ML17298B949
| ML17298B949 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/11/1985 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Miller W NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| ANPP-32113-EEVB, NUDOCS 8503140324 | |
| Download: ML17298B949 (6) | |
Text
REGULATOR INFORMATION DISTRIBUTION 5 EM (RIDS)
ACCESSION NBR:850 FACIL:STN 50-528 STN"50"529 STN 50 530 AUTH SHAME VAN BRUNTpE,ED REC IP. NAME MII LERi N ~ O ~
3140324 DOC ~ DATE! 85/03/11 NOTARIZED:, NO Palo Verde Nuclear Stationi Un) t 1r Arizona Publ i Pal o Verde Nuclear Stations Unit 2~
Ar izona Publ i Pa) o Ver de Nuclear Station~
Unit 3~ Arizona Pub l i AUTHOR AFFILIATION Arizona Public Service Co.
RECIPIENT AFFIl IATION License Fee Management Branch DOCKET 05000528 05000529 05000530
SUBJECT:
Protest payment of license fees. Requests r efund of portions found excessive
~ Conference to discuss resolution of pr otests 8 requests for refund requested.
DISTRIBUTION CODEX'008D COPIES RECEIVED:LTR ENCL SIZE+
TITLE: License Fees NOTES:Standardized plant.
OL: 1 2/31/8'tandardized plant.
Standardized plant ~
05000528 05000529 05000530 RECIPIENT ID CODE/NAME NRR LB3 BC 00 COPIES LTTR ENCL REC IP IENT ID CODE/NAME LICITRAtE 01 COPIES LTTR ENCL INTERNAL: ADM/LFMB EXTERNAL: LPDR 06 03>>
REG FILE 04 NRC PDR 02 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 6
ENCL
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Arizona Nuclear Pomer Project P.o. BOX 52034 o
PHOENIX, ARIZONA85072-2034 ANPP-32113-EEVB/WFQ March 11, 1985 William 0. Miller, Chief Licensee Fee Management Branch Office of Administration United States Nuclear Regulatory Commission Washington, D.C.
20655
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
RECEl'/E0 Units 1, 2, and 3
Docket Nos.
STN 50-528(License No. NPF-34)/529/53P Operating License Fee Assessment
'85 NlR ]p p);3g File: 85-056-026 G.l.01.10
Dear Mr. Miller:
U.S. N.R.C.
t IC.FEE AGENT. BRAN We have this day paid by wire transfer the NRC invoices, Nos.
- D0188, D0189, and D0190, for license fees for Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3, respectively, in the following amounts:
PVNGS Unit 1
$2,550,294.00 PVNGS Unit 2 433,415.00 PVNGS Unit 3 408,352.00 We make such payments under protest and request a refund of such portions thereof as may ultimately be found to have been excessive for any reason.
The bases upon which such protest and request are as follows:
(1) The billing for licensing services by each of the invoices is excessive, because it exceeds the maximum limit imposed by 10 CFR Part 170 for licensing services in effect during the period when such licensing services were provided by the NRC.
The failure of NRC to apply the maximum limits set by 10 CFR Part 170 prior to the revisions of such Part 170 effective June 18, 1984 constitutes improper retroactive application of the revised fee schedule.
A (2) Documentation accompanying such invoices is insufficient to establish the validity of the amounts billed.
Accordingly, pending completion of audits or other reviews which demonstrate the propriety of the billings, it is asserted on information and belief that the invoiced amounts are excessive.
Making the payments under protest and subject to the request for refund is made purposely to obviate any action which might be taken pursuant to 10 CFR $170.41 for failure to pay prescribed fees and the assessment of interest for delay in pay-ment of amounts which are not excessive.
In order to expedite the resolution of our protests and request for refunds, we request that a conference with you and others at NRC knowledgeable in such matters, be scheduled to discuss the issues we have raised herein.
8503140324 85031.1 PDR ADOCK 05000528 P
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Mz". ddilliam 0. Miller Operating License Fee Assessment P-'2113 Page 2
If you have any information that is relevant to such issues which you wish to provide to us in the interest of making such conference more productive or unnecessary, we would be pleased to consider it.
Very truly yours,
~Vc
/~g Executive Vice President Project Director EEVB/WFQ/mb
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