ML20188A223
| ML20188A223 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 06/24/2020 |
| From: | Slaughter D Aerotest |
| To: | Clay Johnson Document Control Desk, Office of Nuclear Reactor Regulation, NRC/OCFO |
| Shared Package | |
| ML20188A221 | List: |
| References | |
| LFB-1849 | |
| Download: ML20188A223 (3) | |
Text
.,
AEROTEST OPERATIONS, INC.
3455 FOSTORIA WAY
- SAN RAMON CA 94583 * (925) 866-1212
- FAX (925) 866-1716 i'vlan:h 30. 2020 ATTN: Dol'llllK'nt Control Desk
( 'hcrish K Johnson. Chief Finanl:'ial Officer U.S. Nuclear Regulatory Commission White Flint North 11555 Rockville Pike Rockvilk, MD 20852-2738 Docket: 50-228: ~lL20073E 1-B March 13. 2020 letter regarding fees assed from Cherish K Johnson, CFO: May I. 20 ! 9 letter disputing fees from Aerotest Operations to Maureen E. Wylie. CFO:
rvILl 9079A245 Letter Dispute offees from Maureen E. Wylie. CFO: MLI 9030A58 l January 22, 20 I 9 Letter Dispute of Fecs to Maureen E. Wylie. CFO; IVILI 9065A048 February 28. 2019 Dispuh: off.;es to Maureen E. Wylie
Dear Cherish K Johnson,
Thank you for the infonuation that you providC'd on Invoice LFB 20-1849 Dated January 15, 2020
$24,047.00 for time billed to us by Geoff~ry A Wentz, Sara E Reed, John T Nguyen and Michael Norris, on NRC 527 fom1s and in your Letter. I already knew that they were working on the review of Aerotesfs Possession only license amendment request (LAR) and audit prcfonned in December 2019. I was looking for detailed infom1ation like travel time, time spend on researching specific items associated with the audit, as the amount of time at our facility, doing the audit was just a brief half day compared to longer prior audits.
I am questioning the validity and reason for the actual on-site audit based on statements that Geoffrey A Wentz and Sara Reed made. You can review tv!L20049A040 February 26, 2020 Response to December 11, 2019 Audit repmt. Two Items that were said in the initial meeting purpose, "gaining a better understanding of the storage locations of the NRC title 10 ... Part 50" ... licensed materials"'. Also, they referenced only 1976. 2005, and 2018 Security Plans and were unaware of other NRC approved security plans including the implemented plan at the last security audit (MLI 2264A000 9/26/12).
The infonnation they were seeking in the recent audit was already available in prior inspections and security audits performed by the NRC inspector Craig Basset. While this audit was communicated to me as a means to better focus the RAis that may be needed in evaluating the LAR. The audit ,vas performed in a half day. When I received the communication requesting additional infonnation, I was asked for information, fuel related questions that could have been easily provided to the NRC staff during the audit i.e., details of description of fuel canisters and floor racks. By the way, the same infonnation that was provided to NRC staff at numerous other times.
This suggests that the audit team ,vas unprepared for their visit or I was misled to the purpose of the audit.
Neither the security audit or LAR audit provided ne\v meaningful infonuation to the NRC Staff or to us.
The cost charged to AO for the audit provided no value and we would request a credit of the charges associated with the LAR audit. The details provided by your office does not allow me to estimate the disputed charges. Please provide an estimate.
In 1 titir ktkr 1 ou said that i\'lr. Ng.u1 en and i-.lr. Ntlrris's charges rdat<.! to re\ie\\ ofi\erotest"s operator licensing and emergency planning as the) pertain to the !AR. I no longer lul\ e operators and send in documents fur our certificated fud handlers: perhaps you meant that. Our AO emergency plan associated with the LAR has just heen submitted on !\larch 26. 2020 sn I am not surt:: what they were reviewing.
Y nu indicated that the dday in responding wa,; due to invalid .::mail addresses: ,, e sent our request to s.::veral difforent emails based on .::mails contact information on prior NRC invoices. '.'Jo inrnlid email returned and no response from any of the email., contacted. They im:ludcd '-=-=-"~"""
I would also like to point out that nut all ofmy correspondence has been posted on ADAI\IS. I could not find our ktt.:r disputing fees dated \lay I.2019 i-.laureen E. \Vylie. CFO. which is attach.::d with documentation that it was received b1 the NRC.
I declare under penalty of perjury that the statements made in the enclosures are correct and truthful to the best of my knowledge.
Should you have any questions or require additional information regarding this submission, please contact AO President David M. Slaughter. Ph.D. at (80 I) 631 5919 or dmsrav.:n(a gmail.com Respectfully.
Davi M Slaughter,~
President, Reactor Administrator, General Manager and Manager
AEROTEST OPERATIONS, INC.
\Tl:',;: [)1>\.'.Ullh.:111 (',,t11r,i/ lk:;k
- \[aun.
- cn I Wyli,:. Chief I inaticial ( lfli..:.:r
{ 1.S '.\'uckar Rcgubt.,r:, ( nnnni,-;i.,11 White Flint i\,,rth 11555 R,1..:bilk P1kt:
RPcbillc i\far:,hllld 21H52-2737 Thank for y\lUr rt:sp,Hbe (~RC ktter dakd April 18, 2019) to my Januar::,. 22, 2019 ldter n.:qu..:sting rt:imburst:ment ofS2.4::l2.6's2.3 l (Agency wide Document::; Access and t\lanag..:111<.:nt System (:\D.-\~!S)
.-\ccessinn J\i"o. i\lf. l 9030:\581 ). and subsequent ktt-:r dated February 2S. 2019 ( ,\D. \MS Access inn 1',;,1.
l\l!. I 9065AO-l-S l. inquiring abt)llt th,;: status of a response to th,;: January letter.
In my January 22. 2019, I statcJ the reason for the rcimhursemcm \\ a:; because i\R(..' sen ices were nnt perfom1cd in a satisfactory manner. This indmlc!J inexcu:rnbly hmg ddays that became cost prohihitive even f\)r a large c1.1111pany kt al,me a small business to continue to pay. Lo,Jking at NRC docum,;:nt::; and in:;p,;:,::tion:; it ::;lww::; this reactl)r is in compliance with NRC regulations. rules and procedures. In reality, this reactor's operations looked nothing like what the NRC shows in its paper trail. Our procedure:;, rules, policies. and tech spe,::s are out-of-date and not incompliance with the current regulation:,;. Yet, the NRC employe,;:s signed documents and reports showing it's \Vas in compliance.
My staff is in the pt\),;es:; of organi1ing th-: sp,xifo.: details tn shcm the NRC costs associated\\ ith the d\),::uments that arc! not incomplianc-: \\ ith the NRC regulatinns \.\.hich th-: NRC signc:d off as in compliance. We are referencing 42 USC 2214 -NRC user fee:; and annual charges and 3 [ USC 9701 Fees and charges for government servke and things of value as the! rea:;on for my reimbursement request.
B,..1th codes both say that fees need to be fair and pro\ide value to recipient. [ foe[ that the charges for the NRC employe-:'s rubber stamping the NRC Documents to say thi::; reactor was in compliance has no value to me. If I were to continue with the restart, I would have to repay for the submission of the documents that were already deemed to be in compliance.
I declare umkr penalty of perjury that the statements made in the enclo:iures are correct and truthful to the best of my knowledge .
. - .-(L"\--
Da\ic1 M Slaughter. PhD President, Readnr Administrator, and Manager cc. U.S. Nuclear Regulatory Commission Office! of inspector Ckneral