ML20024H428

Comment Opposing Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery.

ML20024H428
Person / Time
Site:	Crystal River
Issue date:	05/24/1991
From:	Beard P FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
FRN-56FR14870, RULE-PR-170, RULE-PR-171, RULE-PR-71 3F0591-09, 3F591-9, 56FR14870-00519, 56FR14870-519, NUDOCS 9106040018
Download: ML20024H428 (2)

Text

DOCKET NUMBER PROPOSED RULE N %' '7' 58

%! (50 FC/ N ,

3 Si Mtx 29 P2 :59 Florida Power

.: ur-ss-Crystal River Unit 3 Docket ho. 50 302 May 24, 1991 3F0591-09 Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

Revision to Fee Schedule 56 Fed. Reg. 14870 Request for Comments

Dear Sir:

Florida Power Corporation (FPC) provided input to the comments provided by NUMARC. We endorse those comments as providing a very thorough constructive criticism of the proposed new fee schedule. The NRC Staff is obligated by public law to recover approximately 100% of its budget authority from those who receive benefits from its services. However, it is clear that many services for which nuclear utilities receive little benefit are being funded by nuclear utilities.

Further, as noted in the detailed comments provided by NUMARC, this level of budget recovery obligates the NRC to a higher level of accountability with regard to the hours charged to individual utilities, the amount of contractor dependence, level of administrative and general support and the usefulness of research programs.

One specific point of concern is the incorporation of several categories of overhead costs in the calculated hourly rate for Part 170 costs. These overhead costs are not directly attributable to plant-specific activities. Since the total man-hours per unit is significantly higher for single unit utilities, the burden of the overhead costs is not being equitably distributed. These overhead costs could be included in the Part 171 annual fee which would then be equally shared between each licensed reactor.

Finally, the timing from a budget perspective, is burdensome. Back-charging for services rendered in a single lump-sum in the currert budget year is having a deleterious impact on our ability to plan for the orderly and appropriately prioritized expenaiture of limited O&M funds.

9106040018 910524 c j

{O PDR PR 170 56FR14870 PDR

\;},

A Flonda Progress Company

d May 24, 1991 1

3F0591-09 i Page 2 '

FPC encourages your careful consideration of the industry's comments. The NRC staff should also recognize that the approach taken, after any judicial review that may be forthcoming, will be precedent-setting in the area of 100% fee recovery by large federal agencies. In consideration of this fact, we strongly recommend that your ultimate decision be as f air as possible.

Sincerely, 44eO h.M. eard, Jr.

Senior Vice President Nuclear Operations PMB:KRW xt: Regional Administrator, Region 11 NRR Project Manager Senior Resident inspector

.