ML20023C126
| ML20023C126 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 05/03/1983 |
| From: | Miller W NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Lentine F COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8305110144 | |
| Download: ML20023C126 (2) | |
Text
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1 MAY 0 3 1983 Docket Nos. 50-295 and 50-304 Commonwealth Edison Company ATTN: Mr. F. G. Lentine Nuclear Licensing Administrator Post Office Box 767 Chicago, Illinois 60690 Gentlemen:
Thank you for your letter dated March 18, 1983, which provided your basis for not paying the requested additional $2,800 for your November 7,1980 application regarding assurance of redundancy in the decay heat removal capability of the Zion units. Your letter:
(a) stated that in issuance of the license amendments on June 22, 1981, the NRC consolidated two previous applications (May 23, 1980 (operable) and November 7, 1980) for which $3,200 was paid, and since these applications were basically as provided in the model Technical Specifications (TS), it is difficult to understand how the NRC's actual costs exceeded the $3,200 that was paid, l
(b) caquested an itemized bill of actual costs, and (c) stated that it was your position that the review for your November 7 application, as well as the May 23 application, was adminstrative and pro forma in nature since you essentially followed the model TS.
In connection with item (a) above, the following information is provided l
for clarification. The Class III fee assessed in our letter dated December 29, 1982, was for your November 7, 1980 application and not for I
the license amendments issued June 22,1981, that approved the May and l
November applications. Although these applications were approved by a single amendment, they were received and reviewed as separate applications.
The May 23 application was determined to be administrative and pro forma while the November 7 application was determined to be more than adeinis-trative in nature.
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8305110144 830503
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PDR ADOCK 05000295 P
PDR omcs >
l smuan cava >
INRCFORM 318 (10-80) N RCM 0 240
' OFFICI AL. RECORD CO"Y
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. MAY 0 3 1983 i
The fees in 10 CFR 170.22 are not based on the number of amendments issued, but rather on each application filed and the complexity of the request. A single application might be completed by the issuance of more than one amendment and/or a single amendment may be issued to include more than one completed application. Also, the flat fees in the current 10 CFR 170 are based on the average cost to process an application with a recognition that some applications for license amendments and other approvals will be below the average cost while others will exceed the average cost. Under the pro-posed Part 170 revisions, the proposed amendment fees will be based on the actual cost of the review. As stated in the p.oposed revision, the total cost will include the professional staff hours expended for the review of the application and any associated contractual services costs.
Since the flat fees assessed under the current regulations are determined i
by the complexity of the application, and since our letter of December 29
[
pertained to the November 7 application, the cooments that follow are ap-plicable to the November application. These comments are in response to concerns (b) and (c) referred to in the first paragraph of this letter.
(a) Since professional staff hours are maintained and available in the NRC tracking system, we are pleased to provide the time expended for the review of your November application. The total professional staff hours expended were 78. As you know, the proposed rule lists a rate of $62 per professional hour to be assessed for work done by the ONRR review staff based on the Commission's FY 1981 costs. Thus, the cost of the review of the November application amounted to $4,836.
(b) The ONRR review staff agree that the TS for Zion 1 and 2 were essentially the same as the model provided to you. However, they do not agree that the review performed was administrative or pro forma in nature. On this basis, it is still their posi-t tion that Classes III and I fees are appropriate for the Zion units. These fees are consistent with what has been assessed other licensees for a.similar change. Therefore, the $2,800 is due the NRC for your November 7 application.
We hope that this letter is responsive to all your concerns. -If further information is desired, please let us know.
DISTRIBUTION:
Sincerely, PDR LPDR
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as e, s. Jepsi nouswer. Jr-Regulatory Docket (016)V
[0g D. Wigginton, ORB-1
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C. Parrish, ORB-1 William 0. Miller, Chief R. M. Diggs, LFMB License Fee Management Branch 4
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