JPN-91-021, Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments. Approx 300% Increase in NRC Fees for FY91 Will Have Major Impact Upon Operating & Maint Budgets of Plants

Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments. Approx 300% Increase in NRC Fees for FY91 Will Have Major Impact Upon Operating & Maint Budgets of Plants

ML20077C478
Person / Time
Site:	Indian Point, FitzPatrick
Issue date:	05/13/1991
From:	Ralph Beedle POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-56FR14870, RULE-PR-170, RULE-PR-171, RULE-PR-71 56FR14870-00408, 56FR14870-408, IPN-91-018, IPN-91-18, JPN-91-021, JPN-91-21, NUDOCS 9105210432
Download: ML20077C478 (2)

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& Authority 31 Mt,': 16 P::v. L =:g;r-May 13,1991 lPN 91018 JPN 91-021 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing and Service Branch -

Subject:

Indian Point 3 Nuclear Pcwor Plant .

Docket No.50 286 James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Comments on Proposed Rule Revision of Fee Schedules; 100% Fee Recovery

Dear Sir:

On April 12,1991, the Nuclear Regulatory Commission (*NRC") published the proposed changes to its licensing, inspection, and annual fee schedules in the Federal Register. The proposed changes to 10 CFR Parts 71,170, and 171 were aimed at recovering 100% of the NRC budget authority for fiscal years 1991 through 1995. Written comments were requested to be submitted by May 13,1991.

The Power Authority fully endorses the comments submitted by the Nuclear Management and Resources Council, Inc. ("NUMARC") concoming the Proposed Rule on Revision of Fee Schedules, in addition to the NUMARC comments, the following specific comments are provided. It is j in the public interest to have periodic reporting of NRC expenditures and variances between expenditures and budgeted costs at the program element level. Also, the NRC budget j preparation process should include opportunities for public comment. At the start of the planning and budget cycle, the Commission should draw upon utility industry expertise to assess the cost-I effectiveness of proposed generic programs and to eliminate potential duplication of industry-sponsored programs. An advisory committee of industry executives, for example, could draw upon years of operational experience to provide applicable industry perspective on proposed programs.

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In addition, the approximately 300% increase in NRC fees for fiscal year 1991 will have a major impact upon the operating and maintenance (O&M) budgets of the Indian Point 3 and James A. FitzPatrick nuclear power plants. Fiscal year 1991 NRC fees would account for approumately 4.2% of the total O&M budget. Certain plant betterment improvements will have to be deferred.

If you have any questions regarding this matter, please contact Mr. P. Kokolakis or Mr. J. A.

Gray Jr. of my staff.

Very trulyyours,

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Ralph E. Beedle Executive Vice President Nuclear Generation cc: U. S. Nuclear Regulatory Commission 475 Alleridaic Road King of Prussia, PA 19406 Resident Inspector's Office indian Po;nt 3 U.S. Nuclear Regulatory Commission P.O. Box 337 Buchanan, New York 10511 Office of the Resident incpector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, New York 13093 Mr. Francis J. Williams Jr.. Project Manager Project Directorate 11 Division of Reactor Projects I/II U.S. Nuclear Regulatory Commission Mail Stop 1482 Washington, D.C. 20555 Mr. Brian C. McCabe Project Directorate 11 Division of Reactor Projects 1/11 U.S. Nuclear Regulatory Cornmission Mail Stop 1482 Washington, D.C. 20555