ML20125C128

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Package of Affirmation Response Sheets Re SECY-83-495
ML20125C128
Person / Time
Issue date: 03/06/1984
From:
NRC COMMISSION (OCM)
To:
Shared Package
ML20125C017 List:
References
FOIA-84-564 NUDOCS 8506110664
Download: ML20125C128 (4)


Text

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LF rns cc: Dircks A'F F i R 5 A T ! O N RESPONSE SHFFT hF' T0: SAMUEL J. CHILK, SECRETARY OF THE COMMISS10N d k

FROM: COMMISSIONER GILINSKY Y

SUBJECT:

SECY-83-495 - LICENSE FEES - FINAL RULE APPROVED xx/with mod. DTSAFROVED ABSTAIN NOT PARTICIPATING REQUEST DISCUSSION COMMENTS:

I would leave the present ceiling of S20,'000 for review of topical reports and approved topical report revisions. Resolving safety problems on a generic basis through Topical Reports introduces greater uniformity among utilities and closer scrutiny by NRC, and vendors should be encouraged to issue them.

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. T0: SAMUEL J. CHILK, SECRETARY OF THE COMMISSION FROM: COMMISSIONER ROBERTS

SUBJECT:

SECY-83-495 - LICENSE FEES - FINAL RULE sumer to cucas acus W

APPROVED m DISAPPROVED ABSTAIN .

! NOT PARTICIPATING REQUEST DISCUSSION COMMENTS:

[. Agree with Ocumissionar Gilinsky's ocment.

. 2. All categories ahculd hava a r=414ng rather than specify full cx>st.

Me need to reove uncertainties so that licensees and venacxrs can adequataly

! plan. I suggest that we either (a) keep the old ceilings the see for those cases where we have inadecmata data to base an updated W. .

sebaAsia, or (b) use acune-htism factor or other indicator to fix the ceiling.

3. There ahculd be a provision which gives us an option not to charge
licensees for discretionary in Wdens and investigations. - w i=11y in those cases where we are chasing dcun allegations which are later found i not to have marit.

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SECRETARIAT NOTE: PLEASE .ALSD. RESPOND TO. AND/OR COMMENT ON .0GC/0 .

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FROM: COMMISSIONER ASSELSTINE

SUBJECT:

SECY-83-495. LICENSE FEES - FINAL RULE DISAPPROVED ABSTAIN ~

APPROVED .

NOT PARTICIPATING REQUEST DISCUSSION COMMENTS:

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SECY-83-495 - LICENSE FEES - FINAL RULE APPROVED < DISAPPROVED ABSTAIN ~

NOT PARTICIPATING REQUEST DISCUSSION COMMENTS:

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, Coa 4M877EE ON ENVlftONMENT AND PUSUC WOftRS amasw.vaamen.mammen was sans"*" WAeMINeTON. D.C.10510 March 13, 1984 The Honorable Nunzio J. Palladino Chairman U.S. Nuclear Regulatory Commission

Dear Joe:

In November of 1982, the Commission published a Notice of Proposed Rulemaking, announcing its intention to amend the schedule of fees chargec cy the Commission for inspections and review of applications for permits, licenses, amendments, renewals, and special projects. This initiative was undertaken to enable the Commission--through its fee schedule--to recover those costs incurred by the Commission in providing services to identifiable recipients.

During the course of a hearing conducted on March 10, 1983 before the Subcommittee on Nuclear Regulation, I expressed a number of concerns about the Commission's proposals to modify the fee ehedule.

Now, as the Commission prepares to promulgate a final revised fee schedule, I would take this opportunity to renew those concerns. After careful examination of the proposed rule, and based upon comments from many who ar'e involved in this industry on a day-to-day basis, I was greatly concerned about the proposed revisions to the fee schedule for source material licenses. I urge you, once again, to consider retaining the concepts of fixed fees and of fees based upon incurred costs, but subject to specified maximum amounts. These concepts are essential, in my judgment, to provide to licensees reasonable predictability as to licensing costs, to retain incentives for efficient management, and to provide for reasonable limitations on the Commission's authority to " pass through" to licensees the costs of the Commission's activities.

I recognize the Commission's responsibility, under Title V of the Independent Offices Appropriation Act of 1952, to recover those expenses deemed appropriate by the Commission, and '

I support the basic concept underlying that legislation. But I also firmly believe that the Commission's responsibilities under this Act can be effectively reconciled with the notion f providing the public, the licensees, and the Congress assurances that the Commission is performing its functions in an efficient i and In order to carry out these twin gresp.onsibilities, cost-effectivemanner.I urge the Commission to again review carefully the categories of its activities that it proposes to include among the recoverable costs, in order to ensure that activities.

t 0({ undertaken in the public interest, such as non-routine inspections Q or investigations, are not being imposed harshly or improperly on licensees.

o

,3 Ch2irman Policdins

  • Pcgo Two Finally, I urge you to take whatever steps may be -

necessary to ensure that the functions of the Commission are carried out in an efficient and effective manner and, in particular, to work closely with the individual states to minimize, to the extent possible, the duplication of regulatory effort.

I am enclosing for your review two letters that I trust you will find of great interest, and I urge you to consider the comments raised in these letters as the Commission moves forward with promulgation of its revised license fee schedule. r'~1 Mos sincer ,

Ala L Ikolit \11%C OF CALIKM M

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I , February 3, 1984 .

Senator Alan Simpson

' 709 Hart Building Washington, D. C. 20510 Honorable Senator Simpson:

I am writing with regard to the proposed increases in the U. S. Nuclear Regulatory Commission (NRC) fees for licensing and regulating nuclear source materials. Although my primary interest is in the NRC licensing and regulation of the .

uranium industry, I feel compelled to comment on the entire nuclear power cycle.

The nuclear power industry spawned by the federal government is going through the most costly development period of any techn'o logy today and despite all the years and money, has' yet to reach maturity. one can hardly pick up a newspaper without reading another horror story involving a reactor project somewhere in the country. The cost we are paying '

for the combined mistakes of private sector management, unions, and the Federal URC cannot be accurately measured, but rest assured, it will translate into higher energy costs which further restricts our ability'to compete in world trade.

The NRC licensing fees for commercial reactors run into

-illi:nr ef C:ll : r, but I'  ::.s-tha'i 1: -:t Y:;in t; c:"or the cost of complian:e. If the entire nuclear power cycle were examined, the cumulative fees, starting with the mining of uranium and ending with fuel waste disposal, would be impressive and the total cost of compliance would be staggering.

It's time to examine the regulatory process and determine a measure of cost benefit. The NRC should be required to analyze its costs and justify the benefit to the licensees before any fee increases are approved.

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52nator Alcn Simps:n OC Tebruary 3, 1984 ,

Page two For example, a substantial portion of the licensing data submitted for a source materials license to in situ (solution Mining) mine uranium is a duplication of information submitted to and reviewed by state agencies. Many of the requirements of NEPA should be excluded from the licensing process and have no business in the domain of NRC.

In a letter to Jim Curtiss earlier this week, I outlined our licensing experience for an in situ mining operation in the South Powder River Basin of Wyoming. Over the period of four years and nine months required to go through R&D and Commercial licensing, we spent millions ~of dollars to provide the supportive licensing data plus over $94,000 in NRC fees. The total cost, when related to our recoverable uranium ore reserves, is between one and two dollars per pound of U O -- and a number of future license amendments are assured during operation by conditions written into the license. In today's competitive international uranium market, one or two dollars a pound nearly 10% of the current spot market price, can decide a project's economic viability.

If our experience licensing a mining site with no serious regulatory problems is indicative of what takes place throughout the nuclear power cycle, we are paying dearly for NRC's

" help".

In conclusion, quoting statutes which authorize recovery of NRC costs through fees isn't an acceptable justification for a fee increase. Demonstrating what measures will be taken by the NRC to reduce the time and cost of the licensing and regulatory process to the licentse is a benefit which might allow a fee increase. However, we, the industry, should have a say in its evalation as to the benefits.

Respectfully, UNC TETON EXPLORATION DRILLING, INC.

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T. G. Melrose Vice President Solution Mining TGM/mdd e

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ACTION CONTROL DATES , CONTROL NO. f* N3 Aiaa Stupeem h " " " * ' L2LM ) 12MP7 CMTE OF DCENMENI mTuwu mEPLY ggg A FREPARE FOR SIGNATURE i

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OTM.R DESCRIPTION O m O usuo O napoaf G OTHER SPECIAL INSTRUCTIONS OR REMARKS Causasts re License Fees Priority -

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C0k.lSP0rIDEllCE CONTROL TICKET . 3 Alan Simpson. l NUMBER: 84-0292 ' LOGGING DATE: 3/13/84 F'"..._.___

0FFICE OF THE SECRETARY ACTION OFFICE: EDO AUTHOR: Sen Alan K. Simpson AFFILIATI0s:

LETTER DATE: 3/12/84 FILE CODE:

ADDRESSEE: Palladino

SUBJECT:

Final RM decision concerning NRC licensee fees ACTION: Chairman's Signature and Com Review...

Mar 22 DISTRIBUTION: OCA to Ack, Docket Rec'd off. EDO oste...:3..I4-l' SPECIAL HANDLING: None Time...l;t.(h..f._ . . . . . ,

SIGNATURE DATE:

FOR THE C0tif1ISSION: Billie D

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bfillier. J. Dircks Executive Director for Operations FR0ft: Janes K. Asselstine 50 -

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SUBJECT:

SECY-83-495 -- LICENSE FEES .

In SECY-83-495, License Fees, the proposed ceiling for routinc in-spections for operating reactors is set at $160,000. Based on a $50 per hour rate for inspection, this corputes to 3,200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of in-spection t year per reactor. This seems low to sr.e. Prior to affim-ing this rule, I would like e coraplete listing of the actual number of routinc inspectior, bours of all the plants which were in operatiori ir

, 1981, the year that these rates are based, at well as a rationale for the proposed $160,000 ceiling.

cc: Cbt.iman Palladino Comissioner Gilinsky Comissioner Rcberts Comissioner Bernthal OGC OPE SECY r

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NUCLEAR REGULATORY COMMISSIOVr WASHINGTON, D. C. 20555 l g N;Y}j

  • *** April 5,1984 fy gyg CHAIRMAN The Honorable Alan K. Simpson -

United States Senate Washington, DC 20510

Dear Senator Simpson:

This responds to your letter of March 13, 1984 in which you expressed concern about the Commission's proposed revised license fee schedule as it affects source material . licenses. Enclosed with your letter was correspon-dence you had received from Mr. Glenn Catchpole of Ogle Petroleum, Inc., and Mr. T. G. Melrose of UNC Teton Exploration Drilling, Inc.

Based on comments received concerning the proposed removal of a fee ceiling .

for facilities and major fuel cycle applications and licenses, the Commission has decided to retain a predetermined ceiling or maximum fee for a majcrity of these applications and licenses. Fees would be based on full costs (professional staff hours and contractual costs expended) to conduct the review or inspection up to a predetermined limit. The ceilings would represent, in most instances, the top of the cost range for the various fee categories of applications and licenses contained in the November 22, 1984 Notice of Proposed Rulemaking. In certain instances, due to a lack of licensing activity and the consequent lack of cost data, there would be no ceilings. This would not, however, apply to source materials and applica-tions; fixed fees would be retained for these small programs.

We share your concern that the Commission's activities be conducted efficiently. To ensure that applications are processed in a timely and cost

- effective manner, each NRC office in the licensing process is required to develop and work within an approved operating plan. This means that appli-cations are scheduled for review and resources allocated based upon the staff time determined necessary to complete the particular type of review a'ctivity. The staff's performance in meeting schedules is monitored by staff management.

With restect i to the use of outside resources, we secure the services of experienced laboratories and contractors to supplement the agency staff.

The technical assistance program managers who manage these contracts exercise close oversight, including cost and schedule control and are responsible for the review and approval of all contract costs that are to be included in license fees.

In the November 22, 1982 proposed fee schedule, the Commission proposed for the first time to recover the costs of non-routine (reactive) inspections.

Both routine and non-routine inspections deal with the fundamental issues of safety, health physics, safeguards and physical security of special nuclear materials, and protection of the environment. The cost of providing this service of non-routine inspections has become a significant effort for the

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The Honorable Alan K. Simpson staff and cost to the agency. For these reasons, we believe it is incumbent upon us to recover the costs of these services.

No fees will be assessed for investigations conducted by the NRC Office of Investigations. Also, the Commission is considering waiving all costs that result from third party allegations, i.e. , resulting from a party other than licensed management or NRC staff.

The NRC will continue to maintain a close working relationship with State regulatory agencies. We believe this effort helps to avoid unnecessary duplication of regulatory effort.

Commissioner Roberts adds:

"I strongly believe that the recovery of expenses should be subject to established fee ceilings. It appears to me that this would be a relatively simple matter, particularly for materials license reviews, which we have been performing for many years and which are fairly routine and mechanical. For other types of reviews, we could still update our previously established ceilings by considering recent cost data or by applying some sort of factor or indicator which reflects increased review costs due to inflation or higher salaries of our technical staff. In addition to removing some of the uncertainties associated with licensing reviews and inspections, I believe the establishment of fixed fee ceilings would prompt an officient use of NRC staff resources." -

I appreciate the time which you have taken to raise these questions concerning t,e h Commission's proposed fee schedule. The Commission received a large number of public comments on the November 1982 Notice and these will be carefully considered before the Commission makes its final decision on this matter.

Sincerely, Original sic :d b7 Eunzio J. Pallaf.ine i

Nunzio J. Palladino Cleared with all Cmrs' Offices by SECY Ref.-CR-84-27 1

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y'gg icy 5~C=~^ 9)Cnitcb SLafes Senafe COMMITTEC ON ENVIRONMENT AND PUBLic WORKS JeMw w. Taeca Ja MsMonf?V WTAF7 DtRECTDs WASHINGTON. D.C. 20510 March 13, 1984 The Honorable Nunzio J. Palladino l Chairman ' U.S. Nuclear Regulatory Commission

Dear Joe:

In November of 1982, the Commission published a Notice of Proposed Rulemaking, announcing its intention to amend the schedule of fees charged by the Commission for inspections and review of applications for permits, licenses, amendments, renewals, and special projects. This initiative was undertaken to enable the Commission--through its fee schedule--to recover those costs incurred by the Commission in providing services to

  • identifiable recipients.

During the course of a hearing conducted on March 10, 1983 before the Subcommittee on Nuclear Regulation, I expressed a number of concerns about the Commission's proposals to modify the fee schedule. Now, as the Commission prepares to promulgate a final revised fee schedule, I would take this opportunity to renew those concerns. After careful examination of the proposed rule, and based upon comments from many who are involved in this industry on a day-to-day basis, I was greatly concerned about the proposed revisions to the fee schedule for source material licenses. I urge you, once again, to consider retaining the concepts of fixed fees and of fees based upon incurred

            ' costs, but subject to specified maximum amounts. These concepts are essential, in my judgment, to provide to licensees reasonable predictability as to licensing costs, to retain incentives for
      .         efficient management, and to provide for reasonable limitations on the Commission's authority to " pass through" to licensees the costs of the Commission's activities.

I recognize the Commission's responsibility, under Title V of the Independent Offices Appropriation Act of 1952, to recover those expenses deemed appropriate by the Commission, and I support the basic concept underlying that legislation. But I also firmly believe that the Commission's responsibilities under this Act can be effectively reconciled with the notion of providing the public, the licensees, and the Congress assurances that the Commission is performing its functions in an efficient yandcost-effectivemanner. In order to carry out these twin  !

         \ responsibilities, I urge the Commission to again review carefully g        the categories of its activities that it proposes to include among the recoverable costs, in order to ensure that activities undertaken in the public interest, such as non-routine inspections r investigations, are not being imposed harshly or improperly f                on-licensees.
        ' Chairman Palladino Page Two Finally, I urge you to take whatever steps may be necessary_to ensure that the functions of the Commission are carried out in an efficient'and effective r.anner and, in particular, to work closely with the individual states to minimize, to the extent possible, the duplication of regulatory effort.                ,

I am enclosing for your review two letters that I trust you will find of great interest, and I urge you to consider the comments raised in these letters as the Commission moves forward with promulgation of its revised license fee schedule.

                                                            .i
                                 .             Mos /sincpr Ala      S       son United State Senate
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        -AKS:jrc Enclosures as noted cc: Glenn J. Catchpole T.- G. Melrose 4

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OGLE ETROLEUM NC. OF CA FORN]A Tt . f rumt fic'i 2P-MM 2'!L Eut IMw Sistn. Snn => l u irm t.10h 2t+.N5* Cont a. Moutsc 1:W

                              .                        February 10, 1984 The Honorable Alan K. Simpson       .

Committee on Environment and Public Works United States Senate Washington, D.C. 20500

Dear Senator Simpson:

It has come to the attention of Ogle Petroleum Inc. of California (OPIC) that the matter of revised NRC licensing fees will soon be coming before the Commission for final rulemaking. In this regard I would like to briefly restate some 'of the concerns that my company had with the original draf t r egul ations. I am quite sure that our concerns are shared by many, if not all,- of the uranium mining operators in Wyoming. OPIC of course has no way of k,nowing what changes .(if any) have been made in the proposed revised licensing fee schedule but it is hoped that there are either fixed f ees or caps to the fees f or the va rious types of licensing action. Without fixed fees or upper limits there will be no incentive whatsoever for the NRC to conduct timely and efficient reviews of mine company license

     -                     and amendment applications.       Also, mining companies will have no way to budget for licensing if there are no fixed fees or caps.

If the proposed final rulemaking does contain fixed fees or caps, it is hoped that the amounts are reasonable. For example, if the f ees for licensing an in-situ uranium solution mine jump f rom S10,050 (1978) to 5253,111 (the NRC stated cost of processing OPIC's license application) in just six years then something is wrong. It has been and continues to be my firm opinion that the NRC can process an in-situ license at a cost equal to or less

            -               d.an .he cur:en. 756,500 f ee :.i they will l' .aintain capable and knowledgeable staff, 2) utilize generic EIS!s, and 3) great-ly reduce the use of outside consultants.

If it' costs the NRC over S250,000 to process a license application for a typical in-situ mine then I believe there is a serious problem with the overall system and major reform is in order. Af ter all, industry pays for the various environmental and hydrologic studies and the NRC simply reviews the informa-tion. If the NRC feels that the information they get is not adequate then I would say the NRC needs to let industry know more clearly and precisely what information they want, the level of detail, etc. Currently, the NRC has such an abundance of dis-jointed and overlapping rules, regulations, regulatory guides, and draf t regulatory guides pertaining to uranium mining that it is extremely difficult, if not impossible, for industry to deter-t

4 ' q (. REVISED 5RC LICENSING FEES FEBRUARY 10, 1984 . PAGE TWO.

                       - mine what should or should not be included in a license applica-tion.                                         ~

Although it is beyond the scope of the matter of NRC licensing fees, I would like to state my concern over the tremendous duplication 'of ef f ort between the NRC and the Land Quality Division of D E Q. This redundency. of effort is particularly visible in the hydrologic aspects of an application where the two groups of ten come up with dif f ering opinions and conflicting license requirements. It seems 'like such a waste of regula tory manpowe r, time, and money; not to mention the con-

                       - fusion and frustration it causes the mining companies.

Thank you very much for taking the time to consider the above comments. Please let me know if I can be of any assistance to you in connection with this . mat te r. Judy and I greatly . enjoyed visiting with, you the other night in Casper despite the weather - wish Ann could have been ,0ith you. Best ,regards, . OGLE PETROLEUM INC. OF CALIFORNIA fj s . Glenn J .'Catchpofe > President GJC:csg e E 4 o

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February 3, 1984 Senator Alan Simpson 709 Hart Building Washington, D. C. 20510 Honorable Senator Simpson: I am writing with regard to the proposed increases in the U. S. Nuclear Regulatory' Commission (NRC) fees for licensing and regulating nuclear source materials. Although my prim.ary interest is in the NRC licensing and regulation of the uranium industry, I feel compelled to comment on the entire nuclear power cycle. The nuclear power industry spawned by the federal government is going through the most costly development period cf any technology today and despite all the years and money, has yet to reach maturity. One can hardly pick up a newspaper without reading another horror s, tory involving a reactor project somewhere in the country. The cost we are paying for the combined mistakes of private sector management, unions, and the Federal NRC cannot be accurately measured, but rest assured, it will translate into higher energy costs which further restricts our ability to compete in world trade. The NRC licensing fees for commercial reactors run into 7111iens of doll rs, but I'm rure they de not begir to cover the cost of compliance. If the entire n,uclear power cycle were examined, the cumulative fees, starting with the mining of uranium and ending with fuel waste disposal, would be impressive and the total cost of compliance would be staggering It's time to examine the regulatory process and determine a measure of cost benefit. The NRC should be required to analyze its costs and justify the benefit to the licensees before any fee increases are approved.

, . . *, r

              ,                                                 (
          .   .                     s Senator Alan Simpson

'UMC February 3, 1984 L. , Page two For example, a substantial portion of the licensing data submitted for a source materials license to in situ (solution Mining) mine uranium is a duplication of.information submitted to and reviewed by state agencies. Many of the requirements of NEPA should be excluded from the licensing process and have no business in the donain of NRC. In a letter te Jim Curtiss earlier this week, I outlined our licensing experience for an in situ mining operation in the South Powder River Basin of Wyoming. Over the period of four years and nine months required to go through R&D and Commercial licensing, we spent millions of dollars to provide the supportive licensing data plus over $94,000 in NRC fees. The total cost, when related to our recoverable uranium ore reserves,,is between one and two dollars per pound of U O -- and a number of future license amendments are assured buring operation by conditions written into the license. In today's competitive international uranium market, one or two dollars a pound nearly 10% of the current spot market price, can decide a project's economic viability. If our experience licensing a mining site with no serious regulatory problems is indicative of what takes place throughout the nuclear power cycle, we are paying dearly for NRC's

                      " help".

In conclusion, quoting statutes which authorize recovery of NRC costs through fees isn't an acceptable justification for a fee increase. Demonstrating what measures will be taken by the NRC to reduce the time and. cost of the licensing and regulatory process to the licensee is a benefit which might allow a fee increase. However, we, the industry, should have a say in its evalation as to the benefits. Respectfully, UNC TETON EXPLORATION DRILLING, INC.

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T. G. Melrbse Vice President Solution Mining TGM/mdd

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MEl1ORANDUM FOR: William 0. Miller, Chief License Fee Management Branch Office of Administration , FROM: Elliott A. Graher, Program Analyst Program Suppt t and Analysis Staff Office of Inspection and Enforcement

SUBJECT:

FY1981 ROUTINE INSPECTION EFFORT AT OPERATING REACTORS Comissioner Asselstine has requested data on routine inspection hours of all plants which were in operation in 1981, the year that the rates upon which the proposed license fee rule (SECY-83-495) are based. Enclosure 1 is a copy of the Commissioner's request. Based on your request we have prepared four computer runs .for the specifkd 75 operating reactors covering efforts during the period October 5,1980 thru October 3,_1981: Regular hours effort (for activity codes PAP, PP1, and DOC-- preparation, onsite/offsite inspection, and documentation, respectively) for these plants based on 8 typesof regional personnel: PIC 41, 51, 52, 53, 61, 62, 71, 81-(see enclosure 2). ( Regular hours effort (re: PAP, PP1, DOC) for types of regional personnel: the above 8 plus PIC 11,12, and 13 (s'ee enclosure 3) Regular hours effort (re: PAP, PP1, DOC) for all types of regi:;nal personnel (see enclosure 4) Regular hours effort (re: PAP, PP1, and DOC) for all types of regional personnel by docket and within docket by PIC code. (see enclosure 5). , I also include enclosure 6 the computer run dated 08/11/83 that you supplied. (see enclosure 6) Comissioner Asselstine questions the upper limit set for routine inspection fees in the license fee paper. This upper limit works out to ($166,100 divided by $53/ hour) 3134 hours. A number of plants exceeded -that limit depending on the criteria used. For instance: i 60 ff I

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Encl. 2 Encl. 3 Encl. 4 Encl. 6 Duane Arnold 1963 hrs. 3148 hrs. 3752 hrs. 3147 hrs. Trojan 3390 hrs. 5872 hrs. 7157, hrs. 5872 hrs. 3 17 ,a 16

     # of plants exceeding 3134 hours                                  ('22jf3fptus Enclosure 5 is provided so that you can select which data is most appropriately included or excluded. Ia ould sugg_est that all or nearly all the effort be included _ ,_Vendo_r inspectors,~1nvestigators and even licensing special~ists can Se_useito_ perform routine irtspection when they are availalil_e, competent ano are needed. Similarly, supervisors--especially section chiefs--can be involved in routhinspertina when there is a need and no inspector is available to perform the inspection.Such part-time use of section chiefs is often an inherent budgeting assumption.
   > In developing a ceiling for license fees it may be appropriate to consider effort in non-regular hcurs. Hopefully, all such effort should occur during regular hours but scheduling and deadlines often prelude that. I understand the reason that licensees will not be billed for future effort during non-regular hours, but this reason may bot be operative or appropriate in calculating a ceiling for such fees.(piven the time constraints we did not provide data on non-regular hours effort.

Please call on me if you require additional assistance, liott A. eher, Program Analyst Program pport and Analysis Staff Office of Inspection and Enforcement

Enclosures:

As Stated cc w/ encl. 1: J. L. Blaha, IE A. J. Burda, IE

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PACE 1 ROUT 1hE SAFETY & SAFEG AROS INSPECTION g 04/12/84 FOR F183 REPORT s2/ SELECT 10N B 0 ON ll PIC-CODES..

                        --.......--........------...--........................u-.,-n__                                                               eaa.

REGULAR NON-REG TOTAL HOURS ' DOCKE T FACILITY NAME HOURS HOURS ~, NUMBER 2,432.R 122.0 2,554 8 ........---. 00CKETM9 TOTAL 05000313 ARKANSAS 1 rs 2,497.3 105.0 2,602.3 00CP.ETNG TOTAL 05000360 ARKANSAS 2 2,447.5 237.0 2,684.5 , 00CkETNO TOTAL 05000334 PEAVER VALLEY 1

  • 2,623.0 171.0 2,794.0 DOCKETH0 TOTAL 05000155 BIG ROCK POINT 1 1,571.7 94.0 1,665.7 00CKETN0 TOTAL 05000259 BROWNS FERRY 1 1,003.7 90 0 1.C93.7 LOCKETN0 TOTAL 05000260 HROWNS FERRY 2 749.1 58.0 807.1 l 00CKETN0 TOTAL 05000296 BROWNS FERRY 3 r 2,322.5 132 5 2,455.0 l DOCKETNO TOTAL 05000325 BRUNSWICK 1 2,249.0 137 5 2,3P6.5 DOCKLTNO TOTAL 05000324 BRUNSWICK 2 1,798.5 127 5 1,926.0 I

00CKETNO TOTAL 05000317 CALVERT CLIFF 3 1 a 1,554.0 123 0 1,677.0 00CKE f fd0 TOT AL 0500031P CALVERT CLIFFS 2 2,298.5 115 5 2,414.0 00CKLTh0 TOTAL 05000315 COOK 1 2,129.5 103,0 2 232.5 00CKE TNO TOT AL 05000316 COOK 2 g 3,320.2 191 5 3,511.7 00ChtTNO TOTAL 0$00029R COOPER STATION  % 2 579.5 253.5 2,833.0 ' 1 00CMETN0 TOTAL 05000302 CRYSTAL RIVER 3 3,869.0 316.5 4,185.5 00ChETN0 TOTAL 05000346 DAVIS-BLSSE 1 r5 351 0 29.0 380.0 DOCFETNO TOTAL 05000010 DRESDEN 1 2,254.5 294.5 2,549.0 c. 00CKLTN0 TOTAL 05000237 DPLSblN 2 1,539.0 214.0 1,753.0 DOCNETNO TOTAL 05000249 ORESDEN 3 8 2,581.0 183.5 2,764.5 00CKEINO TOTAL 0b000331 DUANL ARNOLO 2,315.9 130.0 2,445.9 00CKETf40 TOTAL 05000348 FARLEY 1 g 1,595.5 102.0 1,697.5 DOCMLINO 10TAL 05000364 FARLEY 2 '"' 3,822.0 131 0 3,*e53.0 D0r KL T f40 TOTAL 05000333 f!T2 PATRICK r -- 's

() 04/12/84 ROUTI%E SAFETV E SAFEGUARDS INSPECTION PAGE 2 FOP FT83 gg REPORT 82/ SELECTION B ASED ON 11 PIC-CODES FACILITY II DOCKET REGULAR NON. REG TOTAL HOURS NUneER NAME HOURS HOURS

                                                                                                                                                                                                                                                                     ,,   p DOCKETNO TOTAL 05000285 FORT CALHOUN 1                                                                   , 3,800.0                                           279.0       4,079.0 00CMETNO TOTAL 05000267 FORT ST VRAIN                                                        .               4,694.0                                          80.5       4,774.5                                                                                  rs DOCKETNO TOTAL 05000244 GINNA                                                                                2,258.0                                         219.5       2,477.5 1,728.5                                                                                                                                               GB Du DOCKETNO TOTAL 05000213 HADDAM NECK                                                                                                                          305 5       2,034.0 i

DOCMETNO TOTAL 05000321 HATCH 1 2e433.5 164.5 -2,598.0 00CNCTN0 TOT AL 05000366 HATCH 2 2,041.5 114.0 2,155.5 00CKETNO TOTAL 05000003 tfIDIAN POINT 1 95.0 20.0 115.0 DOCKETNO TOTAL 05000247 INDIAN POINT 2 3,967.0 717 5 4,684.5 e DOCMCTNO TOTAL 05000286 INDIAN POINT 3 3,104.5 379 5 3,464.0 DOCNETN0 TOTAL 05000305 MEUAUNEE 2,604.5 133.5 2,738.0 DOCFETNO TOTAL 05000409 LA CROSSE 1,964.0 113.5 2,077.5 - 1 00CnTTN0 TOTAL 05000309 MAINE YANKEE 3,131.0 346.5 3,477.5 l DOCKCTN0 TOTAL 05000369 MCGUIRE 1 2,515.0 211 0 2,726.0 l l DOCKETNO TOTAL 05000245 MILLSTONE 1 1,386.5 224.0 1,610.5 ,g DOCKETH0 TOTAL 05000336 MILLSTONE 2 1,828 5 296.0 2,124.5 00CKCTN0 TOTAL 05000263 NONTICELLO 2,361 0 224.0 2,585.0 00CKETNG TOTAL 05000220 NINE HILE POINT 1 2,108 5 145.0 2,253 5 l DOCKLTNO TOTAL 05000?38 NORTH ANNA 1 1 526.0 76.0 1,602.0 00CFl.TNO TOTAL 05000339 NORTH ANNA 2 1,455.0 103.5 1,558 5 00ChiTNO TOTAL 05000269 OCONEE 1 1,768 7 8T.9 1,456.6 O DOCKETNO TOTAL 05000?70 OCONEE 2 1,106.T 44 1 1,150.P DOCME TNO T OT AL 05000287 OCONEE 3 1,125.2 36.6 1,161.8 I j 00CKETNO TOTAL G5000219 OYSTER CREEK 1 3,494.0 315.5 3,3gg,g ,,

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n -_ - - - ROUTINE SAFETY & SAFEGUARDS INSPECTION PAGC 3 04/12/84 FOR FY83 g REPORT s2/ SELECTION BASED ON 11 PIC-CODES DOCKET FACILITY REGULAR NON_ REG TOTAL HOURS NUMPER NAME HOURS HOURS _ _____.._____....__......._..______.________.__ ......_____... .__._. __..________..........____.__.._____.......__......_____..... g, DOCKf.1NO TOTAL 05000?55 PALISADES 3.134.0 150.5 3,284.5 1,540 5 167.0 1,707.5 r' DOCKETNO TOTAL 05000277 PEACH DOTTOM 2 1,659.0 155.5 1,813.5 DOCK!TNO TOTAL 05000278 PEACH BOTTOM 3 3,023.5 481.0 3,504.5 DOCKETNG TOTAL 05000243 PILGRIM 1 2,435.5 53.5 2,489.0 DOCKETNO TOTAL 05000266 POINT DEACH 1 2,188.5 45.5 2,234.0 00CkLTN0 TOTAL 05000301 POINT DEACH 2 1,743.5 71.0 1,814.5 00CKCTN0 TOTAL 05000262 PRAIRIE ISLAND 1 1,736.5 78.0 1,814.5 r 00CKETNO TOTAL 05000306 PRAIRIE ISLAND 2 2,154 5 172 5 2,327.0 . 00CkETNO TOTAL 05000254 QUAD CITIES 1 DOCKETNO TOTAL 05000265 OUAD CITIES 2 1,509.0 124.5 1,633.5 3,702.5 3,928.0 - N DOCKETNO TOTAL 05000312 RANCHO SECO 1 225.5 00CKL TNO TOTAL 05000261 ROUINSON 2 2,811.5 230.0 3.0,41.5 00CKfTN0 TOTAL 05000272 SALEM 1 2,250 0 209.5 2 459.5 DOCKLTNO T0TAL' 05000311 SALEM 2 1,997.5 233.0 2,230.5 m>

                                                                                                                                                                                              ~ M     i 1,476.0        141.5     1,617.5                         g 00CKETNO TOTAL 05000206 SAN ONOFRE 1                                                                                                                                                     r l

2,103.0 83.0 2,186.0 DOCKETNO TOTAL 05000327 SEQUOYAH 1 1,472 0 69.5 1,541.5 rs DOCKETNO TOTAL 05000328 SEQUOYAH 2 2,225 5 142 0 2,367 5'  ; 00CKETNO TOTAL 05000335 ST LUCIE 1 2,128.6 136.0 2,264.t DOCKLTNO TOTAL 05000280 SURRY 1 00CKETN0 TOTAL 050002H1 SURRY 2 1,824.2 85.5 1,909.7 ( 7,160.5 641.0 7,801.5 l DOCRETNO TOTAL 05000289 THREE MILE ISLAND 1 O 5,498 5 513 0 6.011 5 DOCKETNO TOTAL 05000320 THREE MILE ISLAND 2 3,169 5 112.0 3,2P1.5 g DOCKETNO TOTAL 05000344 TROJAN

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_ ~ O PAGE 4 04/12/e4 ROUTINE SAFETY & SAFEGUARDS INSPECTION FOR FT83

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                      -                               REPORT 82/ SELECT 10N BASED ON 11 FIC-CODES DOCKET             FACILITY               REGULAR          NON_ REG            TOTAL HOURS NUMBER                NAME                 HOURS             HOURS

__..________.........................__ ____..............................................____ 2 723.5 DOCKETN0 TOTAL 05000250 TURKEY POINT 3 2 555.0 168 5 2,249.5 114.5 2,364.0 m 00CKEff30 TOTAL

  • 05000251 TURKEY POINT 4 l

3,049.0 361.0 3,410.0 DOCKETNO TOTAL 05000271 VERHONT TANKEE 1 W le74P.5 181.0 1,929.5 00CKETNO TOTAL 05000029 YANKEE-ROWE.1 2,278.5 72 5 2,351.0 DOCNT TNO TOTAL 05000295 ZION 1 2.556.0 84.0 2,640.0 00CKETNO TOTAL 05000304 ZION 2 w

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l () o PAGE S 04/12/84 ROUTINE SAFETY f0 gag {gyA05 INSFECTI,0N REPORT a2/ SELECTION BASED ON 11 PIC. CODES gg ) 00CMET FACILITY REGULAR NON-REG TOTAL HOURS 8% NAME HOURS HOURS NUMHEP 175e780.6 13.400 6 1A9,181 2 F4 GRAi40 10TAL s e I O I s i r3 J ' O f

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