ML20126K287
| ML20126K287 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 06/07/1985 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Miller W NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| 32300, NUDOCS 8506190214 | |
| Download: ML20126K287 (4) | |
Text
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' CORSum813 Power wwc C0mpany vu, n.,u.. n.i... e.si i.s e.d Co.saruc,io.
General offices: 1946 West Parnell Road, Jackson. MI 49201 e (617) 7eE0453 fa ;
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U William 0 Miller, Chief
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' Office of Administration
-US Nuclear Regulatory Commission Washington, DC 20655 MIDLAND ENERGY CENTER PROJECT -
I' OPERATING LICENSE FEE ASSESSMENT FILE 0485.11, 1300 SERIAL 32300
REFERENCES:
- 1) Letter, J W Cook to W 0 Miller, Midland Energy Center Operat-ing License Fee Assessment, Serial 32196, dated March 7, 1985 1.
- 2) Letter, W 0 Miller to J W Cook, dated April 12, 1985 In Reference 1 Consumers Power requested that the due date on the bills be extended for at least 90 days. We had concluded that.certain of the charges making up the $3,077,400.00 for each Unit might be improperly billed and should be checked. Charges associated with the Order modifying the l
Construction Permit and work associated with the contested hearings (reviews, hearing preparation and attendance, contracts and inspections) would not be 4
i valid charges. Our review of the backup information provided by Reference 2 substantiates our concern that a large portion of the billing is attributed to the NRC activities associated with the Order modifying the Construction Permit and subsequent contested hearing.
Reference 1 also stated our legal position regarding the retroactive applica-1 j
tion of the new fee schedule, and provided the basis for that position.~The l
1etter concluded with a request, pursuant to 10 CFR 15.31(c), to schedule a l
conference or interview to discuss the considerations raised in the letter.
l We believe that Reference 1 fully complied with the Note on the billings that i
"the'due date can be extended only if a request for review stating why the l
debt is incorrect in fact or in law is received by NRC before the Due Date.
l 10 CFR 15.31, 170.50."
l I
I For the foregoing reasons we again ask that the due date for fee bills be extended while we work with the NRC to resolve these matters.
i Our review of the billing backup material has been hampered by the lack of
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specific information in some of the documentation previously provided. A 8506190214 850607 OC0685-7257A-MP04 PDR ADOCK 05000329 A
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2 listing of the initial comments from review of the billing backup material from Reference 2 is attached. Further reviews and additional information will likely raise additional questions as well as settle some of our current questions. We request that you schedule a conference with us to address these matters at your earliest convenience.
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OC0685-7257A-MP04
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s-Attechm:nt Serial 32300 June 5, 1985 REVIEW OF BILLING INFORMATION DO 184 and D0 185, Midland Units 1 and 2 I.
Accounting Questions A.
For Unit 1, Professional staff hours for NRR were invoiced for 46,855.8 regular manhours. Total hearing staffing hours under codes E07, R06, R07, R16, R17, E17, 100, 115, 125, R26, R27 R35, and E35 total 3,898 regular manhours, not 1,726.
In addition, 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for training, which is the first entry for 1975, and 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> for advanced concepts, E55 Page 20 should be deleted. These three items represent 2194.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> ($85,585.50) credit.
B.
For Unit 2, NRR staff hours were invoiced for 50,211.6 regular manhours. Total hearing staff hours were 9,174.80, not 9,075.30.
The difference, 99.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (approx $4,000), should be credited.
C.
For Unit 1, there appears to be a total variance of 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> in the Regional Office Billing as follows:
Year Invoiced Documentation 1974 1,012.70 1,009.20 1983 2,361.00 2,368.00 1984 1,707.50 1,735.00 5,081.20 5,112.20 Which is correct?
D.
Contract / Consultant and Cost Data sheet for FIN B3077 says that "183, 488 was allotted equally" to five actions.
It appears that Midland was billed the total 183 thousand dollars plus another one/fifth of the total. What is correct? Were we overcharged by the 183 thousand dollars?
II.
Documentation Questions A.
ACRS staff hours are not supported by any documentation. Total costs are $41,895 and $15,370 for Units 1 and 2 respectively.
B.
Contract costs are not supported by documentation such as copies of purchase order / contracts, material and/or time sheet support. Total cost for both units is $2,170,963.39.
In addition, some of the contract sheets had insufficient infornation to tell what task it represented, who the contract was with, or whether it in fact represents a Midland task.
It is requested that for each of the l
Contractual / Consultant Cost Data forms (ie, each FIN No.) an actual i
contract providing the work scope be provided.
FIN Nos B2354 and B2172 do not provide any data other than the branch and cost.
MIO685-7257A-MP04 i
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l pe Attachtsnt Serial 32300 June 5, 1985 il' III. Billings which should be deleted in consideration of the Commission Order rule or contested hearing rule.
A.
The November 6, 1984 C J Holloway memos (two) provide summaries of IE-HQ and Regional staff hours and contractual service cost. The Regional offices have included nearly all hours, despite the concen-trated resources spent by the NRC in support of resolution of the
' December 6, 1979 Order and the contested hearings. Two Region III individuals (Callagher and Landsman) charged over 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br />. These charges should be deleted, along with-any other charges for individ-unis supporting the hearings, all of which were contested.
I B.
The only Contract / Consultant Cost attributed to a category other than " Safety" or " Environmental" was A2315, which went to " Contested Hearing". This billing should not be chargeable.
From the limited information available, the following, at least, appear to support l
the activities stemming from the 2.204 soils ruling or contested hearing, and should be deleted:
B8035
$ 98,000 B6826 242,500 i
l B6878 166,300 B5004 and ?
7,500 A3714 17,612 A2315 5,000
$ 536,912 C.
It would appear the hours listed for the Headquarters staff would in many cases have been directly attributable to the activities associ-i ated with the soils 2.204 issue and should not be chargeable. Some of the effort expended in producing NUREG-0793 (SER) and most of the l
effort associated with Supplement 2 should not be chargeable.
i IV.
Billings questionable in terms of applicability to Midland.
A.
Region III individuals J R Creed W A Hanson, M Corcoran, Z Cordero, M Ring, D Robinson, R Janke, W Key, and R Shultz charged over 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br />. These names are not ones which the current project people remember. Please confirm that the hours are correctly chargeable to Midland.
B.
The contracts to ANL (A 2001 and A-2121) for environmental review assistance ($282,400) and audit of calculations of plant transients using RELAP 5 (671,100), totaling $953,500, is higher than many of the other plant total NRR technical assistance contracts. Were these reviews Midland-specific and necessary only for Midland l
licensing or were they at least in part done for generic or B&W plant information so that their cost should not be totally carried by Midland?
I MIO685-7257A-MP04