ML20091R572

Requests Precise Delineation of Applicable Regulations & Accounting of Prof Staff Hours Expended Re Review Costs Charged for Withdrawal of CP Application.Waiver of Any Interest Penalty Requested

ML20091R572
Person / Time
Site:	Black Fox
Issue date:	06/08/1984
From:	Conrad V PUBLIC SERVICE CO. OF OKLAHOMA
To:	Miller W NRC OFFICE OF ADMINISTRATION (ADM)
References
NUDOCS 8406150171
Download: ML20091R572 (2)

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s PUBUC SERVICE COMPANY OF OKLAHOMA A CENTRAL AND SOUTH WEST COMPANY P.O. BOX 201/ TULSA, OKLAHOMA 74102 / (918) 599-2000 / TWX 910-845-2106 June 8,1984 Office of Administration U.S. Nuclear Regulatory Commission License Fee Management Branch Wa hington,'1C 20555 Re:

Docket Nos. 50-556 and 50-557 Bill No. C0203 Attention: William 0. Miller, Chief Dear M.'.

Miller:

By correspondence dated May 3,1984, your office notified the co-owners of the Black Fox Station Nuclear Project of the Commission's intent to invoice them for the review costs of the withdrawn construction permit application; such an invoice was subsequently issued by the Division of Accounting and Finance, Office of Resource Management, on May 8,1984, in the net amount of 5884,275.

On June 1,1984, I spoke at length with your Ms. Reba Diggs, Facilities Programs Coordinator, who provided me with some further information regarding the computation of the review fee.

Although she was most helpful, she was unable to provide more than a gross accounting of the professional staff hours. As I explained to her, any further expenditures on behalf of the Black Fox project, either for termination of contractual obligations or for operating expenses in pursuit of an orderly disposition of assets, requires substantial documentation prior to payment.

These requirements are in accordance with Order No.. 217735 of the Okla-homa Corporation Commission in Cause 27639 issued on June 3,1982, and the sub-sequent order on June 22, 1983 of the Federal Energy Regulatory Commission adopting the Proposed Settlement in Docket No. ER82-80-000 and ER82-389-000.

In addition to these orders which bind the Public Service Company of Oklahoma, the other-two co-owners, Associated Electric Cooperative, Inc.- and Western Farmers'-

Electric Cooperative have substantially similar requirements flowing from the Rural Electric Administration and the Cooperative Finance Corporation.

Finally, in addition to these regulatory requirements, our respective managements and the outside accounting fims of Arthur Anderson & Co. and Coopers & Lybrand will require a more substantial. accounting. At the same time, counsel for the co-owners will review the regulations for applicability to our factual situation. Please recognize that these standards of documentation and review have been and are being applied to each and every termination claim for the Black Fox Project and are documented in quarterly filings to the Oklahoma.

Corporation Commission and the FERC.

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Office of Administration June 8,1984 U.S. Nuclear Regulatory Commission License Fee Management Branch Washington, DC 20555 Re: Docket Nos 50-556 and 50-557 Bill No. C0203 i

Page 2 More specifically, in order to satisfy our many overviewers as to the acceptability of the billing and the prudence of payment, we will require a precise delineation of the applicable regulations and an accounting of the professional staff hours expended. This should include identification of the organization making the billing, the purpose of the time spent by review subject, and the time period during which the expenditure was charged (broken into the smallest available billing unit).

In addition, we will need documentation and justification regarding the hourly rate at which the professional staff hours were billed, including all NRR, I&E, Contract, and ASLB personnel. This should also include a documentation and explanation of any loadings designed to re-capture support expenditures.

The docinentation should be specific as to expenses charged by indi-viduals for lodging, travel or out-of-pocket expenses during the field inves-tigations or the public proceedings in the Tulsa area.

If these were not individually charged to the Black Fox project, please explain how these expenses were handled.

It has been said that not all review hours and hearing hours were billed; please explain how this delineation was made.

Accordingly, the Black Fox Station Co-owners request, for good cause shown and the reasons enumerated above, a waiver of any interest penalty while the Commission provides substantiation for the referenced billing.

Your office should address all correspondence to the undersigned who has been designated by the Black Fox Co-owners as responsible for the resolution of this matter. We would appreciate a prompt indication as to your projected schedule for response.

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REFERRED TO DATE RECEtVED SY DATE Ltr. requesting itamized costs i

for Black Fox h withdrawn construction Reba M. Diggs with 6/13 permit application documentation prior cy. i M actian to payment. Ltr. also requests a E M E of any interest penalty while INu r&i@t* ~ bh Commission provides substantion for the referenced billing under CO203.

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