ML20044F836

From kanterella
Jump to navigation Jump to search
Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Opposes Rules
ML20044F836
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 05/24/1993
From: Byram R
PENNSYLVANIA POWER & LIGHT CO.
To: Chilk S
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR21662, RULE-PR-170, RULE-PR-171 58FR21662-00319, 58FR21662-319, PLA-3979, NUDOCS 9306010106
Download: ML20044F836 (2)


Text

' ' ~ ~

% 05-25-1953 CB:53 9 P.c2 x

A, 120&l7)

(STFYL1tuz)

Od.j_~'_] Pennsylvania Power & Light Company 3 l'l Two North Ninth Street

  • Allentown, PA 18101-1179
  • 2151774 5151 93 9' 25 W :54 Reben G. Byrsm ,

semor ves presmun-Nucasse -

215177t.-7502 MAY 241993 Mr. Samuel J. Chilk, Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn.. Docketing and Service Branch SUSQLT.HANNA STEAM ELECTRIC STATION COhBIENTS TO PROPOSED RULEMAKING 100% FEE RECOVERY, FY 1993 Docket Nos. 50-387 PLA-3979 FILES R41-2/A17-11 and 50 388

Dear Mr. Secretary:

Pennsylvania Power and Light Company (PP&L) is sulnatting the following comments to the NRC proposed ntlemnWg titled "FY 1991 and 1992 Proposed Rule Implementing the US Court of Appeals Decision and Revision of Fee Schedules; 100% Fee Recovery, FY 1993" (38FR21662).

  • The approximate 7% increase to the professional hour rate ($123/hr. to

$ 132/hr.) appears excessive when compared to the current inflation rate.

PP&L recognizes that a portion of this incrasse results from NRC's review pursuant to the Chief Financial Officers Act of 1990 (CFO Actl which resulted in additional professional hours being nasdad to accomplish some specific tasks. Howevar, we do not believe that it is necessary to increase the total number of FTE's in response to the CFO Act review, but rather utilize alternative personnel management strategies (ie: reduce inspection hours by use of SALP, combining NRC Regions, reducing Research since it's NRC's intent to have industry perform more of this type activity).

  • With regard to the cost passthrough concept, PP&L agress that the ability to passthrough costs should not be a criteria for setting annual fees. The studies required to justify exempting or reducing Licensee annual fees cannot be done accurately or cost efficiently. Also, the burden of paying the fees which are exempted would f all on power reactors which in most cases because of their Public Utility Commission Regulations cannot passthrough these costa.

9306010106 930524 PDR PR 170 5BFR21662 PDR

A 05-25-1993 08:53 P.C3 L

FILES R41-2/A17-11 PLA-3979 Page 2 of 2

= With regard to the continued exemption of annual fees for non-profit educational institutions, PP&L supports the Commission's continued exemption for non-profit educationalinstitutions. We feelthat the benef!t for education outweighs the cost placed on power reactors.

  • With regard to LLW, PP&L supports either Alternatives 1 ar.d 2. We agree that alternatives 3 or 4 are not acceptable because of the problems associated with the equatable distribution of the fee to all applicable licensees.

PP&L appreciates the oppormnity to comment on this proposed miemaking.

Verf truly yours,

.L

.B cc: NRC Region I Mr. R. J. Clark, NRC Sr. Project Manager (OWFN) (w/o)

Mr. G. S. Barber, NRC Sr. Resident Inspector (SSLS) (w/o) f l