ML20046A866

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 Rule

ML20046A866
Person / Time
Site:	Hatch, Vogtle
Issue date:	07/16/1993
From:	Mccoy C GEORGIA POWER CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR21116, RULE-PR-170, RULE-PR-171 58FR21116-00493, 58FR21116-493, HL-3395, LCV-0078, LCV-78, NUDOCS 9308020029
Download: ML20046A866 (2)

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93 JUL 19 P(:18 Georgia Power

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July 16, 1993 Docket Nos. 50-321 50-424 HL-3395 50-366 50-425 LCV-0078 Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Comuission Washington, DC 20555 ATTENTION: Docketing and Service Branch Comments on "NRC Fee Policy" (58 Federal Recitter 21116 of April 19. 1993)

Dear Mr. Chilk:

Georgia Power Company has reviewed the policy "NRC Fee Policy," published in the Federal Register on April 19, 1993. In accordance with the request for comments, Georgia Power Company (GPC) is in total agreement with the NUMARC comments which are to be provided to the NRC.

In addition to NUMARC's comments GPC believes that it is also important for the NRC to begin to control its internal cost in order for the nuclear industry to be successful in reducing overall program costs. It is noted that over fifty percent of the NRC costs are overhead and administrative.

These are extremely high percentages in the budget - areas where significant cost reductions are possible. Therefore, in addition to the need to revise the NRC fee policy and the associated legislation, the NRC should review their organizational structure and target changes to reduce management levels, overhead and duplications between organizations.

The combination of inappropriate fee allocat' ' noted by NUMARC in ceajunction with excessive NRC overhead costs nave placed an inordinate regulatory cost burden on power reactor licensees. The ultimate fees charged to this class of licensee are disproportionate to services received by thit. segment of the industry. The culmination of these inequities has resulted in NRC regulatory expenditures in excess of five 9309020029 930716 PDR PR 170 SBFR21116 PDR f:

C-4 ueorgia Power sa U. S. Nuclear Regulatory Commission Page 2 percent of our plant operating budget. The NRC and Congress must resolve these inequities if the industry is to be successful in reducing nuclear program costs.

Should you have any questions, please advise.

Respectfully submitted, f ,

C. K. McCoy ,

CKM/JDK /

cc: Georaia Power Comoany J. T. Beckham, Jr., Vice President, Plant Hatch J. B. Beasley, General Manager - Vogtle Electric Generating Plant ,

H. L. Sumner, Jr., General Manager - Plant Hatch U. S. Nuclear Reaulatory Commission. Washinaton. DC '

K. N. Jabbour, Licensing Project Manager - Hatch D. S. Hood, Licensing Project Manager - Vogtle U. S. Nuclear Reaulatory Commission. Reaion II S. D. Ebneter, Regional Administrator L. D. Wert, Senior Resident Inspector - Hatch B. R. Bonser, Senior Resident Inspector - Vogtle ,

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