ML20059E957
| ML20059E957 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 10/28/1993 |
| From: | Denise Edwards YANKEE ATOMIC ELECTRIC CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR50859, RULE-PR-171 58FR50859-00134, 58FR50859-134, NUDOCS 9311040059 | |
| Download: ML20059E957 (2) | |
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.YAN KEEy October 28, 1993
'93 OC 29 P4 :13 FYC 93-022 Mr. Samuel J. Chilk i.
Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i
SUBJECT:
Restoration of the Generic Exemption From Annual Fees for Nonprofit Educational Institutions (58FR50859).
Dear Mr. Chilk:
Yankee Atomic Electric Company (YAEC) appreciates the opportunity to comment on the subject proposed rule.
YAEC is a New England utility which owns the Yankee plant in Rowe, Massachusetts and provides engineering and licensing services to other nuclear power plants in New England. This letter is also submitted on behalf of the Vermont Yankee Nuclear Power Corporation and the Maine Yankee Atomic Power Company.
We have long supported the nation's non-profit educational institutions and continue to believe that the nation's nuclear research reactors and associated nuclear education programs are a vital resource to the country which must not be jeopa dized. The Commis ion, in reconsidering its July ruling, acknowledged the multiple societal benefits provided by these reactors: not only in maintaining the nuclear energy option, but in scientific disciplines and fields as varied as medicine, geology, archaeology, food science, and textiles.
All these externalized benefits are clearly in the broad public interest.
Thus, it is in the nation's interest to relieve the nuclear research reactors from regulatory agency user fee burdens which could result in such dire consequences as a university discontinuing operation of its valuable activity in this area.
Accordingly, we support the restoration of the generic exemption from the annual licensing fee for nonprofit educational institutions; but not at the expense of the nation's electric ratepayers who rely on nuclear power.
Nuclear power reactor licensees should not, again, be asked to provide the funding mechanism to subsidize an activity that clearly benefits society as a whole.
Further, should the Commission decide to restore the generic exemption from annual fees from non-profit educational institutions, it's rulemaking should address the recovery of those costs in a manner such that no NRC licensee subject to annual user fees, either as an individual class of licensees or collectively, has to subsidize an activity which, though in valuable to the national interest, does not relate directly to a service for that licensee.
C76\\370 l
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PDR PR 171 58FR50859 PDR b5 /0
Mr. Samuel J. Chilk Page 2 October 28, 1993 We also request that the Commission address this user fee policy issue in the context of its response to Congress under the Nuclear Policy Act of 1992 which requires the Commission to review and report on its policy of assessment of annual fees.
The Commission should give the most serious consideration to recommending to Congress legislative changes necessary to f airly subsidize the costs associated with the subject exemption.
In addit'an, other changes are necessary to address the inequities inherent within the present federal mandate for 100% recovery of the NRC budget via user fees on licensees.
Such action is necessary to ensure equitable treatment of the nation's nuclear electric ratepayers, and all NRC licensees.
In funding NRC's annual budget in the future, there are clearly numerous agency activities and functions which provide broad societal benefit but which should be evaluated for funding outside of the annual fee recovery process.
Accordingly, while supporting relief from NRC user fees for the nonprofit educational institutions on the basis that the alternatives provide a broad societal benefit; we request that the Commission evaluate and consider recommendations to Congress for the recovery of this cost.
Additionally, all partions of the NRC annual budget which are infrastructure costs or costs in support.f the broad national interest should be recovered by a means other than vi;.ser fee assessment on NRC licensees.
Sincerely.
/
Donald W. Edwards Director, Industry Affairs C74370
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