ML20046D038
| ML20046D038 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/26/1993 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR21116, RULE-PR-170, RULE-PR-171 58FR21116-00535, 58FR21116-535, 93-280, NUDOCS 9308160064 | |
| Download: ML20046D038 (2) | |
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'93 JUL 28 P 3 :54 VIRGINIA POWER July 26, 1993 Secretary, U. S. Nuclear Regulatory Commission Serial No.93-280 Washington, D. C. 20555 NL&P/RBP R1 Attention: Docketing and Service Branch Gentlemen:
COMMENTS ON NRC FEE POLICY in the April 19,1993 Federal Register, the NRC solicited public comments on the need for changes to its fee policy and associated legislation. This action responds to recent legislation that requires NRC to review its policy for assessment of annual fees, solicit public comment on the need for changes to this policy, and recommend to the l
Congress changes to the existing law which are needed to prevent unfair fiscal burdens on NRC licensees.
We endorse the NUMARC comments sent separately to the NRC on this issue. In l
addition, the following two points are highlighted for consideration in revision of fee j
i policy.
First, although we strongly endorse the NUMARC position that implementation of the pubiic law (OBRA-1990) should not result in the arbitrary and punitive collection of i
exempted and unbillable fees by assignment to individual licensees or classes of i
licensees for which there is no direct connection to the activities or service provided,
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we recognize the need and are concerned about the elimination of the exemption for j
nonprofit educational institutions such as university research reactors. We note that if NRC fees are charged to these institutions, many will be forced to halt their educational projects due to lack of funding. We believe that these educational facilities not only benefit the entire industry, but have a far broader societal benefit in terms of government and public welfare. Accordingly, we recommend that these l
programs be legislatively excluded from NRC 100% recovery. We believe that these educational services, based on that broader sense of public good, should be funded out of general revenues collected from the entire public. P % mn cannot convince 1
Congress to totally exclude these institutions from fee recovery, means of collecting
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l the fees other than the present arbitrary method of limited application should be found.
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4 Secondly, a major issue for licensees, which was noted in the Federal Register, was the large and often unanticipated increases in the annual fees that have occurred from increases in the NRC budget and could occur from reduction in the number of licensees for which the costs.are allocated. We endorse the concept of limiting fee increases to stabilize licensee budgeting processes. We, therefore, strongly support the NUMARC recommendation that increases in annual fees and hourly review rates be tied to the Consumer Price Index. In addition, we recommend that if the number of licensees decrease or the necessary NRC support for licensing of new plants declines, the NRC staffing and budget should correspondingly be reduced instead of reassuaing the fees to the remaining smaller number of licensees.
If you have any questions, please contact us.
Very truly yours, c'
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W. L. Stewart cc:
Mr. Ron Simard Nuclear Management and Resources Council 1776 Eye Street Suite 300 Washington, D. C. 20006-3706