ML040700518
| ML040700518 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Watts Bar, Sequoyah  |
| Issue date: | 03/03/2004 |
| From: | Burzynski M Tennessee Valley Authority |
| To: | NRC/SECY/RAS |
| Ngbea E S | |
| References | |
| +adjud/ruledam200505, 69FR04865 00010, PR-170, PR-171 | |
| Download: ML040700518 (2) | |
Text
DOCKETED USNRC (jm/
March 5, 2004 (2:45PM) rI CaOFFICE OF SECRETARY RULEMAKINGS AND Tennessee Valley Authority. 1101 Market Street, Chattanooga, Tennessee 37402-2801 ADJUDICATIONS STAFF March 3, 2004 Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attention: Rule Making and Adjudication Staff Ladies/Gentlemen:
TENNESSEE VALLEY AUTHORITY (TVA) - COMMENTS ON PROPOSED RULE -
REVISION OF FEE SCHEDULES; FEE RECOVER YFOR FISCAL YEAR 2004 (VOLUME 69, NO. 4865, FEDERAL REGISTER, DATED FEBRUARY 2,2004)
TVA submits the following comments on the Nuclear Regulatory Commission's proposed rule, Revision of Fee Schedules; Fee RecoveryforFY2004 (69 Federal Register 4865). TVA believes that NRC should charge licensees only for expenditures related to licensee activities and reduce the agency's overall budget through more efficient decision making and use of resources. In general, TVA supports the comments on the proposed fee schedule provided by the Nuclear Energy Institute.
Specifically, TVA believes that support for homeland security activities should be funded through the general treasury because homeland security related to nuclear power plants is fundamentally part of the nation's responsibility to protect its critical infrastructure. In addition, WVA questions the long-term need to increase NRC staff resources being applied to security, to approximately 140 full time equivalent employees (FTEs). TVA recognizes the short-term need for additional resources for the review of revised security plans required by the April 2003 order; however, once the security plans are reviewed and inspected, the number of FTEs allocated to security should drop to a staffing level much closer to what existed prior to the September 11, 2001, incidents.
TVA also notes that there is a disproportionate allocation of NRC expenditures recovered through 10 CFR Part 171. Approximately 74 percent of the NRC's budget is recovered through 10 CFR Part 171 and only 26 percent under the discrete fee provisions of 10 CFR Part 170. In effect, NRC has only identified 26 percent of its expenditures as directly supporting its licensees. The aggregation of a substantial portion of non-discrete expenditures does not support strong fiscal oversight and makes it virtually impossible for TVA to realistically determine whether resources are being appropriately applied to NRC activities. Consistent with the notice and comment rulemaking provisions of the Administrative Procedure Act, stakeholders should be told the costs associated with each component of reactor regulation and all other generic costs in sufficient detail to enable them to provide meaningful comment.
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U.S. Nuclear Regulatory Commission Page 2 March 3, 2004 Thank you for the opportunity to submit comments on this subject.
Sincerely, Mark urzynski Manager Nuclear Licensing cc:
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001