0CAN088804, Comment Opposing Proposed Rules 10CFR170 & 171 Re License & Annual Fees.Nrc Portion of Cooperative Programs Should Be Taken from Remaining 55% of Funds Appropriated by Congress

Comment Opposing Proposed Rules 10CFR170 & 171 Re License & Annual Fees.Nrc Portion of Cooperative Programs Should Be Taken from Remaining 55% of Funds Appropriated by Congress

ML20151R826
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/04/1988
From:	Howard D ARKANSAS POWER & LIGHT CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR24077, RULE-PR-170, RULE-PR-171 0CAN088804, 53FR24077-00029, 53FR24077-29, AC80-2-45, CAN88804, NUDOCS 8808120316
Download: ML20151R826 (2)

Text

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29 ARKANSAS POWER & LIGHT COMPANg Aug -8 P 4 '.09 August 4, 1988 , . .

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0CAN088804 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station P1-137 Washington, D.C. 20555 ATTN: Mr. Samuel J. Chilk Secretary of the Commission

SUBJECT:

Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Proposed Revision to 10CFR170 and 171 on License and Annual Fees

Dear Mr. Chilk:

Arkansas Power and Light Company (AP&L) has reviewed the proposed revision to 10CFR170 and 171 and has the following comments:

1 In the analysis of legislation on Section II, it is explained that in I computing tne 45% of costs to be collected, "assessments" will be 1 included or credited. However, it is stated that monies received for I cooperative research programs are not considered assessments and, therefore, should not be credited toward the utility's annual fee. We  ;

agree in principle with the logic described. However, if the NRC '

funded portion of a conperative research program is allocated back to the industry, then the program is not cooperative in this regard. l Therefore, the NRC portion of cooperative programs should be taken from '

the remaining 55% of the funds appropriated by Congress.

The B&W Owners are currently considering joint funding of a cooperative research program with NRC. Any agreement so reached is meaningless if the NRC assesses their portion in entirety back to the Licensees. If the rule, as stated, is not altered to address this concern, the future of any cooperative program must be reconsidered in light of the obvious economic implications for the utility.

Also, under the Part 171 fee breakdown for B&W units, the "Continuing Experimental Capability" is listed. It is our understanding that this 8808120316 880804 PDR PR 170 53FR24077 PDR D5/0 MEMBE A MOOLE SCUTH UTittTiE9 SYSTEM

Samuel J. Chilk August 4,1988 '

l project was to represent a testing /research facility applicable to GE, CE, Westinghouse, and B&W reactors. Therefore, the costs should be divided accordingly.

We thank you for the opportunity of commenting on this proposed ' rule change and hope you will take our com:nents into consideration.

ours, Very truly y/

Dan R. Howard Manager, Licensing DRH:MCS:de

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