ML20046A880

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

ML20046A880
Person / Time
Site:	Farley
Issue date:	07/16/1993
From:	Woodard J SOUTHERN NUCLEAR OPERATING CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR21116, RULE-PR-170, RULE-PR-171 58FR21116-00494, 58FR21116-494, NUDOCS 9308020054
Download: ML20046A880 (2)

Text

p t,. . Souttern Nuco+r Operttin0 company -

Post Offica Box 1295  :~.T ,Q,

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Birminghim. Alabama 35201 Telephons (205) 868-5086

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a. o. wooo.ro Southem Nuclear )perating Company Executive Vice Presioent 93 JUL 19 P " ~Ner soumem electne system July 16, 1993 Docket Nos. 50-348 50-364 Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Docketing and Service Branch Comments on "NRC Fee Policy" (58 Federal Reaister 21116 of April 19. 1993)

Dear Mr. Chilk:

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

In addition to NUMARC's comments SNC 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 allocation noted by NUMARC in conjunction with excessive NRC overhead costs have 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 this segment of the industry. The culmination of these inequities has resulted in NRC regulatory expenditures in excess-of five 9300020054 9307161' 5YR2111b PDR_ lD

if f 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. '

. Woodard -\ -

((({ J. '

JDW/JDK cc: Southern Nuclear Operatina Company R. D. Hill, Plant Manager U. S. Nuclear Reaulatory Commission. Washinaton. D. C.

T. A. Reed, Licensing Project Manager, NRR-U. S. Nuclear Reaulatory Commission. Reaion II S. D. Ebneter, Regional Administrator G. F. Maxwell, Senior Resident' Inspector b