ML031290146

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Comment (23) Submitted by Arizona Public Service, Gregg R. Overbeck, on Proposed Rule PR- 170 & PR-171 Re Revision of Fee Schedules; Recovery for Fy 2003
ML031290146
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 05/01/2003
From: Overbeck G
Arizona Public Service Co
To:
NRC/SECY/RAS
Ngbea E S
References
+adjud/ruledam200505, 102-04937-GRO/TNW/RKR, 68FR16374 00023, PR-170, PR-171
Download: ML031290146 (2)


Text

,iL:-I-A 68 FR 16374 Gregg R. Overbeck Mail Station 7602 Palo Verde Nuclear Senior Vice President TEL (623) 393-5148 P.O. Box 52034 Generating Station Nuclear FAX (623) 393-6077 Phoenix, AZ 85072-2034 102-04937-G RO/TNW/RKR DOGCWKW May 1, 2003 PROPOSM 'I DOCKETED U. S. Nuclear Regulatory Commission USNRC ATTN: Rulemaking and Adjudications Staff May 8, 2003 (11:11AM)

Secretary, U. S. Nuclear Regulatory Commission OFFICE OF SECRETARY Washington, DC 20555-0001 RULEMAKINGS AND ADJUDICATIONS STAFF

Dear Sirs:

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2 and 3 Docket Nos. STN 50-528/529/530 Comments on Proposed Rule to Revise Fee Schedules (68 FR 16374)

Arizona Public Service (APS) has reviewed the Nuclear Regulatory Commission's (NRC) proposed rule to revise fee schedules as published in the Federal Register on April 3, 2003 (68 FR 16374). APS endorses the comments submitted by the Nuclear Energy Institute (NEI) and Strategic Teaming and Resource Sharing (STARS).

APS understands the concept and regulation for NRC cost recovery through Licensee fee allocation. However, APS believes that there should be some specific accountability and reasonableness in that assessment. Therefore, the inclusion of security issues into the fee base when some of the financial responsibility lies within other governmental jurisdiction is unacceptable. In the same manner, many of the efficiencies gained from the current regulatory environment should also be reflected. APS also believes, as noted in the NEI letter, that better cost explanations for evaluation by licensees and stakeholders should be provided. Therefore, APS encourages the NRC to consider NEI's comments and recommendations.

Should you have any questions, please contact Thomas N. Weber (623) 393-5764.

Sincerely, G RO/TNW/RKR/kg ",eeoxf/I /

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

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U. S. Nuclear Regulatory Commission ATTN: Rulemaking and Adjudications Staff Comments on Proposed Rule to Revise Fee Schedules (67 FR 14818)

Page 2 cc: E. W. Merschoff J. N. Donohew N. L. Salgado Senator John McCain Senator Jon Kyl Robert Aiken