ML031320141
| ML031320141 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/09/2003 |
| From: | Widay J Rochester Gas & Electric Corp |
| To: | NRC/SECY/RAS |
| Ngbea E S | |
| References | |
| +adjud/ruledam200505, 68FR16374 00024, PR-170, PR-171 | |
| Download: ML031320141 (2) | |
Text
Joseph A. Widay Vice President and PlantManage 0 DOCKETED USNRC May 9, 2003 Secretary U.S. Nuclear Regulatory.Commission ATTN: Rulernakings and Adjudication Staff Washington, DC 20555
Subject:
Reference:
May 9, 2003 (2:58PM)
OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF Proposed Rule: Revision of Fee Schedules; Fee Recoveryfor FY2003 (68 Federal Register 16374, April 3, 2003)
R. E. Ginna Nuclear Power Plant Docket No. 50-244 Letter from Stephen D. Floyd, Nuclear Energy Institute (NEI), to Secretary, USNRC, dated May 2, 2003 Gentlemen:
Rochester Gas and Electric Corporation (RG&E), license holder for the R.E. Ginna Nuclear Power Plant (or Ginna Stations, would like to take this opportunity to endorse the Nuclear Energy Institute (NEI) letter referenced above with respect to the proposed NRC fee recovery for fiscal year 2003. In addition, RG&E would like to offer the following specific cornments.
The proposed changes to 10 CFR Part 171 would increase the annual fees for Ginna Station from
$2,849,000 to $3,278,000, an increase of $429,000 or 15%. A large reason for this increase is attributed to homeland security activities ($29.3 million budgeted). It is both NEI's and RG&E's position that these costs should be funded through the general treasury as part of the nation's protection of critical infrastructure. Other industries within the United States are not burdened with these type of costs and neither should nuclear power plants.
Also, the NRC's total budget authority for fiscal year 2003 is $584.6 million. This is an increase of $26 million from 2002 and $97.3 milion since 2001. While the NRC's obligation to recover its budget authority through fees decreases each year by 2% (the current recovery is 94%), only 24% of the 2003 fiscal year budget is recovered under 10 CFR Part 170 as discrete fees. The remainder of the budget authority (76%) is obtained through annual fees to license holders like RG&E. It is inaccurate to assume that the large majority of these budget increases are not directly related to licensees and should therefore only be recovered through general annual fees.
These costs should instead be allocated to the individual licensees to provide accountability of these activities.
An equal opportunity employer 89 East Avenue I Rochester, NY 14649 tel (5 B 5 pJ00 wW.e.con I
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.5ACY Erast Company Always at Your Servfce --
- D 17~~~R'1 7 (68 FR 3 1 1)
Thank you for the opportunity to submit comments on this matter.
Very truly yours, Qep tsp A. Widay MDF/291 xc:
The Honorable Charles E. Schumer United States Senate 313 Hart Senate Building Washington, DC 20510 The Honorable Hillary Rodham Clinton United States Senate 476 Russell Senate Office Building Washington, DC 20510 Mr. Stephen D. Floyd Nuclear Energy Institute 1776 I Street, NW Suite 400 Washington, DC 20006-3708 1000728