educational institutions. Almost all of our activities involving facilities or materials licensed by the Atomic Energy commission involve research sponsored by an agency of the Federal Government. I assume that any license fee established would be considered a direct cost of the research project and would thus be borne by the Government contract or grant. I hope that it will not be made necessary to in effect transfer these small fees from one Government agency, and in some cases from one part of the Atomic Energy commission, to the fee collecting office of the Atomic Energy commission. If the regulation is eventually adopted as now proposed, I urge that the commission make an educational institution such as Brown exempt from the payment of these license fees. Sincerely,
;lfl4L ),);;{;:;::;;-
Malcolm s. Stevens Vice President MSS:mc
THE VICTOREEN INSTRUMENT COMPANY 10101 WOODLAND AVE., CLEVELAND, OHIO 44104 . VICTDREEN PHONE: [2HII 71115*8200 TWX (810) 421*8287 TELEX 0118*153815 April 24, 1967 lt CIETEO USilEC APR 261967 Office of the Secretary U. S. Atomic Energy Commission Washington, D.c. 20545 REF: Docket No . PRM-30-17 Gentlemen: Victoreen Instrument Company wishes at this time to withdraw its petition for rule making contained in its letter dated April 23 , 1964 and assigned your docket No . PRM-30-17. The withdrawal of this petition, which involved the general licensing of electronic tubes containing up to 100 microcuries of americium- 241, is based upon (a) the decision that the seemingly remote possibility of destruction of one of these tubes in the field resulting in the spread of americium- 241 does not outweigh the potential danger due to the relatively high toxicity of americium- 241, and (b) the availability of other isotopes with much higher safe body burdens and the development of better techniques for incorporating these isotopes in sLmilar devices , which have come about in the interim. Yours very truly, VICTOREEN INS'rRUMENT COMPANY Cl£{}CJ?1;ao t.t;h~- C. Miller Radiological Safety Officer JCM/er
r n-t~ VICTOREEN INSTRUMENT CO. -U.S.POSTAGE 101. 0DLAND AVE.
CLEVELAND, OHIO 44104
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VICTDREEN
':E T-N METER 604856 Office of the -3e cretary U. S.Atomic Energy Commission ' Washington, D. C. 20545
OOCI~ NUMBER PR-11;, ~o, St;, P.RO~OStJ> RULE . __?i:J, /'10 STATE OF ILLINOIS CIVIL DEFENS.-E AGENCY 111 EAST MONROE STREET SPRINGFIELD, ILLINOIS 62706 TEL. (AREA CODE 217) SB 525-7860 . COL. DONOVAN M. VANCE STATE DIRECTOR April 24, 1967 Secretary U. S. Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
Transmitted herewith is an expression of the opinion of a Radiological Defense Officer from Mt. Carmel, Illinois, which pertains to license f ees for Civil Defense training. Sincerely, OUETED USl&EC
~/f:z,, ~ C-<_
D. M. Vance APR261967 Director llllf ,r Ille Secretary DMV: RSR: sn Milt Pnceedl*P Enc.
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NATIONAL LEAD COMPANY NUCLEAR METALS DIVISION (S18) 489-4781 1130 CENTRAL AVENUE, ALBANY, NEW YORK 12205 A. STEWART, JR. Manager April 24, 1967 Secretary United States Atomic Energy Commission Washington, D. C. 2 0545 Gentlemen: Pursuant to your publication on March 11, 1967, (32FR3995) of a proposed new regulation which would establish fees, I wish to make the following comments:
1. The establishment of these fees represents a new form of taxation which is discriminatory against an evolving industry.
It also appears that the income from these fees will be insignificant in terms of thecwera.11 expenditures in the Atomic Energy Program.
2. The principle of charging for licensing actions raises the question of creating a function that is not under government budgetary control and not under industrial control, and could conceivably grow at its own pleasure at industrial expense.

3. In certain areas of business; i.e., the development of non-nuclear uses of source material, the existence of these fees will substantially hamper participation by new firms.
I believe that the establishment of these fees at this time is premature and will be detrimental to the growth of the nuclear industry. fl~UlE APR 261967
~Et 0 A. Stewart, Jr.
Manager Offle&tft!le$ecn:w, l'nltlic klCo.talllP AS:bc
SINCE1 - OOCIET NUMBE~Pil IIQr.QSED au.LE '. _3~-~ 50 7~ t1b , Tln.l!PHONE, WALNUT 5.7157.se JAMES M. CAS MANUFACTURERS - ENGINEERS - DISTRIBUTORS CHARLES FORD FIRE PROTECTION SPECIALISTS PA . REG . ENG. NO, 7843 918 VINE STREET PHILADELPHIA, PA. 19107 April 21, 1967 Secretary , United States Atomic Energy Commission Washington,D C 20545
Dear Sir:
Your notice to AEC licensees dated March 13, 1967, invited comments on the proposed establishment of fees for materials licensees. These are our comments. We wonder if this establishment of fees might not be in restraint of trade for Small Business. We are presently one of more than 100 distributors of the products of Pyrotronics inc. , manufacturer of Pyralarm Fire Detector devices. There are in Philadelphia alone 2 other such distributors. We operate over an area including Penna. , Delaware, Maryland and New Jersey. Altogether crossing the lines of almost a dozen distributors. If these states should decide to follow your lead in establishing license fees your modest fee for each of us would be multiplied by 4 and considering 12 of us it would amount to 48 fees for distribution of a single product in a very localized area. This would be requiring a new licensee to put up a substantial sum of money in anticipation of doing business in these states which might restrain him from entering business. If it is necessary to collect a fee to offset the cost of analyzing a specific product for distribution and to supervise the record keeping required for a specific license , we think it should be limitted one fee for a single product , regardless of how many distributors are at present or would in the future want to handle the product. We think this license fee imposes an unreasonable hardship upon Small Business engaged in the service of fire detecting devices. We would like to point out that these devices are used solely for the protection of life and property and protection of the public welfare as such we believe special consideration is in order. KET ED IJSiAEC APR2 5 1967 ftlr.e of tile Secrew,
/>ub//cBllrilc<:*~ings
Page 2 Secretary , April 21 , 1967 United States Atomic Energy Commission We take this opportunity to object formally to the imposition of an annual license fee for distributors of Pyralarm Fire Detection devices and respectfully request reconsideration by the Commission. ares Ford Registered Engineer President, James M. Castle, Inc. CF:mf
DOC1tET NUMBEIPR ~(),W),S'O,
- ., l!IQP.QUO RULE -~ . '"' no Sisters of Charity St.Vincent Hospital Santa Fe, New Mexico 87501-Telephone (505)983-3361 April 21, 1967 Secretary U.S. Atomic Energy Commission Washington, D.C. 20545
Dear Sir:
Reference to your letter of March 13, 1967, notice to AEC Licensees. The contents of the Federal Register~ March 11 , 1967 (32 F.R. 3995) is written to the effect that hospitals utiliz-ing radioactive materials must apply and be licensed annually. The number of procedures , although they are medically necessary, do not warrant the cost of licensing. Again, this is another increase to hospital costs initiated by the Federal government. Sincerely yours , APR DDIIIUI as 1967 Ass 1 t Administrator tffllttftl1C-- flaM*1*111
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Secretary PR 2 5 1967 G EORG E A. P OL K
u. s. Atom ere, dlnit on P .O. Box 237 Washington WES TFI EL D, I LL .
Re: License Fee OCD TBAINmNG SOURCE SET.
Dear Sir:
Relative to your recent letter propos i ng the establishment of a License Fee, for holders or new applications for License for use of Atomic :;Energy Products, which would include the Licensee of OCD Training Source Set, used for the training and calibrating bf Civil Defense trainees, and workers. It was at some considerable time, expense and over 2000 miles travel( 11 weekly trips of 186 miles each, in some very bad weather) in getting the necessary training to obtain a License for use of an OCD Training Source Set. It is my opinion that it would be well to cause a change in the announced policy of making a fee for the License for use of an OCD Training Source Set, which would serve the cause of Civil Defense better. In the second Class 4 others finished the Course successfully, (which I attended as a Reb her Course) and were entitled to apply for License wut did not do so, and no fee was involved, so it would seem best not to charge a fee f ar such a license. Very truly yours,0 nl
~r a . y H!,J(_/
License number George A. Polk.
~-10706-1 Westfield. Illinois 62474
RECE IVED 1167 AP 24 PM 32 U.S.J\ T011IC ENERG Y C1 iM. R~ 1tll .t-TORY MAIL & REC0 :: . SEC ION
W. PAUL WOODS, Mayor oocr-rr NU .
"W.. PR-_!{),lfO, S'll, EDWARD L. SALE, Director Dial 647-0065 PJOf!Oi(J) <<Ull ) E>{JR Dial 647-5155 210 E. CHESTNUT ST . Canton Civil Defense Agency CANTON, ILLINOIS @ April 19, 1967 Secretary u.s . Atomic Energy Commission Washington, n.c. 20545
Dear Sir,
I am writing this letter in regards to paragraph J of your notice dated March lJ, 1967 proposing the establishment of license fees which would include the licenses now held for use of the OCD Training Source Set . I presently hold license number 12-11947-01 which is used for the sole purpose of Civil Defense Training. It is my opinion that the establishment of a fee for licenses held for the sole purpose of training radiological monitors would be equivalent to charging a soldier for issuing him his serial number, as both are in the interest of National Defense. I have donated many hours of my time to Civil Defense and I assure you that if the AEC penalizes me for my public service, by charging license fees, they can have both my license and Training Source Set . I am sure that many other RD0 1 s feel the same way . If administrative expenses are such that fees are necessary, then may I suggest that said charges proposed for Source Set licences be made to the Defense Department and not to the local Civil Defense Agencies. el s, )
,,. z:, "
o Jr. 1 cc: Col. D. M. Vance Radiological Defense Officer Ill. State Dir. Fulton County Civil Defense 64J East Walnut Street Robt. S . Ritz Canton, Illinois 61520 (Residence)
Ill. State RDO Robt. McNamara Sec. Defense flfl UWD PR?51'67 tmce er the ~ Nie ._ llrnc*~- Oft4......
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GENERAL SURGERY JOSEPH E. STRODE , C. M. BURGESS, M.D. M.D. STRAUB CLINIC 888 SOUTH CT NUM13Eft
.osw KING STREET RULE PR 3D,Yt>,'St>, -1,,r:u, FOUNDED 1921 HONOLULU, HAWAII 96813 G. C. FREEMAN, M.D.
JAMES W. OiERRY, M.D. ANESTHESIOLOGY ELMARS M. BITTE , M.D.
. JOHN C. ROBERTS, M.D.
ARTHUR Y. SPRAGUE, M.D. April 20, 1967 NEUROLOGICAL SURGERY JOHN J . LOWREY, M.D. H. WM. GOEBERT, JR. , M.D. OCCUPATIONAL MEDICINE
& INDUSTRIAL SURGERY HERBERT K. N. LUKE, M.D.
ORTHOPEDIC SURGERY WILLIAM H. GULLEDGE , M.D. DONALD A. JONES, M.D. ALBERT Y. T. KONG, JR ., ALAN PAVEL, M. D. M.D. Secretary, United States Atomic Energy Commission OPHTHALMOLOGY SHIGEMI SUG IK I, M.D. Washington, D. C. 20545 OTOLARYNGOLOGY TRUETT V. BENNETT, M.D.
Dear Sir:
D. C. NEWBILL, JR ., M.D. R. T. KAKU, M.D. Re: Facility and Materi-a.ls Licenses Proposed Fees PERIPHERAL VASCULAR SURGERY ROBERT l. KISTNER , M.D. PLASTIC, RECONSTRUCTIVE I would like to state my opposition to the charging of fees
& MAXILLOFACIAL SURGERY for both the license application and the annual fee, particu-ELDON R. DYKES, M. D. larly for physicians in the practice of medicine.
THORACIC SURGERY NIALL M. SCULLY, M.D. Such charges at the price levels indicated by you would seem UROLOGY WALTER S. STRODE, M.D. to me to deter doctors from the practice of nuclear medicine, E. LEE SIMMONS, M.D. especially those starting out in the practice of nuclear medi-OBSTETRICS - GYNECOLOGY cine. It is my feeling that this would be better done on a COL IN C. McCORRISTON, M.D. RODNEY T. WEST, M.D. nominal basis without requiring either an application or an annu-FUGATE CARTY, M. D. W. J. NATOLI, M.D. al fee. WILLIAM H. HINDLf, M.D. INTERNAL MEDICINE H. L. ARNOLD, SR. , M.D. Thank you for this consideration. S. E. DOOLITTLE, M.D. L. CLAGETT BECK, M.D. F. I. GILBERT, JR. , G. 8. GARIS, M.D. M.D. Very truly yours, FRANK J. BRUCE, M.D. RALPH M. BEDDOW, M.D. ARTHUR W. NEILSON, JR ., M.D. NJ;;f\\. JAMES J . BALL , M.D. REGINALD HO, M.D. CARDIOVASCULAR DISEASE ~ -6 ALFRED S. HARTWELL, M.D. EDWARD L. OiESNE, M.D. DERMATOLOGY RAN:mk HARRY L. ARNOLD, JR. , M.D. RAYMOND M, WILLIAMS . M.D. ROBERT KIM, M.D. NEUROLOGY . U fED M. M. OKIHIRO, M.D. IJSAEC NUCLEAR MEDICINE ROBERT A. NORDYKe, M.D. PR 2 5 1967 PATHOLOGY I
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20545 D9ar :r,.rr . Ritz, t hat license s held for Civj l fuf9ns~ purpose s be 9xe mp t fr o~ tm Com.nission, and da.1..,ed March 13, 1967. We aN glad tha t Di!"3c '" or Vance se n t a l 9tter re - qw,sting emmpt ion, because W8 t oo are jn agr eemen t wH.h sarr3 . R9 spe ct fully, OCIETED UUEC APR 24 1967
-Pike County Civil Defense Agency Eldon R. At:wood, Director OOCi,ET Nur.1~:r: '")
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10c(2 0 Pittsfield, 1llinois 62363 April 19, 1967 Secretary of U. S. Atomic Commission Washington, D. C.
Dear Sir:
I have a c .Opy of the notice dated March 13, 1967 stating that the Atomic Energy Commission proposes the establishment of License fees which would include the license now held for use of the O.C.D. Training Source Set. It seems to me that the people who volunteer their services to train personnel for Radiological Defense should not be charged a license fee to use the Coliia l t 60 Source Set. At best, it is difficult to obtain qualified instructors, and if this fee is added, it will become more difficult. I have been training Radiological Monitors since 1957 and obtained a Source license five years ago. I have given all this training as a volunteer, receiving no compensation, ::. and should this license fee be applied, I, for one, will drop the project in this county. I have enjoyed teaching these classes and feel that it has been beneficial to the State and Federal Government as well as the local citizens of this area, but if I am required to pay for this service to the people, I cannot do so. incerely, OCH TED USlEC R~ Eldon R. Atwood, Director APR 24 1967 Pike County Civil Defense Off!c, of the Secretary Pt*b:lc Proc~~dlngs
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MUrdock 7-8000 A Subsidiary of Boker Industries, Inc.
JOSEPH E. JOHNSON President April 19, 1967 c* (
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Dear Sir:
This is in response to Notice to AEC Licensees, dated March 13, 1967, inviting
comments on the proposed establishment of fees for materials licenses.
Pyrotronics, Inc., is a manufacturer and distributor of Pyr-A-Larm fire detection devices. Each of our devices contain a small quantity of Americium 241 and as such comes under the rules and regulations of the Atomic Energy Commission. We are a Specific Licensee for the distribution of our product and market it through well over 100 distributors throughout the United States. Each of our distributors is required to have a Specific License for the transfer of the device and for the ins ta Ilat ion involved. The devices themse Ives are genera I ly licensed for sale to the public. We assume that our Specific License and those of our distributors comes under Category #1 which would provide for an annual fee of $25. The amount of the fee is not large but many of our distributors are very sma 11 businessmen and th is is another expense added to their operation which must be passed on to the end user. Since our product is designed for life safety and property protection against loss from fire, it is a most valuab le device in the protection of our country's assets. We would have serious objection to the imposition of the Iicense fee because of the added cost of doing business for distributors * . An even more serious objection can be implied by the fact that it is entirely possible that the Agreement States will follow the lead of the Atomic Energy Commission in imposing fees on materials licenses. Since our distributors operate in many in-stances, in severa I states, if such procedure is fol lowed they wou Id be required to pay license fees to each of the Agreement States in which they operate and the amounts of fees imposed cou Id be substantia I. It is our fee Iing that th is action by
Secretary. United States Atomic Energy Commission Page 2 April 19, 1967 the Atomic Energy Commission will set a precedent that will be duplicated and will cause increasing hardships in the distribution of life safety equipment. We request that the Commission reconsider its proposal to impose the annual license fees for the type of materia I which we distribute. Sincerely, JEJ:rsm
APR 2 4 1967 DOCKETED O&\EC Diat-ri utio
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WILKES COLLEGE WILKES-BARRE PENNSYLVANIA 18703 April 18, 196 7 Secretary United States Atomic Energy Commission Washington, D. C. 20545
Dear Mr. Secretary:
The Central Pennsylvania Section of the American Association of Physics Teachers held its annual meeting at Juniata College, Huntingdon, Pennsylvania, on April 14 and 15. At this meeting the proposed Atomic Energy Commission license fees were discussed. The Central Pennsylvania Section would like to go on record as opposing such fees for educational institutions. They feel that in view of the Atomic Energy Commission I s stated policy of promoting interest in the use of radioactive isotopes in education, it is impossible to reconcile a by-product material license fee with this stated policy. Surely, the small fees to be obtained from most four-year institutions are rather inconsequential in the Atomic Energy Commission 1 s overall budget, yet this small amount of money can be put to reasonably good use by these institutions. We certainly hope that it is not the Atomic Energy Commission 1 s intention to change its policy regarding the use of radioactive isotopes in colleges and high schools although the present proposed rule constituting license fees seems to change at least a minor portion of this policy. We are sending a copy of this letter to Dr. Arnold Strassenburg of the American Institute of Physics urging that the Institute take action to strongly oppose such a license fee. Sincerely,
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xYv;ftlt/41-/ SJH:hab S. J. Holden Secretary-Treasurer CC: Dr. Arnold Strassenburg American Institute of Physics 335 East 45th Street New York, New York 10017
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I FOUNDED 1921 7K, -i 70 STRAUB CLINIC GENERAL SURGERY 888 SOUTH KING STREET HONOLULU , HAWAII 96813 JOSE PH E. STRODE, M.D.
C. M. BURGESS, M.D. G. C. FRE EMAN , M.D. JAMES W, CHERRY, M.D. ANESTHESIOLOGY EIMARS M. BITTE, M.D.
. JOHN C. ROBERTS, M.D.
ARTHUR Y. SPRAGUE, M.D. April 17, 1967 NEUROLOGICAL SURGERY JOHN J . LOWREY, M.D. H. WM. GOEBERT, JR., M.D. Mr . w. B. McCool, Secretary OCCUPATIONAL MEDICINE
& INDUSTRIAL SURGERY Atomic Energy Commissi on HERBERT K. N. LUKE, M.D. Washington, D. C.
ORTHOPEDIC SURGERY WILLIAM H. GULLEDGE , DONALD A. JONES, M.D. M.D.
Dear Mr. McCool:
ALBERT Y. T. KONG, JR., M.D. ALAN PAVeL, M.D. I note in the March 11, 1967, Federal Register, pages 3995-3997, OPHTHALMOLOGY that there has been proposed a licensing fee for the use of SHIGEMI SUGIKI, M.D. byproduct materials. OTOLARYNGOLOGY TRUETT V. BENNETT, M.D. D. C. NEWBILL, JR., M.D. R. T. KAKU, M.D . I submit that the magnitude of the fee proposed is very excessive PERIPHERAL VASCULAR SURGERY and serves no us efu l purpose other than to raise the t otal cost ROBERT L. KISTNER , M.D. of medical care at a time when this has already become a prohibitive PLASTIC, RECONSTRUCTIVE expense.
& MAXILLOFACIAL SURGERY ELDON R. DYKES, M.D.
I presume t hat the purpose of the licensing is to control the THORACIC SURGERY NIALL M. SCULLY, M.D. utilization of radioactive byproduct material. This can be done with a similar fee such as is charged for narcotics licenses, UROLOGY WALTER S. STRODE, M.D. that is, $1 per year. I am sure that the Atomic Energy Commission E, LEE SIMMONS, M.D. is not pr oposing to become self-s upporting on the fees that it OBSTETRICS - GYNECOLOGY would collect from physicians for the licensing of byproduct COLIN C. McCORRISTON, M.D. RODNEY T. WEST, M.D. mater ial. FUGATE CARTY , M.D. W. J . NATOLI , M.D. WI LLIAM H. HI NDi e, M.D. I would greatly appreciate a prompt answer from you on this INTERNAL MEDICINE H. L. ARNOLD, SR. , M.D. matter. I have already written to Senators Daniel K. Inouye S. E. DOOLITTLE, L. CLAGETT BECK, M.D. M.D. and Hiram L. Fong , and Representatives Spark M. Matsunaga and F. I. GILBERT, JR. , G. 8. GARIS, M.D. M.D. Patsy Mink f or their information and propose t o pursue the FRANK J. BRUCE, RALPH M. BEDDOW, M.D. M.D. matter further should you plan to continue in your effort to ARTHUR W. NEILSON, JR ., JAMES J. BALL , M.D. M.D. charge such a fee. REGINALD HO, M.D. CARDIOVASCULAR DISEASE Sincerely ALFRED S. HARTWELL , M.D. EDWARD L. OiESNE, M.D. DERMATOLOGY HARRY t. ARNOLD, JR., M.D. RAYMOND M. WILLIAMS. M.D. ROBERT KIM, M.D . es J . all, M. D. NEUROLOGY side t, Hawaii Chapter M. M. OKIHIRO, M.D. iety of Nuclear Medicine NUCLEAR MEDICINE ROBERT A. NORDYKe, M.D. JJB: j a PATHOLOGY I. l . TILDEN, M.D. PEDIATRICS JOHN C. MILNOR, M.D. W. A. MYERS, M.D. H. M. SEXTON , M.D. DOCKETED GEORGE M. EWING , M.D. W. F. MOORE, M.D. USAEC JOHN R. STE PHENSON , M.D. PSYCHIATRY EDWIN P. GRAMLICH, M.D. RADIOLOGY R. G. RIGLER, M.D. D. R. GRININGER, M.D. EXECUTIVE ADMINISTRATOR RICHARD M. KENNEDY ASSISTANT ADMINISTRATOR THOMAS l . BATTISTO
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April 18, 1967 Engineered Products Division TAYLOR STREET and ABBE ROAD, ELYRIA. OHIO 44035 TEL: 216-323-3202 United States Atomic Energy Commission Washington, D.C. 20545 KET£ Attention: Mr. W. B. McCool, llSiAEc Secretary APR 2119
Subject:
10 CFR Parts 30,40,50,70,170 ffice at th Pub/fc o e Secret,,.,, 0 rroce,rl* ~J Bran -u1,1gs Facility and Material Licensees Proposed Fees Gentlemen: We are outwardly and openly opposed to a license fee. We see no reason to charge for a service that was forced upon the radiographic isotope user. We can well remember the promotion by government agencies to use isotopes for industrial radiography prior to its common usage. The services provided by the Atomic Energy Commission at this time was used as an inducement. If the commission is having financial or budget problems, these should have been considered prior to enacting legislature that would broaden their responsibilities and in turn require additional finance not included in the budget. We propose to inform our Congressman and Senate representatives that we do not favor such rule making and recommend that they act negatively upon passage.
~ i(i!:::::r Radiation Officer ENGINEERED PRODUCTS DIV.
Abex Corporation KCL/cds BRIOGWAHR TIRE MOLDS/ELECTRO-ALLOYS CASTINGS /ENGINEERED CASTINGS/ NATIONAL BEARINGS ANO CASTINGS
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312-528-2311 April 19, 196 7 DOCKETED U EC APR 2 11967 Office Of th Secretary Public Pr, e Secreter, OC3edings U.S. Atomic Energy Commission Branch Washington, D.C. 20545
Dear Sir:
As a licensee of the Atomic Energy Commission I received a notice of proposed rule making dated March 13th, 1967. My license covers the use and storage of an OCD Training Source Set which consists of six Cobalt-60 capsules totaling less than 30 millicuries. This material is essential in the teaching of radiological monitors and/or testing and calibrating several survey meters that monitors are trained with. Many hours were donated to receive the proper instructions to become a qualified radiological monitor instructor. Subsequently, many hours are used in an endeavor to form a sizeable class of prospective radio-logical monitors. During a course, many hours are needed for class preparation. Under the circumstances, I feel that an assessment by the Atomic Energy Connnission for the possession and use of the instructors most important tool would be unkindly to say the least. I suggest therefore, that the office of the OCD Training Source Set be declared an education~l tool for the training of Radiological Monitors and could therefore be exempt from any fees as outlined in the notice of proposed rule making. Yourst~ ~
William Lang AEC Lie. #12-11057-1 U-GWL/cf
The Illinois Civil Defense Council 17 April DOCKETED UStAEC APR 21 1967 Secretary, U.S. Atomic Energy Commission Washington , D. C. 20545
Dear Sir:
It is our understanding that the proposal for establishing a
$25 .00 fee for specific Atomic Energy Commission Byproduct Mat-erial Handling Licenses will include Civil Defense Radiological Monitor Instructors.
Most Radiological Monitor Instructors in the State of Illinois are unpaid dedicated volunteers . It has been difficult for local Civil Defense Directors to enlist qualified persons to take the necessary training to become licensed by your commission. It is felt that a $25.00 license fee would make our training pro-gram more difficult if not impossible in many cases . It is also felt that many of these persons qualified and licensed may drop out of the program because of this expense. The requirement for trained Radiological Monitor Instructors in Illinois is high. If a $25.00 fee is manditory we feel that we will be unable to get this particular phase of our program in gear. It is sincerely recommended that your commission exempt volunteer Civil Defense personnel from this license requirement. cfflf:Z/ char~~~ 1 y*
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President 44 E. Downer Place Aurora , Illinois 60504 CHB:es
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detroit, michigan 48227 APRIL 18, 1967 U.S. ATOMIC ENERGY COMMISSION WASHINGTON, D.C . 20545 ATTN: MR. HAROLD L. PRICE DIR. OF REGULATIONS INRE: YOUR LETTER 3/13 CONCERNING PROPOSED FEES FOR FACILITY AND MATERIALS LICENSES.
GENTLEMEN: WE WISH TO ENTER A STRONG PROTEST AGAINST THIS PROPOSED FEE SCHEDULE. WE FEEL THAT THESE FEES WOULD NOT BE IN THE BEST INTEREST OF THE ATOMIC ENERGY COMMISSION OR THE GENERAL POPU-LATION. WE ALSO FEEL THAT THEY WOULD DISCRIM I NATE AGAINST A PORTION OF THE POPULATION AND WOULD REPRESENT A VERY DUBIOUS ECONOMIC RETURN TO THE ATOMIC ENERGY COMMISSION. WE COMPLETELY FAIL TO SEE HOW THE ESTABLISHMENT OF THIS FEE SCHEDULE CAN BE OF ASSISTANCE IN "FOSTERING THE DEVELOPMENT OF NUCLEAR ENERGY". WE WOULD PARTICULARLY LIKE TO POINT OUT THAT AS PROPOSED THIS SCHEDULE DEFINITELY OPERATES AGAINST THE SM~LL OR NEW USER OF INDUSTRIAL RADIATION INSTRUMENTATION, THE COMPANY WITH A REQUIREMENT FOR A SINGLE, SIMPLE INDUSTRIAL LEVEL GAGE WHICH MIGHT COST $800. WOULD BE FACED WITH AN ADDITIONAL EX-PENSE OF $25.00 PER YEAR. THIS FEE WOULD BE THE SAME FOR A LARGE CHEMICAL COMPANY WHICH MIGHT HAVE SEVERAL HUNDRED INSTALLATIONS. THIS FEE WOULD ALSO DISCOURAGE THE OWNER OF A GENERALLY LICENSED GAGE FROM TAKING THE NECESSARY TRAINING IN RADIATION SAFETY TO CONVERT THIS TO A SPECIFIC LICENSE, THIS ALSO APPEARS TO BE AGAINST THE BEST INTEREST OF THE AEC AND THE GENERAL P08ULATION. WE BELIEVE THAT THE PRIMARY PURPOSE OF THE LICENSING PROGRAM IS TO PROTECT THE GENERAL HEALTH AND WELFARE. THESE PURPOSES ARE IDENTICAL TO THE INSPECTION PROGRAMS OF THE UNITED STATES DEPARTMENT OF AGRICULTURE AND THE PUBLIC HEALTH SERVICE. To THE BEST OF MY KNOWLEDGE, THESE SERVICES ARE PROVIDED WITHOUT FEE TO THE SPECIFIC INDUSTRIES INVOLVED. WE THEREFORE BELIEVE THAT THE PROPOSED FEE SCHEDULE DISCRIMINATES AGAINST A PARTICULAR INDUSTRY. FINALLY, WE VERY SERIOUSLY DOUBT IF THE TOTAL INCOME DERIVED FROM THIS FEE SCHEDULE WOULD REPRESENT ANY PARTICULAR PROFIT TO THE GOVERNMENT. WE REFER PARTICULARLY TO THE $25.00
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U.S. ATOMIC ENERGY COMMISSION PAGE 4/18/67 ANNUAL FEE BUT ( THINK THE COMMENTS PROBABLY APPLY TO THE REST OF THE FEE SCHEDULE AS WELL. By THIS WE MEAN THIT WE SERIOUSLY DOUBT WHETHER THE $25.00 WILL EQUAL THE COST TO THE COMMISSION OF COLLECTING THE FEE. I THINK THIS IS EVEN MORE LIKELY TO BE TRUE WHEN YOU CONSIDER THE COST TO PRIVATE INDUSTRY IN TERMS OF BOOKKEEPING AND OVERHEAD TO PAY THIS FEE SCHEDULE. IN OTHERWORDS, MOST CORPORATIONS OF ANY SIZE FIGURE THAT IT COSTS THEM FROM $10. TO $25. TO HANDLE THE PAPERWORK INVOLVED WITH MAKING A SPECIFIC PAYMENT. SINCE USUALLY HALF OF THIS COST REPRESENTS INCOME TAX WHICH WOULD HAVE BEEN PAID TO THE FEDERAL GOVERNMENT, I FAIL TO SEE WHERE THERE CAN BE ANY NET GAIN. WE CERTAINLY HOPE THAT THE COMMISSION WILL RECONSIDER THIS PROPOSED FEE SCHEDULE. VERY TRULY YOURS, THE BASIC SERVICE CORPORAT[ON
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PAUL LAXALT GOVERNOR OF NEVADA STATE OF NEVADA OFFICE OF THE GOVERNOR CIVIL DEFENSE AND DISASTER AGENCY CARSON CITY, NEVADA 89701 DOCKETED April 14, 1967 fJSiAEC APR 2 01967 Secretary U. S. Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
This concerns the Commission s proposed new Part 170 of 10 CFR, which 1 would require the payment of filing and annual license fees. We would like to suggest that all State Civil Defense Agencies be exempt from suc h fees for the following reasons:
l. Where licenses are held for calibration purposes, fees charged to civil defense agencies would be strictly federal money from the Office of Civil Defense. This would be a case where one federal agency is charging another federal agency fees. We see no reason for such a transfer of funds; it is just increasing the paper work.

2. Where licenses are held by civil defense agencies for educa-tional purposes such as the training of radiological monitors, we feel it justifiable and in the best public interest to ex-empt these licenses. State Civil Defense agencies t hat wou ld have to pay such fees are allocated little enough funds to per-form their functions concerning national defense and the pub-lic welfare. Even small additional costs would be felt and since other non-profit educational institutes are exempted we believe civil defense agencies should be exempted.
We would greatly appreciate your attention and consideration of the above suggestions. Sincerely,
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Director
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McLEAN COUNTY OFFICE OF CIVIL DEFENSE 310 N. MADISON BLOOMINGTON, ILL. 61701 Telephone 822-3385 Director AL THOMAS Lexington, Illinois 61753 April 18, 1967 Secretary U. S . Atomic Energy Commission Washington, D. C. 20545
Dear Sir,
We received a notice dated March 13, 1967 that the commission is proposing to establish license fees which would include the license's now held by Civil Defense Agencies for use of the o . c.D. Training Source Set . We believe that all license now held for such use should certainly be exempt from such fees. We would strongly recommend that you discuss this metter with Secretary of Defense Mr . McNamara and I am sure that in the interest of Civil Defense, he will concurr with us. Sincerely, tUI-L--= Al Thomas , Director AT:em cc: Rourke, EC-MAAC cc: Roberts. Ritz, Jr .
l-, r f" vs , W':f FP f,. LOCATED AT i v, l{ CJ,, rE~EPHONES 1505 CASEYVILLE AVE . -?d r J o ;-XPRESS 7-5130 SWANSEA, ILLINOIS * *** ~ ADAMS 3-3012 ST. CLAIR COUNTY OFFICE OF CIVIL DEFENSE P . 0. BOX 271 BELLEVILLE, ILLINOIS LAURENCE E . MILLER DIRECTOR April 1 7 , 19 6 7 Secretary U. S. Atomic Energy Commission Washington, D. C. 20545
Dear Mr. Secretary:
Reference is made to your notice dated March 13, 1967, wherein it is proposed by the Atomic Energy Commission to establish a license fe e for each licensee of the Commission. It is respectfully requested that you consider providing licenses to Civil Defense Agencies, both State and Local, on a no-charge basis. In order to promote the Radiological Defense Program of Civil Defense, it is necessary to maintain a license with your Commission in order to have use of a Source Set for training purposes. Inasmuch as this is the only use to which this particular type of license is applied, and inasmuch as there is no possible way of realizing profit in order to defray the expense of such licenses from this type of operation, it would assist materially with the National Program, the State and the Local Civil Defense to further the Radiological Defense Program at no additional cost. It is sincerely hoped that your review of this matter will be favorable so that we may continue with minimum expense for this operation. Sincerely yours, Laurence E. Miller, Director St. Clair County Civil LEM:cb cc: Wm. Eisele Robert S . Ritz, Jr.
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1 Washington, D. c. 20545 Dear Sirs The enclosed resolution is in response to your Notice To A EC Licenses dated March 13, 1967. The County of Crow Wing, Minnesota is opposed to the establishment of tees for licenses to possess and use radioactive Cobalt 60 sources for Civil Defense training.
The Licensees for Civil Defense maintain their eligibility only to use the Cobalt 60 Source Set in conducting Radiological Monitoring Training Courses sponsored by Civil Defense. The proposed Rule Ma.king as set forth in the notice of March 13, 1967, would deny to this county and its citizens the services of a licensed instructor. The training required in the development of a Radiological Moni taring System would be non-existent.
~~
Barbara Gosen, Director Crow Wing County Civil Defense BG:gl
Enclosure:
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3 o, CfcJ,~SV J WESTERN ILLINOIS UNIVERSITY MACOMB, ILLINOIS 614 55 April 16 , 1967 Secretary U. S. Atomic Energy Commission Washington , D. C. 20545
Dear Sir :
I am writting to you in reference to the fact that we people that are in Civil Defense teaching might have to pay a fee too hold our lis . and use radioactive material . I do not understand why we should have to pay to have a lis . and also pay to be able to use our source of material . The amout of material that we have in our possession is very little . Also we are not in this busness to make a profit like some organizations might be doing . We are in the busness of trying to teach people to be able to possibly sve their lifes and maybe several others . Who knows maybe one of the people or persons that we might help protect would be your own famillys and friends . We put alot of time into our effort and study so that we can do just that . I personlly think that you should reavaulate your thoughts on the subject . Im sure that many others think the same as I do . I will tell you this much that if we do have to pay a big fee that I will send back to people all the equipmentand sources that I have . At least I will have the satisfaction of knowning haw to use a set if need be done . Can you say the same . I think we should all be in this work together for the betterment of the people . For those that would use this materials I can understand the need of a fee and lis . If need be I would even come to you in person and help plead the case in behalf of our National Defense Program and self preservation thru our CO Program . r
,~~ygs Keith Lo~
Ramont Instructor Western Illinois University Police Dept . 900 Blk . W. Adams Street Macomb, Illinois
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- 41111 ~~ .Atomi,c Energy Commission proposes charging fees for nuclear licenses. Under proposed schedule, fees would be charged for licenses to construct and operate reactors and other production or utilization facilities, for specific licenses for the,; source* materials uranium and thorium, for radioisotopes, and for special nuclear materials uranium 233, uranium 235, and plutonium. Applicants for, anJ ' holders of construction permits or operating licenses would pay a $2,500 application fee for power reactors above 15 Mw(th), plus construction permit fees and operating license and annual fees depending on the size of the reactor:
up to 1000 Mw(th), $12,000 construction permit fee and $1 800 operating license and over 1,500 Mw(th) $27 QQQ and $3,800, respectively. _tions will be accepted by ABC until May 11, 1967. fee and annual fee ; for 1,000 to 1,500 Mw(th $18 000 and $2,700, respectively;
. Comments or sugges-
RE.CEW£.0 U.S. i OK *. t#,\l T\ON
' ~ &/. M J . ERVIN, JR,, N.C.
THO MI\S J . 00 0 0, CONN. JAM CS O. ~A~TLANO. MISS., CHAlnM. 9 JOHN L. MC CLr.LLAt,. AftKo EVERETT' MC K IN'LEY DIIO(ID'_ ILL,
,-OMAN L. HRUSKA, NCOft, HIAAM L, FONG, HAWAII r .-,.--
1"H IL1r A, HA.R1", MICH. HUGH scorr. .-A, \ ' LDWAHO V, LONG, MO . aTIIIOM THUftMOND 1 8,C. (OWARO M. K£NNEOY, MASS 0 GIRCH OAYH, IND. ~ Cnifccl ..$fa£cz *..$enafe QU(NTIN N. o u no1Ct<, N. OAK, JOSlii:PH 0, TYOINOS, MO, ,COMMITTEE ON THE .JUDICIARY GCOftOit A, MATHt.,.S , l"LA,
.. April 4, 1967 .\\ .* * .\
Dr. Glenn T. Seaborg Chairman Atomic Energy Conmunission, United States Washington, D. C. 20545
Dear Mr. Chairman:
I am writing with reference to the Commission's proposed regulation requiring fees of licensees of radioactive isotopes, published in the Federal Register of March 11, 1967. In this connection, I am forwarding to you a suggestion . made to me that the regulation exempt practicing physicians from the requirement to pay such fees, as a service to pa-tients requiring use of radioactive isotopes. I call your attention to the suggestion for consideration of the Commis-* sion when the proposed .regulation comes before it for action. With kind regards and aloha,
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Sincerely yours,
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. W. CAR~£N1'1irf March 28, 1967 MASAJI MAHVMOTc.) '
AA50N AL.CX !.Ml'l"H Honorable Hiram Fong U. s. Senator *- -.
1107 New Senate Office Building Washington, D. c. 20510 L
Dear Senator Fong:
Please find enclosed a copy of a le~ter written to the ... Atomic Energy Commi~sion concerning the pl."oposal to establish fees for a license t~ usG radioactive isotopes. As written the proposal would require an annual lice~se
. fee for all holders 0£ AEC licens2s and in some cases there would also be an application fee.
I would ask that you use your good o~Iices to writ~ into the proposal a spec:i;f ic exe:raptio1) for physicians. The over-all income from the ' physician 1 s lice nses would not be great ahd
y~t the fees are such that they would deter physicians fron obtaining a.nd maintaining Atomic Energy- Corr.mission licenses.
. . *:** Hay I suggest that as an altcrnc.:tive, a *nominal $1.00 *. . -: *. r~gistration fee
such as is used by the Internal Revenue
, S~rvice for medical uses of narcotics * . Sincere1~,,
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Reference:
Proposed T.,:cc;i.se Fee for AT-.:C I.ice".!Se:.=!s De.:ir Sir: I wish to protest the p-:oposal for th.:: cstaEishm~r.t of lic~n.;~ 1-::c::: for the use of biproduct material as pu~lishcd in the Fed~:al Ro3ictc~, March 11, 1967, pgs. 3995 to 3997. As I interpret the pro?osal, thia wo~!J include liccri~i ~ h~ld by physicians for diagnosis and treatm~nt c~ patients. The rc~ulatio~s would deter tha use of byprocl~ct m~tc=i~1 in ~sJ ic ~l arplic2tions pc1):"ticularly c;.rr.onz yc,rn:; :,hy:::ici~ns jl.!St co~.1; , ;.6 t:i_ :::.:.:; :::*, ,:::.;.: trciin i ~g. It is this g-:oup of p~1ynicic.~1~ \*ii.~o chould be ~)i":.~i: ir;u ]. ~*:.~.: !.. y \.;~1'2-(.;~~-:~::; r.:d
to becoi;.e licensed and talce a,1 a:::tive pa.:-t :i.n .tl:-c! e:,tci:{c::r.:-~::; :.=~_c:.V, c.f ,,,_-_ :~12.-:.:
medicine. Tr.e regul.:>.tions would .,ilGo ci,c:::te1* phys::.ci.:i.nG lii~1a ;;1:,:n -::-.)_:~ n i10 (iO not use isotore daily but who r:iaintain ,m ' ~tivc intG:CCSt .::r.C: p-;:*oii-:i::?::(;y :!.:':
*'-. nu-:lecir medicine *.
I '/, I think there ii a parallel in the ijternal revenue lice~~e fe~s fo~ the use of narcotics in madicine. Thera a 1ice1:.J e f 2c f o~.. c :'i:7'.::'". .~:*:~ i~~ 1 but for r.,~dical use by physicit.ns, the is ke~: at a ~c~i =n~ $ 1.~( cc: ~ ~nor2~! ~ Patcy Hbk
}lc no:ro.".Jla Spa*:k :,rc.t3 u.1a3a Honorc;~le Hiram Fon.:;
Honorsbla Daniel K. !.nouye ;- '.* * **:
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JOHN 6TCNNIS, MISS. MARGARET C. .MrTH MAIN& L,r,*~s1w .,"' F<<.. STUAR T SYMING T ON , MO, HCNRY M , JACKSO N , WASH,
'sTROM n-iU AMON O , 11,C.,
J ACK M ILL£", SOWA cc, **:-* '. ,.. ,; 01 ((o_, s- c1 5AM J, EAVIN, JR,, N, C, JOHN Q, TOWEPt, Tli:)(,
HOWAPIIO }'V, CAN NON, NEY , JA MEi a, P'EA,.BON, KANI. ROOCAT C . DYAD, W, VA , Ps:TCR H, DOMINICK, COLO, .: _..: "-- 7 ~7 (J &"TCPHEN M, YOUNO, OHIO ' DANIEL K, INOUY E , HAWAII THOMAS J, MC INTY,..E:. N,H 1 DAN I CL B, B .. EWSTE", MO, COMMITTEE ON ARMED SERVICES . kAIUtY P', B'VftO, Jft,, VA, WILLIAM Ho OAftOEN, CHJEP' OP' fJTA.,,.,, April 5, 1967 CHAIILEI , KUUtOW, CHI CIF CLl:IIK CI
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1* Mr. w. B. McCool Secretary Atomic Energy Commission Washington, D. C.
Dear Mr. McCool:
I ' have *received protests from a number . of physicians in Hawaii regarding the proposed fees for the users of radio-active isotopes. It seems to me that while it is often desirable to have a reasonable return on government sponsored research, it might be wiser to realize this return from more commercial enterprises than that represented by the medical profession. It would seem to me that if such fees were not nominal, they would probably be multiplied and passed on to the pa-tient. Perhaps there are other matters which .. I have not considered, but not knowing the particulars, this would be my initial impression. States Senator DKI:at
COMMITTEE ON -R9E: ' BANKING ANO CURRENCY 10TH 01aT,.1CT, GEOIIGIA Qtongress of tbe ~niteb ~ tatts L, r°('V$r~ f* f:{,lft 3i,ouse of l\epresentattbes 3°t,4£! ro,
~- ~ asbfngton, ;D.<lt. ~*" --~' ,* ~ ~ .. - '. :__ *..:-2.~ u April 3, 1967 Mr. W. B. McCool
Secretary to the Commission
u. s. Atomic Energy Commission Germantown, Maryland
Dear Mr. McCool:
I enclose herewith a let t e r I received from Dr. Menard Ihnen, Department of Pathology, The University .'~-* Hospital, Augusta, opposing the proposal to establish fees for the production or use of radioactive isotopes * . *
. . . *-, I would appreciate your taking Dr. Ihnen's views into consideration and, also , letting me know if the cost of this regulation of radioisotopes can
be derived from general funds a*n a not from fees as set forth in March 11th Federal Register.
Thank you *for this courtesy. Sincerely*,
,I RGSJr:r Enclosure
THE UNIVERSITY HOSPITAL LABORATORY AUGUSTA, GEORGIA PHONE: PArk 2-7731 DEPARTMENT OF PATHOLOGY MENARD IHNEN, M.D, March 27, 1967 JAMES W. MITCHENER, M.0, WILLIAM R. MURPHY, M.D. Honorable Robert G. Stephens House of Representatives Washington, D. c.
Dear Mr. Stephens:
I am writing to call attention to a proposal by the _ United States Atomic Energy Commission to establish fees for licensure for the production or use of radioactive isotopes. These proposals were published in the Federal Register, March 11, 1967. It is my belief that this proposal will prove to be a significant obstacle in the medical and industrial
*- ~ development of radioactive isotope techniques at a time when rapid development is urgently needed. Federal regulation of radioisotopes has the function of protection of the general public; federal regu l ation does not benefit those who must be licensed. For this reason, the cost of
this regulation should be derived from general funds and not from fees from those organizations or individuals who are trying to make effective use of these materials.
I would very much appreciatey,ur consideration of the views which I have expressed; if you agree with these views, I would also appreciate any influence which you might exert in opposition to the proposed rules. Sin~s,
' Menard Ihnen, M. D.
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BINGE, HAROLD C. -
(MASSILLON STEEL CASTING co.) L, r ('.c .,_ s; ,_~! /:~p,, r- -* ,
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Respectfully referred to Vrc . Wo B. McCool, Secretary Atomic Energy Commission Washington, D. C. for such consideration as the communication herewith submitted may warrant, and for a report thereon, in duplicate to accompany return of . (
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MANUFACTURERS OF April 6, 1967 CARBON AND ALLOY STEEL CASTINGS COMPL.e:Te: PATTERN SHOP The Honorable Frank J. Lausche Senate Office Building Washington 25, D.C. My dear Senator Lausche: Please find enclosed our comments to the United States Atomic Energy Commission concerning the proposed rule ch a n g es, to enable the collection of license fees for new facilities and material uses. We hope that the en-closed meets with your approval and with that feeling you will suppoTt such action as will direct the program in the direction suggested in our comments. Very truly yours, THE MASSILLON STEEL CASTING COMPANY
~7/' I /j' ./) * / /121-1~41t?: ;/.CJ11v/-
HCB:bw Haro1d C. Binge/ President and Encl. General Manager *
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MASSILLON, OHIO 44646*PHONE: TEMPLE 2-7451 M A NUFACTUR E RS OF Ar.:.--* 1 6, 1967 CA RBON AN D ALLOY STEEL CAST IN GS COMPLETE PATTERN SHOP
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I **
~ P.;RK. M. MATSUN AGA MEMDER1
' *
RULES COMMlllEE
' . HAWAII S(CAETARY1 6TEERINQ COMMITTEE 132.1 LoNGWO,..TH EJu1L.DINO 20515 <lon~re.zz of tbe ~niteb ~tate%* . L (.(' hd iii I (=;st-,,
HONOLULU OFFIC £1 218 FCOCRAL. BUILOINO ~ouze of 3Reprezentatiue~ j " i 'f-01 r v 96813 ' I I *. 7 v - 1_2.p Mla.s'Dington, 11).~. March 31, 1967 Chairman Atomic Energy Commission Washington, D. C. 20545
Dear Mr~ Chairman:
The enclosed correspondence from Dr. Richard R. Kelley, The Queen's Hospital, Honolulu, Hawaii, is forwarded for appropriate consideration. Please investigate the statements contained therein
_and forward me the necessary information for reply.
Your fullest consideration with respect to the alternative suggestions made by Dr. Kelley concerning the proposal to establish -.fees for a license to us~ radioactive isotopes will be appreciated .* Aloha ~nd b~st wishes. Sincerely, iJ~;z;,4 - Spark M. Matsuna~a Member of .Congres Enclosures
. . *. '.* . ' :~ ,' . . ..
"'* 0 1RCCTORS
C. C. Q.l.";CK . PACSIOCNT.
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CART CR CAL. T OOUCL.A5 S . GU l LO Al.l.CN C . WILCOX , JR , , VICC PA'£&1O(N1° MAS . C . J, HA5TCA1 KCNN(TH A. Nu~s,. SCCRETARV 1fonolnlu 6, }I.imaii A , J,HCO~RT Wll.l.lAM C. A..UL.l. WILLIAM C . KCA NATHAN F, OANFll:L.O, iRO . "
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MRS , HAL L.CWtS
""'O RT ON C, BCA" , M . 0 . I< , J , LUKC KC.NNCTH F . UROWN MRS, T, W , CARr'CNTER .March . 28, 1967 MASAJI MARUMOTO M, 8, CARSON Honorable Spark Matsunaga Member of Congress 1321 Longworth Building \
Washington,D. C. 20515
Dear Representative Matsunaga:
Please find enclosed a copy of a letter *written to the Atomic Energy Commission concerning the proposal . to establish fees for a license to use radioactive isotopes. As written the proposal would require an annual license fee for all holders of AEC licenses and in some cases there would also be an application fee. I would ask that you use your good offices to write into the proposal a specific exemption for physicians. The over-all income from .the physician's licenses would not be great *and : yet the fees are such that they would deter physicians from .*. obtaining and maintaining Atomic Energy Commission licenses. * .* . ,_,.
,...:.._> May I suggest that as an alternative, a nominal $1. 00 registration fee such as is
used by the Interval Revenue Service for medic&l . uses of narcotics.
' Sincerely, RRK:11 , . . .,*
1:. Enclosure
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ARSON Secretar y Unit ed States . Atomic Energy Commission ...,.. .... \
Washington, D. C. 20545
Reference:
Proposed Licen se Fee for AEC Licensees
Dear Sir:
I wish to protest the proposal for the estal>lshment of license fees
for the us e of b iproduct material as published

in the Federal Register, _
\~J~Harch 11, 196 7, pg~ . 3995 to 3997. * ..f\ As I interpret ,the proposal, this would include licenses held by physicians for diagnosis and treatment of patients.
The reg ul a tions would deter the use of byproduct material in medical a pplic a tions particularly among young physicians just completing their . traini rig . It is this gzoup of phynicians who should be particularly cncou;;c:igcd to b ecome lic e nsed and take an l!Ctive part in .the extending field of nuclear medic ine . The reg ul a tions would also deter physicians like myself who do not us _e i s otop e daily but_ who maintain an active interest and prof ici.ency in nuclear medicine *. I think there is a parallel in the internal revenue license fees for the us e of narcotics in medicine. There is a license fee for commercial users but for medical use by physicians, the fee is kept at a nominal $1.00 Sine r ely, *- *
.. Ri:d~t~~r-*
1 Path: logist . . * *
~
RRK: en cc: Honorab le Patsy Mink Honorable Spark Matsunaga Honorab l e Hiram Fong *.:* '\ Honorable Daniel K, ~nouye
*.... .../ .. .. *: .. -~. .. \ . ...*. ' *' .. ,*.
.J t-', 4 o, s v 7_~ 7 u STATE OF DELAWARE DEPARTMENT OF CIVIL DEFENSE J . ARNOLD SULLIVAN J>F.LAWAIIR CITY, J>F.LAWAHF. IU706 D I RECTOR 17 April 1967 United States Atanic Energy carmission Washington, D. c. 20545 Attention: Harold L. Price Director of Regulation Gentlemen:
This letter refers to your "Notice to AEC Licensees" dated 13 March 1967, We strongly object to the imposition of an annual (or any) licensing fee for custodians of Office of Civil Defense Radiation Training Source Sets. The sets are property of the Office of Civil Defense, on loan to the respective custodians for the purpose of conducting Civil Defense Training. If a fee is to be required, it should be paid by the Office of Civil Defense . As a suggestion, perhaps CO) could make one annual lump sum payment to cover all Civil Defense custodians. Attached is an information copy of a reply fran one of our local Civil Defense Directors, supp::>rting our p::>sition. encl. 1 cc: CO) Region 2
RECi:.t'/EO 1967 APR It; AM 11 28 U.S.ATOMlC ENERGY COMM. F/'G tll 'Tl'QY MAlL & 1kt.:U;11)J ~H:CTION
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.,,. .. ! Dir ec tor FOR YOUR U~f U
REGEi 1EO 1967 A R 18 AM 11 28 U.. 'TC, il C E ~ GY C M *
f. ." ')' A (1 Y MAIL . c.vJ,,.., ..,;::C TION
NATHANIEL ROCHESTER BOX 75 3 c.:> / 'f e-: S'<-; SOUTH DUXBURY 7-!i...!...7 0 MASS . 02374 April 17, 1967 Director of Regulations U. S. Atomic Energy Commission 4915 St. Elmo Avenue Bethesda, Maryland Attention: Mr. H. L. Price
Reference:
Your Letter of March 13, 1967
Dear Sir:
The proposed license fees for source materials seem unjust when applied to my case. I have an ionization guage (a Jordan Radector), bought August 11, 1955 for $200. It has a calibration source that originally contained 15 micro curies of Sr 90 which has now decayed to 11. 25. In the case of my calibration source, the proposed $25. 00 per year fee seems unreasonably large. Sincerely yours, Nathaniel Rochester
1%7 APR I~ PM 2 44
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March 30, 1967 Respectfully referred to Atomic Energy Commission Washington, D. C. 20545
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* *' for such consideration as the communication *I
1 herewith submitted may warrant, and for a report
,. , *: thereon, in duplicate to accompany return of / :i :.;
inclosure.
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'THE UNIVERSITY HOSPITAL LABORATORY AUGUSTA, GEORGIA PHONE: PArk 2-7731 DEPARTMENT OF PATHOLOGY MENARD IHNEN, M.D. March 27, 1967 JAMES W. MITCHENER, M.D.
WILLIAM R. MURPHY, M.D. Honorable Richard Russell
u. *s. senate Washington 25, D. c.
Dear Senator Russell:
I am writing to call attention to a proposal by the United States Atomic Energy Commission to establish fees for licensure for the production or use of radioactive isotopes. These proposals were published in the Federal
Register, March 11, 1967.
It is my belief that this proposal will prove to be a significant obstacle in the me dical and industrial d e velopment of radioactive isotope techniques at a time when rapid development is urgently needed. Federal regulation of radioisotopes has the function of protection of the general public; federal regulation does not benefit those who must be licensed. For this reason, the cos.t of this regulation should be derived from general funds and not from fees from those organizations or individuals who are trying to make effective use of these materials. I would very much appreciate your consideration of the views which I have expressed; if you agree with these views, I would also appreciate any influence which you might exert in opposition to the proposed rules. Sincgly yourS, Menard Ihnen, M. D.
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March 29, 1967 l
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Respectfully referred to DOCTOR GLENN T. SEABORG Chairman
'*1 ......... Jl.! .. R.~ .. At.omic...Ener.g;y: ..Co.mmis~ion ........................ .
I
. Washington, D. C. 20545 for such consideration as the communication herewith submitted may warrant, and for a re0ort * ; thereon, in duplicate to accompany return of
. ~ inc lo sure. By direction of WOINWM u. s. s.
. ---~... -.. .. . .. THE UNIVERSITY HOSPITAL LABORATORY AUGUSTA, GEORGIA PHONE: PArk 2-7731 DEPARTMENT OF PATHOLOGY MENARD IHNEN, M.D. March 27, 1967 JAMES W, MITCHENER, M.D. WILLIAM R, MURPHY, M.D.
*, I Honorable Herman Talmadge U. s. Senate Washington 25, D. c.
Dear Senator Talmadge:
I am writing to call attention to a proposal by the United States Atomic Energy Commission to establish fees for licensure for the production or use of radioactive isotopes. These proposals were published in the - Federal Register, March 11, 1967. It-is my belief that this proposal will prove to be a significant obstacle in the medical and industrial development of radioactive isotope techniques at a time when rapid development is urgently needed. Federal regulation of radioisotopes has the function of protection of the general public; federal regulation does not benefit those who must be licensed. For this reason, the cost of this regulation should be derived from general funds .and
not from fees from those organizations or individuals who are trying to make effective use of these materials.
I would very much appreciate your consideration of the views which I have expressed; if you agree with these views, I would also appreciate any influence which you Sir;r_:rs, might exert in opposition to these proposed rules. Menard Ihnen, M. D.
DOCKETED U&AEC APR 1 8 1967 Office of the Secretary Public Frcc,~dings i ll. B. J *
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DOCi',H NU1,i~:-r; r, ") _ 3D,'l6, 5'11 PROrOSED RULE r *\ 7&, (/0 KETEo IJSiAEC PR 181967 ilce of the Secret Ub//c l'rar * **1 ary Bran ?gs b .
Dtstmibution:
For l Pi
up e ntal U ecretaJ'Ut Public: Doe nt loom S:PAB GLHutton : aaf 4/ /67
TH E MERCER -------- HOSPITAL 446 BELLEVUE AVENUE
BOX 1658

TRENTON 8, NEW JERS EY 08607 Director of D epa,*tment of Radiology Associates ANDREW N. CONTE, M. D .
A ril J.L , 1967 S. W. CHAN. M. D.
,,J..I Pf . . .
Harol d L. Price Director of Regulation
u. S. Atomic Energy Commission Washington, D. C. 20545 Re : "Not i ce of Proposed Rule Making on License Fees"
Dear Mr. Price :
In reference to the above , we are licensed by the U. s. Atomic Ene gy Commission for the use of byproduct materials for human use. Our AEC Byproduct Materials License number is 29-01698-02 . I would like to know if the above proposal pertains to our use; and , if so, wha t the cost woul d be for applying for additional uses and/or renewal . Yours truly, DOCKETED ~ /.A..41'{,,<-~-<<.X...~V L £_ t1--I,-;{! y USilEC (Mr * ) Sylvia Hadad , R. T. De rtm3nt of Radiology APR 18 1967 o*rce af the secretarJ 1"J1]r. ~F-'C"'i~gs
RECEIV ED 1967 APR 17 M,1 11 48 U.S ./\ T0, *11 C EN RG Y COM,~.
~~.,l I P l y MAIL & It. *urli.J ' ECTION
~;-~'.~0sl i;u~~- ~- , * - ;~;7{:'
MONSANTO RESEARCH CORPORATION D AYTON LABORATORY
D AYTON , O HIO 45407 NUCLE AR S O U RCES D EPARTME NT 1615 NICHOLAS ROAD AR E A C ODE 5 13 PHONE 268 - 5481 14 Ap ril 1967 U. S . Atomic Energy Commission Washington., D. C. 20545 Attention: Mr . Harold L . Price 1Cb Director of Re g ulation ---..:.....--
Reference:
Notice of Proposed Rule Makin g on License Fees Gent l emen: In response to y our 13 March 196 7 letter inviting comme nts on the Proposed Rule Making, we would submit the followin g observa-tions : (1) Your letter relates the Commission ' s proposed fees to its r espons ibilit y for fostering the development of nuc l ear ene r gy . How the proposed fees wou l d serve this purpose is unclear to us, as a lic ensee . The facts wou l d appear quite to the contrary ., as the fees would impose still another element of cost on the licensees., however nominal the proposed fees may appear . The motivation for the p roposed fees and/or the rationale whereb y licensees would be taxed is unclear to us, and we feel it would be to the Commission ' s benefit to clarify this point . (2) The primary beneficiary of the Commission's r egulatory pro - grams i s the general p ub l ic . Insofar as the average licensee is concerned., the provisions of Chapter 10 are restrictive and, while they may be entirely justified in the public interest., they are a source of substanti al incremental operating costs . With the licen s ees bearing the costs incident to comp lianc e , it would ap p ear logical that the primary beneficiary of the re g ulations should bear the costs of the re g ulatory apparatus . (3) We have noted a number of ne g ative responses from the small users, individuals in some cases . We suggest you may wish to consider a one - time fee., without a continuing annual fee , if you conclude a fee, per se ., is in fact justified in these instances. A SUBSIDIARY OF MONSANTO COMPANY
U. S . Atomic Energy Commission 14 April 1967 In conclusion, it is our feeling that such license fees would be undesirable for a number of reasons . On the other hand, we acknow le dge the possibility that we may not have all the fac ts, and we wou ld again note the apparent need for the Commiss ion to clarify its objectives and purposes in proposing the fees. Very respectfully, R. Murph Jones Director, Nuclear Products RMJ/jec
I' PROM DATE OF DOCUMENT iENATOR PHILIP A. HART (MICH.) 4/]4/67 1 1 SUSPENSE DATE
FILE CODE ro CLASSIFICATION REPLY DATES SPECIAL INSTRUCTIO NS lCR Series, u Acknowledge,..,du.-_,.,4'--1--/__.J,..8,..___I D Appropriote Hondling Copy,_ _ _ _* of,_ __ lnteri .. ~ - - - - - - - ,
DESCRIPTION, I.TR Kl Original O Copy O Other Final PREPARE FOR SIGNATURE OF, ~RPu1'S . A LTR FM DINSMORE INSTRUMENr CO., R. C. DINSMJRE, 0 CHAIRMAN 0 DIV./O FFICE DIRECTOR illQUESTING THE SENATOR ' S SUPPORT AGAINST PERMITrING THE 0 GENERAL MANAGER XJ DIR, OE' ERG, lEC TO CHANGE ITS POSITION & OPERATION BY CHARGING 0 ASST. GENERAL MANAGE ~ICENSE FEES REMARKS,
NCLOSURES LTR DTD 3/28/67 TO SEN. HARI1 FM DINSIDRE INSTR NT CO.,
~. C. DINSMORE WITH CY OF LTR TO SECY. A.EC FM DINSMORE STRUMEN.r CO., DTD 3/28/67 ATrACHED. REFERRED TO DATE RECEIVED BY , DATE H interim r eply nec<'~s:n-y prennre for sig-!lntu~'c of ROBERT D. O'NT~ILL, mm~GTOR CONGRESSJ.ONAL RELATl.ONS and r oute dirc~tly to Congress ional Relations , INFORMATION COPIES SENT TO, 0 CHAIRMAN O GENERAL MANAGER _OO~C.....__ _ _ _ _ [X OC'R li S!;P. . L;;!;,;:;::!: S~E~ C::Y;t,~B~Qa!:B~~~ -------- GENERAL MANAGER'S COMMUNICATIONS CONTROL
,. , U, S , ATOMIC E ERQY COMMISSION * * ..,4, _ ~ri .,"'., '.~.J:... ~.:V: ,,._. -~~-, * ... "
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Respectfully referred to Congressional Liaision
.........................Atomic Ener_gy. Commission ...................... .
for such consideration as the communication 1j herewith submitted may warrant, and for a report thereon, in duplicate to accompany return of i ! ,. inc lo sure. By direction of
. ~
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.DINSMORE INSTRUMENT COMPANY BOX 3'°'5
FLINT, MICHIGAN "'8501 U'. S. A.
March 28, 1967
*Senator Phillip A. Hart Senate Building Washington, D. C.
Dear Senator Hart:
We are enclosing a photocopy of a letter we have recently sent to the Atomic Energy Commission. This very properly states our position on such fee charging and tax raising operations and we respectfully request your support against permitting the Atomic Energy Commission to change its position and operation by charging license fees. Very truly yours, DINSMORE IN TRUMENT COMPANY
~ R. C. Dinsmore
RCD/bw enc: photocopy of letter to the US Atomic Energy Comnission OCKETED.
Us.\EC PRl 7 1967
l fficP. of tilt Secretar,
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DINSMORE INSTRUMENT COMPANY aox 345 F l I N T, M *1 C H I G A N 4 8 5 0 1 u. s. A. March 28, 1967
Secretary, U.S. Atomic Energy Commission Washington, D. C. 20545 Gentlemen:
A 13 March notification from the Atomic Energy Commission, Harold L. Price, Director of Regulation, asks that any comments with regard to the proposed amendments for initiating a licensing fee be sent to this address. Our comments follow: We feel that since the Atomic Energy Commission is a division of the United States Government and is totally tax supported, that no license fees whatsoever should be initiated or charg-ed by the Commission. The Commission itself was essentially set up as a Public Service Commission to guard and protect the welfare of the people of the United States from the misuse of and dangerous use of atomic energy materials. To make such a body , a tax collecting body as well adds a duty, considerable extra work, a much more massive payroll, and a function that does not properly belong to sue~ a body. For the above reasons, we submit t.hat the addition of fees for such licenses and the collection of such fees should not be permitted to the Atomic Energy Commission . Very truly yours, DINSMORE INSTRUMENT COMPANY OCIETED R. C. Dinsmore USIAEC RCD/bw APR 1 7 1967
m~.e aiatqolic ,niuersitl;! of J\merit:a
~lhtsqington, lEL QL .20017 SCHOOL OF ENGINEERING AND ARCHITECTURE DIVISION OF NUCLEAR SCIENCE AND ENGINEERING DOCKETED USIAEC April 14, 1967 APR 1 7 1967 Dfflr.e Df the Setr WJ Secretary P&~!lc Frnc-:,r.!lngs U.S. Atomic Energy Commission Washington, D.C. 20545
Dear Sir:
With respect to the proposed change establishing license fees for operating licenses issued under 10 CFR Part 50 and for the by-product source and special nuclear materials licenses issued under 16 CFR Parts 30, 32-35, 40, and 70, we feel that the imposition of license costs within a small university environment would be prohibitive and would greatly restrict the use and certainly the expansion of the use of radioactive materials in our facility. Functioning within a university environment, with the limited budgetary considerations imposed in this framework, we feel that the fees would represent a significant and intolerable increase in our yearly operating budget. Such an increase would certainly prevent the continued use of radioactive materials and would, therefore, be in opposition to the intent of the U.S. Atomic Energy Commission to foster and further the utilization of radioactive materials and the generation of power from nuclear sources. It is further believed that the wording in the proposed rule is quite vague as it relates to educational institutions. We realize that the cost to the government of establishing the validity and safety of a request for a :facility license may be quite high. This cost, if passed on to an educational institution whose primary function is to train people in the safe handling and use of radioactive materials and nuclear power reactors appears to be illogical, as this will not foster but rather restrict training since fewer institutions will participate if required to pay an additional fee for this purpose. We cannot comment on the validity of the cost for construction per-mits for large power reactors but the initial cost of operating license and annual fees for a research reactor would be excessive for a university at the present time. It is the total of these proposed fees for the multi-plicity of licenses at a university that constitute an intolerable finan-cial burden. We believe that if one relatively small fee, on the order of
$100 per year, should be assessed to cover the spectrum of university licenses, i.e., a fixed fee independent of type of licenses or number.
To Secretary, U.S. Atomic Energy Commission We hope the foregoing explains our position and if further comments are desired, please do not hesitate to contact me. Sincerely yours,
? Lewis Battist, Ph.D.
University Radiological Safety Official cc: Dean D. E. Marlowe Rev. R. Trisco Dr. E. D. Jordan LB/em
£.. t C(bt.(,SLl,£i F('t- , ;j "' 4 V UNITED STATES DEPARTMENT OF THE INTERIOR FISH AND WILDLIFE SERVICE BUREAU OF COMMERCIAL FISHERIES RADIOBIOLOGICAL LABORAT ORY BEAUFORT, NORTH CAROLINA 28516 April 13, 1967 Secretary U.S. Atomic Energy Commission Washington, D.C. 20545
Dear Sir:
In reference to your notice of March 13, 1967, to AEC licensees, we have no objection to paying the license fee you propose if you deem it necessary. Sincerely yours,
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Thomas W. Duke Acting Director DOCKETE D USAEC APR 1 7 1967
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. ____ . 1..!:'-.,,..1? o Towson Baltimore Maryland 21204 VICE PRESIDENT-FINANCES GOUC H ER CO LL EG E 12April 1967 The Secretary U.S. Atomic Energy Commission Washington, D. C. 20545
Dear Sir :
I am writing to comment on the proposed rule published in the Federal Register on March 11, 1967. Goucher College presently holds a license for the use of byproduct materials. Under the proposed rule, I gather that we would be subject to an annual fee of $50.00. We presently use for teaching purposes approximately $.13 worth of P32 annually. The license fee seems disproportionate to the value of the materials being used and I would hope that the regulation can be revised to exempt specifically insti-tutions such as ours, which use only limited quantities of radioactive materials. If the regulation cannot be so re-written, I would hope that we could qualify for an exemption under the proposed paragraph 46 of section 170 . 11 . I appreciate your consideration of this request. Jr.
tf u1s1ANA C1v1L DEFENs A GENCY BLDG. 309A . AREA B . JACKSON . BARRACKS NEW ORLEANS. LOUISIANA 70140 12 April 1967 JOHN J . MCKEITHEN MARSHALL T. CAPPEL STATE DIRECTOR GOVERNOR L, r~ # s' II .1' F°,A t<l c, Secretary
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u. s. Atomic Energy Commission _7tJ.t. i 7 o Washington, D. c. 20545
Dear Sir:
In your "Notice to AEC Licensees" dated March 13, 1967, you requested connnents on the Atomic Energy Connnission's "Proposed Rule Making" regarding the establish-ment of fees for AEC licenses . After studying the proposal, as it was published in the Federal Register on March 11, and considering our position as civil defense, I have the following comments to offer: Civil Defense is a nonprofit, government supported activity dedicated to the public defense and welfare. Actually, it is government acting in disaster emergencies . We have 27 Byproduct Material License holders in Louisiana, mostly Civil Defense organizations; a few are individual holders . All are used in Civil Defense activities . Civil Defense budgets in most instances are inadequate and must be care fully _ administered . This is a case of government charging government with no gain . In view of the above, I feel that Civil Defense organizations should be exempt from payment of the proposed fee, and also, individuals licensed for OCD Training Source Sets used only in monitor training . Sincerely, DOCKETED IJ&tEc APR 171967 Office Of th Pub/fc , ,e Secretary
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m~e (llat~olic ,ni'uersiiij of J\mtrita J!llhts~iugton, ;!EL (ll. .20017 SCHOOL OF ENGINEERING ANO ARCHITECTURE DIVISION OF NUCLEAR SCIENCE AND ENGINEERING DOCKETED April 14, 1967 US!AEC Secretary U.S . Atomic Energy Commission Washington, D.C. 20545
Dear Sir:
This is in response to your notice of March 11, 1967 proposing the establishment of license fees for operating licenses issued under 10 CFR Part 50. I note that the proposed annual operating fee for research reactors up to a power level of one thermal-megawatt level would be
$300.00. We have an AGN-201 training reactor (no research capability}
with a maximum power rating 0.1 watt and with an operational level of no more than 100 hours a year. To put our reactor in the same class as a one thermal megawatt reactor with all its attendant licensing and regulatory problems is not realistic. We feel that such a fee would hamper our reactor operations and ultimately deter the effectiveness of our educational program. Therefore, as Reactor Administrator for this facility, I should like to strenuously protest the initiation of such a fee for a facility such as ours.
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Edward D. Jor an, Head Department of Nuclear Science and Engineering EDJ/eh
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March 24, 1967 Mr. Bennett L. Harless, Chief State Agreements Branch Division of State and Licensee Relations U.S. Atomic Energy Commission Washington, D. C. 20545
Dear Ben:
This office has been provided with a copy of a letter which Mr. H. Glasser of Radiological Service Company Inc. wrote to the
u. S. Atomic Energy Commission concerning the proposed license fees and whether his company, which is located within the State of New York, would be charged a fee, as i t relates to waste disposal.
I would appreciate your providing this office with a copy of any response that is sent to Mr. Glasser in connection with this matter. Furthermore, I would appreciate your attempting to deter-mine whether the application fee and license fee, which are specifically directed at waste disposal licensees, are limited to those organizations that are to dispose of radioactive waste by burial. The $500 application fee and $100 annual license fee might appear to be appropriate in a major waste burial operation, but this would seem to be extremely high in a situation where a company is really collecting wastes in approved packages for transfer to a burial facility. Since the evaluations associated with repackaging wastes are relatively straightforward, it would appear that even in this type of situation, the application and annual license fees are quite high. DOCKETED RDV:arns IJ&1Ec cc: Mr. H. Glasser
. t Dr. Morris Kleinfeld APR 111967 Mr. Hanson Blatz Dr. James Lade Mr. Sherwood Davies
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PRESIDENT VICE., PRES I DENT AND GENERAL MANAGER GUIDO R. PERERA ROIIERT F . DINNIE MONTAUP ELECTRIC COMPANY GENERAL OFFICES AND MAIL ADDRESS GENERATING STATION SOMERSET, MASSACHUSETTS April 14, 1967 P. O. BOX 391 FALL RIVER, MASSACHUSETTS 02722 IETtlJ IJ&AEO PR17 1967 Secretary, mo, f th, Secretary U.S. Atomic Energy Commission Pub,t ' nc -:dtnga Washington, D. c. 20545
Dear Sir:
COMMENTS - A.E.C, LICENSES PROPOSED AMENDMENT PART 170 AND RELATED FEE SCHEDULES In response to the Notice to A.E.C. Licensees dated March 13, 1967, we believe that nuclear materials licenses issued solely for Civil Defense purposes should be exempt from any fees. Yours very truly, MONTAUP ELECTRIC COMPANY R,£[)~ By: R. F. Dinnie, Vice President and General Manager.
. D,5'01 STATE OP- ILLINO . . r-,:, GENERAL OFFICE DEPARTMENT OF PUBLIC SAFETY SPRINGFIELD 62706 ROSS V. RANDOLPH*, DIHCTOII ~3 STATE OF ILLINOIS DEPARTMENT OF PUBLIC SAFETY April 12, 196 7 DIVISION OF STATE HIGHWAY POLICE SPRINGFIELD, ILLINOIS 62706 Secretary, U. s. Atomic Energy Commission
Washington, D. C. 20545
Dear Sir:
This Department has been informed of your proposal to establish a
$25.00 fee for specific Atomic Ener gy Commission By Product Material Handling Licenses. We therefore want to make the following comments and recommendations.
AEC Licenses are in the hands of twenty (20) persons in this Department and four (4) more will be requested in t he near future. We also anti-cipate a need for ten (10) more instructors in our institutions within the next twelve (12) months. These men are regular employees of the Department and are used to train the twelve hundred (1200) Illinois State Police and all Prison Guards as Radiologi cal Monitors. This is a continuing program to maintain an emergenc y operational capability . It is extremely difficult to get trained, dedicated people to handle these assi gnments. It would be difficult to obtain money to pay these fees and unthinkable to require the individual Department members to pay their own fees. Radiolo gi cal Monitoring training is a never ending task due to a never ending sequence of retirements, discharges, additional manpower, etc. The addition of paying these $25.00 fees could destroy the whole program. It is therefore recommended that Atomic Energy Commission By Product Material Handling Licenses granted by the AEC to users for training of Radiological Monitors for Civil Defense purposes be exempt from the requirement to pay a fee for the license as proposed by the commission. Sincerely,
~tt1 Ross V. Randolph D i r e c t o r RVR:DW:vll
ETH ICON I NC. S O MER V ILLE* NEW JERSE Y RESEARCH DIVISION April 13J 1967 DOCKETED U~EC Mr. W. B. McCool Secretary APR 1 7 1967 U.S. Atomic Energy Commission Office cf the Se:rctar1 WashingtonJ D. C. 20545 Public Prmedl,~i;s
Subject:
PROPOSED SCHEDULE OF FEES FOR LICENSES
Dear Mr. McCool:
We would like to make the following comments on the Schedule of Materials License Fees:
1. While we are in agreement that the collection of an application fee is justifiedJ we strongly urge the Commission to eliminate the annual fee possibly at the cost of some increase in the application fee.

2. The need to keep yearly records at both endsJ in addition to the multitude of other periodic re-porting and renewal requirementsJ means additional clericalJ filing and expense burden.

3. We cannot believe that the additional income would justify this burden. Perhaps it could even cost more to collect the renewal fees than what it would yield.
Why add another burden when the main mission of the AEC is the promotion of the use of radiation technology. SincerelyJ C ILT;;;{/4,/, J.t; Charle s J:a.:-;~ Ph.D. Director of ResearchJ Suture Products CA:s
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PHONE, 225-5541 1!,ouse of l\epresentatibes PHON E, 866-9271 BRIDG EPORT ROOM 841 DANIELE. R EED, JR. Ba~bfngton, 111).Ql:. 20515 855 M A IN STR EET DI S TRICT COORDINATOR PHONE, 335-1646 866-3325 April 13, 196 7 Hon. W! B. McCool Secretary to the Connnission Atomic Energy Connnission Washington, D. C.
Dear Mr. Secretary:
A constituent of mine has written to me opposing certain aspects of your proposed regulati ons which would establish license fees for many of your licensees. The particular case which interests me is that of the private practicing physician. Appended for your consideration is a letter by Dr. Willi.am Eckhardt . I think that the points he has made are well taken and I hope that you will review carefully this aspect of your proposals. DJI:ra OCKETEO US!AEC PR 14 1967
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Dear Congressman Irwin:
I am writing to call your attention to the enclosed notice to Atomic Energy Commission Licenses proposing a license fee schedule for the possession of byProduct radioactive isotopes. ~s with every article published in the Federal Register it becomes very unclear whether the proposed fees would apply to possessors of A.E.C. licenses for purely medical purposes. I am also enclos-ing a small introductory pamphlet about the growth of radioactive medicine and of the increasing wide dissemination of centers where radioactive medical diag-nosis can be performed. I am particularly interested in avoiding a fee schedu!e where it is applied to the medical uses of radioactivity. I started the first small unit for radioactive diagnosis in my office before any of the hospitals had established their own diagnosistic units. I think I would have been somewhat dissuaded from attempting to establish a radioactive medical unit, if additional fees had been applied by the Atomic Energy Commis-sion. The A.E.C. is turning over much of the regulatation of A. E.C. licensees (to states and it seems a little bit ambiguous for them to again now want to establish l.,a Federal License fee schedule. As far as the medical usage of tadioactivity are concerned, the Atornjc Fnergy Commi ssion inspects the units very periodically, to determine whether proper safety precautions are being employed.' It exerts no other direct or indirect function in the medical field, and it is for this reason that I feel an ,*additional fee schedule would stiffle the growth of what is one of the most fastest growing branches of medicine. I am also sending a copy of this letter to the Secretary of the U. s. Atomic Energy Commission, Washington, D. c., 20545 With warmest personal regards, I remain. Yours sincerely, William F. Eckhardt, Jr., M. D. WFE:amh dictated but not read or signed.
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OFFICIAL. BUSINESS l ~t, - 1967 Hon. W. B. McCool Secretary to the Connnissi ona Atomic Energy Commission Washington D. C. 20545
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DOCKETED U&AEC APR 14 1967 Office of the Secretary ullllc Proceedings rice I I I 7 4/ I 1
oocKET NUMBER PR io,'{o,s~, PROPOSED RU LE ., - ?o,r7o STATE OF I EW YORK ATO IC E RGY COORDI AT G Cou CIL COM TTEE O LICE SING P. 0 . Box 7036 ALBA Y, . Y. March 24, 1967 DOCKE TED USIAEC Mr. Bennett L. Harless, Chief State Agreements Branch Division of State and Licensee Relations U. S. Atomic Energy Commission Washington, D. c. 20545
Dear Ben:
This office has been provided with a copy of a letter which Mr . H. Glasser of Radiologica Service Company Inc. wrote to the U.S. Atomic Energy Commission concerning the proposed license fees and whether his company, which is located within the State of New York, would be charged a fee, as it relates to waste disposal. I would appreciate your providing this office with a copy of any response t ha t is sent to Mr. Glasser in connection with this matter . Furthermore, I would appreciate your attempting to deter-mine whether the application fee and license fee , which are specifically directed at waste disposal licensees, are limited to those organizations that are to dispose of radioactive waste by burial. The $500 application fee and $100 annual license fee ight appear to be appropriate in a major waste burial operation, but this would seem to be extremely high in a situation where a company is really collecting wastes in approved packages for transfer to a burial facility. Since the evaluations associated with repa ckaging wastes are relatively straightforward, it would appear that even in this type of situation, the applic ation and annual license fees are quite high *
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/'i;\ Illinois Bell ~ Telephone Company D. M. Goff April 12, 1967 civil defense coordinator Secretary, Atomic Energy Commission, Washington, D. C. 20.545
Dear Sir:
In reply to your notice to AEC Licensees concerning proposed fees for Facility and Material licenses, I would like to submit the following comments. Though the fee ie nominal for the type of Material License we have, it appears that the application and annual fees would be prohibitive to smaller organizations and i ndividuals. Even mor e important, however, the principle of paying a fee for in effect doing a service for the Government does not appear to be appropriate. The efforts of the Department of Defense-Office of Civil Defense to train radiological monitors throughout the Country will certainly be thwarted by this contradictory policy and, I feel, will negate the progress of the entire program. May I suggest a review of your position with the Office of Civil Defense before proceeding with the republication in the Federal Register of your action. Yours very truly,
&~w KETE D ~c PR 14 1967 b'e> Of' /!re- S"trCl?fl!Jr ~ulll/c Prnr.*,1,r.gs,
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INDIAN A UNIVERSITY M edical Center 1100 W E S T MICHI G A N S TR E ET INDIANAPOLIS , INDIANA 4620 7 DEPARTMENT OF RADIOLO G Y Apri 1 10, 1967 DOCKETED IJ&AEc APR 13 J967~ 4
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1l!g1 Secretary U. S. Atomic Energy Commission Washington, D. C. 20545
Dear Sir,
I would like to protest the lack of clarity of section 46 under paragraph 170.11 (Exemptions) in the proposed fees for atomic materials license under 10 CFR as it appeared in the Federal Register. I believe that educational institutions might be more precisely defined. I also believe that the wording is vague as to what serves the "public interest 11 and would allow the Commission to arbitrarily exempt some institutions and not others. It would seem more equitable to define non-profit, tax-supported educational institutions and exempt them, without allowing the committee arbitrary judgment. Respectfu 1 ly, F. Mishkin, M. D. Asst Professor of Radiology Director of Isotopes Ind i ana University Medical Center
'-< ce,~,,,,.s ftl__,t (:'(11 .- o, ~ tJI .f'V 7 '!,1../ 7 0 NEW. CASTLE COUNTY CIVIL DEFENSE CONTRQL CENTER, N.C.C. ENGINEERING BUILDING, KIRKWOO D HIGHWAY P.O. BOX 5137, WILMINGTON 8, DELAWARE .
OFFICE OF THE DIRECTOR 11 April 1967
Subject:
Re; Letter of 13 March 1967 " Notice to AEC License:s" To: Secretary U. S. Atomic Energy Commission Washington, D. C. 20545 Concerning r eference. letter *proposing establishment of license fees for operating licenses issued under 10 CFR Part 50 and for specific byproduct, Parts 30, 32-35, 40, and 70, I would .like to urge that fees not be charged for licenses
to p o sses and use sources for Civil Defense operations and instruction purposes.
Office of Civil Defense, Department of Defense grants free instruc-tion to individuals requiring such licenses because Civil Defense is not a profit making or commercial organization. Radiological Survey Instruments are provided free by OCD/ DOD and in order to calibrate in low levels and to teach use of the instruments licensed instructors are required. In most cases they are unpaid, volunteer individuals whose services wou ld be lost to Civil Defense if license fees are required. For this reason I strongly urgecnnsideration of no fees for licenses granted Civil Defense personnel engag ed in use of byproduct sources for teaching and handling Radiological Surve Instruments.
---~ ~~--.I._/
KET£ D Ee L. A. 31957 Ret . , Secrefllly Colo lli,7v IAZ/ g Dir Member: United States Civil D ense Council Delaware Valley Civil Defense Federati on Delmarva Peninsula Civil Defense Association
Nuclear Materials and Equipment Corporation Apollo, Pennsylvania 15613 Telephone 412-842-0111 Cable NUMEC September 9, 1968 Director of Regulations United States Atomic Energy Commission Washington, D.C. 20545 Attention: Mr. John L. Sul I ivan, Administrative Officer
Dear Sir:
Thank you for your letter dated August 13 regarding the estab-1ishment of I icenses fees. Among the fees is one for sealed sources of 100,000 curies or more for irradiation of materials. It would appear that establishment of this fee favors the use of machines for irradiation of materials. Accordingly, it is suggested that I icense fees be charged for such machines, or that fees be el im-inated for use of sealed sources. I would appreciate your comments. Very truly yours,
/pds DOCKETED IJS.m A Subsidiary of Atlantic Richfield Company
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GENER, Lfl ELECTRIC NUCLEAR ENERGY COMPANY DIVISION 175 CURTNER AVE., SAN JOSE, CALIF. 95125 . . AREA CODE 408 , TEL. 297-3000, TWX NO. 910-338-0116 Septem her 2 7, ootlEHD
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ott1ce at tlle seuetVY Secretary, U.S. Atomic Energy Commission P\IIIHC Pf'OC'-~~lnP Washington, D. C. 20545 Attention: Chief, Public Proceedings Branch
Subject:
License Fees for Facility Licenses and Materials Licenses Gentlemen: We have reviewed the amendments to Parts 30, 40, 50, and 70 and new Part 170 published in the Federal Register on August 1, 1968 (33 FR 10923). We respectfully suggest that the Commission revise the regulation at a convenient time in the future to indicate more clearly that license fees will not be required for certain facilities licensed for possession, but not for operation. It is our understanding that the Commission does not intend to assess fees for such facilities as the VBWR, EVESR and TCA which are currently licensed for "possession only". As a practical matter, sufficient evidence of that intent will be apparent by the absence of notices that fee payments are due for these non-operating reactors. Nevertheless, it is suggested that 10 CFR 170, Section 170.11, "Exemptions", be amended to include the following new subparagraph.
"A license authorizing the possession, but not the operation, of a production or utilization facility. 11 truly yours, D. Wilson Manager-Nuclear Safety-NFD MAIL CODE 824 ems
"j ) STATE OF NEW YORK DEPARTMENT OF COMMERCE 112 STATE STREET ALBANY , N .Y. 12207 NEAL L. MOYLAN FIRST DEPUTY COMMISSION ER September 27, 1968
CKErro US!AEC Secretary

CT 2 1968 U.S. Atomic Energy Commission rt/ce or the Seer t Washington, D.C . 20545 Public frr.c~*~in~~
Dear Sir:
We have reviewed the Commission's Notice of Rule Making published in the Federal Register August l, 1968 (33 FR 10923), establishing a new Part 170 of the Commission's regulations which imposes licensing fees for certain Commission licensees. We have noted the changes made from the proposed rule published March 11, 1967, particularly the elimination from the present regulation of most fees for materi als licensees. Since Agreement States would not be obliged to similarly impose fees on their licensees, the new regulation would not have a direct impact on the State's regulatory program. Nonetheless, we continue to feel that the Commission's fee requirements could affect the development of the atomic energy industry with an impact which extends beyond jurisdictional boundaries. We have noted the statement set forth in the Statement of Considerations, that the "Commission is continuing to study the matter of fees for materials licensees". In connection with the Commission's further study of this matter, we wish to reiterate our belief that licensing fees are not clearly warranted and properly should not be imposed on materials licensees. To assist the Commission's further study relating to imposition of fees on U.S. AEC materials licensees and to explore the effect upon Agreement State programs and upon activities conducted under multiple jurisdictions, we urge the Commission to establish a working group with representatives of Agreement States. Perhaps this can be accomplished as part of a regular or a special meeting of Agreement States with the Commission.
We also suggest that the Commission give further consid-eration to whether, in all cases, the existence of separate licenses warrants the imposition of separate and additive fees for activities which in some sense are related. For example, there may be instances in which an irradiated fuel element is removed from the reactor and used as a source of gamma radiation for experimental purposes which are not part of the oper atio n of the reactor. This is carried out under a separate byproduct and special nuclear materials license. While these two activities may be separate for the purposes of licensing requirements, we believe that the relationship may be sufficiently close as to make imposition of dual fees unwarranted and unnecessari ly burdensome . Executi ve Secretary New York State Atomic
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,. rrr \ ', ~3 Honorable Daniel~. Inouye United State* Senate Dear Senator Inouye1 In your letter of April 26, 196d, you asked to be advised of our final proposal concerning the etabl{.hment of fees for licensee to uao radio-isotope* Enclosed 1* an ABC presa release with a Notice of Rule Making in this matter wbich contain* the hteat text of the fee proposals. The notice wa published in the 1ederal Jtegister on Augu9t 1, 1968, to be effective October 1, 1968.
The . new schedule of fees differs in several w4ys from the proposal pub-lished for comment March 11, 1967. Among the more important change* ia the elimination of feu for radioisotopes licenses except for those for 100,000 curiaa or more in aealed aourcee, and tho** for waeta d1apoaal licensee. The Coaad.aaion 1a continuing to atudy the subject of fw for
*tarial 11ceaau not eonrtMI bJ th* achedule.
l _iacarely, ..
*c si~ned ) Harold L. Price Harold L. Price Mrector of laplatioa
Enclosure:
AEC Preas Rel...* DISTRIBUTION: Suppl File RPS Secretary (2) . Formal File OCR (2) Public Document Room OGC (2) DR Reading File HLPrice
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DATE *--~ 11 I 68 _____________ _. _81 ___ I 68 ________ _ HLPri~e ------*- ------------------------- --- - -------------c-- __ a1_ __ _/68. ___________ a[. ___L6a _________ *------------------------- .--- ~ .&.'S'V"'!-.tl:'IG./1l- G...At:\
Western New York Nuclear Research Center, Inc. ( Power Drive Buffalo, New York 14214 WASHINGTON . D .C . 20545 New York State Atomic Researcl
& Development Authority 230 Park Avenue New York New York 10017 August 13, 1968 IIT Research Institute 10 West 35th Street Chicago, Illinois 60616 NOTICE TO AEC LICENSEES ON LICENSE FEES Attached is a copy of a notice of rule making published by the Atomic Energy Commission in the Federal Register on August 1, 1968, establishing fees for facility construction permits and operating licenses and for certain specific byproduct, source, and special nuclear materials licenses.
We ~uggest that AEC licensees study the attached notice for the full scope and application of the rules and regulations pertaining to this subject. Attention is invited in particular to the schedules of fees in sections 170.21 and 170.31 of Part 170 and section 170.11 which includes a number of exemptions from fee requirements. An initial proposed license fee schedule was published for comment in the Federal Register on March 11, 1967. After consideration of the comments received, and upon further study, the Commission has adopted the attached rule which becomes effective on October 1, 1968. Under the established schedule, fees will be charged for licenses to con-struct and to operate nuclear reactors and other production or utilization facilities; for licenses for byproduct material of 100,000 curies or more in sealed sources used for irradiation of materials; for licenses for special nuclear material in quantities sufficient to form a critical mass (except plutonium-beryllium neutron sources); and for waste disposal licenses specifically authorizing the receipt of waste materials from other persons for the purpose of commercial disposal by the waste disposal licensee. The schedule adopted by the Commission differs from the earlier proposal in several ways, chief among which is the elimination of fees for byproduct material (radioisotope) licenses except for those of 100,000 curies or more in sealed sources and for waste disposal licenses . The Commission is continuing to study the subject of fees for materials licenses not covered by the current schedule. Revisions in the earlier proposal also have been made in the fees for reactor construction permits and operating licenses and for annual operating fees. Construction permit fees, operating license fees, and annual fees for power reactors will be based on the maximum capacity (expressed in thermal mega - watts) stated in the permit or license.
- Program Assistance Branch, RPS, August 21, 1968.
r August 13, 1968 Although the new Part 170 and appropriate amendments to Parts 30, 40, 50, and 70 have been adopted to be effective 60 days after publication, the Commission is inviting interested persons to submit comments within that time as indicated in the attached notice of rule making. Licensees are requ e sted not to remit fees at this time. Please note the following: I
1. Applications for construction permits or materials licens e s received by the Commission on or after October 1, 1968, will not be accepted for filing or processed prior to payment of the full fee specified in Section 170.21 or 170.31.

2. Fees for construction permits and operating licenses issued on or after October 1, 1968, are payable when the provisional construction permit or provisional operating license, if any, is issued. Otherwise, fees are payable when the construction permit or operating license is issued.

3. Annual fees are payable, for licenses outstanding on October 1, 1968, one year after October 1, 1968, and annually thereafter.

4. In the case of licenses issued after October 1, 1968 , annual fees are payable one year after the first of the month following the date of issuance of the license or provis i onal operating license, if any, whichever is earlier, and annually thereafter.
Questions regarding the attached notice of rule making should be submitt e d in writing to: Director of Regulation U.S. Atomic Energy Commission Washington, D. C. 20545 Attention: Mr. John L. Sullivan Administrative Officer ( Harold L. Price Director of Regulation
Attachment:
Notice of Rule Making
OOCl<ET NU tv"iSC: ,a.~O,S!,.Identical letters sent -- Saxton Nuclear Experimental RO~OSED RUL
111,170 - Corp .
UNITED STATES P. 0. Box 99
----~ ATOMIC ENERGY COMMISSION <:\} WASHINGTON , D.C. 20545 Saxton, Pennsylvania 16678 Rhode Island Nuclear Science Center DOCKETED South Ferry Road USl1EC Narragansett, Rhode Island August 13, 1968 02882 Consumers Public Power District Gen. Office P.O. Box 499 Columbus, Nebraska 68601 NOTICE TO AEC LICENSEES ON LICENSE FEES Attached is a copy of a notice of rule making published by the Atomic Energy Commission in the Federal Register on August 1, 1968, establishing fees for facility construction permits and operating licenses and for certain specific byproduct, source, and special nuclear materials licenses.
We suggest that AEC licensees study the attached notice for the full scope and application of the rules and regulations pertaining to this subject. Attention is invited in particular to the schedules of fees in sections 170.21 and 170.31 of Part 170 and section 170.11 which includes a number of exemptions from fee requirements. An initial proposed license fee schedule was published for comment in the Federal Register on March 11, 1967. After consideration of the comments received, and upon further study, the Commission has adopted the attached rule which becomes effective on October 1, 1968. Under the established schedule, fees will be charged for licenses to con-struct and to operate nuclear reactors and other production or utilization facilities; for licenses for byproduct material of 100,000 curies or more in sealed sources used for irradiation of materials; for licenses for special nuclear material in quantities sufficient to form a critical mass (except plutonium-beryllium neutron sources); and for waste disposal licenses specifically authorizing the receipt of waste materials from other persons for the purpose of commercial disposal by the waste disposal licensee. The s chedule adopted by the Commission differs from the earlier proposal in several ways, chief among which is the elimination of fees for byproduct material (radioisotope) licenses except for those of 100,000 curies or more in sealed sources and for waste disposal licenses . The Commission is continuing to study the subject of fees for materials licenses not covered by the current schedule. Revisions in the earlier proposal also have been made in the fees for reactor construction permits and operating licenses and for annual operating fees . Construction permit fees, operating license fees, and annual fees for power reactors will be based on the maximum capacity (expressed in thermal mega-watts) stated in the permit or license. - LProgram Assistance Branch, RPS, August 19, 1968_/
August 13, 1968 Although the new Part 170 and appropriate amendments to Parts 30, 40, SO, and 70 have been adopted to be effective 60 days after publication, the Commission is inviting interested persons to submit comments within that time as indicated in the attached notice of rule making. Licensees are requested not to remit fees at this time. Please note the following: \
1. Applications for construction permits or materials licens e s received by the Commission on or after October 1, 1968, will not be accepted for filing or processed prior to payment of the full fee specified in Section 170.21 or 170.31.

2. Fees for construction permits and operating licenses issued on or after October 1, 1968, are payable when the provisional construction permit or provisional operating license, if any, is issued. Otherwise, fees are payable when the construction permit or operating license is issued.

3. Annual fees are payable, for licenses outstanding on October 1, 1968, one year after October 1, 1968, and annually thereafter.

4. In the case of licenses issued after October 1, 1968, annual fees are payable one year after the first of the month following the date of issuance of the license or provisional operating license, if any, whichever is earlier, and annually thereafter.
Questions regarding the attached notice of rule making should be submitted in writing to: Director of Regulation U.S. Atomic Energy Commission Washington, D. C. 20545 Attention: Mr. John L. Sullivan Administrative Officer ( Harold L. Price Director of Regulation
Attachment:
Notice of Rule Making
August 13, 1968 NO?ICE TO AEC LTCENSEES ON LI CENSE FEES Attached is a copy of a notice of rule making published by E.ergy Commission in the F'ecleceal Register on Augus t 1, 1968 , estab li shi ng fees fo r facility constru~t*on permits and opera i ng licens es and for certain speci fic byproduc, source, and special nucl ear ma erials licenses . We sugg e t t' at ~EC lic ensees study the at t a c hed notice for the full s cope and app l ication of the rules and regu l at i ons pertaining to t h is subject . At ejtion is i vited in par ic lar t o the s chedu les of f ees in sections 170 . 21 and 170. 31 of Part 170 and s e c tion 170 . 11 whi ch inc ludes a numbe r o f e:,.emptio ns f r om fee requi remen t s * . An i~1itial proposed license fee nche<lule was publ i s e d for c ommen in the Fcuerai Re;1ister on 1.1.rch. 11, 1967 . After c ons i dera tion of t h e com:nents r c eived , ,:md U?On further study , the Co:mni s s ion ha s adop ed
-he att.:1cl1ed rule w1i c h becones effective 011 Oc obe r 1, 1968 .
Under the e st.'.l.1 lished schedule, :i:u::s will be c:wrged f or licens es t o c on-struct and to Oj_Jer.:1te nuclear l" -..,,~.:: cor,: ~:. <l oth r p r oduct i on or u t iliza tion facilit i es; for lice-:ses foi- :,., >_0C:uct __-;iteri.J.i of 100 , 000 curies or more in sen.led sources used for irt"c:i ' :i.*. i:::ion cf materia l s; fo r licen ses f or ep::::cial nuclear n.:: u::erial in qu.1:,tic::ie s suffic ient to foYm a critica l I cass (excep pluto:.1..i1:1- be:ryl iu:.:. neu;;ron sources) ; and fo ~ uas te di sposal 1
censes sp0c

f icolly a chori.zi.:-~3 *he. receipt: of waste mater i a l s f rom ot*-:.cr per:;;on.s fo r the urposc of ccr;z1e,:cial disposal by tl waste d isposal lice:n::::ce .
=~c schedule ado?ted by *he Cv~.::niss!o~ differs fro~ the ea r lier p r oposa l in several ,m.y3, c~,ic_ a,.1->!'~ *:;11ic!:: L t:1e elimination of fees for byproduct r:-.aterial (radioisoto_;>e) licec:s_s c:~cc~:,t for those of i O ,000 c r ies o r more in :,c£1.lcd scurces and for ,mste dislJOsal licenses . T 1e Cont!nission
s co .tin

n::; *-o study the subject: of fees for materials l icenses not c overed vY ,e cu rent s c ~cdule. Revisions in tle earlier propo sal a so have been made i11 the fee., for rcaCLOl' c0nstructi n permi sand oper a t ing i cens e s and :for ar:.,1 a opera in;; fees.
Construe ion per.,it fees, opera..:ing icense fees ~ and annua l f ees fo r power reactors ~:ill be based on the ,:w.xiI:n.:m capacit y ( expr e s s e d i 1 t he rmal mega - wattc) stated in tlc pe it or licenGe .
FEDERAL REGISTER, VOL. 33, NO, 149--THURSDAY, AUGUST 1, 1968 Rules and Regulations 33 FR 10923 Published 8/1/68 DOCKETED Effective 10/1/68
~EC AUG 16 1968-..
ff/co or the secretary Public *rnc:~dings rt1e 10-ATO. IC E. GY Chapter I-Atomic Energy Commission , LICENSE FEES FOR FACILITY LICENS::S AND MATERIALS LICENSES A notice of proposed rule making was published by the Atomic Energy Com-mission In the FEDERAL REGISTER on March 11, 1967 (32 F.R. 3995) proposing the establishment of license fees for facility construction permits and operat-ing licenses issued under 10 CFR Part 50 and for specific byproduct, source, and special nuclear material licenses issued under 10 CFR Parts 30, 40, and 70. The . fees were set out ih a proposed new Part 170. Amendments to Parts 30, 40, 50, and 70 to r eflect proposed application filing fee requirements also were proposed. The Commission's decision to propose fees for licenses was made in accordance with Title V of the Independent Offices Appropriation Act of 1952 (65 Stat. 290; 31 U.S.C. 483a) which states:
It Is the sense ot the Congress that any work, servi.ce, publication, report, document, benefit, privilege, authority, use, franchise, license, permit, certificate, registration, or sl!llllar thing o! value or utility performed, furnished, provided, granted,. prepared, or Issued by any Federal agency * *

to or tor any person (Including groups, associations, organizations, partnerships, corporations, or businesses), except those engaged in the transaction o! official business of the Gov-ernment, shall be self-sustaining to 'the full extent possible, and the head of each Federal agency Is authorized by regulation * * !' to prescribe therefor such 'fee, charge, or price, I! any, as he shall determine, in case none exists, or redetermine, in case ot an existing one, to be talr and equitable taking Into consideration direct and Indirect cost to the Government, value to the recipient, publlc policy or Interest served, and other perti-nent tacts * *

General policies for developing an equitable and uniform system of charges in implementation of the above-cited provisions of the-Independent Offices Ap-propriation Act of 1952, have been set forth by the Bureau of the Budget in Circular No. A-25 and In a memorandum
10924 RULES AND REGULATIONS dated February 15, 1955, directed to . poses, but does not have a loan agree- PART SO-LICENSING OF PRODUC-heads of Federal agencies. ment or university reactor assistance TION AND UTILIZATION FACILITIES The notice of proposed rule making al- ,contract with the Commission. lowed 60 days for comment by interested A new '§ 170.11 (a) (5) has been added 3. Section 50.30 of 10 CFR Part 50 is persons. By notice published in the which specifically exempts Government amended by adding a new paragraph (d) FEDERAL REGISTER on April 18, 1967 (32 agencies from licensing fe~s. ,. to z:ead as follows: F.R. 6099) the time for fl.ling comments A number of editorial changes of a § 50.30 Filing of applications £or Ii- . was extended to July 9, 1967. Many com- clarifying nature also have been made. censes, oath or affirmation. ments have been received. Pursuant to the Atomic Energy Act The amendments which follow have of 1954, as amended, and sections 552 * * * *
been adopted by the Commission after and 553 of title 5 of the United States (d) Filing fees . Each application for careful consideration of those comments Code, the following amendments to Title a production or utilization facility li-and further Commission study. The re- 10, Chapter 1, Code of Federal Regula- cense, including, whenever appropriate, a vised fee schedule eliminates most fees tions, Parts 30, 40, 50, and 70, and a new construction permit, othe:r than a license for materials licenses included in the pre- 10 CFR Part 170 are published as a docu- exempted from Part 170 of this chapter, viously proposed amendments, including ment subject to codification, to be effec- shall be accompanied by the fee

pre-those for medical uses. The Commission tive 60 days after publication in the FED- scribed in Part 170 of this chapter. No is continuing to study the matter of fees ERAL REGISTER. 'l'he Commission invites fee will be required to accompany an for materials licenses. all interested persons who desire to sub- application for renewal, amendment or The categories of materials licenses mit written comments or suggestions in termination of a construction permit or which will be subject to application fees connection with the amendments and operating license, except as provided in and annual fees are: regulation to send them to the Secretary, § 170.21 of this chapter.
a. Licenses for byproduct material of tJ.S. Atomic Energy Commission, Wash-100,000 curies or more in sealed sources ington, D.C. 20545, Attention: Chief, PART 70-SPECIAL NUCLEAR used for irradiation of materials; Public Proceedings Branch, within 60

b. Licenses for special nuclear material days after publication of this notice in MATERIAL in quantities sufficient to form a critical the FEDERAL REGISTER. Consideration will 4. Section 70.21 of 10 CFR Part 70 is mass, except for licenses for plutonium- be given such submission with the view amended by adding a new paragraph (e) beryllium neutron sources; and to possible amendments. Copies of com- to read as follows:

c. Waste disposal licenses specifically ments received may be examined at the authorizing the receipt of waste radio- Commission's Public Document Room at § 70.21 Filing.
active materials for the purpose of com- 1717 H Street NW., Washingto;n, D.C. * * * *
mercial disposal by land or sea burial. PART 30-RULES OF GENERAL APPLI- (e) Each application for a special nu-(This category of fees would not be appli- clear material license, other than a li-cable to licenses which authorize collec- CABILITY TO LICENSING OF BY- cense exempted from Part 170 of this tion, processing, storage, and transfer of PRODUCT MATERIAL chapter, and other than an application wastes to another person for land or 1. Section 30.32 of 10 CFR Part 30 ls

for renewal or amendment of a license, sea burial to be performed by the amended by adding a new paragraph* (e) shall be accompanied by the fee pre-transferee.) to read as follows:
The exception of licenses for special § 30.32 Applications for specifi!= licenses.
. scribed in § 170.31 of this chapter.1 nuclear material in plutonium-beryllium 5. Chapter 1 of Title 10 of the Code of neutron sources, which was not included * * * *
Federal Regulations is amended by add-1n the proposed rule, is based upon the (e) Each application for a byproduct ing a new part 170 to read as follows:
lack of criticality considerations involved ' material license, other than a license ex- PART 170-FEES FOR FACILITIES AND 1n the licensing of such sources. empted from Part 170 of this chapter, MATERIALS LICENSES UNDER THE The schedule of fees for licenses for and other than an application for re-production and utilization facilities in newal or amendment of a license, shall ATOMIC ENERGY ACT OF 1954, AS
§ 170.21 of Part 170 eliminates the broad be accompanied by the 1fee prescribed in AMENDED categorization of reactors set Jorth in Part 170 of this chapter . GENERAL PROVISIONS notice of proposed rule making published Sec.
on March 11, 1967. Fees for power 170.1 Purpose. PART 40-LICENSING OF SOURCE 170.2 Scope. reactors will be assessed on the basis MATERIAL 170.3 Definitions. of the number of megawatts of rated 170.4 Interpretations. power (sliding scale) of the facility 2. Section 40.31 of 10 CFR Part 40 is 170.5 Communications. involved. Single fees for other facilities amended by adding a new paragraph (f) 170.11 Exemptions. are established. The Commission con- to read as follows: 170.12 Payment of fees. siders that such a basis for assessment is § 40.31 Applications for specific licenses. ScHEDULE OF FEES more equitable than the grouping basis set forth in the notice of proposed rule * * * *
170.21 Schedule of fees ror production and making. (f) Each application for a source ma- utll!za.tlon facUltles.
170.31 Schedule or fees for materials Proposed § 170.11 (a) (4) has been re- terial license, other than a license ex- licenses.
vised to exempt from licensing fees li- empted from Part 170 of this chapter, censes for materials or facilities other and other than an application for re- ENroRCEMENT than power reactors issued to nonprofit newal or amendment of a license, shall 170.41 Failure by licensee to pay annual fee.
educational institutions, used for train- be accompanied by the fee prescribed in AUTHOJUTY: The provisions or this Part 170 ing, teaching, or medical purposes. Many Part 170 of this chapter.* ls&ued under 65 Stat. 290; 31 U.S.C. 483a v .. d licenses for facilities or materials of this sec. 161, 68 Stat. 948: 42 U.S.C. 2201. type would have fallen within the ex- !or Section 170.31 prescribes rees !or licenses 1 byproduct material or 100,000 curies or emption of § 170.11 (a) (4) as set forth in more in sealed aources used for irrad.!ation or 1 Section 170.31 prescribes fees for licenses the proposed rule for licenses issued to materials, and for waste disposal licenses tor special nuclear material In quantities nonprofit educational institutions hold- specifically authorizing receipt of waste by- sufficient to form a critical mass as defined ing an AEC research assistance contract product material from other persons !or com- In § 170.3 of this chapter, except for licenses* or loan agreement. The present exemp- mercial disposal by land or sea burial by the authorizing possession and use or plutonium-tion, however, applies to a nonprofit edu- waste disposal 11censee. berylllum neutron sources; and for waste dis-
Section 170.31 prescribes fees for waste posal licenses specifically authorizing the cational institution which is licensed to disposal licenses specifically authorizing the receipt or waste special nuclear material operate a facility, other than a power re- receipt or waste source material from other from other persons for commercial disposal
. actor, for teaching, training, or medical persons for commercial disposal by land or by land or sea burial by the waste disposal purposes or to use materials for such pur- sea burial by the waste c1isposa.J. licensee. licensee.
RULES AND REGULATIONS 10925 GENERAL PROVISIONS .to the provisions of §§ 50.21(b) or 50.22 (j) "Source material" means:
§ 170.1 Purpose. of this chapter. (1) Uranium or thorium, or any com- <g> "Production facility" means: bination thereof, in any physical or The regulations in this part set out o > Any nuclear reactor designed or chemical form; or
fees charged for licensing services ren- used primarily for the formation of plu-dered by the Atomic Energy Commission, <2> Ores wh!ch contain by weight tonium or uranium-233; or one-twentieth of one percent (0.05 % ) or as authorized under Title V of the Inde- (2) Any facility designed or used for more of (i> uranium, <ii) thorium, or pendent Offices Appropriation Act of the separation of the isotopes of uranium (iii) any combination thereof. Source 1952 (65 Stat. 290; 31 U.S.C. 483a) and or the isotopes of plutonium, except lab-provisions regarding their payment. ora.tory scale facilities designed or used material does not include special nuclear material. *
§ 170.2 Scope. for experimental or analytical purposes only; or <k> "Special nuclear material" means:
Ex~ept for persons who apply for or (3) Any facility designed or used for (1) Plutonium, uranium-233, uranium hold the licenses exempted in § 170.11, the processing of irradiated materials enriched in the isotope 233 or in tl-Je the regulations in this part apply to each containing special nuclear material, ex- isotope Z35, and any other material person; who is an applicant for, or holder cept (i) laboratory scale facilities de- which the Commiss:on, pursuant to the of, a specific license for byproduct ma- signed or used for experimental or apa- provisions of section 51 of the'Act, deter-terial of 100,000 curies or more in sealed lytical purposzs, and (ii) facilities in mines to be special nuclear material but sources used for irradiation of materials which the only special nuclear materials does not include source material; or issued pursuant to Part 30 of this chap- contained in the irradiated material to (2) any material artificially enriched ter, for special nuclear material in be processed are uranium enriched in the by any of the fore going, but does not quantities sufficient to form a critical isotope U"'" and plutonium produced by include so:.1rce material.
mass as defined in § 170.3 of this chap- the irradiation, if the material processed (1) "Special nuclear material in quan-ter, except for licenses authorizing pos- contains not more than 10** grams of tities sufficient to form a critical mass" session and use of plutonium-beryllium plutonium per gram Qf U"'" and has fis- means uranium enriched in the isotope neutron sources, issued pursuant to Part sion product activity not in excess of 0.25 U"' in quantities in excess of 350 grams 70 of this chapter, for the receipt of millicurie of fission products per gram of of contained U'"; uranium-233 in quan-waste byproduct material, source mate- u=. t ities in excess of 200 grams; plutonium rial, or special nuclear material from (h) "Research reactor" means a nu- in quantities in excess of 200 grams; or other persons for the specific purpose of clear reactor licensed by the Commission any combination of them in accordance commercial disposal by land or sea burial under the authority of subsection 104c with the following formula: For each by the waste disposal licensee issued pur- of the Act and pursuant to the provisions kind of 5Pecial nuclear material, deter-suant to Parts 30, 40, and 70 of this of § 50.21<c) of this chapter for opera- mine the ratio between the quantity of chapter or for a production or utilization tion at a thermal power level of 10 mega- that special nuclear material and the facility issued pursuant to Part 50 of this watts or less, and which is not a testing quantity specified above for the same chapter. facility as defined by paragraph (m) of kind of special nuclear material. If the
§ 170.3 Definitions. this section. sum of such ratios for all kinds of special (i) "Sealed source" means any by-
nuclear materials in combination ex-As used in this part: product material that is encased in

a ceeds unity, the quantities are deemed
<a> "Byproduct material" means any capsule designed to prevent leakage or sufficient to form a critical mass. For radioactive material <except special nu- escape of the byproduct material. example, clear material) yielded in or made radio-active by exposure to the radiation incident to the process of producing or utilizing special nuclear material. *(b) "Government agency" means any executive department, commission, in- (m) "Testing facility" means a nu- § 170.4 Interpretations.
dependent establishment, corporation, clear reactor licensed by the Commission Except as specifically authorized by the wholly or partly owned by the United under the authority of subsection 104c of Commission in writing, no interpretation States of America which is an instru- the Act and pursuant to the provisions of
of the meaning of the regulations in this mentality of the United States, or any § 5021 (c) of this chapter for operation part by an officer or employee of the board, bureau, division, service, office, ~= . Commission other than a written inter-(1) A thermal power level in excess of pretation by the General Counsel will officer, authority, administration, or other establishment in the executive -10 megawatts; or be recognized to be binding upon the branch of the Government. (2) A thermal power level in excess of Commission.
(c) "Materials license" means a by- 1 megawatt, if the reactor is to contain: product material license issued pursuant * (i) A circulating loop through the core * § 170.5 Communications. to Part 30 of this chapter, or a source in which the applicant proposes to con- All communications concerning the material license issued pursuant to Part duct fuel experiments; or regulations in this part should be arl- . 40 of this chapter, or a special nuclear (ii) A liquid fuel loading; or dressed to the Director of Regulations, material license issued pursuant to Part (iii) An experimental facility in the U.S. Atomic Energy Commission, Wash-70 of this chapter. core in excess of 16 square inches in ington, D.C. 20545. Communications may (d) "Nuclear reactor" means an ap- cross-section. be delivered in person at the Commis-paratus, other than an atomic weapon, (n) "Utilization facility" means any sion's offices at 1717 H Street NW., Wash-designed or used to sustain nuclear fis- nuclear reactor other than one designed ington, D.C.; at 4915 St. Elmo Avenue, sion in a self-supporting chain reaction. or used primarily for the formation of Bethesda, Md.; or at Germantown. Md. (e) "Other production or utilization plutonium or u= and any other equip-facility" means a facility other than a ment or device determined by rule of § 170.11 Exemptions. nuclear reactor licensed by the Commis- the Commission to be a utilization facility (a) No application filing fees, license sion under the authority of section 103 within the purview of subsection 11cc fees, or annual fees shall be required for: .or 104 of the Atomic Energy Act of 1954, of the Act. _ * (1) A license authorizing the export as amended (the Act), and pursuant to (o) "Waste disposal license" means a only of a production or utilization the provisions of Part 50 of this chapter. license specifically authorizing the re- facility. (f) "Power reactor" means a nuclear ceipt of waste byproduct material, source (2) A license authorizing the export reactor designed to produce electrical or
material, or special nuclear material from heat energy licensed by the Commission other persons for the purpose of com- only or import only of byproduct ma-under the authority of section 103 or mercial disposal by land or sea burial terial, source material or special nuclear subsection 104b of the Act and pursuant by the waste dis_,POsal licensee. material.
10926 RULES AND REGULATIONS (3) A license authorizing the receipt, after the first of the month following SCHEDULE OF FEES ownership, possession, use or production the date of issuance of the license or § 170.21 Schedule of fees for produc* of byproduct material, source material, provisional operating license, if any, tion and utilization facilities. or special nuclear material incidental to *whichever is earlier, and annually the operation of a production or utiliza- thereafter. Applicants for construction permits or tion facility licensed under Part 50 of (d) Method of payment. Fee payments operating licenses for production or uti-lization facilities and holders of con-this chapter, including a license under shall be by check, draft, or money order st11,1ction permits or operating licenses Part 70 of this chapter, authorizing possession and storage only of special payable to the U.S. Atomic Energy for ' production or utilization facilities nuclear material at the site of a nuclear Commission. shall pay the following fees: reactor for use as fuel in operation of SCllEDULE or FEES the nuclear reactor or at the site of a spent fuel processing plant for processing Facility (thermal megawatt values Application
Annual fee at the plant. refer to the maximum capacity stated foe for Construction Operating ofter issuance in the permit or license) 1 construction permit fee license fee of operating (4) A construction permit or license permit license
. applied for by, or issued to, a nonprofit . educational institution for a production (1) Power reactor *.***.*.*........... .*. *.* $2,600 $5, 000+$10/Mw(t) * $2/Mw(t) * $2/Mw(t) I 'tacility or utilization facility, other than (2) Testing facility ..........**...***.*.**** 800 3,000 1,000 1,000
p. power reactor, to be used for teaching, training, or medical purposes, or for by-mg~~;~?~~cct~~or utiii"z.at.ion i~cility:: 300 1,500 2,000 5,000 500 2,000 500 2,000 product material, source material, or 1 Amendments reducing capacity shall not entitle the applicant to a partial refund of any fee; applications !or special nuclear material to be used for runendments increasing capacity to n higher fee category will not be accepted for filing unless accompanied by the teaching, training, or medical purposes, prescribed fee less tho amount already paid.
or in connection with a facility, other

Thermal megawatts. * .
than a power reactor, used for teaching, § 170.31 Schedule of fees for materials training, or medical purposes. licenses. (5) A construction permit or license Applicants for materials licenses and applied for by, or issued to, a government holders of materials licenses shall pay agency. the following fees: (b) The Commission may, upon appli-ScHEDULE OP MATERIALS LICENSE FEES cation by an interested person, or upon its own initiative, grant such exemptions from the requirements of this part as it Category or materials license Applies- Annual tion fee fee determines are authorized by law and are otherwise in the public interest. 1. Licenses for byproduct material $Ii()() * $100
§ 170.12 Payment of fees. of 100,000 curies or moro in sealed sources used for irradia-(a) Application fees. Each application tion of materinls.
2. Licenses for ~pccial nuclear ma- 300 100 for which a fee is presc1ibed in this part terial lo quantities sufficient to shall be accompanied by a remittance in form a critiral mass, except for licenses authorizing possession the full amormt of the fee. No applica- and use of plutonium*beryllium tion will be accepted for filing or proc- *a. w~fotr~rs;~~f~icenses spccifl- &)() 200 essed prior to payment of the full amount . cnlly autbori*ing the receipt or waste byproduct material, specified. Applications for which no re- source material, or special nu-1 clear material from other mittance is received may be returned to ncrsons for the purpose of com-mercial disposal by land or sea the applicant. All application fees will burial by waste disposal Ji.
be charged irrespective of the Commis- censee. sion's disposition of the application or a withdrawal of the application. ENFORCEMENT (b) Construction permit fees and op- § 170.41 Failure by licensee to pay an-erating license fees. Fees for construc- nual foes, tion l)ermits and operating licenses are In any case where the Commission payable when the provisional construc- finds that a licensee has failed to pay the applicable annual fee required in this tion permit or provisional operating li- part, the Commission may suspend or cense, if any, is issued. Otherwise, fees revoke the license or may issue such or-are payable when the construction per- der with respect to licensed activities as mit or operating license is issued. No the Commission determines to be appro-provisional construction permit or pro- priate or necessary in order to carry out visional operating license, or construc- the provisions of. this part, Parts 30, 40, tion permit or operating license, as the 50, and 70 of this chapter an_d of the case may be, will be issued by the Com- -Act. mission until the full amount of the fee (Sec. 161, 68 Stat. 948; 42 U.S.O. 2201; 65 prescribed in this ,>art has been paid. Stat. 290; 31 u.s.c.~a) * (c) Annual fees. Annual fees pre-scribed in this part are payable in the
Dated at Germantown, Md., this 26th day of July 1968.
case of licenses outstanding on the ef:. fective date 'of this part, 1 year after For the Atomic Energy Commission. the effective date of this part and an- W. B. McCOOL, . nually thereafter. In the case of the Secretary . licenses issued after the effective date of [FB. Doc. 63-9160; Filed, JUly Sl, 1968; this part, annual fees are payable 1 year 8:46 a.m.J
DOCl<ET NUMBER PR 30,<{t!>, So PROPOSED RULE \ - 7s, t'lO LICENSE FEES FOR FACILITY LICENSES {i,<1AA,d,t,',3/4.j 1~ AND MATERIAL LICENSES Name and Address Sent
1. Aero-Jet General Corporation AUG l 3.1968 P. 0. Box 77 San Ramon, California 94583

2. Arkansas Power & Light Co.
Ninth and Louisiana Streets P. 0. Box 551 Little Rock, Arkansas 72203
3. Atomics International Division of N. A. Rockwell Corp. DOCKETED Canoga Park, California 91303 US!AEC

4. Babcock & Wilcox Company AUG16 1968._
1201 Kemper St. fflce or the Secretary Pub/le Prmsd/ngs Lynchburg, Va. 25401 B
5. Baltimore Gas & Electric Co.
Gas & Electric Building Charles Center Baltimore, Maryland 21203
6. Battelle Memorial Institute 505 King Avenue /
Columbus, Ohio 43201
7. Battelle Memorial Institute Pac. N. W. . Lab.
Richland, Washington 99352
8. Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199

9. California Nuclear Inc.
2323 S. Ninth Street Lafayette, Indiana 47901
10. Carolina Power & Light Co.
336 Fayetteville Street Ra l eigh, North Carolina 27601
11. Combuston Engineering Inc.
Nuclear Power Department WindsorJ Connectitut 06502 12 . Commonwealth Edison Company 72 West Adams Street Chicago, Illinois 60690
e. Name and Address Sent
13. Connecticut Yankee Atomic Power Co.
P. O. Box 270 AUG l 3 1968 Hartford, Connecticut 06101
14. Consolidated Edison Company of New York, Inc.
4 Irving Place New York, New York 10003
15. Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201

16. Continental Oil Co.
P. 0. Drawer 1267 Ponca City, Oklahoma 74601
17. Department of Forests & Waters Commonwealth of Penna Harrisburg, Pennsylvania 17105

18. Department of Water & Power of the City of Los Angeles Water and Power Square 111 North Hope Street Post Office Box 111 Los Angeles, California 90054
/
19. Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226

20. Dow Chemical Company Midland, Michigan 48640

21. Duke Power Co.
422 S. Church St. P. O. 2178 Charlotte, N. C. 28201
22. Fine Line Brazing Company Commercial St.
Watertown, Connecticut 06795
23. First Atomic Ship Transport, Inc.
River & First Streets Hoboken, New York 07030
24. Florida Institute of Technology, Inc.
Country Club Road Melbourne, Florida 32901
Name and Address Sent
25. Florida Power & Light Co. AUG 1 3 1968 P. 0. Box 3100 Miami, Florida 33101

26. Florida Power Corporation 101 Fifth Street South Post Office Box 14042 St. Petersburg, Florida 33701

27. General Dynamics Forth Worth . Division Box 748 Ft. Worth, Texas 76101

28. General Electric Company Atomic Power Equipment Dept.
175 Curtner Ave. P. 0. Box 254 San Jose, California 95125
29. General Electric Company -SEFOR-Advanced Proqucts Operation 310 De Guigne Drive Sunnyvale, California 94086

30. Georgia Power Co.
270 Peachtree Street, N. W. Atlanta, Georgia 30303 /
31. Gulf General Atomic Inc.
Box 608 San Diego, California 92101
32. Indiana & Michigan Electric Co.
2101 Spy Run Avenue Fort Wayne, Indiana 46801
33. Indistrial Reactor Laboratories, Inc.
Plainsboro, New Jersey 08536
34 . Isotopes Inc.
Westwood Labs 50 Van Buren Avenue Westwood, New Jersey 07675 35 . Jersey Central Power & Light Co. Madison Ave. at Punch Bowl Road Morristown, New Jersey 07960
36. Ke~r McGee Corp.
Kerr McGee Building Oklahoma City, Oklahoma 73101
Name a nd Address Sent
37. Laboratory for Electronics 2030 Wright Avenue AUG 1 3 1968 Richmond, California 94804

38. Ledoux & Company 359 Alfred Avenue Teaneck, New Jersey 07666

39. Lockheed Aircraft Corp.
Georgia Division Marietta, Georgia 30060
40. Long Island Lighting Company 250 Old Country Road Mineola, New Yo\~ 11501

41. Maine Yankee Atomic Power Company Principal Engineering Office 441 Stuart Street Boston, Mass. 02116

42. Mallinckrodt Chemical Wks.
3600 N Second Street St. Louis, Missouri 63147
43. Martin-Marietta Corporation Nuclear Division Baltimore, Maryland 21203 I

44. Martin Marietta Corp.
Middle River, Maryland 21220
45. McDonnell Douglas Corp.
Missile & Space Systems Div, 2955 G. Washington Way Richland, Washington 99352
46. Metals & Controls Attleboro, Massachusetts 02703

47. Metropoli tan Edison Co .
P. 0. Box 542 Read ing, Pennsylvania 19603
48. Millstone Point Company P. 0. Box 2370 Hartford, Connecticut 06101

49. Mobil Oil Company Research Dept.
Paulsboro, New Jersey 08066
Name and Address Sent
50. Monsanto Research Corp~ AUG 1 3 1968 1515 Nicholas Road Dayton, Ohio 45418

51. National Lead Company 1150 Central Avenue Albany, New York 12201

52. New York State Electric & Gas Corp.
4500 Vestal Parkway East Binghamton, New York 13902
53. Niagara Mohawk Power Corp.
300 Erie Blvd. West Syracuse, New York 13202
54. North American Rockwell Corporation P. 0. Box 309 8900 De Soto Ave.
Canoga Park, California 91304
55. Northern States Power Company 414 Nicollet Avenue Minneapolis, Minnesota 55401

56. Northrop Corporate Laboratories 3401 West Broadway Hawthorne, California 90250 /

57. Nuclear Fuel Services Inc.
Box 124 West Valley, New York 14171
58. Nuclear Fuel Service Erwin, Tennessee 37650

59. Nuclear Materials & Equipment Corp.
Apollo, Pennsylvania 15613
60. Omaha Public Power District 1623 Harvey Street Omaha, Neb. 68102

61. Owens Corning Fiberglas Corp.
Technical Center Granville, Ohio 43023
62. Pacific Gas & Electric Company 245 Market Street San Francisco, California 94106
Name and Address Sent
63. Philadelphia Electric Co. AUG 1 3 1968 1000 Chestnut Street Philadelph ia, Pennsylvania 19105

64. Power Reactor Development Company 1911 First Street Detroit, Michigan 48226

65. Public Service Company of Colorado Public Service Company Building 550 15th Street Denver, Colorado 80202

66. Public Service Electric & Gas Co.
80 Park Place Newark, New Jersey 07101
67. Lucius Pitkin 50 Hudson Street New York, New York 10013

68. Rochester Gas & Electric Corp.
89 East Ave. Rochester, New York 14604
69. Sacramento Municipal *utility District 6201 S St reet Post Office Box 15830 I Sacramento, California 95813

70. San Diego Gas & Electric Co.
6th and E Street Post Office Box 1831 San Diego, California 92112
71. Southern California Edison Company P. 0. Box 351 Los Angeles, California 90053

72. Southwest Atomic Energy Associates 306 Pyramid Bldg .
Little Rock, Arkansas 72203
73. The Babcock & Wilcox Co.
Nuclear Development Center P . 0. Box 1260 Lynchburg, Virginia 24505
74. The Carborundum Co.
P. 0. Box 337 Niagara Falls, New York 14302
e Name and Address Sent
75. Thermo Electron Engineering AUG 1 3 1968 85 First Avenue Waltham, Massachusetts 02154

76. Torrence Extrusion Corp 896 S. Hathaway St .
Banning, California 92220
77. Union Carbide Corp.
Ca rbon Products Division 12900 Snow Road Parma, Ohio 44101
78. Union Carbide Corp.
Lawrenceburg, Tennessee 38464
79. Union Carbide Corp.
Sterling Forest Res. Center P. 0. Box 324 Tuxedo, New York 10987 80 . United Nuclear Corp. Chemicals Division Hematite, Missouri 63047
81. United Nuclear Corp.
Chemical Operations / 3600 N 2nd Street St. Louis, Missouri 63147
82. United Nuclear Corp.
Grasslands Road Elmsford, New York 10523
83. United Nuclear Corp.
Development Division (Pawling Hot Lab) White Plains, New York 10601
84. United Nuclear Corp.
Metallurgical Labs New Haven, Connecticut 06501
85. Vermont Yankee Nuclear Power Corp.
77 Grove Street Vernon, Vermont 05701
Name and Address Sent
86. Virginia EJ.ectric & Power Company AUG 1 31968 Post Of f ice Box 194 700 East Franklin Street Richmond, Virginia 23209

87. Westinghouse Electric Corp.
3 Ga teway Center P. 0. Box 2278 Pittsburgh, Pennsylvania 15230
88. Westinghouse Electric Corp.
Defense & Space Center Friendship International Airport Box 746 Baltimore, Maryland 21203
89. Westinghouse Electric Corp.
Electronic Tube Division Elmira, New York 14902
90. Whittaker Corp.
Nuclear Metals Division West Concord, Massachusetts 01781
91. Wisconsin Electric Power Co.
231 W. Michigan St. Milwaukee, Wisconsin 53201 I
92. Wis consin Michigan Power Co.
231 West Michigan Street Milwaukee, Wisconsin 53201
93. Wisconsin Public Service Corp.
600 No rth Adams Street Green Bay, Wisconsin 54301
94. David Witherspoon 901 Maryvi lle Pike Knoxville, Tennessee 37920

95. Yankee Atomic Electric Company 441 Stuart St.
Boston, Massa chusetts 02116
96. Ethicon Incorporated Manufacturing D\ vision Somerville, New ~ersey 08876
Name and Address Sent
97. The American Novawood Corporation AUG l 3 1968 2432 Lakeside Drive Lynchburg, Virginia 24501

98. Neutron Products, Incorporated P. 0. Box 95 Dickerson, Maryland 20753

99. Gamma Process Company, Incorporated
160 Broadway New York, New York 10038 100. State of Hawaii Departmen t of Agriculture 1428 South King Street Honolulu, Hawaii 96814 101. American Mail Line, Ltd.
1010 Washington Building Seattle, Washington 98101 102. Ca lifornia Sa lvage Company 709-745 North Pacific Av enue San Pedro, California 90731 103. Nuclear Engineering Company, Inc. P. 0. Box 594 I Walnut Creek, California 94597 104. Dow Corning Corporation Midland, Michigan 48640
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MEMO ROUTE SL See me about this. For action .
Form AEC*!l3 (Rev. May 14, 1947) Note and return. For Information. TO (Name and unit) INITIALS REMARKS Stan Robinson Attached is a copy for the Secretariat- au~ efte SECY B-427 DATE <o~, is co be tra~smittea eo ehe Public Doeumeae Ro0ffl". T O (Name and unit) INITIALS REMARKS DATE 7 TO (Name and unit) INITIALS REMARKS DATE FROM (Name and un it) REMARKS G. L. Hutton, Chief Program Assistance Branch BETH 010 PHONE NO. DATE 7382
~'; (:-:_ !:t:*f ;'H'.j:.., *_,\ (*' 5f},lf0, SO, rno~o rn KULE_:,,L* 11 , 110 AUG 3 1 r . John T. Co way Executive Director Joint Commi tee on Atomic Ener y Co gress of t':i.e United St.:ites
Dear Mr . Conway :
Thanl* you for your letter of ugust 23, 1%7 , rega r ing the Com-missio 11 s proposal to establish fe s for fa cility and ma ter ials licenses . The comment period on t ~*s prcpose rule expired Ol July 9, 1967. We .:ire nearing co pletio of our evaluation of t he 250 letters com1.i.1e ti113 on tie proposed rule . fos of t 1 letters object d to th-e pro osed fees , particularly he pr osed fees f or material s licenses . Prior to ta dn3 final action on t l e pr posed fee sc:1edule ~ e pl an to arrange a raeet:!.n 6 with yours aff o iscuss the rule and any su *stantive c 1an3 s which n-iay e ,aade in t he proposed fee s chedu le as t e r sult of
l

c coli ts a urtl er staff s t udy .
I r . Chris I-lend rson will contac you within t e nex t few weeks to ar ange a suita le date for t he meeting . Di str i bution : SinceI"ely yours , Distribution: Dire ct or of Regulation Cong . Rel. ( 2) OGC Forma l F il e Supplementa l File
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850 THIRD AVENUE* NEW YORK , N.Y. 10022
PLAZA 4-1075 August 24, 1967 DOCKETED U&AEC Secretary United States Atomic Energy Commission Washington, D.C. 20545
Dear Sir:
This is in further reference to proposed 10 CFR Part 170 re-garding the establishment of fees for certain AEC licenses, published in the Federal Register on March 11, 1967, and to the letter of connnent of June 16, 1967 submitted by the Atomic Industrial Forum's Working Group on Licensing Fees. The last paragraph of the Working Group's letter contained the following request:
"Should the Connnission determine that it must proceed to establish a schedule of fees for certain licenses, despite eaese and other considerations militating against such action, the Working Group respectfully request an oppor-tunity to discuss the proposal with appropriate AEC rep-resennatives and/or furnish additional written connnents."
The purpose of this letter is to inquire whether decisions or staff reconnnendations have been reached as to: (1) whether a schedule of fees will be imposed; (2) if so, in light of the many connnents submitted on the proposal, whether it will be in substantially revised form; and (3) whether or not it will be published for public connnent before being put into effect. Th e working group would reiterate the request quoted above if a sch edule of fees is planned to be promulgated in any form without the opportunity for further written connnen t . Yours truly, 0 s~ cretary Working Group on Licensing Fees cc: Harold Price, Director of Regulation
DOCKET NUMBER PR-30,'to,so, PROPOSED RU LE ?D, (70 nace1111, .-** DOCKETED USAEC UG i 1967 aJ I 7
;;:;;:!JS I~ - 650 ACKERMAN ROAD
COLUMBUS , OHIO 43202 July 27, 1967 Secretary United States Atomic Energy Commission Washington, D.C. 20545
Dear Sir:
Please find below our comments in regard to the proposed 10 CFR 170 to establish fees for certain AEC licenses. Industrial Nucleonics Corporation is opposed to the establishment of fees for the following reasons:
1. The Atomic Energy Commission's regulatory program is utilized to provide safety not only for licensee personnel, but also for the public at large. The licensee is not deriving a specific benefit from his license. The licensing system is really only a method to impose regulatory safety standards on the users, rather than being a method of extending a privilege. The funds for such a program, then, should be derived from general sources of revenue.

2. Many gauging devices, and particularly less expensive units, are distributed under a specific license. Charging fees for possession of this radioactive material can hardly be considered compatible with the Atomic Energy Commission's responsibility for strengthening free enterprise and promoting the use of isotopes.
For any particular application, gauging devices may be in competition with devices not utilizing radioactive materials (X-ray, mechanical means, electrical methods, etc.). Even though the nuclear approach may be the superior one, gauging devices in this situation acquire another serious disadvantage to be added to (1) the fact that a license is mandatory and (2) the fact that leak-testing is required. Fees obviously will not improve this situation.
3. After canvassing a number of Agreement States, we find that they are not inclined toward the establishment of fees, for their
Secretary United States Atomic Energy Commission page 2 own individual reasons. Undoubtedly this will cause more confusion for our small nuclear industry. We recommend, therefore, that the proposed 10 CFR 170 be abandoned. Very truly yours, E. R. Ferraro, Manager Government Regulations ERF:jkr
~ Process Control Systems
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11D Baltimore, MARTIN MARIETTA CORPORATION Maryland 212 0 3 July 7, 1967 OCKETEI Refer to: ACC-562 Ulm CWK:845 UL 13 1967 Secretary mce ,1 tht Secretary United States Atomic Energy Commission Mlle Pnt!tflDlt Washington, D. C.
Subject : Licensing Fees - Proposed Title 10 CFR Part 170 We have reviewed the proposed Title 10 Code of Federal Regulations Part 170 which was published by the Commission in the Federal Register dated March 11, 1967. We feel very strongly that the enactment of the proposed 10 CFR 170 requiring fees for AEC licenses for facilities and materiel is incom-patible with the Commission's responsibility to foster the development of atomic energy . This action would be a deterrent to the continued expansion and emergence of a viable commercially oriented nuclear industry . The policy of the United States is clearly stated in Chapter I, Section lb Atomic Energy Act of 1954: "the development, use and control of atomic energy shall be directed so as to promote world peace, improve general welfare, increase the standard of living, and strengthen free competition in private enterprise" . (Underscoring supplied) . Further, Chapter 1, Section 3, Part b states "a program to encourage widespread participation in the development and utilization of atomic energy for peaceful purposes to the maximum extent consistent with common defense and security and with the health and safety of the public". (Underscoring supplied) . It is difficult to see how the impoqition of fees as contemplated by the proposed Title 10 CFR 170 is in consonance with the established policy of the United States. The proposed establishment of fees for facilities and materiel licenses is in opposition to the Atomic Energy Act and are primarily for the raising of revenue. Alcohol and various drugs have been deemed necessary to control by imposition of licensing requirements because of the public health, safety, and welfare, but have not required such fees for the licensing service .
Refer to : ACC - 562 July 7 , 1967 Page 2 As a revenue producing action this regulatory enactment is neither consistent with the policy of the United States, as stated in the above Act, or conducive to the development of a new and developing industry. We urge the United States Atomic Energy Commission withdraw the proposed Title 10 CFR 170 . Very truly yours, MARTIN MARIETTA CORPORATI ON illiam H. Alper Director - Business Management Nuclear Division CWK :bm
OOOKET NUMBER 31),CfO,SD,
.PROPOSED RULE PR-1°,11D filommissioner A.B . COLYAR. M.D.
BERT i. BRUNDAGE , M.D . , PRESIDENT OTHO R. WHITENECK, 0.D . S., VICE PRESIDEN T MR. R. L. LOY , SECRETARY WAYNE J. BOYD , M . D .
~tah~ ~ eparlment of ~ra1t4 ROBERT L. LOFTIN, M.D.
ROBERT D . McCULLOUGH , D.0 , ~btt.e of klaqoma: EUGENE A. OWENS , M.D . CARL 0. OSBORN , M . D. 3400 NORTH EASTERN WILLIAM N. WEAVER , M.D. OKLAHOMA CITY , OKLAHOMA 73105 July 7, 1967 CKETED IISAEC Mr. W. B. McCool Secretary UL 13 1967 Atomic Energy Commission 1717 H Street, N.W. Washington, D.C. 20545
Dear Mr. McCool:
This is in regard to the proposed regulations published in the Federal Register with respect to the levying of application and licensing fees upon licensees of the Commission. First, we believe that the Commission's proposal has failed to adequately justify the need for such fees except to imply that such fees will be used to defray the expenses incurred in the servicing of the licenses issued. Further, we see no assurances in the proposed regulations that services to the licensees will be improved or other-wise increased once the fees are levied. Second, we would like to comment on these fees as they relate to the development of nuclear energy. With respect to Category 1 of materials licenses (proposed section 170.31), we believe that an annual fee of $25.00 would not be reasonable for those licensees authorized to possess relatively small and minor amounts of radioactive material, particularly in the light of the generally limited amount of use made of such material and the services rendered to such licensees by the Commission. Examples of such uses include 30 millicuries cobalt-60 Civil Defense source sets and those licensees who maintain single sealed sources for educational, testing, and/or calibration purposes. The imposition of fees will surely discourage persons, to some extent, from applying for and holding licenses; a regulation which tends to decrease the use of radioactive material is hardly compatible, in our opinion, with the encouragement of the development of nuclear energy. However, perhaps of greatest concern to us is our position as an agency which is presently contemplating the assumption of certain responsibilities of licensing and r egulation as a_u thorized by s ection 274(d) of the Atomic Energy Act of 1954, as amended. Due to the close
Mr. W. B. McCool July 7, 1967 association and liaison between the Commission and the various agree-ment states and due to the singular purpose of the Commission's and the states' regulatory programs, we believe that an imposition of licensing fees by the Commission would add significant weight and impetus for agreement states, present and future, to follow suit. We do not believe that such an occurrence would be in the best inter-ests of the licensees, the atomic energy industry in general, and the regulatory agencies involved. We trust that you will give careful consideration to these comments and that the Corrnnission will decide to withdraw the pro-posed regulations. Very truly yours, A. B. Colyar, M.D. Commissioner of Health ABC:PL
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PROPOSED ~ui.l"' 1fJ, 17!' VIC E CHAIRMAN MELVIN PRICE. ILL.
AICHARO D. RUSSELL, GA. WAYN E N . ASPINALL. COLO. CLINTON P . ANDERSON, N. MDC, THOMAS O. MORRIS, N. MEX, ALB ERT GORE, TENN. JOHN YOUNG, TEX. H ENRY M . JACKSON , WASH. BOURKE O. HICK E NLOOPEft1 IOWA G EORGE D, AIKEN, VT* WALLACE F. l!I.ENNETT, UTAH
<!Congress of tbe '<Mniteb $tates CRAIG HOSMER, CALIF.
WILLIAM H. BATES, MASS. JOHN 8. ANDERSON, ILL. WILLIAM M. MCCULLOCH, OHIO CARL T. CURTIS, NEBfl, JOINT COMMITTEE ON ATOMIC ENERGY, JOHN T. CONWAY, PECUTIVI: DIIIIE'.CTOfl 'I I* *
June 27, 1967 Mr . Jerom.e J. Steerman University of Illinois Department of Physic, Urbana 0 lllinoie
Dear Mr. Steerman:
This refers to your"* letter o! May 11, 1967 to the Secretary of the Atom.ic Ene rgy Con:.mission concerning the .AEC!s Notice of Proposed Rule Making regarding the charging of fees for ,l icenE?es issued to individual and corporate members of the public. I appre-ciated your bringing__ this mattei- to ray attention by sending me a. copy o! your lettere I have looked into this matter and arr.1. informed by the AEC that lt plans to give vu1*y cza.raful consideration to the co:mrr.1.ents \\ hich 1 it has received from the public on the question of collecting fees from nonprofit institutions for AE C licenses . 1 believe that the Con-ill'.tission should move very carefully in this area, for even a relatively modest fee could be the proverbial straw that broke the camel's back for soma educational, research, medical and other nonprofit institutions using small quantities of nuclear materials under AEC license . Such a result would hardly-be consistent with one of the major purposes of the Atomic Energy Act, namely, to foster the use of atomic energy for peaceful purpose& .. Accordingly, I plan to follow very closely in the coming mopths any action that the Co~saion may take in this regard. , , Sincerely yours, Melvin Price Chairman, Subcommittee on Hon. Glenn T. Seabori Re search, Development and Chairman USAEC Radiation
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Dear Siri . .. I wish to comment on your Notice of Pl"opos~d Rule Ma.king on. Lice_n ge !l'ee$e
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*-. di,.ted M~. l3e 1967.* - 1 have been deeply involvad in A.~.o. Li.cendng ,: r:::~t~;;rs ..;.~ :*. , .. ,. ' ei.nce 1953, 'both e.a the Univer!l'lt:, Health PhyRicht nt the Univerwity- of Illi* . :.:-:,. r* :,
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fenrae orgo.nhation. (Inoidenta.ll;r, I \fa a a.ho involved on the other ei.de of the_ .: .
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two organh;ntiona mentionfld above. How0ve1** I lu>.ve been encoura,;ed b:, both to * * * *., : -_. express my personal convictions on this mntter to you.. ,* \,
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at~ted policy of fostering the develop~ent of uaeg of nuclenr energy. For yeBre, A*~. C. has been dangling the bright prospects of nuclear energy before the noses of hospitalci, industry. a nd educa.tfona.l and ra f! ea.rch 1nst11.-uUonB* Now that many fish hnve rlnen to the bsit. does A,?,C. intend to get the hook1 Thia new ta.x h likel7 to have a negntive affect whoso value, .f11.r exceedR . the actual

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A cage in po in.t h the 11-cendnP, <1f *Civil DefenM aourco nets used in .
training of local Civil Defcnne volunteers n.nd for instrument calibrnti on. Tax * * ' these And thotlflanda cf couroe sets will 'be returned.
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which Civil Defen,Jr could not function )_- are difficult enough to ncq_uh'e and re- ., , tain. Start imposing finnncial burden9* no
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DGCEET NUMf.ll::R l"", .,.,.96>, 54', P.ROPOSEO .RULE ,.,., R- ?~( 171> JUL l O 1967 I I *, 1 ru.* v/ fet: IIOC:UlllllmtloGll Attn: tan lobinaoa 7/ /67
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eROPOSED RU LE 1&, 170 DEPARTMENT OF THE ARMY OFFICE OF THE SECRETARY OF THE ARMY OFFICE OF CIVIL DEFENSE WASHINGTON , D.C. 20310 JUL 'l 1967 MEMORANDUM FOR THE SECRETARY, U. S. ATOMIC ENERGY COMMISSION
SUBJECT:
Proposed Rule ~- Establishing License Fees for Specific Byproduct Material Licenses Issued under 10 CFR Part 30 The Commission's announcement proposed the establishment of fees for its facility and materials licenses which it believes to be reasonable and compatible with the Commission's responsibility for fostering the develop-ment of nuclear energy. Application fees for new licenses and/or annual fees are proposed for all specific byproduct material licenses issued pursuant to 10 CFR Part 30. Exemption to payment of fees are provided for some licenses held by certain educational institutions. There appears to be no question as to the prerogative of the Commission, pursuant to the Atomic Energy Act of 1954, as amended, the Administrative Procedure Act of 1946, as amended, and Title V of the Independent Offices Appropriation Act of 1952 {65 Stat. sec. 290) to impose and collect fees as a means of recovery of user charges. However, OCD questions the reason-ableness and compatibility of imposing an annual fee on certain byproduct material licenses issued pursuant to 10 CFR Part 30. In our opinion this will be in direct conflict with the Commission's responsibility for foster-ing the peaceful uses of nuclear energy, particularly by individuals and small profit or nonprofit organizations. It is noted that the Commission has already eliminated the fee for the initial application for almost all specific licenses for the use of byproduct material. It is our opinion that for the vast majority of the licenses issued, the major effort required by the AEC would be in evaluating the initial application; and renewal of these licenses would be much less effort. Admittedly, the inspection of licenses by the AEC on a periodic basis is costly. It is our understanding that Federal appropriations are provided for AEC salaries and related costs. However, the "cost" to the licensed organization to pay the $25.00 annual fee and the indirect cost to the collecting agency, the AE~ could be several times the actual $25.00 annual fee. OCD is also concerned regarding the effect the imposition of an annual fee will have on our field programs in the many communities across the country. Our instrument maintenance and calibration program is now 100 percent federally financed; therefore, OCD would end up providing indirectly reim-bursement to AEC for the annual fees in all State Civil Defense calibration facilities. Much of our training is 100 percent OCD financed through the U. S. Office of Education and therefore, OCD would indirectly provide reim-bursement to AEC for the proposed annual fees. Other Civil Defense organ-izations participating in our program undoubtedly would be reimbursed 50 percent of the fee under our Personnel and Adminstrative Expense Program.
There are many individuals who are now licensed and are volunteering their time for Civil Defense purposes. We are sure that they are almost uni-versally opposed to the imposition of annual fees. We are actively urging and encouraging the States to become licensed for the possession, use and control of all Civil Defense source sets being used within the State, This materially reduces the number of individual licenses for Civil Defense use. Therefore, we feel strongly that it would be in the public interest as well as more compatible with the Commission's responsibility for fostering the development of nuclear energy to eliminate the annual fee for all category 1 material license users as listed in proposed section 170.31 such as you have done for the initial application fee, If the annual fee for all category 1 users is not eliminated, then it is respectfully requested that all Civil Defense users be declared exempt from any type fee under proposed section 171,11 (b), DOCKETED USAEC
?:t!~Jnl~f-Chairman, OCD Isotopes Committee
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__7__~~.L7 0 DOCKETED STATE OF NEW YORK US!AEC EXECUTIVE DEPARTMENT OFFICE OF ATOMIC AND SPACE DEVELOPMENT UL 101967 P. 0 . Box 7036 ALBANY July 7, 1967 Secretary U.S. Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
We have reviewed the Commission's proposed Part 170 and related proposed amendments to Parts 30, 40, 50 and 70 (32 F.R. 3995, March 11, 1967), establishing fees for licenses for radioactive materials and nuclear facilities. The Commission has made it quite clear that the impo-sition of fees by Agreement States is not, in the Commission's view, a matter of compatibility under the regulatory agree-ments between the Commission and Agreement States, such as New York, and that therefore, any Commission decision on the questions presented by these proposed regulations would not have any direct impact on this State's regulatory program. We are submitting comments, however, not only because the proposed regulations would have a direct impact upon licenses within the State over which the Commission has re-tained jurisdiction (e.g., production and utilization facilities), but also because the Commission's decisions could affect the development of the atomic industry with an impact which extends beyond jurisdictional boundaries. Further, any precedents established by the Commission would obviously have to be reviewed very carefully by State agencies administering similar programs. Overall Effect of Fees Upon Use of Nuclear Materials We are concerned about the detrimental effects that the proposed fees will have upon the utilization of nuclear materials by industry, education, medicine, government, etc.
Secretary, USAEC July 7, 1967 The extremely careful and safety conscious attitude of all segments of the atomic energy industry - an attitude which has been fostered by governmental regulatory programs - inherently results in substantial costs to licensees and users (e.g., in terms of equipment , personnel, study, review, quality control) far beyond equ i valent costs in other industrial ac-tivities. While these costs may , in some sense, tend to "discourage" a particular potential application of atomic energy, we feel that the extremely high degree of safety associated with the atomic energy industr y indeed serves to foster its development. In any event, we believe that these costs, which are directly and actually associated with providing adequate assurance of public and industrial health and safety, can and must be borne by the atomic energy industry as a cost of doing business. Recognizing these often very substantial costs of safety borne by the atomic energy industry, we believe that further cost burdens in the form of licensing fees, such as those pro-posed by the Commission , are not clearly warranted and properly should not be imposed on materials licensees. The regulatory program has, as its primary and direct beneficiary, not the regulated licensee, but the general public. The regulatory agency checks and reviews the proposals of the applicant and inspects his activities when licensed for the sole purpose of independent assurance that the activities in fact provide adequate safety to workers and the public. Although the licensee benefits in the sense that in the absence of a license he could not lawfully engage in the particular activity, such benefit is not the purpose of , but only an incidental result of, the regulatory program. Thus, in our view, the AEC regula-tory program with respect to materials licenses clearly falls within the criterion of paragraph 3 (a) (2) of Bureau of the Budget Circular No. A-25 :
"No charge should be made for services when the identification of the ultimate beneficiary is obscure and the service can be primarily considered as benefiting broadly the general public ... "
Secretary, USAEC July 7, 1967 Particular Activities Which Should be Exempted We are also concerned about the particular impact of the proposed fees on certain activities involving the use of licensed materials or licensed facilities. In addition to the general public interest in the development of the benefits of atomic energy (an aspect of public interest common to all seg-ments of the atomic energy industry), there are particular uses and applications which entail additional considerations of public interest and which we believe warrant specific exemp-tion from licensing fee requirements, if such fees are generally imposed. These include the medical uses of radioisotopes for diagnosis and therapy and of radioisotopes and facilities for research into causes and cures for a wide range of human ill-ness. We believe that there is a strong public interest in assuring the ready availability to the medical profession, without additional cost burden, of the most efficacious tools and medicines of modern technology in the fight against human illness. Use of radioactive materials and facilities for e du-cational purposes is affected with the public interest in assuring our young people the finest tools for the broadest sweep of knowledge in all subjects, but especially in the sciences. In this connection , we believe that the limited exception of proposed 10 CFR Section 170.ll(a) (4) for only certain nonprofit educational institutions is not sufficiently broad and is not consistent with the policy which provided preferential treatment for nonprofit educational institutions under Section 170(k) of the Act. The use of sources in programs of civil defense is obviously affected with the public interest which led to the establishment of these programs. Similarly, the use of radioactive materials and nuclear facilities in the activities of State and local governmental agencies and public benefit corporations are affected with the significant public interest in assuring that the public's servants - its governmental agencies and instrumentalities engaged in activities to protect and enhance public welfare -
Secretary, USAEC July 7, 1967 are prepared and equipped to operate at the forefront of modern technology. In many of the instances we have . noted above, we believe that the g~idance of the Bureau of the Budget Circular No. A-25 would indicate that exceptions should be made to cost recovery fee policies. Specifically, paragraph 5.b. of Circular A-25, states in pertinent part:
" ... In establishing new fees and in-creasing existing fees the agency may make exceptions to the general policy ... under such conditions as illustrated below .. .
(3) t he recipient is engaged in a non-profit activity designed for the public safety, health or welfare (4) payment of the full fee by a State, local government or non-profit group would not be in the interest of the program." Certain Commercial Activities We are also somewhat concerned that the fees would im-pose upon equipment employing licensed radioactive materials a position of disadvantage when competing with other devices in commercial markets. Purchasers of items such as instrumentation apparently are often still hesitant to select equipment employing licensed radioactive materials because of the regulatory requirements attendant upon the use of such devices. Although we believe that the careful control requirements of the regulatory programs are very significant in the constant efforts to achieve the highest degree of safety in connection with the use of radio-active materials, the effect of the regulatory requirements
Secretary, USAEC July 7, 1967 and the associated "paperwork" in dampening the enthusiasm of potential purchasers must be recognized and appreciated. The granting of general licenses for certain devices and equipment has been very beneficial in this regard. However, many such items must carry the load of specific licensing requirements in competing in the commercial market. We are concerned that the additional burden of the licensing fee on such potential purchasers may severely strain the com-petitive position of products employing licensed radioactive materials. This would be, as many comments have stated, a barrier to the growth of atomic energy utilization. Further, in many instances, the materials in competi-tion with licensed radioactive materials present less desirable radiological characteristics, e.g., radium compared to tritium. In other instances, competing devices employ ionizing radia-tion in equipment (e.g., X-ray machine radiography) whose radiological characteristics may not be subject to close regulatory review in some States. In these instances, a tendency to discourage the use of regulated by-product or source material would be a disservice to the general public. Fees for Production and Utilization Facilities We believe that, in keeping with the purposes of the Atomic Energy Act of 1954, as amended, of "conducting, assisting, and fostering research and development in order to encourage maximum scientific and industrial progress," the Commission should not impose license fees upon production and utilization facilities constituting research and development projects. In order to permit continued growth of the development and utilization of atomic energy for peaceful purposes, it is essential that facilities be constructed and operated to pro-vide required information as to the technology of nuclear systems and to define and identify actual operating character-istics. These research and development projects - such as the breeder reactor projects being considered by industry - will carry, for the sake of future nuclear projects and energy users, the burdens of uncertainty as to eventual total costs
Secretary, USAEC July 7, 1967 which are inherent in any pioneering project as well as possible known economic disadvantages attributable to the novel features of the project. It would appear to us to be incongruous for the Com-mission to add a further burden to such research and develop-ment projects by requiring that they pay license fees in the same manner as would commercially viable projects. If license fees are to be imposed upon production and utilization facilities, we believe that the regulations should specify that such fees would be imposed only upon a Commission finding that the facility or type of facility involved has had suffi-cient operating experience to verify that such facility is commercially competitive in operation , either in terms of a "practical value" finding under section 102 or some other similar criterion established by the Commission for these purposes. If the Commission, notwithstanding our comments, de-termines to impose licensing fees on production and utiliza-tion facilities generally in accordance with the present proposal, we believe that , as set forth above under "Particular Activities Which Should be Exempted" , specific exemptions should be provided for medical, educational and governmental facilities. In addition, while we agree with the desira bility of drawing cutoff points for step-wise increments in fe e s if such fees are established, we question the very broad range of the first step of the power reactor category and of the research reactor category. Establishing a single category so broad as to include all power reactors up to 1000 Mwt would group many small facilities together with much larger electric power projects of up to approximately 300 Mwe, thus imposing a substantial disadvantage upon the small facilities, which would include primarily the already burdened research and development reactors. Surely the small power reactors - for example, those with power levels less than 250 Mwt - involve regulatory considerations (such as credit for engineered safeguards) substantially different from those associate d with reactors of 1000 Mwt and would not warrant a filing fee, a construction permit fee , an operating license fee and an annual fee greater than those applicable to a testing facility.
Secretary, USAEC July 7, 1967 Similarly , a research reactor operating at a level of 100 watts or less surely entails regulatory considerations substantially different from those associated with reactors operating at 1 Mwt and would not warrant the fees associated with the larger facilities. Waste Disposal We believe that the definition of "waste disposal license," in proposed Section 170.3(n) should be changed to reflect more clearly the intent indicated in the Commission's letter to Mr. Hyman Glasser, dated April 13, 1967, namely, that "Category five ... [waste disposal licenses] was not in-tended to include licenses which authorize collection, processing, storage and transfer of wastes to another person for land or sea burial to be performed by the transferee." We would suggest that the proposed definition be amended to read as follows:
"Waste disposal license means a license specifically authorizing both the receipt of waste byproduct material, source material or special nuclear material from other persons [for the purposes of] and the commercial disposal by land or sea burial of such materials by the licensee."
Licensees of More than One Jurisdiction Another point which we feel should be considered in connection with the proposed fees is the effect of multiple fees on licensees of both the Commission and the Agreement States, should the States also adopt similar fee schedules. As we indicated above , the Commission has made quite clear its view that this is a matter of fiscal policy for each state to adopt or reject in its own judgment. Nonethe-less, recognizing that fiscal pressures on all levels of
Secretar y , USAEC July 7, 1967 government - Federal , State and local - ar e substantial, the Commission ' s determination to charge fees for licenses issued by it, will result in precedents to which the Agreement States may eventually subscribe . In this event, the Commission and the Agreement State s should take positive steps to assure that there is not an undue multiplicity of fees upon activities conducted under multiple jurisdictions . Consequently, we feel that if the Commi ssi on does adopt the proposed fees, the Commission and the Agreement States should, at their next meeting , review the potential effects of licensing fees on various categories of persons licensed by both the Commission and Agr eement States o Very truly yours, Oliver Townsend Director
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.,. 7..~.J.. 7 p NATIONAL AERONAUTICS AND SPACE ADMINISTRATION WASHINGTON, D.C. 20546 IN REPLY REFER TO:
r i * .:.J Mr. ~-T. B. McCool JUL 1 CJ 1961
* * , 1 tM secretarJ Secretary 1 ll *~ ~roc;id\ngs United States Atomic Energy Commission Washington, D.C. 20545
Dear Mr. McCool:
This is in regard to the proposed AEC regulations relating to fees for facility and materiels licenses (32 F.R. 3995). As we read the proposed regulations, should they go into effect as presently drafted, agencies of the Federal Govern-ment, including NASA, would not be exempted from t he licensing fees proposed* therein. Furthermore, contractors of Federal
agencies would be required to pay such licensing fees even where the contractors' needs for AEC licenses stemmed solely from the work to be performed by the. contraators under their contracts with the Government. In such situations, of course, the Government agencies for which the contracts were being performed woula* inevitably pay, albeit indirectly, for the costs to the contractors of the licenses.
We believe that you may wish to give serious consideration to exempting Federal agencies and their contractors from the proposed licensi!1g fees. As to the proposed imposition of licensing fees directly on Federal agencies, we find ourselves in agreement with the Departm nt of the Navy (letter from Albert H. Ste.in, Acting General Counsel, Department of the Navy, to Secretary, United States Atomic Energy Commission, 29 May 1967): In view of the position adopted by the Comptroller General in a number of decisions on questions similar to the one at hand, this office would feel constrained to advise NASA's fina cial officers that until the Comptroller General rules otherwise, the.re would appear to be a substantial question as to whether NASA has the authority to pay the proposed fees. As to the imposition 0f AEC licensing fees on NASA contractors, it is obvious that AEC license fees . paid for by Government contractors in connection with their work for the Government
2. will result in contract price increases at least equal to the license fees paid by the contractors . It is our position , therefore, that a contractor of a Federal agency should not be required to pay an AEC licensing fee where the contractor's sole need for the license stems from its contract with the agency. In this regard we note that the AEC appears to be basing its authority to charge licensing fees on Title V of the Independent Offices Appropriation Act of 1952 (5 u.s.c. [1964 Ed.] 140, 65 Stat. 290). As you know, that provision provides, among other things, that agencies may charge fees in connection with the issuance of a license to " any person (including groups, associations, organizations, partnerships, corporations, or businesses)." However, " those engaged in the transaction of official business of the Government " are excepted from such fees . In view of such language and of the Congress's purpose in adopting the provision (see H.R. Rep. No. 384, 82nd Congress, 1st Sess. 2 (1951) ; 97 Cong. Rec. 4809 (1951)), we feel that there is a serious question as to whether the AEC may rely on the provision for authority to charge contractors of other Government agencies for AEC licensing services, where the contractors' needs for the licenses arise solely from the work to be performed under Government contracts. As a final technical matter, we have been advised that the term "critical mass," as used in item No. 4 of section 170.31 of the proposed regulations, may be subject to various non-quantitative interpretations and thus would appear to require definition. Sincerely yours, 8 ~ Art u D. Holzman Assistant General Coun el
a,,,,,,. ,o. r - 1,,,110 WABCO MELPAR, INC. 7700 ARLINGTON BOULEVARD, FALLS CHURCH, VIRG INIA 22046 ~ A S U BSIDIARY O F W E ST IN GH OU SE AIR BRAKE COMPANY DOGHTED IJSAEC 6 July 1967 Secretary U. S. Atomic Energy Commission Washington, D. C. 20545 Re: Proposed License Fees (new Part 170) Gentlemen: The referenced proposed new Part 170, as covered in Notice to AEC Licensees dated 13 March 1967, has been reviewed for possible comment. I would suggest the desirability from a public policy viewpoint of exempting licensees from the payment of fees w here the license would be for use in Research and Development activi ties or in the performance of Government contracts. Very truly yours, MELPAR, INC. Secretary and House Counsel
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The Oh mart Corporation 4241 ALLENDORF DRIVE P.O. BOX 9026 CINCINNATI, OHIO 45209 June 29, 1967 Secretary DOCIETED U. S . Atomic Energy Commission OOAEC Wash i ngton, D. C. 20545 Ref: Proposed 10 CFR 170 Fees for AEC Li censes
Dear Sir,
Much has already been written about the proposed establish-ment of fees for AEC l icenses. The Ohmart Corporation c oncurs with most of the arguments against the establishment of the fee. We, especially, support the comments submitted by the Atomic Industrial Forum. Rather than repeat all of the arguments against th i s proposal, let us present specifi c examples which illus t rate some of the undesirable feat ures of t he proposal . The Ohmart Corporation markets gages which range in price from about $700.00 for a simple off-on level gage to almost $100,000.00 for a complicat ed sheet mat erial gage with automati c controls. We are particularly concerned about the purchaser of the $700.00 gage. The useful life of this simple gage is, at least, 8 years. If the proposed fee schedule
is adopted, the licensee would pay a total of, at le as t, $200.00 in fees - almost 30% of the purchase pri ce .
Coupled with this is the cost just to write the check . This could easily be $10.00 - or even $25.00, the same as the fee. If this cost is added to the fee the percentages become 40 % to 57% of the purchase price. Do these percentages seem re a sonable? Wi ll adoption of the fee further the peace f ul use of atomic energy? Admittedly, the above example is the extreme. However, the mainstay of gamma gaging - the density gage - sells for about $2500 . 00. Here, the percentages become 8% for the fee alone or 11 % to 16 % for the fee and paperwork . Even at t he
WORLD LEADER IN PROCESS CONTROL THROUGH NUCLEAR ENERGY

I Page 2 higher se l l i n g price - do the percentages see m reasonable?
Our answer to these questions is: NO . Therefore, The Ohmart Corporation opposes the establ i shme n t of fees for AEC licenses . Sincerely, THE OHMART CORPO ATION H.L. Cook, Jr. Vice President HLC / pat
GENERAL OFFICES
2501 HUDSON ROAD* ST. PAUL, MINNESOTA 55119. TEL. 733-1110 Nuclear Proclucts June 26, 1967 Secretary United States Atomic Energy Commission Washington, D. C. 20545
Subject:
Proposed License Fees for Facility and Material Licenses
Dear Sir:
The purpose of this letter is to register our strong opposi-tion to the proposed schedule of fees for facility and ma-terial licenses appearing in the Ma rch 11, 1967 issue of the Federal Register. We have noted the many adverse comments this proposal has received to date and one in particular, from the Atomic Industrial Forum, deserves your close exami-nation. We concur wholeheartedly with the position taken by the Forum on this issue. As manufacturers of a broad line of radioactive products we are not unduly concerned with the slight increase in "operating costs" such fees would mean to us, but we are vitally concern-ed with what the fees would mean to the ultimate user - especially the smaller users in the educational, medical and industrial fields who comprise the backbone of this young, growing radioisotope industry. It has been our experience that the use of these products, in many cases, is a "last resort" type situation. The additional burden of a fee, small as it may seem, to the existing burden of government, and in some cases state, regulations would tend to further discourage t he use of products containing radioactive materials. It is almost inconceivable that the Commission does not view the fees as a direct contradiction to their mandate to foster the de-velopment of nuclear energy. We furt her question the Commission's conclusion that they are obli gated to ch~rge fees for licenses in accordance with Title 5 of t he 1952 Independent Offices Appropriation Act. It app~ars to us that the benefits from this type of licensing do not accrue to the licensee himself but rather to the publ1c at ffilNNESOTA ffilNING AND ffiANUFACTURING comPANY
Secretary June 26, 1967 USAEC large. The licensing and compliance functions of the AEC are primarily concerned with insuring that the licensee does not exceed specific limits in terms of exposure of the general public ~nd radiation workers. It would appear that the AEC's responsibility in this area is similar to that of the FDA with respect to drugs. Another area of concern to us is the problems that are likely to arise as more and more Agreement States take over the re-sponsibility of by-product material licensing in their states. It is our opinion that the present licensing structure in-volving the AEC and Agreement States is complex enough and the i~troduction of ~n additional complexity in the form of the fee schedule would have a discouraging effect on the use of radioactive products. Should the Commission decide to proceed with the establishment of a fee schedule in view of the widespread opposition already voiced we would like to request that industry, via the Atomic Industrial Forum, be given an opportunity to discuss t his situation with appropriate AEC representatives. Very truly yours, (:p~ P. Ry.an O--- anager uclear Products JPR/mw
JUN 2 8 1967 Hor,orabla Albert R. Quie Eouse of R presentatives Dear Hr . Quie ~ Th::mk you for your letter of June 14 , 1967, t o t hcit S0cre tary, traua-cittini t he viot1s of fl:. Dwight z. ust&bon on t he Commissiou' a proposed license fees. EncloG&l is a copy of the Notice of ~reposed Rule Making published in the Fe..:fora~ Regi~ on March 11, 1967. This notice. which -was i3$ued for p blic coumi.ont, proposed the ost abliem1ent of fees for r~actor construction permits and operating l i cen~es, and for licenses to posse~s and use t4dioactivc rnater iru.s which are iosued by the AEC. Tho proposed fees are set forth in the notice. 1 am also enclosing a opy of a public announcCJ!len: discussing t he proposed fees. 'i'be fees proposo . in the notice. have not been establish~ as final . We ve receive numerous letters c.mmnenting on t h p-roposed -rule. lu vicvi of his interest we have m*to.nded t he comment period to J uly 9, 967 * ...he com::::t!nts of Mr. Gustafson and those which may be 8Ubmitted by any oth~r nterested person wi ll be carefully consi dered by the Com:raiosiou before eaches a final decision on t he proposed fe& achQdule . /. As requested,. I returning the correspondence which was attached to yo *r 1 tor. Distribution: Si ncerely yours. Dir ector of Regulation Cong . Rel. (2) Of . of t he Gen . Counsel
'( signed ) Harold L Price Fonnal File Supplemental File Harold 1, , ~ ~ - - --xi>cr etari at w/cy for Direct or ot Regulation Publ ic Document Room At t n: St an Robin son Ee" c ocuran: Of. of t he Controller L No *ic " of Proposed Rul e 'Making bee : c. K. Beck 2 . Copy of Public An11ouncet1ent M. M. Mann
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PLAZA 4-1075 June 26, 1967 Public Proceedings Branch Office of the Secretary U. S. Atomic Energy Commission Washington, D. C.
Dear Sir:
I have not received the customary acknowledgement of receipt of my letter concerning proposed 10 CFR Part 170 (establishing fees for licensing, duplicate copy enclosed) dated 6/16/67 and presumably postmarked 6/16/67. I wonder if you would be good enough to advi s e me whether it has in fact been received. Yours truly, oseph B. Knotts, Jr. Secretary Working Group on Licensing Fees JBK:aj enclosure
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PLAZA 4*1075 June 16, 1967 ocKETE Secretary USilEC United States Atomic Energy Commission Washington, D~C. 20545 JUN 28 1967 RE: Proposed 10 CFR 170 (and related amendments) to establish fees for certain AEC licenses
Dear Sir :
This is to provide the cormnents of the Working Group on Licensing Fees of the Atomic Industrial Forum on the subject proposed regulations which were published in the Federal Register on March 11, 1967 . These cormnents were developed at a meeting of the Working Group held at the Forum's headquarters in New York City on May 9, 1967. The following Forum members participated in the development of this letter: H. L. Cook, Jr . Vice President Omhart Corporation Eugene Ferraro Manager , Government Reg. Industrial Nucleonics Co. J. S. Hanks Secretary and Treasurer Industrial Reactor Labs.
0. H. Jones Accountability Representative The Babcock & Wilcox Co.
T. N. Lahr Manager, Pilot Plant 3M Nuclear Products Carlton Nelson General Manager Cambridge Nuclear Corp. Thomas Russell Manager ATCOR C. W. Waggoner Attorney United States Steel Corp. Benefit to Public at Large In the view of the Working Group, it is not appropriate to charge fees for AEC licenses for source, special nuclear and byproduct material and for construction permits and operating licenses for research, training and testing facilities. (The group did not address itself to the question of fees for central station nuclear power plants.) The public at large, rather than the licensee, is the beneficiary of the Commission's regulations. Costs of licensing should, therefore, be borne through general sources of revenue and not fees paid by the licensee. To elaborate on this point, federal user charges are to be applied, in the words of the Bureau of the Budget Circular A-25, to licenses, permits and the like which * "cortvey special benefits to identifiable recipients above and beyond the benefits accruing to the public at large". Thus, there must be something beyond the mere fact that a license is received which makes "user charge" applicable.
Secretary Page 2 United States Atomic Energy Commission The Working Group believes that in most AEC licensing situations the intent and the result is to benefit the public at large - to protect its health and safety. The Working Group notes {hat this was essentially the position taken by the California Department of Public Health in its report on fees for licensing of radioactive materials submitted to California legislative bodies in 1962. The Department concluded:
"The Department believes a) that the radioactive material regulatory program is truly a public health program, and b) that the fees made necessary by present statutory requirements represent an undesirable deterrent to beneficial uses of radio-active materials. Thus, the Department recommends that the statute be appropriately changed so as to provide , for an adequate state radiation control program to be financed principally from general support funds", 1(
Resolutions of the Department's Advisory Committee on Radiological Health and of the State Board of Public Health were to the same effect. It is the Working Group's understanding that the reasons these resolutions and recommendations were not acted upon were extrinsic to their merits . Adverse impact on users of atomic energy : statutory mission A second basic concern is that, in many instances, the exaction of a fee will tend to discourage the use of atomic energy materials or devices in the absolute or in relation to competing means (e.g . radium, X-ray and other non-isotopic means) of accomplishing a given end. Such a result runs counter to the statutory promotional mission of the AEC "to encourage widespread participation in the development and utilization of atomic energy for peaceful purposes to the maximum extent consistent with the common defense and security and with the health and safety of the public". The negative effects wou ld be particularly severe where the fee itself is a significant proportion of the value of the material involved or where the added paperwork of an annual fee reduces the attractiveness of radiation devices to users outside the "nuclear business". Further, in some instances, materials competing with regulated by-product or source material present less desirable radiological safety characteristics. In other instances, competing devices employ ionizing radiation in equipment whose radiological characteristics have not been sub jected to close regulatory review . In these instances, a tendency to discourage the use of regulated by-product or source material would be a disservi c e to the general public .
"Report to/Assembly Interim Committee on Public Health/Senate Governmental Efficiency Commit t ee/Pursuant to/Assembly Concurrent Resolution No. 19/
Concerning/Licensing fees for Radioactive Materials".
Secretary Page 3 United States Atomic Energy Commission "Conflict of Interest" Morever, in a system where the regulator is "compensated" by the regulated, there would seem to be posed a theoretical "conflict of interest" situation, though it is by no means suggested that any actual conflict would arise. Agreement State Licensees Finally, consideration should be given to the initial discriminatory impact on that group of licensees not in Agreement States (only one has fees presently, to the knowledge of the Working Group) and to the subsequent impact on organizations having Agreement State and AEC licenses if, as appears likely, the Agreement States follow the AEC'S lead. Should the Commission determine that it must proceed to establish a schedule of fees for certain licenses, despite these and other considerations militating against such action, the Working Group respectfully requests an opportunity to discuss the proposal with appropriate AEC representatives and/or furnish additional written comments. Yours truly, c£f!:~ Secretary Working Group on Licensing Fees JBK:aj
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The attached communication is sub-mi tt ed fo r your cons i deration, and to ask that the r equest made therein be complied with , if possible . If you will advise me of your action in this mat t er and have the l etter returned to me with your r ep ly, I will appre c i a te it. ALBERT H. QUIE
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OFFICE OF THE JUDGE ADVOCATE GENERAL WASHINGTON, D.C. 20310 DOCKET NUMBERPR ge,lftJ.SO. PROPOSED RULE . 7~1/'JO U 573 JAGU 196 7/9473 DOCKETED June 1967 USAEC Mr. W, B. McCool Secretary Atomic Energy Commission Washington, D,C. 20545 Re: Part 170 - Fees For Facilities and Materials Licensed Under The AtomiE..§nergy A£!_of 1954, As Amended
Dear Mr. McCool:
As duly authorized counsel for the Secretary of the Army, I wish to submit the following comments on behalf of the Department of the Army opposing the above-entitled proposed rule making to the extent indicated, The pertinent statutory provision under which this proposed rule making is promulgated provides in pertinent part: It is the sense of th~ Congr ess that any work, service , publication, report, document, benefit , privilege, authority, use, franchise, license, permit, certificate, registration, or similar thing of value or utility performed, furnished, provided , grant ed, prepared, or issued by any Federal agency (including wholly owned Govern-ment corporations as defined in the Government Corporation Control Act of 1945) to or for any person <includ!n9 groups, associations, organ-izations, pa!tnerships , corporations, or busi-
~esses), except_those engaged in the transaction of official business of the Government, shall be .self-sustaining to the fu,11 extent possible, and the head of each Federal agency is authorized by regulation (which, in the case of agencies in the executive branch, shall be as uniform as practi-cable and subject to such policies as the President may prescribe) , to prescribe therefor such fee, charge , or price , if any, as he shall determine, in case none exists, or redetermine, in case of an existing one, to be fair and equitable taking into consideration di rect and ind i rect cost to the Gov-ernment, value to the recipient , public pol i cy or interest served , and other pertinent facts, and any amount so determined or redetermined shall be
U 573 JAGU 1967/9473 13 June 1967 SUBJECT : Part 170 - Fees For Facilities and Materials Licensed Under The Atomic Energy Act of 1954 , As Amended co l le cted and pa i d i nto the Treasury as miscel-laneous receipts , Section 501 , 65 Stat. 290 Underscor i ng added ) . The language in that portion of the statute underscored above , creates considerable doubt that the proposed fee could be assessed lawfully against another gov ernmenta l agency. It seems clear that the Government is not a pe r s on in th i s sense and to exempt persons "engaged in transaction of official business of the Government" a fortiori exempts any Gove r nmen t agenc y. A thorough reading f the proposed ru l e mak i ng r ev ea ls no spe cific exempt i on in this respect . Inconsistent ly an exemption i s provided for ce r tain nonprofit edu-cational inst i tutions . The proposed rule shou l d be modified to exempt any government a l age ncy. Withstanding for a moment the ega l prohibition aga i nst exacting a license fee from a Gover nment age ncy in this instance, there are a number of reasons for ex c udi ng any governmental age ncy from th e rule . In parti cu ar the Depa r t ment of the Army now has 120 licenses which under the pr oposed fee schedu l e wou l d r equire ~6,400 in Depa r t-men t of the Army funds pe r annum t o maintain . As additional l icenses are issued the costs wou l mu tip y . Many of the activities unde r - t aken by the Department of the Army i n the fie l d of atomic energy are shared with the Atomic Ener gy Comm is sion and the Commis ion can re ly upon t he Department of t he Ar my' s compl ete coope r ati on in the futu r e . No good purpose would be erv e ny e te ndi ng the fe es t o th i s Depart-ment . To the contrary , the impositio n of a lice ns e fe e wi ll ma t er ia ll y increa s e the or l oa d and ov er head cos ts of t he Depa rtme nt of the Army and wi l resu l t i n a net in crease in cos ts to t he Gov ernment . Fo r the fo r ego in g r ea s ons , rtment of the Army t hat the proposed rul e mak i ng gove r nment al agencies from the i cen se fee req uirement . 2
GENERALfj ELECTRIC COMPANY
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DIVISION 175 CURTNER AVE., SAN JOSE, CALIF. 95125 .. AREA CODE 408, TEL 297-3000, TWX NO. 910-338-0116 June 12, 1967 Mr. W. B. McCool, Secretary U. S . Atomic Energy Commission Washington, D . C. 20545
Subject:
Proposed Establishment of Licensing Fees
Dear Mr . McCool:
The Nuclear Energy Division of General Electric Company has reviewed the proposed establishment of licensing fees published in the Federal Register on March 11, 1967. While the amounts of the various fees applicable to the Division's nuclear activities do not appear unreasonable, as currently pro-posed, it would have been helpful to our deliberations if the notice had pre-sented additional background information concerning implementation of the Independent Offices Appropriation Act including comparisons of the fee schedules for other agencies. The following specific comments are offered for your consideration:
1. Fees for Post-operational Construction Permits As set forth in 10 CFR 50. 91, a construction permit may be issued by the Commission for any material alteration of a licensed facility .
Presumably, filing and construction permit fees would be required in such cases and in the same amount as if the facility w ere being initially constructed- The basic problem is imposed by the absence of published standards for determining which modifications will be considered "material a lterations". Absent such standards or criteria for identifying material alterations, an applicant for authorization of a change in a facility could suffer unwarranted delay and administra-t ive expense when review of the application results in its return to the applicant for non-payment of fees under the material alteration - construction permit ruling.
GENERALfj ELECTRIC Mr. W. B . McCool -- June 12, 1967 Page 2 To avoid such delays, it is recommended that Section 50. 91 be amended to provide definitive criteria specifying the type and magnitude of facility alterations for which prior construction permits will be required. The necessity for establishing such criteria obtains, irrespective of whether a construction permit fee is established. Exemption of post-operation permits from the proposed fee schedule, however, would temper the delaying effect of the lack of such criteria.
2. Licenses for Materials Incidental to Facility Operation The exemption proposed by Section 170. 11 should be revised slightly in order to clarify that the fee exemption includes materials licenses is sued prior to the issuance of the facility operating license. While this may be implied by the term "licensed under Part 50", the language would be less subject to misinterpretation if modified as follows:
"A license authorizing . .... material incidental to the operation of a production or utilization facility for which a construction permit or operating license has been issued under Part 50 of this chapter, including a license ..... etc."
3. Timely Payment of Construction Permit or Operating License Fees Proposed Section 170. 12(b) states that no permit or license will be issued until the fee has been paid. While it is likely that most actions that are contingent on the payment of fees will have been preceded by advance notification of proposed issuance of the license or construction permit, it is believed that the applicant deserves regulatory assurance that he will be advised of the amount of the fee due and that such notifi-cation will be made sufficiently in advance of the issuance date to permit fee payment without delaying the issuance date.
Very truly yours, Administrator - Lie ens ing Mail Code 824 BDW:eg
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. G_U_S_T_AF_SO_N_ P.;;;H_D_N_E_3_8;;;.8_ 4_0_6_7----s PEC 111.llS TS IN so UN D DONALD R. GUSTAFSON, Vice-President ( AREA CODE 612) PUBLIC ADDRESS
INTER-COM RECORDING EQUIPMENT Red Wing, Minnesota 55066 June 9 , 1967 DOCKETED lJSiAEC JUNl 3 1967~
Secretary Office Of th Pub,. e Secretary United States Atomic Energy Commission ,IC Pr .~ :_?h~ Branc;, * .,s Washington, D. C. 20545 Dear Sir; We have just seen a copy of your Notice to AEC Licensees, dated March 13, 1967, requesting comments on your proposal for the estab-lishment of fees for materials licenses . We are distributors of Edwards fire alarm systems and as such, will be distributing Pyr-A-Larm fire detection devices . We know that we will have to have a Specific License for the transfer and install-ation of these devices . It would appear from your bulletin that we would come under the Category# 1 with an annual fee of $25 .
We realize that this is not a large sum but we are a small business and all of the various small costs add up very quickly. We are in an extremely competitive business and fractions of a percent difference often settle the award of a contract . Anything whi ch increases our costs puts us in a less favorable position in bidding for jobs . The devices involved are de-signed for life protection and property protection . It does not seem that this type of item should carry additional casts.
There is the further possibili ty that the various states will fallow your lead and i mpose license fees . We do business in five states . This becomes one more stumbling block far small business-men. The Federal government has established many bureaus and committees to study the problems of the small businessman and try to help them. Every additional tax, license fee, report , and an and on, add to our costs. We respectfully request that you reconsider your proposal to im-pose license fees on this material . Sincerely,
~ s o n , President DEG;ld cc: Edwards Company, Inc .
Albert Quie
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745 Fifth Avenue, New York, N. Y. 10022 1967 ETED IJ&AEG Office of the Secretary UN 12 1967 U.S. Atomic Energy Commission fflce at the S!cretary Pab!lc Prac;* ,:17gs Washington, D. C. 20545
Dear Sir:
We refer to notice published in the Federal Register March 11, 1967 of proposed amendments and regulation for the establish-ment of facility and material license fees. As a pharmaceuti-cal company directly involved in the research and development of isotope materials for human medicinal use, we have a vital interest in these proposals, and accordingly, we offer for your consideration the following comments. The proposed regulation (Part 170) will require the practicing physician utilizing by-product material in clinical programs to pay an annual fee of $25 or $50, depending upon the type of material license issued. In some cases an additional applica-tion fee of $100 will be required. There is no need to demonstrate to the members of the Commission that the future success of clinical research and development in this new and exciting area of medicine depends essentially upon the willingness of the practicing physician to be a member of the research team. Any action or measure by the Commission that has the potential for discouraging the practicing physician from participating in that research effort should be carefully considered. If, on balance, such measure or action by the Commission will frustrate the primary purpose of the Commission to promote the peaceful ends of nuclear energy, such an action or measure should not be adopted. There can be no doubt that the harassment and additional financial burden of this revenue measure will discourage the independent physician from obtaining a material license and maintaining it in force. Any funds made available to the Commission through this revenue device will be miniscule in comparison to the funds appropriated The "Priceless Inaredient" of every product i s the honor and integrity of its maker
by Congress to carry out the Commission's responsibility to exploit the peaceful uses of nuclear energy. If the price to be paid for such a small contribution to the national ef-fort is frustration of the primary purpose of the enabling legislation, the price is too high. We respectfully point out that Congress did not see fit to make provision in the Atomic Energy Act of 1954 for the establish-ment of any such fees. The validity of any regulation, purport-edly implementing a provision of the Independent Offices Appro-priation Act, is open to question, if such regulation is not compatible with the Commission's primary responsibility to foster the development of the peaceful purposes of nuclear energy. Title V of the Independent Offices Appropriation Act of 1952 specifies that the prescribing of any such fee depends upon such factors as the "value to the recipient" and "the public policy or interest served." We submit that the establishing of the proposed fees serves neither the interest of the license holder nor the public interest. Accordingly, we respectfully suggest that the proposal to establish material license fees is ill-advised, especially at this time of pioneering development in the medical uses of by-product material, and we respectfully recommend to the Com-mission that the proposed amendments and regulations not be adopted. Respectfully submitted,
& SONS, INC. ~ ,~~
n F. Bradley/ ssistant Secretary me
DOCKET NUMBER PR-$$,/.fC,'ilJ, 170 PROPOSED RULE 'l~. JUN ? 1967 Distribution : ormal File
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- PROPOSED RULE PR-1&,110 VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND , VIRGINIA 1'3l07 June l, 1967 DOCKETED IISIAEC Secretary U. S. Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
We have reviewed the changes proposed for Chapter l of Title 10 of the Code of Federal Regulations, Parts 30, 40, 50, 70, and the new Part 170, as announced on March 10, 1967. We believe the proposed changes are reasonable and appropriate, and are compatible with the Commission's responsibility for fostering the development of nuclear energy. With respect to the various rev1s1ons to parts of existing regulations, and to Part 170 as a proposed regulation, we do have several suggestions which you may wish to consider prior to issuance of this part in final form, and they are as follows:
1. On page 1 of the release, a statement is made to the effect that if a single application is made, covering more than one facility, only a single application fee need be paid. The proposed revisions of the various parts, and the new Part 170, do not expressly state this, however, and we suggest inclusion of specific language on this point.

2. On page 2 of the release, a statement is made to the effect that where a facility 1 icense is outstanding, no additional fees will be charged for operator 1 icenses under 10 CFR, Part 55. The proposed revisions, however, do not expressly state this policy in either Part 55 or in Section 170. 11 of the new Part 170.

3. With respect to the payment of annual fees, we believe that it would be much more convenient for all concerned if all fees, other than the initial filing fee, are payable on a single annual date , such as June 1. It would also be of considerable assistance to 1 icensees to be billed by the Commission thirty days in advance of that annual payment date.
Very truly yours, Senior Vice President
AMERICAN ELECTRIC POWER Se r vice Corpor ati o n
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I 2 Broadway, New York, N. Y. 10008 HA 2-4800 May 31, 1967 Secretary U.S. Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
This is in regard to the Proposed Rule Making published by the Commission proposing the establishment of license fees for facility instruction permits and operating licenses issued under 10 CFR Part 50 and for specific byproduct, source and special nuclear materials licenses issued under 10 CFR Parts 30, 32-35, 40 and 70. I believe that the license fees pertainjzg to the use of nuclear sources in our civil defense program is not com-patible with the national goal of having industry financially support its own civil defense program to meet theneeds of nuclear attacks. Very truly yours
,lt~~
A. F. Gabrielle Assistant Head System Operating Division AFG:rm DOCKETED IJ&IEC JUN
UNITED STATES DEPARTMENT OF AGRICULTURE AGRICULTURAL RESEARCH SERVICE WASHINGTON , D.C. 20250 OFFICE O F ADMINISTRATOR MAY 3 1 1967 Mr . W. B. McCool Secretary to the Commission U. S. Atomic Energy Commission
Dear Mr . McCool:
Reference is made to the Proposed Rule Making which appeared in the March 11, 1967 issue of the Federal Register whereby the Atomic Energy Commission is proposing to establish fees for facility construction permits and operating licenses issued under 10 CFR Part 50, and for specific byproduct, source and special nuclear materials licenses issued under 10 CFR Parts 30, 32-35, 40 and 70 . e note that the proposed regulation and fee schedules apply to all persons except those who apply for or hold licenses exempted in ection 170. 11 . The Department of Agriculture does not hold facility construc-tion permits and operating licenses and does not comtemplate applying for such permits and licenses in the foreseeable future . However, as a Federal agency we consider that this Department and other Federal agencies should be exempted at least from payment of fees which would be charged for materials licenses . This is based on the following reasons: (1) finance personnel would become involved in licensing matters; (2) considerable administrative effort would be required to effect payment; and (3) overall expenses incurred would exceed actual cost of fees . Concomitantly, the AEC would incur similar administrative problems and costs. In view of the above, we respectfully submit that the Department of Agriculture and other Federal agencies should be exempted from the payment of fees for materials licenses and request that the Commission grant such exemption . Sincerely yours ,
f oocKn ~a ri~R PR 1b,,,,. ,o, 1Je PROPOSE- LE - 10,111 ~ 12 3 5 lffily 24 , 1967
-~:1. F. K. Dougl1er -y
2905 Windsor Place O~cla 10::r.2. Ci ty, Oklal-ior.r. .a
Dear It.tr. Dougherty:
Tha nk you o,* your letter co*1-
~er ing the pr*oposad rule r:-.:.aklng 0:1 license fees by the Atomic :Snorgy Co~~.d.s~ion. I cm not fully far1i l ia1" i:,~i th this p::opos 1 or the D3Gd for .,I 3se license fees, and 11 ve asked the Atomic Energy Com:.*:1.:i. ssion for a full report on it. itJhen I lY*ve furtt.o:c- inforr:ation, I will be in touch with you f:.lS* in.
Sim orely yours, _ .i: 3D R. El"l.RRIS U. S. Scnc:B J.' '
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0 ullllt Proc~id\ngs
Dear Senator,
Re: Proposed rule making on License Fees by the A:.*omic Energy Com.11issio:-i, from Federal Rog:i.ster, *larch 11, 1967 As Chi~~ Pharmacist for the loading vol~_tary hospiwl in Okls.ho::-:.a, and anticipati;1g bcco.; ng more and more involved in pharm::i.c utical use of radioactive agents, I wish to express my opinion th:it the sctti-ng up of a foo for licenses issued by the Atomic Energy Commission is urn:.-m.rranted and tha. t tho ex.._)~: di tures of those** licensees involved make such a foe m j. ,stificd. It seems there is an ever grc.'.?.. ter tendency for tho Govorr.m.ent or its agencies to take advantage of anyone it cnn ra thor than to make a genuine effort to practice economy and be of grcato ser-vice to its people . I, therefore, ask that you do what you can to prevent t.'1.is proposed rule making on License Fe s f~om Ulking place. You.rs/'.tr ly;,-1 /*/ 7 l--zf;/};~(c:/~ '
* .
Dough,._/' /
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PROPOS-EO RULE . 1*,170 SOUTHWESTERN STATE COLLEGE Weatherford, Oklahoma 73096 ~~~~~~~~~~~~~~\: DIVISION OF MATHEMATICS AND PHYSICAL SCIENCES May 12, 1967 DOCKETED USIAEC Secretary U. S. Atomi c Energy Commission Washington, D. C. 20545
Dear Sir:
Reference:
Proposed New Part 170 and amendments to Parts 30, 40, 50 and 70 of Title 10 of the Code of Federal Regulations. A number of comments and questions have occurred to us concerning the proposed establishment of fees for facility and materials I icenses issued by the Atomic Energy Commission. At present we have three sources on specific licenses here at South-western State College, and we anticipate growth in this area during the next few years. The licenses we have at present are (1) 300 micro-curies of Sr-90 in a slow neutron survey meter-license No. 35-11189-1(H67); (2) 30 mi 11 icuries of Co-60 used for Civi I Defense training courses-I icense No. 35-4534- 1(A66); and (3) 32 grams (2 curies) Pu~Be in a neutron howitzer used for educational purposes- l icense No. SNM-873. Our Pu-Be source was obtained on a loan agreement, so our interpreta-tion of the proposed regulations is that this source would be exempt from annual fees. Is this correct? Our concern relative to our other sources and application - annual fees in general is three fold. (1) The Sr-90 source is an integral part of a slow neutron survey meter which we purchased for $450.00. Under the pro-posed annual fee system, the dollar investment to maintain a current I icense on this source would rapidly become a significant fraction of our original investment for the instrument. (2) The Co-60 source is used for Ci vi I Defense courses taught to non - student audiences. We are not certain whether we or Civi I Defense would be responsible for this fee, although it appears from the proposed regulations that we, as I icense holder, would be responsible. Would this source be considered exempt under paragraph 170.11, section b. (3) We anticipate, as a smal I college attempting to present comprehensive radiochemistry training at the undergraduate level, a situation where application fees and annual fees would account for a significant percentage of our annual operating budget.
Page 2 May 12, 196 7 In summary, we feel that paragraph 170. 11, section b, would permit tlexibi I ity by the Atomic Energy Commission in granting exemptions, but we have not been able to determine what type of I icenses would quality tor consideration under this section. Finally, we feel that licensed sources at non-profit educational institutions should be exempted it these sources are only incidentally related to instructional activities or it the assessment of the tees would seriously imperi I the proper execution of the educational processes. 1Joi~lctv Earl A. Reynolds, airman Division of Mathern ics and Physical Sciences EAR:ljs
DEPARTMENT OF THE NAVY 9 :~;~:E~u;~~~RPR-:,~~~,o, OFFICE OF THE GENERAL COUNSEL WASHINGTON , D . C . 20360 OGC/WLB:pl May 1967 CKE TE D U&AEC Secretary U. S. Atomic Energy Corrnnission AY31 I967 Washington, D. C. 20545 ftice at th, Secretary
.:ti/le rot~Jlnga
Dear Sir:
The Bureau of Medicine and Surgery has called to our attention the proposed regulations published in the Federal Register (32 FR 3995) setting forth fees to be charged for licensing services rendered by the Atomic Energy Corrnnission . The Bureau states that fifteen naval medical facilities currently are licensed to use byproduct material and that it also assists the Chief of Naval Operations with licenses for six cormnands. The Bureau objects to payment of the pro-posed. fees. We note that while the proposed regulations provide that the Cormnission may grant such exemptions as it deter-mines are authorized by law there is no provision expressly exempting Federal agencies from payment of the fees. On the basis of informal discussions with a representative of the Cormnission we understand that collection of the fees from Federal agencies is contemplated. However, for reasons to be stated, it is our view that this would not be legally permissible. The proposed regulations state that the authority pursuant to which the fees would be charged is Title V of the Independent Offices Appropriation Act of 1952 (65 Stat. 290, 5 U.S.C. 140). This Act, in pertinent part, provides:
" It is the sense of the Congress that any work, service .*. license ..* or similar thing of value or utility performed, furnished, provided, granted, prepared, or issued by any Federal agency ... to or for any person .** except those engaged in the transaction of official business of the Government, shall be self-sustaining to the full extent possible, and the head of each Federal agency is authorized by regulation *.. to prescribe therefor such fee .** as he shall determine .*. to
\. be fair and equitable ... and any amount so detennined ... shall be collected and paid into the Treasury as miscellaneous receipts. . . " (Underscoring added.) It seems clear that this Act neither contemplates nor authorizes the collection of a fee for services rendered by one Federal agency to another. The Comptroller General has held in several cases that statutes authorizing and directing the collection of fees may not be regarded as authorizing or requiring that such fees be collected from the United States or its agencies, except where they specify expressly or appear to require by necessary implication that the fees be collected from another agency of the Government . The general rule enunciated by the Comptroller General is that payment for services rendered by one agency of the Government for another is not autho-rized where the services are required by law in carrying out the nonnal functions of the perfonning agency and for which appropriations are specifically provided. The Comptroller General has held that in these circumstances the appropriation of the Government agency receiving the services would not be available for payment of fees. In light of the foregoing, it would appear that the proposed regulations should be revised to expressly exempt Federal agencies from payment of the fees, and we urge that this be done. Should they be adopted without such exemp-tion, it would be necessary for this Department to submit the matter to the Comptroller General before payment could be made. Sincerely, (}
~ii-~-
Albert H. Stein Acting General Counsel
MAY 2 ll 1967 Distribution: o File Supp1 ental ile
*ec::.l'et riat Public Document Room DOCKE TE D i.SAEC MAY2 91967 '
fflce of the Secr~tary Puflllc Proc*,~ings
PAB GLHutton:vd 5/ /67
~ongress of tb e Wnite'tl ~ta:tes oo::;;,ET NUMBER PR PROPOSED RULF ji)oull'e of ll\eprell'entatiuell' -
f![r . iis. r,Jld :;:_, . Pl*i e: e Diree:tor of ~~e~;ulo.tio!'.l. .\*c\_)i/li(; Bncrt;:,r Cor.1rn::.. ssion i1ashin~(tcn, D. C. S ir: The attached corrrrnunication i s sent f or your cons i deration. Pl ease i nvestigat e the st atements contained therein and forward me the necessary information for re - ply, returning the enclosed c orre-spondence with your answer. Yours truly, JAi, 1,{J~ 0-V--- I will a:ppreci'J.tc every consid.crn.tion-that ,,iay oe ,;.i. ven t o :iJr . Ket~.nis ' co,, '11ents, a ncl will 1)e crateful for a re~)ort con:::err~,r.d~d tc'fff_oyY"~r~eJ, uc;~:3- __.S,1-:2,..SP't_J. Ti.ne___ li-~1~------ Be h,--~i-.-r22°~'f-
1229 DOCKETED 0$AEc May 11, 19 6 7 MAY291967 Office of the Secreta,y PulltJc Jlrot:eed/nga , BranC/J The Honorable John Jarman s The House of Repres e nt a ti v es Washington 25 , D .C.
Dear Sir:
This letter concerns a disturbing proposal whi c h we ha~e recently received from the Atomic Energy Commission, suggesting that fees for licensing of private and institutional handlers of radioactive isotopes may be instituted, and that there may also be fees instituted for r adioisotope installations . The fee s as they are suggested by the Commi s sion are relatively s mall for a private individual but rise to alarming proportions for installations of various types. I am writing you as Chairman of the Radioisotope Committee of this hospital, and this letter represents the unanimous opinion of all of the doct o rs of the Committee, all of whom have experience in isotopes . First,. medical radio i sotopes are a very useful art which has progres-sed rapidly in its childhood, and I believe that they have great potential for medicine. A number of things can be done with isotopes which c annot be done at all by other means, or are much. less conven - ient. However, medical radioisotopes have almost invariably been a losing proposition, financially, since the beginning, and have been used very ~idely only in institutions where cost is no object, and where there is no need for given department to be self-supporting . We feel that a further cost of this nature, added to the already
unfavorable financial outlook, will further discourage private prac-tition~rs of medicine from participating actively in radioisotope studies, and will further elevate the ~ost of these studies to the patient . It is, in many cases, nearly prohibitive already .
As you know, there are a number of states which have begun par~ici - pating in control of medical radioisotope laboratories and instal-lations. If this precedent of fees for all licensing services is institite<l, then many . of the states will probably follow
the leader, and many of, ,t~e companies, who are licensed in all fifty

st~tes, and a num ber of doctors that are licensed in more* than one state , may simpl y have to withdraw from participation. A given license at present ~s issued only f o r use of isotopes in one l o cati o n, and if
The Honorable John Jarman - p. 2 5 6 7 there are multiple laboratory areas supeivised by an individual, t1e fee s might also be . prohibitive, indeed . In short, we feel that medical radioisotopes hold an enormous promise for the futµre, and that this particular science should be nurtured carefully, rather than disc o uraged financially more than it already is. With further study and further usage, many of the costs pertaining to this s c ience will diminish, but only if the re
is large usage and only if further study is enc o uraged rat her than discouraged. We also plan to protest to the Commis-sion, ~ut we feel that jou should be informed o f the benefit to medicine which w~ feel is in real je o~ard y by this act .
S i ncerely,
)~ f ~ H*t2 Harry J, Kearns, M.D.
Chair ma n, Radioisotope Committee, Saint Anthony , Hospital Oklahoma City, Oklahoma JK /mah
- UNION COUNTY Civil Defense Association JONESBORO, ILLINOIS April 21, 1967 Secretary U.S. Atomic Ene r gy Commission Washington, D.C. 20 545
Dear Sirs:
In accordance with Paragraph Three (3) of the notice date d 1arch 13, 1967, proposing establishment of License Fees, I wish to state that civil defense organizations everywhere usually operate on budgets far too small for the job expected of them and should be exempt from any such
fees.
The material we have, we hold and use at the request of the Federal overnment for the eventual benefit of the people. How then can you justify taxing us, a non-pro~it organization. for rendering this voluntary and unpaid service? If the fees become established, our local organization,for one, will discontinue this attempt at such emergency st and-by service, simply bec ause we cannot afford it. Vefy truly yours,
~ t.#!7~ - a~ . Colre ( ~_)
Director Union County CiYii Defense RFC:sh
-c AY29 J967 fflce of th KETEo Pub/Jc P e Secretary Braroczar/r.,, ..,.8
OFFIBE OF nm _CH."-"9m _
. .s-*~c). j ' 'IO: ~~For approp**r io.cc rondlinc Replj £6r Chairman's Sisnacure
__ With or __. without ~opie~ for
. Core.missioners *
--- For .Information REMARKS _ _ _ _ _ _ _ _ _ _ _ _ _ __ Arnold R. Fritsch
*For 'the Ch~irman
.:;OHN !J . /\~:OCRS ON nt,:-,\~'lo:IT vuv:.*:
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* ~_fn l O1 !:iTR:c-r. I LLIN0IS p .POSED llULE 7 Cl { 7 Cl 1225 LO NGWO;,TII 8UILDING WA SIII NGT 0 U, O.C.
M CMIJCR: C1:0H!JtC%5 of tue ~initeb @ptate% JOI NT COMMl1, CC ON DISTrllCT O rFICC: ATOM I C EN DlG Y ROCK R I V ER SAVING::; OUILlJWC C0MMIYT CE ON nuu:: s 4 0 1 W . S TI\T C STll CCT
%)ottzc of !Repre£ientntit1ez ROCKFORD, ILLU IOI!;; GJ 10 1 ~[for;f)ington, i!\.<£:. 20515 ~1ay 19 , J.9G7 Hcnorc:1blo Gle nn T. Seabo1*g , Chairma n Ato mi c Energy Corn1,1 ission Washi ngton , D. C ., 205Lr5
Dear Mr. Chairman :
I wo uld appreciate your reviewing th e enclosed copy of a communicatio n received from a constituen t and I would welcome your commer,ts on hi s inquiry . It would be helpful if you r respo nse would include answers to the fo llow in g questions.
1. Will the AEC fee schedule a pply for all power reactors?

2. What is the schedu le of fees?
3 . When do es t he co mmen t period expire? With all good wishes . JBA :j ig Rec'd o*ff;. 9,ir, of ,Reg~ Date ___ -?_/.2£"Lf.2._
T'ime __ __Io' .:.:.> ------ _-,.....,o
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DOC:'ET m.JM3rn DR 3' Cir {I~ 10,. PRO?osrn RULE I 7a I7 0 R#2 Rochelle, Illinois 61068 May 9, 1967 ,Hon0rable John B. Ande.rson 1225 Longworth Bldg. Washington, D. C. 20515
Dear Congressman:
Thank you for your NEWS LETTER informing us on what's doing in Congress. I am informed that the Atomic Energy Commission is proposing to charge a fee for license to build a nuclear fired power plant. At first thou ght this seems like a reasonable requirement but on further consideration I am not sure. I fear that this might be another scheme of the socialist planners to further handicap the private power companies in their competitive struggle with the government financed systems such as TVA. Would these federal and municipal systems be exempt from this license fee as they are now exempt from other taxes? If so then~ of course, the adoption of this proposal by the AEC would . serve to further our progress toward complete socialism. Another point in this proposal which I question is that the fee would apply only to units with a capacity rating in excess of 15,000 kilowatts. Now, since it is well known that no private electric utility system would install a generating unit as small as 15,000 Kw. municipally owned plant that at some future date might attempt to operate nuclear unit of this small size in spite of it's known inefficiency. I hope that Congress will study this proposal from the AEC carefully before giving their approval to it's adoption. Yours truly, Isl J.D. Biggers J. D. Biggers
MAY 2 6 19li1 ICIE ra USrlEC AY 26 1967 Office of the Secretary Public Prcmttlnga
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l> :ulation Co
l. (2)
Of. of Oen. Co
'( sio-ned ) Harold l, Price le .. r bee: C. k
M. M. Mann C. t. on B. K.
G REG Co
Ral.
GLButt utvd S/2J/ 7 SI /61 SI /61 SI /67 5/ /67
liSJEG MAY 2 6 1961 MAY 26 1967 ftlce of the 3er.retar, ubac ProceedJ,1gs lation Co
al. (2) 1 ,il7'nPtt r ff :irriH L Price Of. of the O

Counsel le cal il at Doc ent
f. of the Cont r bee : c.
Beck M.

Mann
c. L. H on H. K.
ooc Con. el. GLH tton :vd ~1.11enaes~on llLPr~c 5/1 /67 5/ /67 Sf /61 SI /67 5/ /67
DOCKET NU MBER PRJb,1(0,,t_ PROPOSED RULE - 1", r/0 CKET-ED U&AEG AV 26 1967 ffic? of the Secretary Pub'ic rr,r * *: *;s
----====' f lation * (2) '( sifned ) Harold [. Price Gen, Coun el l ile
oc nt oo Of. of the Controller bee: c. K. c:k M. M. Mann
c. L. nd r on H. JC. Sha ar RPS: OGC R Cong. Rel.
GI.Hutton: d CLRe son BL ric S/22/ 7 5/ /67 SI /61 5/ I 7 5/ /67
DOCKET NUMBER ]/J,f/1),SIJ, RROPOSED RULE PR- 1", f7tJ UNION C O UNTY CIVIL DEFENSE JONESBORO . ILLtNOIS ril 21, 1967 Seer t ry to ic e
Co iss ion ton , .c. 20 545 r Sir:
In r r Th {3) of th notice t 9 ?, ro si t bli of C i sh to s te eivi n e or an iz tions e yo on b ets s all f or th of sho be exe t fro any such
fe s .
The rial h ve , w hold n use a t the request of the r al Gov m ent or th . event l benefit of the people . Ho th n can you justify t x* u, non- profit or nization, or r n rin this volunt ry unpa id s rvice? I f th b co establishe , our l oc l or niza tion, for on , iscontinu thi tte pt t such e r g ency st nd- by rvice,
ply b c us cannot affar it .
V fy trul y yours , J d
Co tor nion county Civil fen e R C:ah ocHlE OOlEC A'l 26 1967 Ottiee o1 \lie secre\al'Y PubllC Procee~lngs
. DOCKET NUMBER pR-3&,1/~, so, . PROPOSED RULE Js, 170 MAY 2 4 1967 DQSKEHD ~~EC 1107 Distribut1ou; Formal File Supplemental ile
.:::,-- ' - --- ~ecretariat Public Document oom RPS :PAB GLllutton:vd
}/ 24 / 67
1'-1223 DOCKH tJUM BER PR ~,qc,'So, PROPOSED RU LE - 'It>, 170
~CnHea ..$fafcz ,.!r,encdc DS ,,;:.,..y :G , 1967
-:r . Cha1*les Chodl, JZ!o Ass t . Dire c t or, Civl l Ll~ 'ense
.lo ut.a 2 , i3ox 1023 SL Ciw.rlcs , I l l. 60 17;_ ;\; : cx,~iT1 ,tion fro r, license ,
'l\::c Respectfully re fer red to Atomi c :....1c r gy Corr,rriission for such consideration as the communication herewith submitted may warrant, ond f or a report thereon, in duplioUJ_ to accompany return of inclosure *. oc.r ,* .. : ..
'\!&\EC*: ':: **:
By direct ion of A/2f::fo&t
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Office of.the:~ecr'~iil'ri,' :. Pi:11'.!r. *."r~i:~i1:l1gt **,*:* GPO IHMIN
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Jl7 *, ,.~ 1100 DOCKET NUMBER PR-~,v,,s~, I
,.e,.. , , I r ,t \r *,,_ , ,* ., .', l' ... \ ,* * , t PROPOSED RULE 76', (Jo CIVIL DE FENSE I Director 2-1 0 Eoit Moln Strcot RUSSELL FORKINS St. Chorlc3, Illin ois 601 74 AH:1TT-'X i; DBVP.HSF.
MUN ICIPAL CE NTE
'T'he Ron . se n. ChJrlP. s H. Percy Th0 1Tnit.ed .c; t,.1tes ,c,r:mat.e ,.re1shi.n,.,.t.on, D,r,, ?."510 Dr.:i '* lfon . c, fr:
F.ncl.os ed is crirrP.:.nondenc8 in r eforP. ncc t.o a nronosed ~? ~.on a year licens/"3 "ee, rrom which WR in locril Gi.v:i.l DP.fP.nse dcsi.-ce to he exempted. i*!U,h rw ltr of the
?~th o f' t'arch, there is a conv of (J..) the ltr of the llt,h of /\pril from Col.
Pit,z to me, (2.) the ltr of tr.9 l.Or.h of ~.nr:i.l from Col. Donoyan ~~ . " an~e to the Ar.r. .* ;nd (). ) ::in excerpt from th e TCDA .~d min . Ltr . Mo. 6 includinn: a 1:i.st, of Il.1.ino i.n c ounties and th13ir volu nteer rad iolor:icDl do fense requirements. 7 he nroposed l.kcns e f1:e would imoosc. on locn l r.;mrcrnmcnt and State nr:encies ;:.md inc;titntions t o the extent that, a 1y ,,01.1.ld inte nd to im11l.eme nt the0r local RAD-SF requirement for trained volimteers . T,icens ino: ( nt no present fee) is required by AFC re~ulatbn in order that-, t:ra i ned :i ns t rnctors m;.y use an OCD Fadio;icU.vc c;ealed Source Tr.::iininFY. Set. Extensive tr:'d.nino; (33 ho11.:rs ) is reaui.red for each *PA!*:01:i:' Jmtr1tctor before OM is pe r mitted to co nduct. , local trn i nj_n r; of mon i tors. 00 1 .onel Va nre's ltr indlcates a *minimum o f 5'19 tr,:i:ined Fi\DF:'l<' ()fficers (who are mmal.ly licensed insl:,ructors who h,we voliln tc1 rily chosne t,o additional l.y t,ake Pm trainin~ / ( a pnrox. 36 hours). In every case of Pf\Dri'.Tc tr::d nin~, the OCD Pad5_oactive c;eal.ed Source Set is used, rqquirin~ a tra ined c1nd ljcensed instructor. ii'rom the forer.,ofoi;, and from the enclosures, then it must be apnarent that, i.f
this orc,~r:1m is to be effectively pursued in Illtnoi.s communit,ies, we must have
*some forebearance of the AEG.
May we req11est, yonr a ss ist,rnce in 1~h is matiter t,hat it rnic:rh .., be possible for your o,.. fice t. o request in wirtt ing +,o the Secret;:iry, U.s. /l.toTT1ic Bnergy Co~Mission, Washin.<ston, D.r.. ?.nSLs' that exemnU.on (as they may al.low :i.n nar . lib of. Sec. 170.11 of t heir orooosal) be
<7,ra nt,e rJ t,o i ndiv i.duci ls or insti.tutions with Statewide licens e orivileges in Ill5.-
n0is 'R.~~'fl~:'l' instr 1ctio n , and to local or,(an; za tions of Givil Defense ,ihi~h are 1
ic ... re r:lited by Tr.DA and which have a RA.!-10N1' capabili.ty, nuthorizini.; that no license
""ees c,h::ill be required either for an0J-:.c::it,i-:,n or rP.ne1-ial. 'I'h::inl< y ou f or your attent inn to -~.his reqt1 est . Your renly will be appreciated.
cc: r:01. /\:i :ron f1 . T.az,ar, Hf.MAAG, TCDA r.01. ChaR , H, Bu ckin~ham, *Pres ., ~r.nn
~ile (2) \
CiViL D~;:[NS~ . *_/
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Dircc/or 2-10 Eas t t,\ai;1 S1r~ct * *,q USSELL fORi<INS St. Charl1Js, Illinois 60174 MU NICl?/\L c:::-rrrn Col . :-'o\Jc1*t S . Hitz, Jr. Ref : Proposod ABC license. fees Iill~0is Civil Dcfensg Agonc y '-pe r their lt.,T of. 3/13/67 111 F.ast Honr oe Street w/ enc losurGs Sprinc;;field , Il.linois 62706 I
Dear Col. Ritz :
NO.*! is the time to nip this ,in r,hn bud , not afte:. their prooosed ar;-,enclments have t\een enacted . This State h;:;s untn the, 10th of ~-ray in ivhic h to r1,et to t hem its com:nents concerni_ng th0 proposed annua l license fees for AEC by-product m;3terials. It is our opinio11* thal-, this ~.t at,3 Agency sr.ould place itself on record by ha*ting requested in wri ti.ng to t ,l;le I I S8cretary, U . S . Ato:-:iic Energy Com:nis s ion, 1,rashin~ton, D .r.. 2n5l..i~ I that e )'.er:1ption ,( as they may allo1*1 in nar . )J'o of Sec. 170 .11 of their, proposal) be
ITanted to indi*riduals with State,v i de lic ense privile ges tn co nnec t i on with Illi-nois RA.V0~-1T instruction , and to loc~l or ~anizat ions of Civil De~ense whicri" are
.uccrAdited by TCDA and ,ihich have a R-".'-'O)TT' caoability , . authorizi.nr, that no licensE:,,
. fees shall be requi'red either for lice ns e ap-plicat ion or rene*,:al.

Tn my pe r sona l view, the whole pro posal is o.;d . It seems to be in nerfect con -
junction with the trend of think inn; uo there in Camp -~un - t..mock: 'i'o continue the
*rresr.-onsible Dron-ram r e cently inauc;l.r.~ated T,ihe::-eby nucler.(r technolo~; is being
..*e:c;:.y c xno~*tt,d to all and sundry ab road, but do:r.estic research and develo9ement is curtailed or harnstrun~.
PtYONT at the local l.evel has enou?,h orobler,1s :-row oersuDding i.r.dividuals of suffi-cien~, ha c 'r:8'ou;-1d, etc., to devote time 1*1illin9:l;:,r to train and qualify for A-SC li-c e :-isin £, 1-1:-i.thout be:i.n<?; :required to heg an j_nstitution or non-enthusias tic local r1 overnme nt to pay an annual fee. "'ew of the presently lice;-ised instructors, myc::P. lf included, c a n .iustify this to the critics of our pro?,r.3:m who, incidentally, con-:-,rol our budc:,et and expens~s 'i!l most c as'3s .
Or else, the TCDA 'S g:oins,: to have to co:ne up i*Jith a better solution if it -plans to effectively pursue the PA.ONT pro~ram in this State, r articulary in rural areas .
o{'indly revie ~-, the AEG proposal ( ::1 coo~., of ,,ihich mus+-, ha*,;e rea~hed you ). 'l'o t!ie, it.- s~und s like a fee of at least t-.25.00 a year for ea ch li.cens e to use the :;e;iled source trclinin~ set. I would anvre ciate your renly on this. Yours truly , for the Director, I.
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DOCKET NUMBER PROPOSED RULE PR JtJ,<<IO,t;O,
- 10,'70 '....!...:.:..'/ . GTA Tt: o;: IL.LINO!:.; <:=:IVI L . DEF E l""lSL AGEN CY 111 CA GT MONrtOt: GTfli::t.::T GPRI N G F' IC LD , ILLINOIG G2.7 00 . 'l'IU. , (AIU:A COD tt '- 1"1) 00 O::\ll *'1000
OL, 00, OVAN M, VANCE ITA'rll DIA\: C'TO ~
April 1 1, 1967* Mr. Charles Chodl, Jr. As sist a nt Civil Defense Director Rou te 2, Box 1023 St. Charles, Illinois 6017 4 118ar i\!r . Chodl:
'l'ransmi tted herewith is a co ;,)y of our State Di1*ector 's lett er to the Atomic Energy Commi ss ion on the subje c t o f licensini fees f or use of OCD Trai n ing Source Sets .
In additi on, the State Superintendent of Public Instru c tion and Department of Public Health will a lso write pr otesting I this fee. FOR ':µIE DIRECTOR:
/, *') J ,.
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Robert S . Ritz, Jr. Chief, Field Services Enc, cc: Col. A. M. Lazar 1*
.e DOCKET NUMBER PR .3o,"4',so, fROPOSED RULE - 'l8Jr (70 I .
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April l O, 18 6 7 D*O'CK ET ED ll&AEC
/*, ,AY 24'1'67
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\V~~:. ro s pcc t to fr10 propos2.l for cst~bli s:,.::.:s.C] c:. $25. 00 foe for specif ic l.'~or:iio Enc ::-0 1 C oi*;; .r,:ssion i3yproduct Matcri.:.l E2 :*.dl ir, 0 Licc :..sGs , this Agc::cy C:csi:'7z to r.:c.1(e t:11::
following c Oi;"l;nen ts und rcc o :r. r::c ,-:C:u ~.io:, s.

AE C *Lic 8 ;;:;cs 0r2 in t:10 hc.nds of six~:r-L:.vo po liLc.:; l su0divis:.o:1s in Il~i.:oi.::.
to p2,:..*,: t se lecte d,* quulificd pc:son~:01 to tc2c:,. C1 c Off~cc of C~v:il Dc:fo:;.se 1
'Ruciiolo0ica l Mo::.itor Course" "1;-i Si.1:)po:t oI thG ?c C: 0::-c:l ;\c::c.iolo,;;icc:.l D0fo::.sc ? rc 0 r~~ o.t.ci ? e ~c:al Corn:11Unity Fallou*~ S:1cltcr ::>:-0 <_:;;."'.::;-;1. rv:os:: o-: :hGSG / ~C:i o lc ~icd Monitori:..g Instructo::s c::rc u,1pc. i d, c. od icc::*wd vob,*.tGo~*s . It is c:..: tre -::.e;l y c:[fi c ul t to .orilist the sc::vicc::; oi fr:.csc Dc . o0l0 - . c::::.d cct t:10.-.--: to 2. ttG:~d .
18 CC 0 , ~:v:: Course I to a~ply for foe lic:c:-:so, c1i1d to tr2i:1 t:-:c nec:cs::;;;.:.-y :
;;1..;,;-r.bc-r of r;.0~1i::o:;s. To 2dd 2. rcquirc::1cr.t for ~ciy:-nc::t o~ $25 . 00 foe for c:;.
1::-ai:1~.,<;; license will, uridoubte:dly, cc:iusc ;-;,c.~'1.1/ to drnp out o-1 *~:10 pro0.a.::.1. *
'l':-c::in:.r;G wc~oio:;;~cc::1 ..ionitors is a -:,ever e~---.0:..:-10 pi.*o;;:-c..r.1 c:.,-:d cl C:i;:fict:.lt or:.e 2 t b8s :. 'l'i:.c nu r.1ocr o-f qu.:::liiicd RMI's c:vc.ilc::;:)lc , c vor, c:ft0r five ye.:.r::; of > ,,,, 10\*1 Ol".1v1C.I... "' '~~io**~=-1 ..iL -..:..;..,,..,,, ,_~.-'""'""* .. 1.L. o-~l **'-*'. 1c. S'"~'*c o"'Ji..,Yli'"'o'~ .._,~c' * .--..::.::e, o:;.;J.J.. .-.~ . , i~ ... ~ ~---'\... .:,..,..1..
1 .;,.,u *"" .J-..;;.- '""'"' Lu,V *'-'-"- , ~\.,,,.J.l'--'L1,.~ \,;,o Lul. *-*j .,-..:, C** v.;e ::i c : i.c
e: ::-.e: G.3 ~blishmer.*~ cf liccns o ~ces wi ll contrfoute to tha fo-ibre of
~:-:is ::, :-00,-:.,,"'.. 'i'i1e srr.c::; 11 a::-.ount of r;1O~1ey derived fro::n this foo would ba oifsa~ °Dy ~:--. e: pc :-::;on;-iGl drive:n out oi ~he progrn,.1 .
I:-1 c::;:;dit icn, Illi::ois nGccis a r.1i;-iimur;1 of 519 T:.::ir1cd R~ciiolocical D8fonsG C .J..,..,
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i' -.:::. c u :- '..:,d:c: ~:..:it this program dcsign0d to r,:oct ?occr2.l :c.:-,;ui.or.rnnts for DO's
'Nill c:. :so b_o :-:.:..-.jcr,3d by tho oz tablish;:-::ent of lic0r.s0 ~00s ":)*/' the A'~o-:::::.c ...,.t.** c-,-,, ,.... __ .. _,, ~ ,..,0..., ** *~ j Vv:" " '*.:> ..., ... u
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v:ui:,~:*~.:l :i*i*c:;:oii:,,J' Licc;1scs 0,c.i-.tcd by J.~*sc to u:;C: :-s fo r ;:l~it.ir1g 7'c:.dioloi:;icd
~,: 0: . . . :~ot~; Io~ Ci\til Dofor1~0 ;Jurpvscz DC! c:..-:c:-,1pt fr0:*t, ti10 roquir_.:::1*~0 ** t to ice: fo,* fr.~ Ec0.is0 as propoz_, ~ci b?. tho C01*.m1is:;io:-.. ,~Y c".i * , I ' * , '* /:: .. .
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DOCKET NUMBER PR !fd,fk),~, PROPOSED RULE _- ?S, 170
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\ 'i'hio c:.:itc:1: llll i.o u detailed 11ppc:.:U.on:,,:}nt o[ li1c Fi::Jci.'a1. Gu1<lc.'iLCO II Co:: ;,,\ni::? ot.:1H .:-.1~<l monitor:i.ni:; ul:utionJ no i:;hc;i:a :i.n 1ic.*.c1; ~ . Ch.:r~l.:a~* ~~
I A~p~nJix l,_o~ the Federal Guitlc. I I
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-r:*1C! sp.1 c c to th e :lmrucdiate rizht of t:hc 11 G0.:1b 11 colu1.r.a lc fol: ,:o::.c.d.o:-: o!;
ncco:;ipliniuncnt:o (l 1 /\c c 11 ) . If a coun.ty <lovc}.o ?b f::.~;t.:.:co 1,;l*, ic;l~ <liH'c.;.* r*.:-:-,:;. t:ho c c uhown i:(:i:c by n;.orc* th1.m 50% the opc.:d.i! :l.(! ~~r:-,r..::.;:; ~\Ji: u~;, b:,, t:,o :)v:.:L;; .. icnl ~ulJdivis:~onn con.ccrnccl, r:hould be c.:ircfolly :,*(;v:'..<.:uc<l. rro:i thcac f:Lsu:ce::;, . dntn in ColULcn r.r. (totnl :i.*'"c;ui1:cs cnc.c ) or the p:::0 0 .:.:.:.l
;J.::p-:!::- (S8 ctio ~1 V n), cLm be dct;c;:minoti . 1:b.c itc~ 2, 3, E, S o'.:: ti**.i.;
ccctlon may bi:? tllkcn directly. No:;t othc'i.' 'ito\.:i:; 0.1.*c dcpcn<lor.t on tho~a
i:.*c c ;i.-.ci c;:.n be ci~tcrwinc<l uoin;; . th~£Ja thri::a .-L.:ijor Gcto pf data co 0 1
~4ci c for calculation,*
Since public ohclccru place n larca drain o~ the oupply of c~~i~cd
~orii.to2.*s the tiaGni t:uclc of t:M.o 1*cquirclilcnt: io e;ivc n by Dhowin~ tho UUC..\JC.:'
1 oi ohcltcn.*o i tho Phnoo '.l:I finiil record :;i:ia'.in J:::ico (Cal:. z-J). I*
- S!li~LTEP,S CA~1 ACIT : ,<J. 00 ) 100 Illino13 1, 94 5 ,,: 5,558 ':i.\1c:,c chcltcr e, o.rc.: db*ic;od into those h~vln 0 cn pc,citien oi: loo~ th.:.n 100 L;µ.:;.ccc (<.100) which ohoul<l lrnvc . three i;_ ;onit:or :, nnd tho:.c with 100 s:wc oo o:.* u:or_c* (>-100) which chculd have five mon itor o*.
All of the. nbov..:: -:Lnfo:cu'll.lHon lu..uJ been developed down \.:o co1.mty lcvc1* . (coun~1 [igu~ca iucluclo all political sub<li~iaiono within tho county 1 bo~n<lar ica). !he totala
of thci individual cou nty figuroo G~a oqual Co tho St~te r:t.iu:i:Gt.> eivan ubovc.
At t:(1Chmao.t: i1 A1*6
DOC.KET NUMBER PR-31,fl),,51J, PROPOSED RULE 1", no Brotzman Diatr:lbut.1on: irector of .IWl>~-.-tton Co * * (2) Of. oft
6

Counael 1 slgnetl l Harofd [. Pric~ omal lle u pl~al Pile wao.a. i. Public oc t
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DOCKET NUMBERPR ~Jg,S*,
PROPOSED RULE - 1t9, 110 MAY 2 8 1967 iJOla.1.11 J. t hlwo. .caat ution : Of DCK't.1.1.8. (2) 1 slgned ) Harold L. Price
Co el lat 111*
t OCKETED uocrummt: OSiAEC Of. of tToll r AY 23 1967 bee.: c. JC. ffice of the Secretary l'uDtic Pl'll~edlnp M. M. C. L. B. *
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el.
Gtlhattoa cvd CUfencler ri S/l~/67 5/ /67 SI I 7 5/ /67 SI I 7
MAY 19 1967 AY 22 1967 ff~ at the Secr*tary Pull/le Pruceed/aga bee: c. K. Beck K. M.
c. L.
B. It. ooc G Con. Rel. GLl!lutten :vd ClJl* derson rice S/15/67 SI I 7 SI /61 5/ /61 5/ /67
. CKET NUMBERPR 3~,'I0, 54, ~ OPOSED RULE - 7a,i7 o UNITED STATES OF AMERICA RAILROAD RETIREMENT BOARD 844 RUSH STREET CHICAGO , ILLINOIS 60611 OFFICE OF SUPPLY AND SERVICE May 15, 1967 DOCKETED U&lEC Mr. Harold L. Price Director of Regulation U. S. Atomic Energy C0111Dission Washington, D. c. 20545
Dear Mr. Price:
I have your notice of March 13, 1967, proposing the establish-ment of license fees for specific nuclear byproduct source material. The Illinois Civil Defense Department has assigned to us a seal source set containing 30 millicuries of cobalt 60. It is used for training radiological monitors belonging to our Build-ing Self-Protection Organization. It is licensed to the Railroad Retirement Board under the Atomic Energy Commission permit 12-9830-1. I have been informed by Illinois Civil Defense authorities that they have protested to you against the proposed licensing fee. We agree with the State's position. Very trur;.ours,
<!/p)j ~
H. O. tle Director of Su ply and Service c:::
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DOCKET NUMol:.k PR-30,l/-0,5!), PROPOSED RULE '/tJ, 170 MAY 1 8 1967 DOCKETED 00.AEC MAYl 91967 Office ot tbe secretary Pllbllc ProC<Jedlngs Distribution: ormal Pile uppl ntal ile -' \~\ - -- ----- er tar1 t blic Doc nt Room RPS:PAB GLHutton:vd SI /67
- DOCKET NU MBER PR 11J,'10,'50, PROPOSED RULE - 1IJ,t7D Distribution :
o al ile Sup lemental File OCKETED
---- ecr tariat OSI\EC Public Doc ent oom AYl 81967 !flee of tile Secr*.tary Ptt !lt rr~r ') "tJ!S j
PS :PAB LHutton :vd 5/l8/67
~ OCKET NUMBER pR30," *'jO, 6
PROPOSED RULE
1l),t10 MAY 1 8 1967 OUbftl Dietribution:
For,nal ile Suppl nt.al 11
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- DOCKET NUMBER PR 30,IJO, 16 1 ~
PROPOSED RULE -
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00CKEW MBER PR 3/),,U,50,
&URGLAR FIRE PROPOB' RULE * ,o,no WALNUT 2-6!500 ALARMS ALARMS SEN*T:INEL ALARM f. n::11*PA RATION ', SENTINEL ALARM CORPORATION !13£.ttn y.)totution 'Jfaou.gh dltt.odnn 'J E.chnology TENTH AND V I NE STREETS
PHILADELPHIA, PENNSYLVANIA 19107 1967 OCKETED USilEC Secretary United States Atomic Energy Commission AY 18 1967 Washington, D. C. 20545 Office of the Secretary P1.1lllc rr,;r.r-1ir.gs
Dear Sir:
This is in reply to "Notice to AEC Licensees, March 13, 1967, " requesting remarks on the establishment of fees for materials licenses. Sentinel Alarm Corporation is a distributor of Pyr-A-Larm fire detection devices manufactured by Pyrotronics, Inc. , Union, New Jersey. The Pyr-A-Larm detection device contains a minute amount of Americium 241 and thus comes under the regulatory control of the Atomic Energy Commission. We are a Specific Licensee for the di stribution of Pyr- A- Larm equipment and directly market it in various states including P ennsylvania, New Jersey, Delaware and Mary land. The main purpose of our product is for life safety and the protection of property against fire losses and it is a very important aid in protecting our country's assets. It is very probable that the agreement States and others will a lso impose fees on materials and licenses if the Atomic Energy Commission sets this precedent. We, of course, strenuously object to being subjected to increases in our costs of doing business and additional complications created because of our operations in various states. We respectfully request that the Atomic Energy Commission reconsider its proposal and not impose annual license fees for the type of material which we market. Very truly yours, SENTINEL ALARM CORPORATION
~ / ' / ' ~ , 0 ,.C:. ~,
t ~ 7r/L.-,
/2.:4.' /. < " James E. Metzgar Sales Engineer /le CENTRAL STATION FIRE AND BURGLAR SYSTEMS
DOCKET NUMBER PR~3t>, ~. so, PROPOSED RULE 71) 1 170
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RECEIVED 1967 MAY 17 AM II 49 U.S.,ATOMI C ENERGY COMM. REGUL t1T*)R Y
MAIL & h-ECUiWS SE CTION
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DOCKET NUMBER f' 1'
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t Distribut.iori Formal il Suppl ~tal File
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IAY 1 7 7 Distribution: Fol'llAl ile Sup 1 eutal P'il enr tariat Public Doc ent Room RPS: Gl.Iiutt.o :vd SI /67
Diatr.U ,ution = Formal 1le Supplenlental 111
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DOCKET NUMBER R vu._ a, jlJ,
.,PROPOSED RULE p _. 7~, ('}(J ~ 1 *; ::.* ."
Distribution: Formal le Supp ental File KETED ~~----~er tariat U&IEc Public Docum.ent Room AYl 7 1967 fftce or the s ic ll<o <<:ret,ry B /:etdfng, S: il GLButton:vd 5/ /67
DOCKET NUMBER lliL 34WJ,5f1, PROPOSED RULE 9' ?o, f]O MAY 1 7 1967 r D18tribution: Fomal il* ,,, Suppl ntal P'il* / ~- - - ~ ecretad.at Public Document oom S: AB Gt utton ivd SI /67
.WAY 1 7 1967 PROPOSED RULE MAY 1 71967 me, ot the Secretary P;:b:ic rroci"rllnis D:f.stribu.t ioni Formal file Suppl ent*a l File
- ---r.:,ecretartat Public ocume t oo _ S: AB GLRutton:vd 5/ /67
DOCKET NUMBER PR 3$,'l©, 56,
- PROPOSED RULE - 7(!), l?t>
Ct:nhal cf? ocky d1/(ountain Cfz.aptei cJl-eaf tfz. <JJfz.yJ.ic1a- ~ocie.ty Route #1, Box 474 8773 Baseline Road Lafayette, Colorado DOCKETED USIAEC Mr. W. B. McCool Secretary U.S. Atomic Energy Commission Washington, D. C. FACILITIES AND MATERIALS LICENSE FEES The Central Rocky Mountain Chapter of the Health Physics Society hereby submits the following comments pertaining to the proposed rule on licensing fees. Although not all chapter members agree, these comments were approved by a majority ballot.
1. In order to assure radiation protection of the general public, we believe that a licensing program is necessary. The use of radioactive materials is a privilege to be granted only to qualified persons. Therefore, the basic principle of charging fees for licensing services seems reasonable.

2. The proposed fee schedule is discriminatory in that the fees are not proportional to the services required of the licensing program. The bulk of the "service" (i.e., paperwork) is performed for new applications, with lesser amounts required for amendment and renewal applications. Instead of annual fees, therefore, we recommend initial application fees and smaller fees for amendment and renewal applications. Regardless of the duration of the license, this system would generate revenue in proportion to the cost of the licensing services performed.
.2.
3. For materials licenses in Category 1 of Section 170.31 of the proposed rules, the licensing fees should be kept to a minimum so as not to discourage use of radioactive materials by small colleges, high schools, and some individuals.
Respectfully submitted, ~~:~~ President JRM:ab cc: Keith Schlager - CSU
ARNOLD OLSEN 4 PROPOSED RU COMMITTEES: 1ST 01STRICT, MONTANA PoST OFFICE ANO CIVIL SERVICE PueucWORKS ROOM 1424, LONGWORTH BulLDING 225-3211
. Qtongress of tbt Wnittb ~tatts PHONE, SUBCOMMITTEES:
POSTAL RATES AND PARCEL PoST. CHAIRMAN CENSUS ANO STATISTICS
~ouse of l\eprestntatibes OPERATIONS CoMPENSATION Ba~bington, :iJll.. FL.00D CoNTROL ROADS WATER DEVELOPMENT May 12, 1967 SPECIAL SUBCOMMITTEE ON THE FED£RAL.AID HIGHWAY PROGRAM Mr. w. B. McCool, Secretary DOCKETED
u. s. Atomic Energy Commission LIS!AEC Washington, D. c. 20545 DAar Mr. McCool:
Enclosed herewith is a copy of a letter I have received from Dr. Ralph Olsen and Dr. Reed Howald of Montana state University dated May 4, 1967 and addressed to you concerning proposed fees. Will you please send me a copy of your reply to Dr. Olsen and Dr. Howald. Thank you in advance for your cooperation and consideration. With kindest personal regards, ARNOLD OLSEN AO/e Enc. P. s. Will you please return the enclosed letter with your reply and send your reply to the attention of Miss Vaughn. Thank you.
;t * **
_ _-._. . Montana State University - - - -'_.!- - - - - - -- Bozeman, Montana 59715 Tel. 406-587-3121 Depart ment of Chemistry College of Letters an d Science May 4, 1967 Hr . W. B. HcCool , Secretary U. S. Atomic Energy Cormnission Washington , D. c. , 20545
Dear Si :
The Radi ation Sources Commit t ee of Montana State University, .Bozema n, Nont -~, would like t o comment on the proposed rule making, 32 F. R. 3995, concer ning proposed fees .
"ile bc l:i.eve tha* it would be unwise t o inotitute the proposed fees .
The ;:mou n . . s proposed arc low enough and there arc sufficient e~cep i ons that t he ice s vould not be a substantial burden to an institution like Montana Sta t e University with a broad and varied research program using r adioisotopes. However, even at the proposed levels, the fees could be a- substan t i.al obstacle in t he deve lopment of research programs and the educational uses of radi oisoi:opes at smaller educational institutions . Thist the proposed fo e s .:Jppc.:i r to be incomp.:it:1.blc with the commission ' s responsibili t y for f os *cring t he development of nuclear energy.
~'he primary rc~sou that the proposed fees would not be a substontial burde n i n many cases, is that the use of licens~d materials in research nnd tea chi ng is being supported by the Federal Government or the various state:~: . Thus, to a large extent, the proposed fees would amount to t .. ans:::ero between fe aerul agencies . Any anticipated decrease in t he consr0ssiona l appropria~ion for the A, E. c. would have to be offset by i ncr eased appropriations for N. s. F. , N. I . H. , etc . There would , of cou:.:sc , be a net loss in the administrn t ive expenses associated with col lectine the fees . We are not sure that making the A. E. c. less dependent on direct congressional appropriations is a good idea, and oincc the proposed fee oystem has raanifest disadvantaeea, we are opposed to it in its entirety.
dr . H. B. McCool Page 2 Nay I:,, 1967 The fees proposed for power reactors are more easily justified, but -rn .s:.:-e not sure that even these are ,-,arranted . Anyone opera ting a nu c lcnr reactor must be financially responsible for whatever expenses are !:ecens.:1ry t o keep it safe . The regulatory function of the A. E. c. is <l (::;igned to sec that safe practices arc maintained, but: it would be unwi se to let a aituation develop in which the regulatory authority is f:i.na ncially depend ent upon the industry it regulates . Sincerely,
&.t~p~n Chairman, Rndiation _Sources Coinm:L ~tee ~~-
Dr . Reed Rowald Committee Secretary and _Radiolog~cal Safety Officer fill/ sb cc: Senator M. Mansfield Congressman A. Olsen (
A A _DOCKET NUMBERPR - ~O,l/0,SO, W W PROPOSED RULE ?", (1(J WALTER KIDDE SALES & SERVICE CO. 736 Fairfield Avenue Kenilworth, New Jersey 07033 Telephone CHestnut 1-2950 a complete line of better fire extinguishing equipment Kidde May 15, 1~67 OCKETE USAEC Secretary AY 16 1967 United States Atomic Energy Commission Washington, D. c . 20545 fflce of the Secretary ubllt ,rot!eilings
Dear Sir:
This is in response to Notice to AEC Licenses , March 13, 1967, inviting comments on the pro posed establishment of fees for materials licenses . Walter Kidde Sales and Se r vice Co . is a distributor of Pyr - a-larm F ire Dection Devices. We come under the rules and regulations of the Atomic Energy Commission because of the small amount of Amer1cu1m 241 contained in our detectors . We are a specific Licensee for transportation of the detectors and for the installat i on involved . The detectors are generally licensed for sale totb.e Public . We assume that our Specif ic License comes under Cate gory #1 which provides for an annual fee of $25 . 00 . Although this is not an excessive fee , it would necessitate a business such as ours increasin g the cost to our customer . We would object to a license fee f or several reasons; One o ur product is a life safety product which protects some of our country's* vital areas . Two, it is possible that the Agreement States will follow suit and impose fees on materials licenses. Since we operate in several states this could impose additional hardships . We request that the Commission reconsider its proposal to impose annual license fees f or the type of material which we distribute . Thank you for the attention we know you will give our request .
& SERVI CE CO
JWG/mg
DOCKET NUMBER R1tJ, tltS.r ~ -: PROPOSED RULE p -"JO, I 7-C
** 1 MAY 1 *, I s.tH:r. * \;~t-~ ~'{ 16 \9'67 ttl~ o1 \lie ~ett~al'Y llll\lC frGC9t~lnts 1 ,.
a Distribution: Formal ile Supplemental File 7')*'1- - -~ fo,cretariat Public I>ocum.ent oom RPS:PAB GLHutton svd SI /67
DOCKET NUMBER PR 10, YfJ, SC1, PROPOSED RULE - 70 , l?O MAY 1 5 1967 t 9H Ei '9 tr£dEC S:PAB GLHutton: af SI l67
DOCKET NUMBER PR -JS,f49, S'e, PROPOSED RULE . 1B, (70 MAY 1 5 1967 OCKETED 11&.lEC AY 16 1957 fflcc of fhe Secrelary
;:b'.lc frsc,, ~~es ===---~~~=
l File t Public Doc nt Room RP :P GLHutton:s SI /61
DOCKET NUMB ER PR . . 3'1,"IO, fid, PROPOSED RULE -70 ,I76 llAY i 5 57 OCHTED USdEC AYl 6 1967 ffic, of the Secretary 1'1:ll'.ic *roc=:ertln:a I, t tion: 11* tal Pile at ici Doe nt 'Room GLlutton;ef SI /61
DOCKET NUMBER PR _3 o,({&, '>!Sj PROPOSED RULE 7(3) , /70 MAY 1 5 1967 DOCKETED USllEC IIDCUIO YGIIIU
Distribution:
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cce ri&t Pub lie Doc nt !loom RP :PAD GLB.utton:lf SI /67
DOCKET NUMBER PR-~39,</49, ~ , PROPOSED RULE 'Je,,l1!J
~fl!fiG AY 16 1967 t
D1atribution: Formal Fil Supplemental File ~,.- 1 _--- cret riat , Publie Document Room RPS:PAB GLliutton:vd 5/ /61
DOCKET NUMBER JtJ, ~ ~ PROPOSED RULE PR-7~, /Jo DOCKETED OSAEC n: 1 File "'"""'- - -- eeretariat 77777 Public Docum nt o GtJlutton:vd 5/ /67
*.*~-. ' .
, *CHARL~TTE T. REID, M.C. , COMMITTEE: 15TH DISTRICT, ILLIN018 PROPOSED R APPROPRIATIONS 1fi us of ep ese t tibe.s Wa.sbington, ;:9.~. 205 5 April 27 , 1967 oHETE
\$EC Mr. W. B. McCool Secretary AY 16 1967 Atomic Energy Commission Washington, D. C. 20545
Dear Mr. McCool:
I am taking the liberty of sending to you herewith a self-explanatory letter and enclosures I have re-ceived from a good constituent , Mr . Charles Chodl , Jr ., relative to the AEC ' s proposed annual $25 license fees for AEC by-product materials . You will note that Mr . Chodl is extremely concerned over this proposal- - and I c ertainly feel that he has made some excellent points as to why local Civil Defense officials and personnel should not be required to pay the proposed fee . I would, indeed, be grateful for any further consider-ation you are able to give to this matter- -and with the return of the enclosures , I would appreciate hav ing any c omments y o u would care to make thereon . With best wishes , Sincerely , Charlotte T . Reid Member of Congress CTR: lq Encls .
.. _; * * . DOCKET. NUMBER pra,1&/t4 Jo,---* vr ;,1. "- 312-584-2700 U&AEC *
. fR0POSED . RULE ..,.,, ,7o AYJ.61967 ffice of the Secrewy ubllc Prmutnp 2-10 East Main Stroot St, Charles, lllinols 7 FILE: ANm:X r, PADIOIDGICAL DE'fi'ENSF.
MU1 ICIPAL CENTE 2u April 1967
~he Hon. ~rs. r.harlotte ~. Reid, M.r.. .C::ubjectt Proposed A~C License f ees TJ ,c:;. House of Representatives per their ltr of 3/13/67 T*!a~hinP.'ton, D.C. 20515
Dear Hon . Madame :
Enclosed is corre~oondence in reference to a pronosed ~25.00 a year license fee, f'rorn which we in local Civil Defens'J des ire to be exempted. Hit,h m.Y ltr of the 2r;th of ~arch, there is a \c ony of (1.' t,he ltr of the 11th of April from Col.
'RHz to me, (2.) the ltr of the 10th of April from Col. Donovan M. Vance to the A"Rr., and (3.) an excerot from t.he Jr.DA Admin. T,tr. No. 6 i.ncludin~ a list of Tllinois counties and their volunteer radiolof1ical defense requirements. ~he proposed license fee would impo~e on local p:overnments and .S tate ae:encies and instj_tutions to the extent. that any would intend to implement their local RAD-SF requirement for trained volunteers. Licensin~ (at no oresent fee) is required by AF.C re~1lation in order that trained instructors may use an OCD Radioactive Seal-ed Source Training Set. Extensive training (33 hours) is requi.red for each RAHONT Instructor before one is permitted to conduct local traininr: of. monitor. Colonel Vance I s ltr indicates a mininrum of 519 trained RADE'F Officers ( who are usua 1.ly licensed instructors who have voluntarily chosen to additionally take RDO trainin~
(apnrox. 36 hours). In every case of RADEW training, the OCD Radioactive ~ealed Source Set is used, requiring a trained ~ licensed instructor.
"'rom the foreisoinP.', and from the enclosure~, t.hen it must be apoarent that, if this orop;ram is to be offect:i.vely pursued ln Illinois communities, we must have some forebearance of the AEC.
May we then request your assi.stance 1.n th:i.s matter that it mi~ht be possible for your ofl"ice to request in writ inr; to the Secretary, _ TJ.-5. Atomic
Energy Commission, Ha~hington, D.C. 20%5 that exemntiori (as they may allow in par. l.ib of Sec. 170.11 of their proposal) be r,ranted to individuals nr institutions with ~tatewide license orivela~es in Illi-nois RAMnNT in8truction , and to local orri:anizatiorn=1 of Civil Defen.cie which are accredited by ICDA and which have a PAMONr capability, authorizing that no license fee~ shall be required either for appllcation or renewal.
Thank you for your attention to this request. Your reply will be appreciated. Yours truly, for the Director
/J. /l - (~£M.J ?7{d4.V.,e,~ /) ~}//,~ . '/ Y.,
cc: Col. Aaron M. Lazar, NEMAAC, ICDA fiarles Chodl, Jr., Asst.
ector Co1. Chas. H. Buckingham, Pres., ICDC Route 2, Box 1023 .
File (2) St. Charles. Illi nois 6017L
Vi" ::JI , vi-li*\1 \.1.~ ~
*I* 312 -584 -2 700 CIV
2-10 East Main Street.*

St. Charles, llllnois 60174

MUNICIPAi.

CENTER
*. .: * :* * ;I :*, "' : . , *. '. ::* ; . Col. F.obert 5. Ritz, Jr. . ** * ... Raf, Proposed ABC license fees ' Illinois Civil Defens9 *Agency 'per their ltr .of
3/13/67
* : * ', * . 111 F.ast Monroe .Street w/enclosures Springfield, Il.linois 62706 .
_... . . I 1
Dear Col. _Ritz:
.' .I
t* .l. I
.. * : NO,! is the tin.a to nip thi in tho bud, not after their pro-posed amendments have
. :. *. *:*
been enacted. This State Pl s until the 10th of Hay in which to r:;et to them its
;* . comments concerni_ng the pro osed annual l:i.cense fees for A'EC by-product _m:3terials ~ '. * , . ... * .-- It :ts our. opinion* that-, this State3 Agency should place itself on record by having . *. :* ': . : requested in . -wri t:i.ng ito the I !,ecre~ary, U.S. Atomic Energy Commission, Washington, D .r.. 205h ~
I
. that exemption (as they may allow in par . Lb of Sec. 170.11 of their proposal) be
( :. ', .. 'Q'I'anted to individuals -with StateNide license privileges .in connect~on with Illi- .
, : *\:
nois RJ\T*!!"lNT instruction, and to local

organizations of Civil Defense which are *
. .: ..
accredited by ICDA and which have

a FA'-'.'mIT caoability,. authoriz in~ that no license
; . ::.
fees shall be required either for license application or renewal.

w * * * '
** .: *. **
i:n my personal view, t he whole proposal is bad. It seems to be in perfect con-junction with the trend of thinkinr.; up there in Camp-Run-P.mock:. To continua the irresnonsible uro!'l'am recently inauo,urated whereby nucle~r technology is being

freely exoort8d to all and sundry* abroad, but do~estic research and developement
. . , .
is curtailed or hamstrun~.

..* P.AJ.~ONT at the local 1.ev'3l has enough problems NOW oersuading individuals of suffi- .
cient hack,9;.round, etc., to devote time willinp:ly to train and qualify for AF.C li-censing:, w'ithout beirn; required to beg an institution or non-enthusiastic local 1:1overnment to pay an annual foe. fow of the *presently licensed instructors, myc;elf included, can .1ustify this to the critics of our progra;rn i~ho, incidentally, control our budC?,et and expens"!s in most cases. Or else, _the ICDA ~s ~oing to have to co~e up with a better. solution if it plans to effectively pursue the PA\~NT _proqram in this SGate, particulary in rural areas.
'l(indly review t he AEC proposal ( a .copy or' w'hich *m ust ha ~e reac11ed you). To 1!'le, it~
sounds like a* fee of at 1,_e ast f-25.00 a year for each li.cense to use the seRled
*source trainin's set. I wou.~d aporeciate y_o ur reply on this. . * ,/ * ' : * , ** * .* :
I I,, *

I* *. , *
*..\ i\\. :i: ji.~Yoursru;., ; / ,' i/.':; *, .* ', **,,.
t1 ~;:~~~~~~~* ti./(,&,b() *(:;j('.t.£-.-':;-,,a I I
II : ,* ",' ; *:_,* ** **** **'. ,r *1/ \ ~,: * '- - * * *' * * * '
** ' i ~-. I.'. ~
* \*, * ,. *. ,t.' * .*
s-rATli: OF ILLINOIS CV EFE SE .AGE Cy *,,*;*, * .. .. ..
, 111 _EAST MONROE .6TR!a£l' ,***.* ,*.:1 ' ',-' 1." ~-~;' ~ :. ~. ~. ,., , ,,, **'(. ... '
COL., DONOVAN M, VANCE *.
',\ :*: ,' *<*,:.:\{:;;*:;:*\5.1.~,.(::::j;~:~ ':~;:*: :::~7°oeo*::.,i't*:*:,*:_. ,/~ .*,,. . _i _;:. .i. ... ._ .. ,** ** . ~ * . * .* : 1 I ::.::,(,;**. :,:l*,::i/::l*.**:,*:,': :,:, ,/,,:,/.; ,(.:,~.',:,/ \*:::::: . ' ....
1 -' ' ::
1
' * ' STATS Dlll&CTOII '\.*: Apr_i l li' .. 1967 .,. ::'. . _,. :. :*:.... *.. .,. ., . ,. .
I, , t
f t*
*.* '..,*,:;gi?I)i'Jt:;7:e.i;trn, . I * : . . ,' ': }* '.!:- ', . .*:* ... * ;:,_.'. ;,<MAY-16' l96t~- * , ,\, *. Mr . Charles Chodl, Jr :
OfflCP. of the Secretary P~l);lc rr,;;**"ililgS
',
t ' ~- .' * : ..
. \ _. ~. "; Assistant Civil Defense Director \ \*;\/-'. *'
Route 2, Box 1023 St~ Charles, Illiriois 60174
' t ' . -=... : .:' ' . .. .
Dear -Mr. Chodl:
,* I *
I !
~*
Transmitted herewi t h is a copy of our State Director's *'. *, !' letter to the Atomic Energy Commission on the subject of* ** *'. ' r . ,
licensing fees for use of. OCD Training Source Sets. ... *.**.*:* ,:*,:
,..-. . ~,-'.{: :* ... :* In addition, . the State Superintendent of Public Instruction * *: .-\,: :.*.
*:* .
and Department_- of *Public Health will also write protesting ,l * *
,::_ ,:_~_ :,_:,;:_*.*,_
,; __;, ,.thi s f ea . .. ..... * *. *., ..::
i;\}i::.:**.i::.** .i:{({(.\t}!:ff\:{;i:. F:~~~~.,~Tir(~,u.:,~.-:*. .*: :;'\ /:\' '* ,. :::;:.
({::. :
'i,.).r r , *\;}:,* fo:~rt

, \ '1:.\ /
1 *
s. ~~tz, J r / *
'. *.Chief, i*Field Serv.i ces ,.J:)L..,, ./.:};: ;.*. ** .,.*
'..' t.\~\...: *i:* DMV:RSR:sn '. 1
**\ '* */
\1~- ~-.:~-'l r *,: .,,,.
. . . ,1: .,. *. . .
cc: ,.- . Col. * *... A.* M. ' . ,:.*
*Lazar ' ,' ',; ,, . : 1' . 1' :
APR ,\ 2 .'lS&! :' **: *. * .*
' I \.
' ~ , ,\
' ~* 'v *'I . 1:, :'*
i' .*
\ . ~ *.?. . *,
t* I .I
Dear Sit:
.* :..\iVHh rosp(;ct to foe pro po cul for cs mblisbing a $25. 00 foe for specific Ator:iic Energy Commission i3yproduct Ma tcria l Hcindling Licenses, this Agency d0sires .:
to r::ake i:h,,,'following cor.1rnents und recommcnda ~ions. * *
AEC Licc.iscs ~re in the hQnds of sixl:.r-f:vo politica.l subdivisio~1s in Illi,,ois
**., .* to pe.rr.iC sckctcd,* quulifi0d pc:soni:icl to tc~ch the Office of Civil Dcfo::lse 1
* * 'Radiolo<;;ic.:il Monitor Course" **i.1 su:,:ipo:t of the ?Gci.ard Radiolo0icc:.l De:fons.e ...

, ; Pro;:rrarn und Federal Community Fallout Shelter Progr.:.m. Mo.st oi these .. .. *.. ,:*:.. i.*':/.
\* .
Radiolcgicci 1 Monitoring Instructors a.c u.1pQid, dedica tcd voh:..1tc~rs. It is .
_';:.* , *, .*.. .
e:xtre.r:0ly difficult to ,e;ilis t tho services of these peo9le a~d get th0r,1 to a ttcmd . . **: :. * * .. *; {'*' the OCD, RMI Course I to apply for foe license, and to tr2in t'h(? neccss~ry .. ) ...*. ;, .. :r
**.
number of monitors. To add a rcquircmcr.t for payrnc.~t of $25. 00 fo0 fer a **. * - * ** ; ** ..:; *!
* . : *~ : ! ./ .. ... . . . ,*;.: raining license will, undoubtedly, cc1use i:.ciny to crop out of. the prograr,1. : .. *.*. . * * *::*.,*
Training rodiologicd monitors is a never <:mding progrc.r.1 end a di:ficult or.G
,. '. ~ '. ; .*.. : .~ ~ *. ; ..* -:>. at best. The nur.iber oi quc:11ficd RMI's av~ilable, even after five y02.rs of .* : *. i , . . .....'.*effort, is still far belo\'/ tho operatio:i.al ~*0quircmcnt of the Stote of Illinois and :,* *.* ** *. .:," ;. ,': we*bclicvc the csmblishment of license foes wii'l contribute to 1:ha failure of * *: \ ,. _.. -.. .:.*.-.. .-: *:
this progi.~m. The sir.all amount of money derived from this foe would ba offs.at . . .. **
by the pcrson.iel driven out of the progrclm. . _:. *.** *:*: *.::*::.\ { ':-/.; In addition, Illi:-iois needs a minimum -of 519 Trained Radiologica l Dsfonsa * *'~ *. : * *
. ,. Of;icc:s (RDO'.;.) and Assist';lnt RD0 1 s. A p:eroQuisite for RDO training is 4, *::.: cor:iplct:i.on of R~diologica W.onitoring for Instructots (Ri.\1I) training. It i s
11 1

our belief thii t this progra m designed to r..oo~ Pcclcrel ;cquitoments for RD0 s *. .- ,
.>. _~ill: also ~-~-*~~:*,je.~d by_tho ~bli~hm.~n.t _of lice~se' ~oe~ b~*: tho .~to~1~c . .'* *,: _:. *~ ., .
.t.nO.\i'Y Cc, ....

i ... ~ ...... o!k". .. . ~.:..* ,._ :, . :<* $t:.::_'.! ..* *.*' **: * ' *'::, *_... * * * * * * ,. '* .'.. *.. *. :
;;";/ .*i~ : '\(:{t':ri/iiI:.iI:\~'.; ~ IIi:t~I::\'.; ;:,\i.i:i?{:/( 1 1 \ ;;_, *. : ::i'.: **/ : : :*: *.,_:::; *
... . . ... . i .. *..* .* . ,*' I',
..:: *rt is, therefore, teco:nmcndcd th~t Atomic E~1orgy Cort. ..,ission By!)rcduct

_:) Mat0ric:l }fondling Lice;1scs gr~ntcd by ABC to user::. for training Rudiolocic;"l ~
1 n .t Mon,!tors'for Civil Dofonza pU(?oses bo c:.,:c:-i1pt fror,i tho roquir.0mGmt to p.;ly *a*. :
.**_::-i.

foe for th.;) lico.1se as prop*osed by the Cort.mission~ ** * *** * *
** I '
1*: *:. : * :,:.*. :: *

~_- ':_;:.\"*/**:*~*.* .* . ._.::* *\'.: .'*. .*. *. ::** :._$.'*~*~..*/*( :'=::;(:;_\ *:-:.:.. . * ..._:...** i;/ ,*.:-:*-':.:)).;- :.: ',,: .. ::::.,: ... ***::..:'
~.,*: ,.. : .*,-_. .. *.~........ . . . :. *:. :: ~~,~ ;-.*., : , ***,:*:~i\ ::':*. . ~_;...~, .... ~.-~:, pinc~,e}Y,,; '°' "' **:'*:~*f.' * \*. ,; . ~.* ~-**: .* \ . ,*.1,/; . * ,* * * ;. r * * ,I * , ,!, ' D~ RSRd ' . ' i ,,. ,*, ,, c** 1** *. , *,f * ,1 ,,, .. .' * *,, ~**1,,, *, ,., ,,,
j ., , ,' .. * * ** *** ~* *, :*~ , '** ' ***' *,* *. 1*\**,,!. **' * *.* . .
I*,, .
',1 .. ** ~ *, I ** ' \, ' * :, 1 ' I / ; I
.. ooCKEr NUMBER PR i* ,.,,ve,,~, * ,
PROPOSED RULE* * '": 7°*, ,)o : . *r ILLINOIS RADIOLOGICAL DEFENSE DATA ,,
*1
I Thia Dl.'.ltorial *is n detailed nppo x tionmcnt of t ho Foclernl_Guidanca .. . '.,.*= :**:.'. . *!
for RADEF otaff and monitoring otat ono aa oho\o/n in Part Et . Chapter s. t * *. ' Appanu x 1,.of. a Fadcral Guide.
,I / * ; { '. ..
To al gonlG or thrco *ma j or opc~ational nccoooitioa a.ro nhown no iollowa s ' .
*~r I I
t * ' RADEF OF *ICERS MONITORS STATIONS
,: Gonl o Ac c. Goa lo Acc. Gon l o Acc.
Illinois 908 58.637 6,253 l.
The apace to the immc dinto ri ght of tho 11 Goalo" column io for nota t ion o f , *.

accompliahmcnta ("Acc 11 ) . If a county dove lops .Hgurco which differ from thoao shown here by more* than 507. , tha aped.He goalo oct up by tho polit* .:

ical ~ubdivisions concerned., sh~uld bo carefully reviewod. * . , . ,..
'* I '. 1, ' *
,: .From these figures , data in Column IX (total requiromcnto) of tho prozram *:: :*.* *. ... *
paper (Section V B) , cnn ba determined. Linc itcOUJ 2, 3, & 5 o f t a.t * .. * . ..: .. . ;:_ .. .. **
oection may be taken diractly. Host othor 'ite~s m:o dapondon t on thoso * .. , , .. ~.. *:' * :- three ond can be dc:termine uain3 theoa thr-ee 'tnajor oato 9 dat4 ae a* . : , .'. ;... basis
for ca,lcula.tion. * * * * ' * ' ' ,. *

1
*. Since pub lic shcltern pla.co n l arga drain on' 'the supply .of t r ained ' . . < :;: '<*:*:*: .*/ *:-: \.:.,: *:**
monitors the magnitude of t h io roquiroment ia given by ohowing* t 1 uumlxlr *.* .:-'. " > '-:i.\**; .'./:*:: : < *of . shelters in io Phaaa II. ruil record sl(Urlin'arics (Cal:.
2a18). * * .' .:. . .* 1 r:::, -._. :.;
SHEL!rms . .. :: ,\ ': I ~ ~
~ .
CAPACIT'l ,'. ' _:;', t * '. ,'* ' ~:*
. ~.'. . <.100 )100 \ *1 **, .
1* ' *.
)*
1,945 5,558
/ , ' \ ,.
Illinois t l
*>,', I . ~ ~* *
These aheltero are div i ded into those having cap~citiea of loaa thun .00 spaces (<.100) which should hovo. t hreo monitors and those with 100 apacoa ;1.:**,, * :, ,.
.
ot:. mor.o (>100) which ahoul have five rnonitor*s*,.

C.KE T'E D

t * :. ' ' : ~ ' ' USIA'EC .
'-. .. . . ' ,' *.. AYJ,~ i'967 ff(ce,.ar t~~ *s~cr~tary P"b,1~. f!'.Oll' . i~gs
ILLIHOlS RADEr' DATA COUNTI HELTERS
MDI-:F OFPlCER K>NITOR STATIO S
_ __ _ _ _ _...;. 10 Cn pc.d. y
.::,;0::.,._,_ _>.:. 10~ 0::__ _Goolo ____ Acc_ . _Coalo _ _ _ _c __
Goala
__ _ _ Ac. _ Aclarns 6 , :rn 10 ,, 542 76 I " j *,' *** ' * , , *
... - 5 149 25 :* *,., \ ; I ' ' ***; .* ..
I '*
3. non 3
. *t: .. .0: 6 I
149 . ' 35
'. I ..
4, noone 2 5 14 26 5 . Brow .. . 5 .: ' ,:,: ; ' ... : ....... 96 * *
24 *.* ,'
,*, .. I . * *! * . ' ' * ,, .* .. '. . . ),*
6. Burenu ,' *.. . :' 3 5 :, 13 .. *'*,. *' .,
414 95 . . . '. *, .. *
' ' l, ' I' l
I Cnlhoun o '. o * ~** I 92 23 ',,. o**. .
a. Carrol
.*:, . ... J*
224 47 , ..
*; I*:,* * .... . .. '. * : * ' I * . *; ... . ** 9 . Cass 36
o. Champa i *.:*... 15 . *, :" .*. *. , * *.
117 ..** .* . * ..-... ...
'I I
I
\ \ . ') ,'
79 * *. * .. ,..,:
. *..* l l . Chris ia 2 . . _. ,**.. ... '**' * *:,
I **' *

2 . Cfork 0 , .... .*: ,* 2 . *'. ' 58' . . *. 37 . ..
13 ~ C ay 6* 7 204 42
' * *, I . : . .
4. Clinto
' \, ' . I o* .. , . . . *-
59 1 ,244 15 , Colao .. *. . . *o 7 34 ..' .*i .:, >
.' . ' ,." .' I . *.*. 16 , Cook 55 . . *.. 24,184 500 ~: ... .. . .
17 . Crawfor I ' ' I _. 1,:,,. : * *
18. Cumberla ':* ,. ,'
\ *. :
34 * *
:*
19 . De Ka r.~- *.:. ::.,::,...
\:< .-,. *.. ' * ~ *. , '._ : ..
I 74 I
20 , De Witt *. 50 ;1; ., 21 . Douglas l " . . , 88 *. . : -:: *,_*::* 45 ..
, I I
I **
... 110 * . 22. Du Paga 0 74 15 960 i ..._ . 23. Edgn 0 *.*~ *.s . 0 245 .: . 55 24 . E war a : .. . . 5 24 *, . *P SE II L RECORD *~*-*u,~ n:'l-_.9.A'rEGORIES 2-8 FACILITill ' I . '," ,, ,; 'r , ;: '.' *, *: ;*:" tachmen *, \':?:_.*:..*.: ~:.'/,,<~ **'i'* '* 1 * *- ,_
. COUN'I'Y .. *e snin.Trms u~ r.Ql~ KAUt~
P.ADE17 owxcm V~1~ \4./ HO. OM STAT ts Copa _ty Coalo cc. ___G alo cc ,
lo C II
< o* *> 00 .25 . Effingha s 8 23 50 "26 . Fayct
0.. 4. 9 7 279 48 2 7. Pord 4 8 258

59 I
. 301 .. 28. Pro.nk n 3 4 9 29 . Fulton 2 .. :
4 3 394 .*. 92

I I
l
30. Gal a :, **,*
6 I .. 28 **' ' 3.
. .. -.: . 2 ' 4 ' ,.
31 . Greeno 8 2 2 . ' *.., .5
*. . .... ~*
32 . Grundy *,. *. 2 7 2 4 33 . Hami to *. *.- 1 1
.','*.**,, 4 , I , 5 ' '., , 44 , I ***l ;,* :1 34 . Hancock 12 357 ' .
35 . * 'Hardin 0 ,, 3 4 .. 87 a i* ' '
.' .* "36. Hcncleraon *.,
0 0 6 '!* ' 144 ' 36 , ;. ' '* ' 37 . Henry 7 12 10 385 76
'* *' I * *,.: 38 *.* Iroquo o , J . 14 .. 422
102
. ... .
39. Jackson ::_.' ' 7 4 '* 8 450
'*.1 ..
40. Jasper
O 7 .. '
75 41 * . Jcfferaon _:*:* :: .*. I 8 .; . _: _*. *. 305 . ;** .
~-,'\ ' ' .. . . '* ',. ~:' ; . . *- > *42, . Jeraey 6 170 *.. ~.., *.. *.43, Jo Davie G 236 \
44 . Johnson
(
., 45 *. l<Dne - * ,, '.91 46 ,
Kankake 89
*:;. . .. * *.* -* . J \' .*. 47, Kend ll" .*.- * *., 34 f .'
I ... ' , * . . .' .
4
1 54 I! '
*.. ' I
\ ,
ILLINOlS lv\DEF 01\'l'.\ (3) COU!IT'l SllELTERS .Rf.l)f_n~ OFJlICBR MONITORS STIIT;{ONS
*50. Ln . Solla <100 I , ,
______;~----------------.....--------
Cn.pacl.ty 6
*.>100 33 Goal:;
16
".cc . Coale 74 1 /.cc , Gou lo l.32, f.~c. !J ... ** J *
51. LnwrcncG :, ,

7 ' .. : .*'
\ *
I ,* * * .
I 261 40
52. Lee *: . 4 * ,,* ,', ' *
10 :*
,; 9 *1*** 68 . . . . I ..
53. tiviaeo1:0n * .* . 13 408 90
*' .. '* ' .. \' .,
54. Loga 9 -: ,*. \ 2tl5 61
..
55 , McDonou~,. 3 . .*.*: ', 5 8 JlO 59
. *' '~ . .
. ' *. 56. Mcllonry . 7 :' 8 293 58 57 . !cLean 17 .. 852 * ,* .. lJ0
.. . I I ~ :'
1, ***** * *
58. Macon 9 , * *. < . 57 :.,
7 ' 54fl ,, 44
. ~, . ... ' . . ;, . . *. 106 . *' ~* 3 . ..'
59. Ha coup
n 4 *. . *':",

2 . -:. *. 14 ' ' .. : . ~* . ;
. . ,. 1.*
90 ;,:- \
\ .
60. 11adison .'_49 .. ':):;\.' 14 . . . ; l, 005 -: , *
102 ' ! ' '~
r: ,; .* * .
... . .I .
61. Mario!\ ,~ . *; '. :,* 9 ,: ' 10 373 . 79 I '.:: , : '
I , * ' *, , !
.. .' ' 62. 1nroha 1 152 36 . . I ' *" l .
I . . 6
. ** *ms .: , '. _1 : *,
63. 1oson 7 . . '
1 -*,*
64 . Macsac 5 . 3 ' . *. ,' ,
'- ~I "' , . . ,*,._' 6S. Mcnar "l} ** ' *'o1 '. .' * , ' [ ' *
66 . Mel.*cer : , :' 2. 3 . *' ..
' * * * ' ~I ' , . . 6 7. Monro-e _l ,__ *: * . 7 .
35 .. ' .
'. 2' . ~ -~:.' ... . . ... ' . ~ . ~
68. Montgomery . 87

69. ,Morgan 7
* ,*
I.
70. ,Moultr o , .7 212
.'r:. . ,, * *, I * *,. :'/ 71 , Ogle 12 :*.'* *: . * ' . ,
342 82
* ~ 'i.
I * * * *
* * *
72 .

Peoria

ll *

j *.... *. **. ," 940 . 73 i' *,* . ' * . ** I ' . ,\ * ,.,.
224 .. 37 711 so '* . .*. '
couirn* G le-1'.l.'Bi\S MDlff Ol'l.1XClm HOllITOns STl\'l'IOHS Coptt ity . Got.\ln Acr:, Goalo cc . Gon l cc .
~ --------------.,;.;.;~---------*- *---------------
100 . .!1- ).00
....' *** f
75. Pika 0 l 12 . * ,.' .*.:., *,>'-
337 .. . Q3 76, Popa 0 5 .. \:_..~:..: ;. '. ; !, ,**_;: :' .*. : . *:. _ 9 6 21. , ,
. I *. .
77. Pufouk 2* 6 131 . 3 **.. *.
7D . l'utnom 0 0 5 92
2
79. n..aodolph 9 .: : ' 26 10 437 70
' 80. ichlilntl l *:: *.
4. 6 59 J4
. 01. Rock la lan . 42 131 /.I \ l, 043 58 103 ... .*. I i
03. Solina :.>_":.-':'.:..* : 2. 2 . ,.., ,*. *.* *, 7 ' i*( ** . :.* . * , .* ** ... 250 l~6
,., ' *. \ ~ . ' .. ; : . '1 , ,. ,, .
04 . Songo.nton .. * ;* ":".*:. 29 .' .' lJ
i-; * :, I *
. \
I. 0 * . **; ,* * *. ,* 1 ' *,* .*..
05. Schuyl r
j **
6 1, * ~
*. ' . .: ' ' *: :~ ,l * , .. ': . ..
06. Scott . .. 0 ', :

0. : 5 22 I
I \ '
.. **, 284 8 7. Shelby 66 - * ' . . *. ~ I I ,* * ..' . 88. Sturk ,* ' ..~
0 *. *. *,
0 *
* , * I i. ' '.
I -~ 5 .. 116 29
'.*** .l 89 . Stephc100 418 63 \ '
90. Tazewell
. -* ., ' '{.'* . 91. Union '.' ('
92. Vo1-milion 120
* : I *** * .
93. Wntn1ah 20 .. ',

.. I '
' * ** t /* ' 94. Wo1*ron .._ 49 ...... . 7 . : ' .. - . *,* . 47 9 5 . Waohington ** J * . ,. *;.:.:: ., ., 199 ' ,,
96 , Wayne I ' ' *1, *.. 235* 97 . W,ito
/ .' . 204 46 I*
90 . W1 it 7. ' **, . 66 i
I' 99 , Wil ... . . .. ..
73
t LLlNOIS RA DEF DA'fi\ (5) COtmn' SHELTERS lv\DEF OFl1ICI::TI. HONITO S STATIONS Ca acity Goa la Ace, Goolo M~a . al c *
< .00 > \ 00 100. w lfomso 7 345 101 . Win . 0 3 60 5 I' ' ~ ~. :*
102.* Woo or
,. 1 8 S* 0 ' I ' I. . .. ': .. ~
I. .., .. ' ~ ,* .
,,I* \ .* ' . * * ,' r . .. . .*~.'. ,,.,,:. ., . * ,1,
., , , ' ,*. * !
1'
*, 1 . *,* * ., f . ,\ ... : : '.* .. ,\ I' I * .',I,.,,
I;,
. .' *' i **
I '
'\
I " ",
**' ~. *.*. . ' ,I \
' . I
I* * *** * *
. :- *.*. ,. , 1' ' ,,
tt cbment. '1!
. ',, .., *r,- , .;: .,. - AL-
/- ~
MIKE MA-a'ISFIELD DOCKET NUMBER PR-~l),t{t,,15.d,
~ MONTANA PR0POSf0 RULE ?tJ, (1 0
~mh ~Wes ~emtfe ffue .of t1/4e ~joritg 1Jleaher ~asJrington, ;m.Qt May 11, 1967 OCKETED USIAEC AV 16 1967 fflce of the Secr~tary Mr. W. B. McCool ~i:b!lc Prac,e~/n~
Secretary Atomic Energy Conmission Washington, D. C.
Dear Mr. McCool:
I have received a letter addressed to you by two professors at Montana State University expressing concern about a proposed rule making which would affect proposed fee charges. In view of the interest expressed by these people, I would ap-preciate your providing me with a copy of your reply. Thank you for your cooperation, and please return the attach-ment for my files. With best personal wishes, I am Sincerely yours, Enclosure
Montana Sta.te University------------ A W DOCKET NUMBER PROPOSED RULf
.&zema,,, Montana 5971.J PR-- 3Q'l0.~0, 7e,, 170 TeL 406-587-3121 DepartmentofChemlstry College of Lettera and Science May 4, 1967 DOCKETED U&1EC Mr. w. B. McCool, Secretary
u. S. Atomic Energy Cormnission Washington, D. c., 20545
Dear Sir:
The Radiation Sources Cormnittee of Montana State University, Bozeman, Montana, would like to cormnent on the proposed rule making, 32 F. R. 3995, concerning proposed fees. We believe that it would be unwise to institute the proposed fees. The amounts proposed are low enough and there are sufficient exceptions that the fees would not be a substantial burden to an institution like Montana State University with a broad and varied research progEam using radioisotopes. However, even at the proposed levels, the fees could be a substantial obstacle in the development of research programs and the educa-tional uses of radioisotopes at smaller educational institutions. Thus, the proposed fees appear to be incompatible with the conunission's
r esponsibility for fostering the development of nuclear energy.
The primary reason that the proposed fees would not be a substantial burden in many cases, is that the use of licensed materials in research and t eaching i s being supported by the Federal Government or the various .. .; .. *:: states . Thus , to a large extent, the proposed fees would amount to transfers between federal agencies. Any anticipated decrease in the congressional appropriation for the A. E. C. would have to be offset by i ncreased appropriations for N. S. F., N. I. H., etc. There would, of course, be a net loss in the administrative expenses associated with collecting the fees. We are not sure that making the A. E. c. less dependent on direct congressional appropriations is a good idea~ and since the proposed fee system has manifest disadvantages, w,e are opposed to it in its ent~rety.
\ ....
Mr. W. B. McCool Page 2 May 4, 1967 The fees proposed for power reactors are more easily justified, but we are not sure that even these are warranted. Anyone operating a nuclear reactor must _be financially responsible for whatever expenses are necessary to keep it safe. The regulatory function of the A. E. c. is designed to see that safe practices are maintained, but it would be unwise to let a situation develop in which the regulatory *a~thoritr is financially dependent upon the industry it regulates. Sincerely, 01,t/,l ~ Dr. ~a lph Olsen Chair man, Radiation Sources Committee
~,/~
i.JJnr. Reed Rowald Connnittee Secretary and Radiological Safety Officer RH/sh cc: Senator M. Mansfield Congressman A. Olsen
PR 3/l,'ll','S6, Automatic Alarm Corporation 2404 Lyndale Avenue South
Minneapolis, Minnesota 55405 DOCKET NUMBER WPOSED RULE -1 &, ( 7D Business Office : 374-3000 Central Station: 336-6678 OCKETED Secretary OOAEC United States Atomic Energy Commission Washington, D. C. 20545 AY161967 May 10, 1967
Dear Sir:
We received your Notice to AEC Licensees of March 13, 1967 and have studied the material submitted. Automatic Alarm Corporation is in the burglar and fire alarm business and covers an area including the entire state of Minnesota as well as the border counties of Wisconsin , Iowa, and the Dakotas. A very minor portion of our business includes the sale, installation, and servicing of Pyr-A-Larm fire detection devices. These devices contain small quantities of americium 241 which is covered by the regulations of the Atomic Energy Commission. Because of this we are required to have a Specific License for the handling of these devices. Although the proposed license fee would only appear to be twenty-five dollars ($25. 00) annually, we feel that no obstacles should be placed in our way where property and life safety protection is involved. If a situation arises where we feel the product of a particula r manufacturer is best suited for a specific application we should not be encouraged to substitute a less effective piece of equipment in order to save a few dollars in our own operating costs. We are not fully familiar with all of the ramifications involved in the policing of radio-active materials, however we would appreciate any consideration that could be given towards the elimination of such annual fees for this type of material which we use. Yours very truly, AUTOMATIC ALARM CORPORATION NL/sjo
/ ~.
N*/ Lewfri: President Burglar Alarm Systems Hold-Up Alarms Automatic Fire Alarms Water Flow Alarms Sprinkler Supervisory Service Building Temperature Supervision lnclustrial and Process Supervision
DOCKET NUMBER PR-10, 17t> 9
'3C,,'lfl, ~,
fROPOSED RULE..;._;..;....-- UNIVERSITY OF ILLINOIS - ..... DEPARTMENT OF PHYSICS URBANA May ll, 1967 Secretary
u. s. Atomic Energy Commission Washington* D. c. 20545
SUBJECT:
A.E.c. License Fees
Dear Sir:
I wish to comment on your Notice of Proposed Rule Making on License lees* dated Mar. 13. 1967. I have been deeply involved in A.E. O. Licensing matters since 1953. both as the University Health Pcysicist at the University of Illie nois and as the Radiological Defense Officer for the Champaign County Civil D8M fense organization. (Incidentally* I was also involved on the other side of the fence as an A.E.o. employee for a period of 10 months i n 195~7 as a Field.Rep-,e resentative of the Licensing ~ranch of the old Isotopes Division. ) My ccmments should not necessarily be regarded as representing the official *! *wpoint of the two organizations mentioned above. However, I have been encouraged by both to express my personal convictions on this mat t er to you . In the first place, I am opposed in principle to the policy of collecting fees for a.ny A.E.c. License because it directly conflicts with the Commission* s stated policy of fostering the development of uses of nuclear energy. For years, A.~. C. has been da.Dgling the bright prospects of nuclear energy before the noses of hospital9:t industry. and educational and research institut1/2ons . Now that m~ fish have risen to the bail., does A.E.C. intend to set the hookl This new tax is likely to have a negative effect whose value far exceeds the actual dollar eo,t to the licensees or the value of revenue to A.E.c. Most licensees find A.E . C, licensing a sufficiently disagreeable process as it is . Ask them to finance their ordeal personally* (and in direct proportion to their anguish) and you have imposed a tremendously inhibiting factor. In the second place, it may well be that in spite of the contrary arguements. A.E . C. has irrevocably decided the time is opportune to milk the heifer (and all that implies) t hat it has carefully pastured these many years. 'l'he philosopey does exist whj<<h post ulates that every possibly profit...aking endeavor licensed by the Governme nt should be taxed and retaxed . However. many A. J . C* licenses are held by non--profit institutions~ Such a ta on organizations like the Uni* versity of Illinois would seem to be inconsistentwith the reasons for their tax exempt status although obviously it would not i nduce them to give up their res search* However* there are many smaller scale licensees whose non-_profit com* mitment to nuclear work is not so strong that an additional burden would not cause them to turn the1~ efforts to more agreeable fields. A case in point is the licensing of Civil Defense source sets used in training of local Civil Defense volunteers and for instrument calibration. Tax these and thousands of source sets will be returned. Voluntary services (without which Civil Defense could not function) are difficult enough to acquire and re* tain. Start imposing financial burdens, no matter how small, and enthusiasm e.nd volunteers melt away together. Very tru.17 y~ur)"~ cc: Melvin Price, House of Representatives Robert Rose, Director, Champaign County C. D. ~ f .~~
DOCKET NUMBER PROPOSED RULE pR~ L/D, S-t;
- 7tJ I '7° MAY 1 5 1967 4U 1 1 7 ,_,,..~t'9;NClt1ahh 1 llOllhlN.Y 0 Di trlbution:
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DOCKET NUMBER PROPOSED RU LE - pR ~c, r/01,0
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~ongrc.sz of tlj e Ulniteb ~tates May 9, 196 7 .
Congressional Liaison Atomic Energy Commission Washington, D. C. 20545 Sir: The attached cormnunication is sent for your consideration. Please investigate the statements contained therein and forward me the necessary information for re-ply, returning the enclosed corre-spondence with your answer. 1330 Longworth Building
.D 8-1197
UNIVERSITY OF COLORAD 4 B OU LDER. COLORADO PRE S ID E NT' S OFFICE PR- 1197
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, "' A MCNAM A RA , MICH. JACOB K, J , N,Y, W ,-.YNE M ORGE , OR CC , WIN S TON L. PROUTY, VT, R AL,~H YAR OORO U OH , T E X. P E TER H, DOMIN ICK , COLO, J 0 S £ P H S. C LA fH(, PA, C E ORCE MURPHY, CALIP', J ENNI N GS R AN OO L P H, W. VA. PAUL J , , ANNIN, ARIZ. HA RR I SO N A. W I LLIAM8, JR,, N , J, CL A I IJ O R NEi: PE L L, R. I. U OWA R O M. KENNEDY, MASS, G AYL OR D NEL S ON , WIS. CO MMITTEE ON RODl!RT P". KENNEDY, N,Y. LA B OR AND PUBLIC WELFARE STEWART K. MCCLURE, CHICP" CLE R K JOHN 8. l"'ORBYTHli:, Clii:N ERAL. COUNSEL May 10, 1967 Mr * . S. Hollingsworth General Ma nager Atomic Energy Commission Wa shing ton, D. C. 20545
Dear Mro Hollingsworth:
I enclose for your attention and consideration a communication from Mro K. R. Spearman, Director Industrial Division Texas Nuclear Corporation Austin, Texas Please let me know what may be done regarding the matter referred to therein, returning the enclosure w
th your reply, and oblige Yours very sincerely,
~
Y rborough tor fro RWY:vnn
~nclosure
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DONALD J. IRWIN 4TH DI STR ICT, CONNECTICUT DOCKET NUMBER pR. _ ~.., 119 8 DISTRICT OFFIC E S , PROPOSED RULE 30 / Yq ~ 70,, /5"~ STAMFORD ROOM 301 COMM ITTEE ON 1 BANK STR E ET A RMED SER VICES 1023 L ONGWORTH O FFICE BUILDING C!tongress of tbe ~ nitel.l ~tatt.£) PHONE, 348-8654 NORWALK WASHINGTON, D . C . PHONE,2.2.5-5541
~ou.se of l\epre.sentattbe.s PHONE, 866-92.71 BRIDGEPOR"'I' ROOM 841 DANIE L E. REED 0 JR.
Mlasbington, 119.'1:. 20515 855 MAIN STRE ET D ISTRICT C OORDINATOR PHONE, 335-1646 866-332. 5 May 9, 1967 Mr . Harold L. Pr i ce Director of Regulations Atomic Energy Commission Wash ing ton, D. C. 20545
Dear Mr. Price:
Thank you for your let t er of Apr i l 27th in response to mine concerning the proposed fees for users of radioactive mate rials subject to your Commission's regulatory authority. Frank ly, I am concerned over t he proposed $25 fee for medical users. I should be interested in a few words on your justification of this fee. DJI:ra b /2-1198
MRS . ROVENA W . PHARES LESLIE G . PHARES President Vice ~President EXPERIEN CE -
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I N TEG RITY L-* ~t- .. ~,., DOCKET NUMBER PR .>P, ~~ r,
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PROPOSED RULE '7 ~h!.,1° ELE CT RONICS TEL. HI 2-6701 Protective Systems, Inc. 1804 LINSCOMB AVE.
P. 0 . BOX 3271 11 May DOCKETED
~
MAYl 51967
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Secretary Mlle ~ceedlap hell United Staes Atomic Energy Commission j tt1 Washington, D. C. 20545
Dear Sir:
This is in response to notice, dated 13 March 1967, inviting comments on the proposed establishment of fees for materials licenses . This company is an independently owned, Texas chartered Corporation established "to install, service and maintain alarm signaling equipment and systems for the protection of life and property . " Perhaps it is moot to say that by necessity we hold licenses from the City of Austin, Texas, Travis county, Texas, The State of Texas just to allow us to transact a business. In addition to all these , we are on the tax rolls of not only these governmental units but The Austin Independent School Districe, The Travis County Water District and of course our Federal government . To engage in our SPECIFIC endeavor of furnishin~ fire and burglary protection, we are also subject to the rules of and the inspection service of the State of
~exas (for the A E c, this is an Agreement State) Health Department , The State of Texas Insurance Commission (for installation procedures), The Underwriter ' s Laboratories and of course the various Cities in which we op~rate for our electrical license .
In addition to the above mentioned regulat ory *bodies, we have seen frot to affiliate ourselves with the N. F. P. A. for many years and the National Burglar and Fire Alarm Ass ociation since it was organized in 1947 . It is our sincere belief that the proposed $25 . 00 fee will not only pr ove burdensome to the operating companies, such as ours but to the Commission itself_ It is also our belief that the license as it stands today gives the Commission absolute full and complete control for the safeguarding of the health and safety standards of the public. Your consideration of the above mentioned facts will be appreciated . Very sincerely yours, LP/1 FIRE ALARMS- BURGLAR ALARMS Leslie G. Phare GUARD - NIGHT PATROL
" TO BE SURE "
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DOCKET NUMBER >u ' 4 ~ _,. ~ pr;f'\' .-- ~,-, q_1_11 F p8. ,. ~ r:~I I 7 c> STATE OF ILLINOIS CIVIL DEFENSE AGENCY 111 EAST MONROE STREET SPRINGFIELD, ILLINOIS 62706 TEL. (AREA CODE 217) SB 525- 7860 COL. DONOVAN M. VANCE STATE DIRECTOR April 14, 1967 Mr. Herman Campbell/Mr. Wm. E. Edwards, Jr. Alexander County Civil Defense 14th and Washington Street Cairo, Illinois Gentlemen: The Atomic Energy Commission sent a notice dated March 13, 1967, to each licensee proposing the establishment of license fees which would include the licenses now held for use of the OCD Training Source Set. In accordance with paragraph 3 of the notice, Director Vance has written to the Secretary of the Atomic Energy Commission recom-mending that licenses held for Civil Defense purposes be exempt from this licens ing charge. It is believed t h at your personal views on the matter expressed in a letter addressed to Secretary, U. S. Atomic Energy Commission, Washington, D. C. 20545, would be useful in causing a change to the announced policy and would further serve the cause of Civil Defense . This letter should be in the hands of the Atomic Energy Commission b efore May 13, 1967. FOR THE DIRECTOR:
~A Robert S. Ritz, Jr.
Radiological Defense DMV : RSR:sn J. [)
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DOCKET NUMBER PR 1°, " .., s-~ 7 PROPOSED RULE ", I 7 b CREMER ENGINEERING COMPANY INCORPORATED 321 NORTH 121ST STREET
MILWAUKEE, WISCONSIN 53226

May 11, Secretary United States Atomic Energy Commission Washington, D. c. 20545
Dear Sir:
This is in response to Notice to AEC Licensees, dated March 13, 1967, inviting conments on the proposed establishment of fees for materials licenses. We are distributors for Pyrotronics, Inc . , which is a manufacturer of Pyr-A-Larm fire detection devices. Each of our devices contain a small quantity of Americium 241 and as such comes urrler the rules and regulations of the Atomic Energy Connnission. We are a Specific Licensee for the dis-tribution of our product and market it in Wisconsin. We have a License for the transfer of the device and for the installation involved. The devices themselves are generally licensed for sale to the public . We assume that our Specific License comes under C tegory #1 which would provide for an annual fee of $25 . 00. The amount of the fee is not large but we are a very small businessman and this is another expense added to our operation which must be passed on the the end user. Since our product is designed for life safety and property protection against loss from fire, it is a most valuable device in the protection of our country's assets. We would have serious objection to the imposition of the license fee because of the added cost of doing business. An even more serious objection can be implied by the fact that it is entirely possible that the Agreement States will follow the lead of the Atomic Energy Connnission in imposing fees on materials licenses. If such procedure is followed we, in Wisconsin, would be required to pay license fees to the State of Wisconsin in which we operate and the amounts of fees imposed could be substantial. It is our feeling that this action by the Atomic Energy Commission will set a precedent that will be duplicated and will cause increasing hardships in the distribution of life safety equipment. JOHN WILLIAM CREMER, REGISTERED PR f"ESSl NAL ENGINEER-WISCONSIN E-528 4
We request that the Commission r e consider its proposal to impose the annual license fees for the type of material which we distribute. Very truly yours, CR>>lER ENGINEERING OOMPANY, INC. JWC:mh
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7" DEPARTMENT OF THE NAVY PROPOSED RULE ( Xc 1= HEADQUARTERS UNITED STATES MARINE CORPS WASHINGTON . D.C . 20380 IN REPLY REFER TO CSY-11-bkp MAY 12 1917 United States Atomic Energy Corranission Washington, D. c. 20545 Attention: Secretary, Atomic Energy Commission
Dear Sir:
Reference is made to the proposed rule making published in the Federal Register on 11 March 1967 which would establish fees for Atomic Energy Corranission licensing services. The Marine Corps is basically opposed to the imposition of these fees on an inter-agency basis. In the interest of economy, it is considered inappropriate to effect the trans-fer of the modest amounts 0£ funds involved between federal agencies and/or departments. The additional expense that would be encountered in budgetary, administrative, and accounting actions to enable the payment of the proposed fees would dictate that a specific exemption be requested for the Marine Corps in the event that a blanket exemption for govern-ment agencies is not incorporated into the regulations. Sincerely,
I- , r"' ,. f' , 'f ~ Ft,ir--1 OOtltET NUMBER PR ~ ~ I 7Pr/?P.
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fo PROPOSED filJ_LE_,, + DUKE POWER COMPANY P. 0 . BO X 2 178 GENERAL OFFICES TELEPHONE : AREA 704 332-8521 422 SOUTH CHURCH STREET CHARLOTTE, N. C. 28201 May 10, 1967 Secretary United States Atomic Energy Corrnnission Washington, DC 20545
Dear Sir:
Please refer to your Notice of Proposed Rule Making suggesting the establishment of fees for facility and materials licenses. In the third introductory paragraph appearing in the Federal Register, it is indicated that only one application fee would apply if more than one facility is included in a single application. This variation does not seem to be reflected in the schedule of fees shown in tabular form in Part 170.21. Applying to both the fee for filing application for c onstruction permit and also to the fee for construction permit, it is respectfully suggested that these two fees associated with power reactors be reduced where a single application includes a second or more duplicate reactors at the same site. Such a reduction would reflect the lower Commission costs per reactor when multiple units are included in a single application. We appreciate the opportunity to have commented on this proposed rule making. Yours very truly, W S Lee Vice President, Engineering WSL-s cc Dr Peter A Morris Director Division of Reactor Licensing
PICKER NUC. 1275 MAMAR AVENUE WHITE PLAINS, YORK 10605 AREA CODE 914 948 0080 FRANK H. LOW VICE PRESIDENT, NUCLEAR PICKER X-RAY CORPORATION DOCKET NUMBER pR JD,ff0,5"q. PROPOSED RULE - 7q 171> May 10, 1967 The Secretary U.S. Atomic Energy Commission Washington, D. C. 20545 11
Subject:
AEC Proposed Schedule of Fees for Licenses", dated March 10, 1967
Dear Sir:
The Association of Nuclear Instrument Manufacturers, which consists of twenty companies which in total account for over 75% of the volume of nuclear instruments manufactured in the United States, at its last Board of Directors meeting reviewed and discussed the proposal of the AEC for charging licensing fees and asked me to report our opinions to you. We are in full agreement with the basic concept that, insofar as possible, government functions should be self-supporting, and we favor the spirit in which the proposal was made. However, we feel that the suggested implementation in regard to radioisotope users runs contrary to at least two basic tenets of government policy in general and AEC objectives in particular: (1) it imposes charges on a group of institutions which are preponderantly non-profit and supported in many cases by government or at least public funds, and (2) it would tend to restrict rather than promote the use of radioisotopes, which is in direct opposition to basic AEC policy. In practical terms, we believe that besides tending to discourage the more widespread use of radioisotopes, the mechanics of fee collection, particularly when state agencies also enter the picture, wi 11 be burdensome for all concerned and result in a relatively inefficient and often inequitable method of taxation. The rather high renewal charges appear to us to be the most inequitable aspect of the whole program. We would like to recommend that the proposal for charging licensing fees for radioisotope users, at least for those dealing with tracer quantities in research and medicine, be shelved for some time to come. Sincerely yours, 18C(ET ED ~<< ~ p OUfC - MAYl 2) 1967 *4 Frank H. Low, President Association of Nuclear Instrument Manufacturers - FHL/ cp
1f NATIONAL AERONAUTICS AND SPACE ADMINISTRATION MANNED SPACECRAFT CENTER HOUSTON , TEXAS 77058 OOCKET 'NUMB'ER pR >.JJ, tj.u, ~ 0 1 eBOPOBED RULE____?_ &, 1 1 CJ IN REPLY REFER TO: DC32-67-L22 00 MAY 1 0 1967 Secretary U. S. Atomic Energy Commission Washington, D. C. 20545 Gentlemen: Reference is made to U. S. Atomic Energy Commission Notice of Proposed Rule Making on License Fees, as published in the Federal Regi ster, March ll, 1967, and enclosed with Notice to AEC Licensees dated March 13, 1967. We concur with the philosophy that where licenses are issued in the public interest, the licensee should pay a fee for the special authorizations granted in the license. However, the practicality of having Federal agencies pay materials license fees is questioned on the basis that administrative costs for transfer of Federal funds will far exceed the relati vely small fees applicabl e to most Federal agency li-censees . It is suggested that the proposed Part 170 of Chapter 1, Title 10, Code of Federal Regulati ons be amended to i nclude in Section 170 .ll an ex-emption for a materials license i ssued to a U. S. Government admini stra-tion, department, agency, bureau or installation. Sincerely yours ,
<ai~ Robert R. Gilruth Director cc :
NASA Hq. , M-1
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. OPOSfO iULE ; '7D,l_?D DELMAR ELDER COUNT Y SUPER I NTENDENT O F SCHOOLS MOULTRIE COUNTY COURT HOUSE --------- O F F ICE PHON E 3 215 SULLIVAN , ILLINOIS (,,f1'i/
May 9, 1967 Secretary of U.S . Atomic Comm . Washington, D.C. 20545
Dear Sir :
Colonel D. M. Vance has received word from the U. S. Atomic Energy Commission stating that in the future there will be a charge of
$25 . 00 for the renewal of their By- Product Material Handler's License. This would include those in Civil Defense as well as Commercial handlers.
In view of the fact that Civil Defense Licensees are volunteer workers, giving of their time and knowledge, it doesn't seem fair to charge for their licensing . Surely we will have many drop outs which we can ill a.fford at this time . Thanking you for any consideration you can give this matter, I am Very truly yours, [J~uVV &M-ev Delmar Elder, County Supt. of Schools Moultrie County DE/jab
children's asthma research institute & hospital 3401 west 19th avenue I denver, colorado 80204 I 433-2591 Constantine J. Falliers, M. D., Jack Gershtenson, Jonas Kiken, Medical Director Administrator National Director of Development May 10, 1967 DOCKETED IJSjEC Secretary U.S. Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
In reference to Part 170 - Fees For Facilities and Materials Licensed Under The Atomic Energy Act of 1954, As amended , I respectively suggest that non-profit foundations engaged in research be exempted. JB:ms founded in 1907 as the jewish national home for asthmatic children at denver officers: Arthur B. Lorber, President; Morris E. Adelstein, Vice President; Sam M. Robinson, Vice President; Harold Stuhlbarg, Vice President; Graham Susman , Vice Pres ident; Joe Alpert, Honorary Vice President; Mrs. Mollie Lifshutz, Honorary Vice President; Lawrence Litvak, Secretary; Irving P. Lindner, Financial Secretary; Norman V. Cohn, Treasurer. denver board : Robert M. Adelstein , Gary L. Antonoff, Sam Baum , Joseph Berenbaum, Mrs. Meyer Castle, Edwin P. Glick, Gerald S. Gray, Isadore Greenblatt, Harold N. Grimes, Gerald V. Harris, Harry H. Herman, Edward Hirschfeld, Philip H. Karsh, Moe M. Katz, Harold A. Lane, Edward Levy, J. Leonard Levy, Jack C. Levy, David Lifshutz, Stephen L. Miller, Leonard Millman, Mrs. Jennie F. Pelis, Irwin Pepper, David M. Pollock, Gerson B. Radetsky, Edward A. Robinson, Robert Rothberg, Charles M. Schayer, Eli H. Sobol, Jack A Speyer, Alex Stark, Caleb Steinberg, Stephen T. Susman , S. Charles Tobias, Robert L. Weil. honorary trustees: Isidore Amter, Mrs. David Schwartz. national board : Mrs. Jacob c . Albert, New York ; Maurice Austin, New York; William B. Blumenthal , Los Angeles; Sam Drey, Phoenix; Morris Dreyfus, Chi cago; Max Firestein , Los Angeles; Robert Fischgrund, South Bend ; Jacob Gerstein, New York; Charles _Goldring, Los Angeles; Samuel L. Goldberg, Kansas City ; Sam Gurse, Los Angeles; Judge Samuel Heller, Chicago; Charles Kline , Allentown ; Stanley H. Kun~berg, New York; Sidney G. Kusworm, Sr., Dayton; Mrs. Joseph B. Levie, Denver; Richard Livermore, Colorado Springs; Hugo Loewy, Seattle ; Sam Luby, Miami; David N. Meyers, Cleveland; Dr. John Myers, New York; Charles G. Reskin , Chicago; Aaron Riche, Los Angeles; Rabbi A. Alan Steinbach , Brooklyn; Benjamin H. Swig, San Fran-cisco; Max E. Youngstein, New York.
DOCKET NUMO!:R PR '81.lfo.!rl, 6~0i~D RULE ~ 119, flD Gordon College and Gordon Divinity School 255 GRAPEVINE ROAD, WENHAM, MASSACHUSETTS 01984 TELEPHONE: (617)-927-2300 May 10, 1967 Mr. W. B. McCool, Secretary U. S. Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
Here are our comments on the proposal of the Atomic Energy Commission to require license fees for facility and material licenses. As we understand the publication , ordinary holders of a by-product material license will be subject to the applied fees, unless they are party to a loan agreement administered by the A.E.C. Division of Nuclear Education and Training , or have a reactor contract. Our small institution does not come under either category. Our license has been obtained for basic research by a member of our science faculty (license 20 - 11735-01). This is a small scale project, with a small budget. The nature of the research requires that we purchase small quantities of by-product materials from time to time , so that we would have to maintain a license from year to year. The annual fee proposed ($25.00) would constitute a significant percentage of the total cost of the by-products used. We suggest that the annual fee is excessive for those whose need for by-product materials is very small and occasional. Possibly non-profit educational institutions could be granted a limited license based on a one-time application fee. When the needs outgrew the limitations of such a license , then an annual fee would be a p propriate.
- yours, ETEB DSIAEC AY 111967 LJC/bh - - - - - - - - 75th Anniversary 1964
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I hav~ noted the copy of your letter to tho
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trial uaar~ of byproduct mntcrials. l can ~pp~ccinto yo-~r concern hero. ~nd l ch.all ha glad to ask tho Comm.coion for ~ raport; on tha schadulod ~ction 1 "'lthou~h I auppo!lo your direct inquir;v will bQ quite~ fruitful
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With beGt wi;has, I c:u Sincerely youra,
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U. S. Atomic Energy Commission AY111967 Washington, D. C. *20545 ttlce of tbs secretary

bile Proeee~IRCI
Reference:
Proposed Uconsing Fees Spocific Byproduct Material Llcensos
Dear Sir:
!* Your lotter dated Morch 13, 1967, signed by Mr. Harold L. Price, Director of Regulations, outlines tho proposod fees which wlll be chargod industrial users of byproduct materials.
As a manufacturer of nuclear level gauges utilizing small sources of byproduct materials, l om dofinltoly ogoi nst the proposed rule that would require llconsaos to pay application and annual foes. Instruments, Inc., since 1948, has pionoered the inclusiTial uso of nuclear gauges for [ controlling both liquid and solid laveb in closed vessels. During th<:>sa eighteen (18) yoars a substantial portion of our .sales tlme was required to convince prospoctivo u50rs that tho radioactive materials supplied would ha safo with respect to thoir plant environments. It was particulorly dlfficult to soil a chemical or food plant on *the idea of using a nuclear levol
. .. gauge, particularly in tha years followlng World War II. Tho much publicized fear of q.*: , ionizing radlation lmmediataly following Hiroshima created an atmosphere of fright among I :. . potential usera. *:. *: In more rocont years we, along with other cuclear gauge manufacturers, havo developod a , * : field of instrumentation that is accepted by the major process plants throughout the U.S. The .* ....: , cultivation of a favorable climate to uso radioactive materials in a process plant has not been . , . easy *
. ;,.:. If the propo$Gd rule outlined fn the March 11, 1967 Federal Register ts adopted, we will again
*/ * 'c-.. be _ faced with a*n unfavorable climate in which to market our nuclear ossoctatod products. To substantiata ol.Q' boilers wtth respect to charging fees for specific liconsos, I <1m attaching a . copy of ono of our customer', letters. Tho opinion of this usor toward license; fees Is quite obvloua--and negative ,, . . .
I * ' . ,* ~ .. ,<,I '
* ,, 'I * ._. ,LUTHER 2..415\
CABLE "INSTINC" DIYl*ION OP NAnoNM. TANII DONPANT
* .. *.* * ,. o. aox TUI.IA, OKLAHOMA 656 Sccrctcry-U.S. Atomic Enorgy Commission Merci, 27, 1967.
PQOe Two Tho explanation given for charging foes for byproduct material liconscs seems oxtrcmely fli msy. I quota, "Tho commission is proposing tho ostohli:;hmont of foes for ib facility and motcdols liconsas which It oolioves to oo rea:;onablo end compotiblo with tha Commission', ros;:x:msibility for fost0ring the c!ovalopmcint o f nuclecr onorgy. "* It is difficult for ma to accept this statement as a vaJid reason for imposing fe es ,inco tho dcvolopmont of nuclear energy for \ industrial use was C£11'tainly supported as much or more so by p-ivato Industry than by the .,. Commission .. 1 ... . I emphatically suggest that tho proposad rules for ~blishing application and annual fees to ~*
*.',::-,:.,:*. *: use byproduct matcrlal1 .
ba dropped c:omple~aly. I .,.
* ,i l :* ' ," *
Vory truly yours, INSTRUMENTS, INC *.. ' ,:~ ,:
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-_:: . . Senator A. S. (Mike) Monronoy, Washington, D.C. '.. ;_'* j ' ' : \ .- *: * * .
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MAR 'Z'l \£.87 Mr. W. Darrell Hunt, Manager Nuclear Controls Department Instruments, Inc. P. o. Box 556 . *;_;: *. Tulsa, Oklahoma 74101 I
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Dear Mr. Hunt:
We are using your Model 200HLFS GAMM-0 SWITCH and type B-20-06 source ..,, holders to sense lime levels in six coolers or our design, and
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contemplate a seventh in tallation. Your records should include de-tailed in.fonnation on these applications.
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' We would appreciate your advice as to the category or license that these installations will ran under, under the Atomic Energy . Commission proposed new Facility and Materials Licensee Regulations, a cow of which is enclosed for your ready reference. * * :; ,.; I *
If either the license *feee, inspections, or regulations become excess-ive, . the use of . this type sensor can no longer be justified. We would
*,_._ therefore appreciate your comments on these proposed new rules.
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a DOC<<ET NUMBER pR-Jo, Cf". -ro,
PROPOSED RULE l 'JQ, l']O REPUBLIC STEEL CORPORATION RESEARCH CENTER 6801 BRECKSVILLE ROAD CLEVELAND , OHIO 44131 WILLIAM A. REED P. o. B ox 7806 D I RECTOR OF RESEARCH JOHN J . HAZEL ASSISTANT DIRECTOR OF RESEARCH May 8, 1967 Secretary, United States Atomic Energy Commission Washington, D.C. 20545 Subject : AEC Proposal to Establish License Fees Regarding Title 10, Code of Federal Regulations, Part 170 Gentlemen :
We have carefully reviewed the AEC proposal ( 10 CFR 170) to establish facility and materials license fees . We believe that the establishment of the fees would do more harm than good . They would add to the paper work involved, increase AEC administrative costs, complicate the licensing procedure still further, delay com-mercial utilization and discourage the expansion of nuclear R & D activities. In view of the continuing successful growth of nuclear technology under past AEC policies, we question the advisability of added restrictive procedures at this time. Consequently, we recommend reconsideration of the proposed fee schedule in order to maintain continued growth of nuclear energy applications in industrial operations. Sincerely yours,
- u / ~ Cl. BecQ__
William A. Reed Director of Research WAR:ja 9CIETED USlEC AY 11 1967 Office Gf tilt Setrctarr l'l:lt)l& ~rs::.~~llir.~
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TITLE 10 - ATOMIC ENERGY Chapter I - Atomic Energy Commission PART 31 - GENERAL LICENSES FOR CERTAIN QUANTITIES OF BYPRODUCT MATERIAL AND BYPRODUCT MATERIAL CONTAINED IN CERTAIN ITEMS PART 32 - SPECIFIC LICENSES TO MANUFACTURE, DISTRIBUfE, OR IMPORT EXEMPTED AND GENERALLY LICENSED ITEMS CONTAINING BYPRODUCT MATERIAL Increase in Quantity Limit for Tritium in Generally Licensed Self-Luminous Aircraft Safety *Devices On February 8, 1967, the Atomic Energy Commission published in the FEDERAL REGISTER (32 F.R. Z649) proposed amendments to its regu-lations 10 CFR Parts *31 and. 32 which would increase the quantity limit of generally licensed tritium in any single aircraft safety device from four curies to ten curies. Interested persons were invited to submit written comments arid suggestions for consideration in connection with the proposed am~nd-ments within 30 days after publication of the Notice of Proposed Rule Making in the FEDERAL REGISTER. After consideration of the comments rece_ived and other factors involved, the Commission has adopted the propose~ amendments. The text of the amendments set out below is identical to the text of the proposed amendments published February 8, 1967. Pursuant to the Atomic Energy Act of 1954, as amended, and the Administrative Procedure Act of 1946, as amended, the following amendments to Title 10, Chapter I, Code of Federal Regulations, Parts*31 and 32 are published as a document subject to codification effective thirty (30) days after publication in the FEDERAL REGISTER.
1. Paragraph (a) of § 31. 7 of 10 CFR !>art 31 is revised to read as. follows:
§31.7 Luminous safety devices for use in aircraft. (a) A general license is . hereby issu~d to own, receive, acquire, possess, and use tritium or promethium 147 contained in luminous safety devices for ~se in aircraft, provided each device contains not more than 10 curies of tritium or 100 millicuries of pr9methium .147 and that each device has been manufactured, assembled or imported in accordance with a license issued under the provisions of §32.53 of this chapter or manufac tured or assembled in accordance with a specific license issued by an agreement State which authorizes manufacture or assembly of the device for distribution to persons generally licensed by the agreement State.
2. Paragraph (c) of §32.53 of 10 CFR Part 32 is revised to read .as follows:
§32.53 Luminous safety devices for use in aircraft: requirements for license to manufacture, assemble, repair or import. (c) Each device will contain no more than 10 curies of tritium or 100 millicuries of promethium 147. The levels of radiation from each device containing promethium 147 will not exceed 0.5 millirad per hour at 10 centimeters from any surface when measured through 50 milligrams per square centimeter of absorber. (Sec. 81, 68 Stat. 935; 42 U.S.C. 2111; sec. 161, 68 Stat. 948; 42 u.s .c. 2201) Dated at Washington, D. C. this first day of __M_a_y_ _ _ _ _ _ _ _ _ __ 1967. For the Atomic Energy Connnission. Secretary AEC INCREASES QUANTITY LIMIT FOR TRITIUM IN SELF-LUMINOUS AIRCRAFT SAFETY DEVICES The Atomic Energy Corrnnission is amending its regulations to permit a greater quantity of tritium in aircraft luminous safety devices used under general license. A general license is one which requires no application to the Commission. The amendments increase the maximum quantity of tritium that can be used in each device from four to ten curies. Self-luminous tritium-activated signs have been used extensively in aircraft since 1962 when the Commission established the general license for their possession and use. These signs contribute to the sa fety of air travel in that they continue to operate in the event of failure of the plane's electrical system. Beta radiation from the tritium acts upon phosphors to produce luminosity. The Commission's action is in response to a petition from the United States Radium Corporation of Morristown, New Jersey. The company plans to increase the initial brightness of the devices in order to meet requirements of the Federal Aviation Agency as well as to insure a longer useful life of the signs and markers. The Commission has concluded that the increase in the quantity of tritium to be used will not endanger public health and safety.
These amendments to Parts 31 and 32 of AEC regulations will be effective 30 days after publication in the Fed e ral Regist e r on I \. 9101 H IGHWAY 183, P . O. B OX 92 67 , A LLA N OAL E STATION , A US T IN , T EXA S 7875 6 P H ONE: 5 12 -452-8 10 1
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PRQ!?OSEO R!Jl-E P.f'l ?_~ 17 TEXAS NUCLEAR CORPORATION, A SUBSIDIARY OF N UC L EA R-CH I CA GO C OR POR ATI ON 9 May 1967 AY101967 - ' ETEo Cl! Bf tfie :tec,e,- 1c 9tbcehQJnu' Secretary United States Atomic Energy Commission Washington, D. C. 20545
Dear Sir :
The following comments regarding p roposed e stab lis hment of license fees by the AEC are submitted for your consi deration.
1. Proposed a p plication fee for categories 2 and 3 leads to Inequities. One can ob tain 99,999 curies und er category 2 for a $100.00 fee b ut one additional curie puts one in category 3 and an additional $400.00 fee.

2. The annual fee of $25.00 under category 1 is unfair to educational g roups with limited financing.

3. The fact t h at fees will b e c h arged (Section 170.12 a) irrespective of the Commissions'disposition of t h e application is a questionable extension of Committee power. The not inconsiderab le fees charged for certain a p plications could make this non-refundable section a difficult hurdle for some a pp licants and especially so for new firms considering entering the field.

4. The prescri b ing of fees by the Commission throws t h e door wide o p en to the agreemen t s tates to set t he i r o wn s c h e d ule of fees. The degree of reci p rocity of state licen s ing b eing what it is, it is only a matter of time b efore specific licenses o b tained under 10 CFR Part 32 will h ave to be o b tained fro m each state where one wishes to do business.
Even with only a $2 5 . 00 a n nua l fee t hi s a mounts to $1,250 . 00 when all 50 states b ecome agreement states and there is no guarantee that the fees will be limited to t h is amount.
. I Secretary, USAEC 9 May 196 7 Page 2 As must be obvious from the above, we are opposed to the establish-ment of the proposed license fees. Also, the need for such fees is not at all clear. For the most part the fees are insufficient to pay for even a portion of the expenses incurred by the Commission and have therefore a very questionable justifi-cation. They do, however, estab lish an objectionable precedent which may lead to abuse of licensing b y the agreement states. Sincerely, TEXAS NUCLEAR CORPORATION
,< {)<~
D. O. Nellis Health Physicist eg
DEPAR T MENT O F RADIOLOGY DIVISION OF RADIATION THERAPY THE UNIVERSITY OF OKLAHOMA MEDICAL CENTER 800 NORTHEAST THIRTEENTH STREET OKLAHOMA CITY, OKLAHOMA, 73104 May B, 1967 tic.IE TEO
~
MAY 101967 4 Secretary U. S. Atomic Energy Commission Washingt on , D. C. 20545
Dear Sir :
The University of Oklahoma Medical Center holds license #35 - 3176-1 which is a br oad license covering all research and cl inical usages of radioiso-topes in the Medical Center complex . The second license #35 - 3176- 2 (E69) covers the sealed cobalt 60 telethera py source in an AECL theratron 80 teletherapy unit . This unit is in clinical us e at the University of Okla-homa Medical Center , Department of Radiology , Division of Radiation Therapy . The Radioisotopes Committe e of the University of Oklahoma Medical Center , which r egulates the usage of all isot opes with i n the Cent er , has met and discus sed the communications of March 13 , 1967 from the A. E. C., and the copy of the Feder al Register 32 F. R. 3995 . We fe e l that some form of fee schedul e is reas onable and necessary for the amount of work whi ch is done by the A. E. C. in i t s licensing a ctivities. We feel however , on the basis that the University of Okla homa Medical Center is a state and federal grant support ed nonprofit educational i nstit ution , it , and ot her inst itutions like it , should be granted an exemption from paying the proposed fees . Sincerely ,
~r!Z Carl R. Bogardus , Jr , M. D.
Chairman , Radioisotopes Committee Director , Division of Radiation Therapy and Nuclear Medicine University of Oklahoma Medical Center CRB/gg
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DOCKET NUMBER PR J", ~°" ro, PROPOSED RULE 1 'i t 10 ISO NUCLEAR CORPORATION 160 Broadway New York NY 10038 (212) - 964 - 3323 May 9, 1967 Secretary U. S. Atomic Energy Commission Washington, D. C. 20545
SUBJECT:
Proposed Rule Making 32FR3995 - Comment on Gentlemen: In the Atomic Energy Act Congress has found that "the processing and utilization of source, by-product, and special nuclear material must be regulated in the na-tional interest and in order to provide for the common defense and security and to protect the health and safety of the public." The Act also gives as one of its purposes the establishment of "a program to en-courage widespread participation in the development and utilization of atomic energy for peaceful purposes to the maximum extent consistent with the common defense and security and with the health and safety of the public." In line with the first of these interests the Commission has for years operated an effective licensing and inspec-tion program which has helped to produce a remarkable record in the national interest and with a maximum con-tribution to public health and safety. Such purposes are properly carried out by funding from public or tax monies . Some domestic examples of such public funding for regulation in the public interest are Department of
Secretary U. S. Atomic Energy Commission May 9, 1967 Agriculture meat inspection, and Food & Drug Administration food additive and drug approvals. No license fees are charged for these functions. Since the proposed fees are not for revenue producing purposes, there seem to us to be strong reasons and precedents for there being no such fees. In line with the second of the Act's quoted interests, fees on individual users will tend to discourage new users, especially the smaller ones. This is surely not consonant with the mandate to promote the use of atomic energy to the maximum extent. In addition, an application fee as proposed places an unstated but nevertheless real pressure on the examiner to approve the application. Also, if AEC charges license fees it is reasonable to expect that individual agreement states would charge license fees. This would raise many questions of dupli-cation and non-uniformity of fee levels, compounding the problems referred to above. It is, therefor, my conclusion that no license fees should be established. William A. Loeb President
A A DOCKET NUMBER PR. ~8, l{6,'i&, W W PROPOSED RULE . , 1o. o 11 Butler and Bremer County -Municipal Civil Defense Administration P.O. Box 117, CourtJ.ouse
.\Itson, Iowa 50602 PJ.one 267-2706 Area 319 BUTLER-BREMER COUNIT I MUNICIPAL e OUfTE Courilioooe 415 E. Bremer Avenue Waverly, Iowa 50677 UU£C CIVIL DEFENSE BOX 117 , ALLI S ON, IOWA 50602 AV 101967 Secretary,
u. s . Atomic Ene rgy Commission ,
Washing ton , D. C . 20545 re : Notice of Proposed Rule Ma k ing to establish fees for AEC Licenses (Federal Register May 11 , 1967) Gentlemen: Following are some comments in regard to your Notice of proposal to establish fees for AEC Licenses and permits under 10 CFR Part 50, and Parts 30, 32 - 35 , 40 , and 70 . 1 . Apparent contrad i c tion in t he lang ua g e as to time covered by the licenses: Under the preliminary discussion ( pp 3 , page 3 9 95), it reads:
"License issuance and annual fees ****** would be deemed assessed ** ****** and paid for at the be g inning of the year ********* "
Fu r ther down , under heading s " Facility license fees" and under
" Materials license fees", it reads that for new licenses the fees are payable at time of a pp licati on , and that annual fe e s are pay-able one year after license is issued .
Comment: The latter arrang ement would a p pear preferable to a c al e ndar or fiscal year basis , since it would g ive the user a full year of license for his fees paid . Also, this would spread the L,'uA/.riJV G-workload of your a g encies throu ghout the year . 2 . Under 11 170 . 11 Exemptions", Part (a) (1) and (2) exempt the fees for license for import and export . Comment : The undersigned can see no reason for exemp tin g this class of license fro m the same fees imposed on domestic users . Such an exemption could give foreigners unfair ec onomic advan t age . And for those materials and facilities that could be of military value , the expor t license fees ought to be very substantially higher - - - - - if, indeed , they are to be licensed at all . 3 . Under "170 . 11 Exemp t ions" (pag e 3996), there is no specified e x emp tion for g o vernment a g encies or political subdivisions. Comment: This may be covered b y impli ca tion in paragraph (b) , but it would be better to have t h is as a specified exemption , as being in the public interest. F or Civil Defense and other defense a g encies, t h is exemption is also merited as for the national de-fense and public p rotection . Also , for federal a g encies, and t h ose subdivision a g encies that receive federal matching funds, the federal cos t plus the bookkeep-ing involved further neg ate the charging of license fees .
., ,. Letter to AEC Page 2 - Re: License fees I
4. Under "170 . 11 Exemptions , (a) (4) ", exempting certain non -
profit educational institutions: Comment: The undersigned feels this is too limited , and ought to be broadened to include other bonafide , non - profit , educational and research institutions , for non - commercial uses . It would seem to be in the public interest to encourage education and research . Control of how non- profit educational and research institutions can qualify for AEG Licenses should be by other reasonable rules and regulations , not by preference in the matter of exemption from fees charged .
5. General comment: As a citizen , I would prefer to have the fees for AEC licenses and permits, if established, be kept as low as possible . While I can see the merit of recovering the costs of the licensing procedures , I can also see the benefits of en -
couraging --- through minimal licensing fees --- the use of nuclear and radioactive materials . Respectfully, Henry Behrends, Jr ., (Director, Butler-Bremer County/Mun . Civil Defense) AEC License# 14- 11907- 01
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KETED U. S. to ic Ener-:y Co i ssio OSIAEC Washi ~to ,D. C. AYl O 1967 '1 r . Ha.rel L. Price , fflce of tbe Secrewy Director Of Re ula tion . le llroceeilnp
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COUNTY OF LA SALLE - *. PROPOSED auLE . . 10 , 170 OFFICE OF CIVIL DEFENSE LA SALLE COUNTY COURT HOUSE OTTAWA, ILLINOIS 61350 PHILIP J. BAILEY Director May 5 , 1967 SUBJECT : Fee for Handling License TO: The Secretary
u. s. Atomic Energy Commission Was hington, D. C. 20545 I have just learned with a great degree of consternation that you are considering a $25 . 00 fee for a Byproduct Material Handling License .
With other Civil Defense personnel I voice mY personal oblig-ation to such a proposal and also that of the other Civil Defense Instructors of La Salle County . A volunteer , local government subsidized organization should be exempted as is the case of a radio license . We have just recently received our federal license to operate a Citizens ' Band radio , and no fee was required . Your consideration of this will be appreciated . Sincerely , Philip J . Bailey , Director OCIETED PJ B/rs OOlEC AYl O1967 Office of the SecrelarJ i.'blle Prmettl11gs
PR DOCKET NUMBER ~&,CfO, so, Pe SED .RUU: .. 76 , (1b STOCK EQUIPMENT COMPANY 731 HANNA BUILDING - AREA CODE 1216) 621-3054 CLEVELAND 15, DH I 0 May 8, 1967 OHETED LISilfC 91967 Office of the Setr!tal'J Secretary Publlc 1*nc1m~lnis U.S. Atomic Energy Commission Washington, D. C. 20545
Subject:
Proposed Amendment Concerning Fees Gentlemen: By way of introduction, we own two sealed sources, 6 me Cs 137 and 300 me KR 85, which we use for experimental work and which are licensed by you . . We are also in the business of manufacturing a level detecting device employing a 2 me radium 226 source, which we furnish to general licensees in agreement states under a specific license by the State of Florida. We comment on the proposed amendments (32 F.R. 3995) as follows: The $25 annual fee required for category 1 of mater-ials license is a large annual cost compared to the value of the sources themselves when only a very few sources are involved. You may wish to consider exempting from fees total quantities of materials less than a certain amount to be given in a schedule similar to Schedule A paragraph 31,100. It is not clear to us what the reciprocity agreement of fees between you and the various agreement states might be. It could well happen that the same mater-ial is subject to fees several times over by various states. For example, in our case we might be subject to a fee from you for the two sources we have for experimental purposes and to a separate fee from the State of Florida for the radium used in manufacture. Conceivably this could ultimately include all the states. It is also not desirable that each person apply for a license from that licensing agency which offers the lowest fees .
- Page one of two -
Specialists in Bunker to Pulverizer and Bunker to Stoker Equipmen t
U.S. Atomic Energy Commission - Page two of two - May 8, 1~7 Some of the agreement states request that persons who actually make the smear for a periodic leak testing of sources of generally licensed equipment be specifically licensed in that state. Of course the persons applying the wipe test kit requires a specific license for this and for the measurement of the smears when they are returned. If a fee were imposed upon the user of generally licensed equipment solely for the purpose of having his man take leak test smears, it could be a serious deterrent to the application of such equipment. The alternative, namely the hiring of an outside man to come in to perform this service, is also expensive and already is a deterrent should the use of leak test kits not be permitted. We trust these comments will be useful in your deliberations. JRS/sjf
DOCKET NUMBER PR-,,,,,o. s, PROPOSED RULE 'Jo , f 70 U.S. NAVAL POSTGRADUATE SCHOOL MONTEREY, CALIFORNIA 93940 IN REPLY REFER TO : NC4(037)ns 3401 Ser: 415.1 5 MAY 1967 C<ETED Secretary IIQlEC U.S. Atomic Energy Commission Washington, D. C. 20545 AY 9 1967 lflce of the Secre~ Mlle l'rti::1t1ncs Docket No. 50-43 Gentlemen: Atomic Energy Connnission Notice to AEC Licensees of 13 March 1967 invited interested persons to submit comments in connec-tion with the proposed amendments to establish license fees for facility construction permits, operating licenses and specific byproduct, source and special nuclear materials licenses. In accordance with Interagency Agreement No. 1019, dated September 27, 1961 the Naval Postgraduate School has not been required to pay use charges. It is therefore recommended that the connnission make additional provisions in Section 170.11 for exemptions from all the fee requirements for the facilities and materials licenses of U.S. government agencies which employ their facilities or materials primarily for training or educa-tional purposes. Sincerely,
-z::: .~ :t+~
E. M. HENRY Cormnander, U.S. Navy Reactor Administrator By direction of the Superintendent CC: Region V Operations Office Atomic Energy Conunission 2111 Bancroft Way Berkeley, Calif. 94704
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~1627 l.oNGWOl>u ingtorc, ~.QC. 20515 S uscOMMllTEE ON TERR ITO R I AL ANO IN SU LAR A F,.-AI R S SU DCOMMITTE E ON NATIONAL PARKS ANO ACCREATI O N SueCOMMITTEC OH INO IA N AFFAIAS April 24, 1967 The Honorable Glenn Seaborg, Chairman Atomic Energy Commission Washington, D.C * .

Dear Mr. Seaborg:
I enclose a copy of a letter from Dr. James J. Ball, President of the Hawaii Chapter of the Society of Nuclear Medicine, setting forth his opposition to the proposed license fees for users of radioactive
,byproduct materials.
I submit Dr. Ball's letter for the consideration of the Commission in promulgation of final rules and regulations in this matter, .and would appreciate having your comments on the points he raises. Many thanks for your attention to this request. Very truly yours, Q ~\.~'- PATSY T.. M~NK Member of Congress enclosure OOCIETED OOAEC
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~- ):/aj[lf,SS C. M ~\.. (,f G . r F~t!/,*Ari , MD JAM E.I W , CH , ** .., , MD .
ANE STH(SIOlOG Y UMARS M 6: Tlf, /.' D. JOHN C R08EPT S, M.0. ARTHUR Y, SPiU(,UE, M D. MC . M 0.
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ONOLULU, HAWAII DOCKET" NUMBEA PROPOSED RUl£ April 17, 1967 9681 J PR- !UJ,lo,"5D, 7a, 170 NEURO LOGI CAL SURGERY JOHN J l OWREY, M D. H. WM . G OE8fRf, H. M 0 . OCCU PATIONA L M tCIC tNE Honorahle Patsy Mink
& IN DUST~ IA L SURGERY tiE RHRT I( , N. LU KE, M 0 .
House of Representatives OR THOPEDIC SURGER Y Washington, D. C. Wlll!A M H. GUl I £0,:"; E, M 0 . OONAlO A . JONfS, M D. LBERT Y. T. KOIIG, JR . , M 0 .
Dear Madam:
ALA N P,WEt. M .0. OPHTH ALMOLOG Y There is a proposal in the March 11, 1967, federal Register, SHIGEMI SUG t(I, M 0 . papes 3Q95-3997, for an exceedingly high li,P.nsing fee for OT OLA RYNGOLOG Y the use of radioactive byproduct material. So useful purpose TRUETT V. BENNEfT, M 0 . 0 . C. NEW 61l l, JI!, MD. would ever he served by such a fee since th* reason to establish R. T. KAKU, M 0. licensing would be only to control the distribution and use of HER A L VASCULAR SURGfRY ROB ERT l ( tS Tt,f
M 0 .
tr.is material.
PLASTIC, R£ CON SI RU( TLVE MAXILl OFACIAL SURGERY The lic~nsini of physicians for the use of r~dioactive byproduct HOON R. ovns. M D, material woul<l seem to fall into the same ca~egory as the licen-THORACIC SURG f ~y sini of physicians for the use of narcotics. This fee is only NIALL M. SCUll 'f , M . 0 .
$1 a year and of course represents a token fee only.
U ROLOGY WAL TER S. STRODE. M 0 . E. lEE SIMM ONS, M.0. I would submit that the proposed fee is exc e ~sive and puts an
)BSTETRICS . GYNECOLOGY unnecessary financial burden on the physici.~s who must pass
OLIN C. McCO RR 1STON , M .0.
l!OONEY T. WEST, M D.
*along this type of cost to his patients. This fee, of course, fl!CATE (AQT 'f, M . D W . J , NATO l t M 0 wi 11 ult i.mately be absorbed hy insurance companies and the WllllAM t-4 M l ' Jf"I F .. ...
6 r>ver1<*.,...,enr- m1r<llt>.1l 1 n"ural"\te- pl"ogr*m. thereby rai.s1ns -t:hc. co!i't IN1E RNAL MEDICINE of med1cal service even further at a time when this is already H. l. AR NOL D, SR . , MD S. E. OOOllTTlf, MD . becoming prohihitive. l . CLAG ETT &!CK , M 0.
f. I Gll& EU , R, MD .
G. e. G,U IS, M 0
~RA~H:: J . &RUC E, M .0 . I would greatly appreciate any help you ¢ould offer with this V.lPH M . &EOOO'N , M .0 .
THV* W MILSON , JR.* M .0 . particular prohlem. JAMES J, &All , M .0 . llEGINAlO HO, M .0 .
AROIOVASCULAR DISEASE S'i.ncerely yours, ALIRE0 S. HAR TW Ell , MD.
IOWARD L. CHE SNE, M. D. .' i I DERMATOLOGY .--11:;*.:1 HAIRY l. AR NOLD JR ., MD ,
,YMONO M . WllllAMS . M. D. A 1 : James J. Ba 11, M. D.
ltOBERT KIM , M D. NEUROLOGY lj
' I President Hawaii Chapter M . M . O KIH I RO, M .D. Society of Nuclear Medicine NUCLEAR MEDICINE IOMRT A. NORD YKE. M .D. JJB: ia OOC<<ETEO PATHOLOGY C I, L TILDrn, M.0.
PED IA TRICS JOhN C. MI LNOR, M . D. W . A , MYERS, M 0 , H. M . S EXTON, M 0 . GEOl!C E M . EW ING, M D. W . f MOOR E, M.0 . JOHN *
STEPH ENSON , M . 0 .
PSYCHIATRY IOWIN , . GRAMLICH . M. D. RADIOLOGY R. G. RIGLER, M . D. 0, R. GRINI NGER, M. D. CECVTIVE ADMINISTRATOR RI01ARD M . KENNEDY >SISTANT ADM I NIST RA TOR THOMAS l . BATTISTO
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April 24, 1967 Mr. Harold L. Price Director of Regulation Atomic Energy Commission Washington, D. c. 20545
Dear Mr. Price:
Enclosed is a copy of a letter which I have received from Dr.
James J. Ball, President,* Hawaii Chapter, Society of Nuclear Medicine, with respect to the proposed fee schedule for the use of radioactive byproduct material.

Your full consideration of Dr. Ball's comments will be sincerely appreciated.
Aloha and best wishes. Spark M. Matsunaga Member of Congress Enclosure 0 USil£C 91967
])e _ 11s1.
STRAUB CLINIC GENERAL SURGERY JOSEPH E. STRODE, M.D. 888 SOUTH .KING STREET HONOLULU, HAWAII 968 ,1 3 C. M. BURGESS, M.D. G. C. HEEMAN, M. D. JAMES W, CHERRY, M. D.' ANESTHESIOLOGY ElMA RS M. BITTE, M.D.
. J_OHN C. ROBERTS, M. D.
ARTHUR Y. SPRAGUE, M.D, April 17, 1967 NEUROLOGICAL SURGERY JOHN J . LOWREY, M. D, H. WM. GOEBERT, JR., M.O. OCCUPATIONAL MEDICINE Honorable Spark M. Matsunaga
& INDUSTRIAL SURGERY HERBERT K. N. LUKE, M.O. House of Representatives ORTHOPEDIC SURGERY Washington, D. c.
WILLIAM H. GULLEDGE, M. D. DONALD A. JONES, M.D. ALBERT Y. T, KONG, JR., M. D.
Dear Sir:
ALAN PAVfl, M.0. OPHTHALMOLOGY There is a proposal in the March 11, 1967, Federal Register, SHIGEMI SUGIKI, M.D, pages 3995-3997, for an exceedingly high licensing fee for OTOLARYNGOLOGY the use of radioactive byproduct material. No useful purpose TRUETT V. BENNETT, M.O. D. C. NEWB ILL, JR. , M. D, would ever be served by such a fee since the reason to establish R. T. KAKU, M.D. licensing would be only to control the distribution and use of PERIPHERAL VASCULAR SURGERY ROBERT L. KISTNER, M.D. this material. PLASTIC, RECONSTRUCTIVE
& MAXILLOFACIAL SURGERY The licensing of physicians for the use of radioactive byproduct ELDON R. DY KES, M. D.' material would seem to fall into the same category as the licen-THORACIC SURGERY sing of physicians for the use of narcotics. This fee is only NIALL M. SCULLY, M. D. $1 a year and of course represents a token fee only.
UROLOGY WALTER 5. STRODE, M.D. E. LEE SIMMONS, M.O. I would submit that the proposed fee is excessive and puts an OBSTETRICS
GYNECOLOGY unnecessary financial burden on the physicians who must pass COLIN C. McCORRISTO N, RODNEY T. WEST, M.D.
M.D. along this type of cost to his patients. This fee, of course, FUGATE CARTY, W. J . NATOLI, M.D. M.D. will ultimately be absorbed by insurance companies and the WILLIAM H. HINDLE", M. D. government medical insurance program, thereby raising the cost INTERNAL MEDICINE of medical service even further at a time when this is already H, L. ARNOLD, SR., M.D, S. E. DOOLITTLE, M. D. becoming prohibitive. L. CLAGETT BECK, M.D.
f. I, GILBERT, JR., M.D.
G. B. GARIS, M. D. FRANK J . BRUCE, M. D. I would greatly appreciate any help yc:ucould offer with this RALPH M. BEDDOW, M.0, ARTHUR W. NEILSON, JR ., M.D. particular problem. JAMES J , BALL, M.D. REGINALD HO, M.D. CARDIOVASCULAR DISEASE Sircerel~ yours~ ALFRED S. HARTWELL, M.D. EDWARD l. CHESNE, M. D. ;'l 1/ ./ ./ DERMATOLOGY DOClETED i./ , / : HARRY l. ARNOLD, JR ., M.D. ~EC I . I . I /:/\: j.,,t, '7 /
' I ! *.
ij:.'!; . _(:___ RAYMOND M. WILLIAMS . M.D. James J .- ' Ball, M.D.--- ROBERT KIM, M. D. I NEUROLOGY
/ President, Hawaii Chapter M. M. OKIHIRO, M.D. Csociety( of Nuclear Medicine NUCLEAR MEDICINE ROBERT A. NORDYKe, M.D. JJB:ja PATHOLOGY I, L. TILDEN, M.D.
PEDIATRICS JOHN C. MILNOR, M. D. W. A, MYERS, M.D, H. M. SEXTON, M.D. GEORGE M. EWING, M. D. W. F. MOORE, M.D. JOHN R. STEPHENSON, M. 0. PSYCHIATRY / EDWIN P. GRAMLICH, M. D. RADIOLOGY R. G. RIGLER, M.D, D. R. GRININGER, M. O. EXECUTIVE ADMINISTRATOR RICHARD M. KENNEDY
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--Montana State University------------ Bozeman, Montana 59715 Tel 406-587-3121 Department of Chemistry College of Letters and Science May 4, 1967 OCKETED USIAEC Mr. W. B. McCool, Secretary 81967 U. S. Atomic Energy Commission Ice of the Secretwy Washington, D. C., 20545 l'ullllc ProC<Je~lr,:a
Dear Sir:
The Radiation Sources Committee of Montana State University, Bozeman, Montana, would like to comment on the proposed rule making, 32 F. R. 3995, concerning proposed fees. We believe that it would be unwise to institute the proposed fees. The amounts proposed are low enough and there are sufficient exceptions that the fees would not be a substantial burden to an institution like Montana State University with a broad and varied research program using radioisotopes. However, even at the proposed levels, the fees could be a substantial obstacle in the deve l opment of research programs and the educational uses of radioisotopes at smaller educational institutions. This, the proposed fees appear to be incompatible with the commission's responsibility for fostering the development of nuclear energy. The primary reason that the proposed fees would not be a substantial burden in many cases, is that the use of licensed materials in research and teaching is being supported by the Federal Government or the various states. Thus, to a large extent, the proposed fees would amount to transfers between federal agencies. Any anticipated decrease in the congressional appropriation for the A. E. C. would have to be offset by increased appropriations for N. S. F., N. I. H., etc. There would, of course, be a net loss in the administrative expenses associated with collecting the fees. We are not sure that making the A. E. C. less dependent on direct congressional appropriations is a good idea, and since the proposed fee system has manifest disadvantages, we are opposed to it in its entirety.
Mr. W. B. McCool Page 2 May 4, 1967 The fees propo sed for power reactors are more easi ly justified, but we are not sure that even these are warranted. Anyone operating a nuclear reactor must be financially responsible for whatever expenses are necessary to keep it safe. The regulatory function of the A. E. C. is design ed to see that safe practices are maintained, but it would be unwise to let a situation develop in which the regulatory authority is financially dependent upon the industry it regulates. Sincerely, aaJ;ti a~ Dr. Ralph Ols en Chairman, Radiation Sources Committee Dr. Reed Rowald Connnittee Secretary and Radiological Safety Officer RH/sb cc: Senator M. Mansfield Congressman A. Olsen
.Protection - Systems Inc. -
DOCKET NUMBER BROP.Oifll iw.£ PR-go,t~ 7", 5"~, I fO 2450 W. WEW ST. MILWAUKEE, WISC. 53231 TEL. 342-5300 140 ADELLA BE. NEENAH, WISC. 54956 TEL. 722-1102 oecretary Uni te 'tc...T,es .ntomic .C::nergy ommi ss ion ashin 6 t on D. C. 20:A5 De&r Sir: rteference is mude to 1 tter of y our office dated
~<.l.I'ch l? , 1967 , titled l otice to A. B. C. Lic ensees , and signed b -r . naro l a. L . - rice , Director of Re gul ations . lurs u ant to this we offer our co mment .
e are dist ributors of* yr-A-Larru d et ecto rs . The yr- -L rm a. et e ctor which we furnish and i nst<.J.11 under t he system trade nc:JI1e of ~yr-a -Larm are furnished to us by Fyro-tronics , nc ., 2343 1orri s venu e , Uni on , -ew J ersey .
- rote c tion bystems , Inc . are licensed by the Atomic Ener-y Commission for the t r ansfer , handlinb and servicin 0 o *
r- - Larm detectors within the .t1. . E . C. regulc..1.tions covering these devices . e assume th&.t the licens i ng of di stributors s eciiic licensees as ours lves shcill come under Category 1 of the referenced ro osed licens ing and fee re gul at ions .
erha**s a summo.ry of our ex erience s and r eaction as on licensee ma.y ave s ome meri t for ~-our cons i deration . v.e are re~resent c.. tives O L o~her first line fire a l arm
&nd y l ant rotection s *stem;:, . It \ c-S a *}!arent that we *rrnul d need a "su r - sen.J itive " ty e of fire detec tion device of su erior ~ualit ana. reliab ility , d much faster than the conventi on1:,l heo. t a.etcction device s . ,;e i nvestig'-' ted all ty* s of s oke detection and so c c-ll ed fire gas d etection devices and found th~t the only one av a il ~ble at the ~ime to be fully a.de uate and reli Gb l e was the ~y r - A-Larm detector .
I-age 2 United ctates 1. tomic iliergy Commission ,fay 5 , 1967
.le a J!lied for and were acce ....Jl; ed to re:._ resent .i.yro-tronics , Inc . as a -yr- A-L~rm distributor . It then be c ame a
2.r ent that we had taken on a product tha t required A. -.-. . C.
licens i n 6 , which a lso re uired s -ecial trc.-. ining and satis-f..... ctory com..:-11 tion or' examinations . li.ccordin 6 ly four ( 4) of our .J:-iersonnel h:::..ve attended cl c:.sses conducted by lyrotonics , Inc . so thdt eac h coul~ h&ndle and service the r - A-Larm etectors . Our cost to tde t~'lis tr'--'-inin 0 to be licensed by A * .c. . C. hc.-s aver~15ed ubou-c ;500 . 00 er man for wage s , travel and lod6in, or a totc.l of about J2 , 000 . 00 . Com~etitors offerin6 inferior fire detection detectors
&dvise clients as to the restrictions when usin 6 lyr-l-L'rm detectors cont a ining r c;.dioactive materi~l . Thu s we find th<-.t o,,ners , arch itects and en ineers 1hen a 11 rized of the 0
restrictions , licensin 0 , etc . re the lyr-A-Larm detectors c;...re more concerned &nd cautious in s~ecifying this e~ui ment . It h'----s been inf erred *co us by persons knovJled eable in radioactive materials that th concentr ~~ion of radioactive materic;.l.s in the - yr-.t. -Lc1.rm dete ctors i s of a ver 101,, order . This did not include -ers onnel of *yrotronics, Inc . m8-king these st ~teuents . It would al:' ear to us als o thc:..t other organiz at ions that illc;. cons i der the devel opment of detectors that may em~loy minute uantity of radioactive filateridls and be com etitive to Pyr-.A- Larm ma feel restra i ned by the * ** C. regulations ana thus not cons ider such develoi,ment a:rzy further . here i s a definite need for broader application of detectors such 2.s the J:-:y-r-A-Larm fire as and smoke detector for life s afety in buildin~s and for critically im ort ant control centers . 'l1he need in many c 2.ses i s extremely cri tic 2.l ,
* &rticul &rly for ltfe safety . Yet the a~plic ation is limited and we are findin5 i t difficult to gain acce- tance due in part to the A. L. C. regulations ~s outlined ab ove . Thus the A* .t: . C. regulations do tend to restrain and to inhibit the a~- lic at ion of this excellent detector , articul arly for life Sc;...fety .
Page 3 Uni~e otates tomic Lnergy Commission Viay 5, 1967 rtdther than to cons i r regQl at ions and licensins that sha ll be more restrictive and more co st ly , erha:ps it may be a11,ropriG.t;e to review the pre s ent regul a tions and determine i f the r adi oa ctive ma teri ~l s as are used in Pyr- -Lurm detec-tors , or as mcty be used bj others in simil &r devices , are of such a lo w order tha t t he regulat ions may be modified to
, ermit a broader a
lic ation of these and similar devices for f ire ~rotection anQ life safety .
Obvious ly we are Ofl_osed to any licensing fee . e feel that our costs to have ersonnel attend cla ss for a week for trainin 6 in the 1 . E. C. regul &tions and for A. ~ . C. 1icensin6 to bes fficient , if not excess ive costs . ecently Je were examined by a represent a tive of your office . le 'iere illi.i:'ressed by n i s dili , ence , t h orough-ness and sincerity . ."e .iere es iven a~i.Jrovc.l tha t "\"J e were conformin 6 to t he regul a tions . we shall con tinue .
, 'e tho.nk you for t hi s op . _ ortuni ty to exliress our o inion on ~ro~osed r egul ~t ions before such regulations be-come l a w.
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