ML040700511
| ML040700511 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/03/2004 |
| From: | Mecredy R Rochester Gas & Electric Corp |
| To: | NRC/SECY/RAS |
| Ngbea E S | |
| References | |
| +adjud/ruledam200505, 69FR04865 00009, PR-170, PR-171 | |
| Download: ML040700511 (2) | |
Text
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5 Robert C. Mecredy Vice President Nuclear Operations DOCKETED USNRC March 5, 2004 (9:52AM)
OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF March 3, 2004 Secretary U.S. Nuclear Regulatory Commission ANTN: Rulemakings and Adjudication Staff Washington, DC 20555
Subject:
PFroposed Rule: Revision of Fee Schedules; Fee Recovery for FY2004 (69 Federal Register 4865, February 2, 2004)
R. E. Ginna Nuclear Power Plant Docket No. 50-244
Reference:
Letter from Stephen D. Floyd, Nuclear Energy Institute (NEI), to Secretary, USNRC, dated March 3, 2004 Gentlemen:
Rochester Gas and Electric Corporation (RG&E), license holder for the R.E. Ginna Nuclear Power Plant (or Ginna Station), 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 2004. In addition, RG&E would like to offer the following specific comments.
The proposed changes to 10 CFR Part 171 would increase the annual fees for Ginna Station from
$3,251,000 to $3,342,000, an increase of $91,000 or almost 3%. A large reason for the increase in annual fees is attributed to homeland security activities ($51.1 million budgeted, an increase of
$15.7 million from 2003). 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 2004 is $626.1 million. This is an increase of $41.5 million from 2003 and $138.8 million since 2001. While the NRC's obligation to recover its budget authority through fees decreases each year by 2% of the total authority (the current recovery is 92%), the total budget increase has more than offset this decrease. Further, only 26% of the 2004 fiscal year budget is recovered under 10 CFR Part 170 as discrete fees.
The remainder of the budget authority (74%) 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 (585) 546-2700 www.rge.com Tremptla e =rSEC -V O 6 7 5EC-t05F-An Energy East Company
Thank you for the opportunity to submit comments 6nthis matter.
Very truly yours, Robert C. Mecredy MDF/313 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 1000956