ML20128K474

Responds to Request for Exemption from 10CFR170 Fee Requirements Due to Undue Financial Burden & Diversion of Funds Required for Safe & Expeditious Facility Cleanup. Request to Waive All Fees Denied on 850426

ML20128K474
Person / Time
Site:	Three Mile Island
Issue date:	05/22/1985
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Standerfer F GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 8505310162
Download: ML20128K474 (2)

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/""44 UNITED STATES y *. NUCLEAR REGULATORY COMMISSION j WASHINGTON, D. C. 20555

= a MAY 2 21985 g * * * . * ,/

Docket No. 50-320 Mr. F. R. Standerfer -

Vice President / Director, TMI-2 GPU Nuclear Corporation Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057-0191

Dear Mr. Standerfer:

By lette'r dated July 13, 1984, it was requested that the Comission exempt GPU Nuclear Corporation from the fee requirements of 10 CFR 170 forThreeMileIslandUnit2(TMI-2). It is GPU's position that, as a result of the unique circumstances at TMI-2 leading to increased licensing activity, 10 CFR 170 causes an undue financial burden on GPU and diverts funds that are needed for a safe and expeditious cleanup of the facility.

'GPU's estimate of fees to be assessed in 1984 was $1.1 million and thereafter $1.8 million each year.

Commission records show that fees paid for TMI-2 over a five-year period

between March 28, 1979, and July 31,1984, total $677,700 ($202,000 for licensing approvals and $475,700 for routine inspections). While the Comission's regulations have exempted and continue to exempt GPU from the payment of fees for review of procedures and those licensing activities

' which are the direct result of the February 11,1980 Commission Order, <

l the request to waive all fees for TMI-2 has been considered by the ,

Comission and was denied on April 26,1985. 1 i

I would note that an analysis of GPU's estimate of fees likely to be assessed shows the estimate to be excessive. Experience does not support fees of one million dollars for 1984 or approximately two million dollars for 1985 and each year thereafter. Fees assessed for licensing and inspection activities in FY 1983 were $156,000, and through July 31, 1984, they have been $101,000. The estimate for  :

inspections appears excessive in tu.; routine inspections under the O QQ \

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6 Mr. F.-R. Stan'derfer. 2 current rule are limited by an annual ceiling of $300,000, and even though non-routine inspections are subject to actual costs, there is no reason to believe a significant increase in non-routine inspections will occur.

If additional information is desired, please contact Willian 0. Miller, Chief. License Fee Management Branch, 301/492-7225.

Sincere 1y, ,

TSigned) Jack W. Roe William J. Dircks

. Executive Director for Operations DISTRIBUTION:

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