ML20117P451

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Requests That Waiver of Interest Be Applied to Invoice D0183 for OL Review.Review of 4CFR102.13(b) & (a) Indicates That Util Responsible for Interest from 850314 Due Date Rather than Interest from 850114 Bill Date
ML20117P451
Person / Time
Site: Beaver Valley
Issue date: 05/31/1985
From: Carey J
DUQUESNE LIGHT CO.
To: Miller W
NRC OFFICE OF ADMINISTRATION (ADM)
References
2NRC-5-080, 2NRC-5-80, NUDOCS 8506060374
Download: ML20117P451 (3)


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'Af 2NRC-5-080 (412) 787-5141 (412) 92M 960 Nuclear Construction Division Telecopy (412) 787-2629 Robinson Plaza, Buttding 2, Suite 210 Pittsburgh, PA 15205 May 31, 1985 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Mr. William Miller, Chief License Fee Management Branch Office of Administration

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Operating License Review

REFERENCE:

Invoice to E. J. Woolever, dated May 8,1985 Gentlemen:

Duquesne Light Company (DLC) recently received an invoice for $36,045.60 in interest on the $1,271,161 previously paid the NRC for Operating License Review for Beaver Valley 2.

In March of 1985, DLC requested a short, 60-day extension to review the NRC's documentation of Invoice D0183.

This extension was necessary because the NRC submitted a $1.2 million non-itemized bill covering a 10-year period, with no supporting data. We appreciate the cooperation your of fice provided in supplying access to supporting data, which enabled us to complete the audit and pay the NRC within the 60-day period.

However, it is our position that DLC would have paid by the due date if a complete billing had initially been supplied.

Our review of 4CFR102.13(b) and. (g) indicates that, at the most, DLC is responsible for the interest from the March 14 due date, rather than interest from the January 14 bill date.

Although the original invoice mentioned that interest would accrue from the bill date, that provision was superseded by the publication _ of $102.13(b) in the March 9, 1984, Federal Register.

Section

$102.13(b) provides that if any agency uses an advance billing, as was done here, interest may not start until the due date.

Section $102.13(g) provides that federal agencies may waive interest where' there is a request for reconsideration.

We believe that waiver of intrest is appropriate in this case, for the reasons set forth in the second paragraph of this letter.

'Your response is requested as soon as pocsible since DLC has received a second notice of the Bill for Collection with interest due by June 8, 1985.

If you have any questions, please contact Mr. T. J. Zog1mann at (412) 787-5141.

DUQUESNE LIGHT COMPANY 05 By J A j. Carey" Vice President TJZ/wjs cc:

Mr. B. K. Singh, Project Manager Mr. G. W.iton, NRC Resident inspector g

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