ML20082J759
| ML20082J759 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/22/1991 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9108280255 | |
| Download: ML20082J759 (2) | |
Text
-.
4 epyt f VDNey DMPf bl@ Oft s~w m e rA bDUCT4 t!,
.as G<o4 5417 Ju %%
August 22, 1991 U.
S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Subject:
Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, - *0ense No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Invoice AM02156-91 l
The purpoce of this letter is to notify the NRC of a disputed debt pursuant to 10 CFR 15.31 and request that an adjustment be made to reflect the actual amount due as specified herein.
on approximately July 18, 1991, we received invoice No.
AM02156-91, dated August 9, 1991, for $29,100.
This is the allocated cost to holders of Quality Assurance (QA) plan approvals for the transportation of radioactive material associated with both use and fabrication'of transportation casks.
It is not, nor has it ever been, our intent to fabricate shipping casks.
Our implementation of the approval of our QA program has been as a user only, and, as such, our allocated cost should be $1,700 plus a $100 surcharge.
Application-for review of our QA program was submitted initially on May 7, 1979, in accordance with 10 CFR 71.101 (f).
Within this part it is recognized that a Commission-approved quality assurance program which s6tisfies the applicable criteria of Appendix B of Part 50 of 10 CFR would be accepted as satisfying the QA program requirements of 10 CFR 71, Subpart H.
A distinction between user and fabricator does'not exist. 'Our renewal application of August 14, 1984, specifically addressed applicability to the packaging and transportation of radioactive materials.
Likewise, our renewal application'of July 10, 1989, addressed transpcrtation.
We are currently preparing a submittal requesting that our QA program approval be amended to identify a limitation to procurement and use
-of packaging for shipment of radioactive materials and to exclude i
[..]1991.
fabrication of shipping casks.
This will be submitted by August 29, q
l a
73 The recent revision (i.e.,
final rulemaking, comment resolution) u to 10 CFR'171.16 to include this fee to holders of QA plan approvals and the NRC's appeal / exemption schedule has placed an unreasonable
)
constraint on our ability to identify the complex mix of fee schedules and to submit this request before the due date/ invoice date of August 9, 1991.
We, therefore, in consideration of the above, request a rofund of an overpayment amount of $27,300.
9108280255 910822 h
i PDR ADOCK 05000334
\\\\D P.
_ _ _._. _ - ~ _ _ _... _,. _. _
Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Invoice AM02156-91 Page 2 If you have any questions regarding this submittal, please contact Mr. Steve-Sovick at (412) 393-5211.
Sincerely, D.
Sieber ice President Nuclear Group cc:
Mr. J.
Beall, Sr. Resident Inspector Mr. T. T. Martin, NRC Region I Administrator Mr. A. W.
DeAgazio, Project Manager Mr. M.
L. Bowling (VEPCO)