ML20135E502

Forwards Payment Due for Review of OL Based on Preliminary Review of Specific Info Requested on 850314 to Assess Correctness of Bill.Amount of Bill Disputed & Requests That Any Addl Amount Due Be Issued in Corrected Bill

ML20135E502
Person / Time
Site:	Grand Gulf
Issue date:	08/29/1985
From:	Dale L MISSISSIPPI POWER & LIGHT CO.
To:	Miller W NRC OFFICE OF ADMINISTRATION (ADM)
References
CON-FIN-A-0422, CON-FIN-A-1301, CON-FIN-A-1308, CON-FIN-A-3346, CON-FIN-A-3349, CON-FIN-A-3396, CON-FIN-A-3730, CON-FIN-A-422, CON-FIN-A-6415, CON-FIN-A-6588, CON-FIN-B-2327 AECM-85-2-0017, AECM-85-2-17, MAEC-85-0273, MAEC-85-273, NUDOCS 8509160419
Download: ML20135E502 (5)

Text

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MISSISSIPPI POWER & LIGHT COMPANY Helping Build A*ississippi EdhhilhilddE P. O. B O X 164 0, J A C K S O N, M SSISSIPPI 39215-1640 August 29, 1985 NUCLE AR LICEN$iNG & SAF ETY DEPARTMENT U. S. Nuclear Regulatory Commission Office of Resource Management Division of Accounting and Finance Washington, D.C.

20555 Attention: William O. Miller, Chief License Fee Management Branch Office of Administration

SUBJECT:

Grand Gulf Nuclear Station Unit 2 Docket No. 50-417 File: 0260/L800.0 Bill No. D0192

Reference:

MAEC-85/0273 AECM-85/2-0017 On August 14, 1985 the Nuclear Regulatory Commission (NRC) sent to Mississippi Power & Light (MP&L) a bill (Revised D0192) for collection in connection with the operating license review for Grand Gulf Unit 2 (GCNS-2) in the amount of $725,343.00.

Previously, on February 15, 1985, NRC had issued bill D0192 for CGNS-2 in the amount of $1,032,937. Af ter MP&L received Bill No. D0192, it requested on March 14, 1985 specific information needed to assess the correctness of the bill. This information included the nature, dates and staff offices performing reviews for which MP&L was charged.

In your August 14, 1985 letter transmitting Collection Bill Revised D0192, (a) you deducted a $307,594 error in the initial Collection Bill, (b) provided MP&L for the first time certain documentation it requested in its March 14, 1985 letter and (c) informed MP&L that the payment due date had been extended 15 days from the date shown on the Bill. You ftirther indicated that if this debt is not paid on or before the due date, interest from the date of the original bill would become due and payable.

Based upon a preliminary review of the data MP&L requested in March and just received, MP&L believes that payment in the amount of $578,209 appears to be the just payment due, and a check in that amount is enclosed.

MP&L requests an extension of time by which to pay the balance of the bill (if a balance is in fact due) until fifteen days after a final determination is made and further requests that interest from the date of mailing the original cp

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bill not become due and payable pending a final determination thereof. MP&L understands from speaking with Mr. Doug Weiss of your of fice, that the enclosed check will be considered timely inasmuch as it is transmitted under postmark l

g not later than the due date. While submitting this payment, MP&L does not waive any rights to contest its correctness in accordance with all applicable l

regulatory or statutory provisions.

8509160419 850829 J16AECM85082601 - I hDR ADOCK 050 7

Memoer miooie sou6n utm6ius oystem

AECM-85/2-0017 PAGE 2 As set forth below, MP&L believes that as to the unpaid balance of the bill, there is reason for it and NRC to question whether the amount billed is correct. Based on MP&L's preliminary review of your breakdown of contractual costs for Units 1 and 2, it is MP&L's belief that the items listed exclusively for Unit 2 should have been split equally with Unit 1 and MP&L has adjusted the payment accordingly. This includes review of emergency operating procedures, seismic qualification, equipment qualification, materials engineering, degraded core (hydrogen control) and an unspecified charge from the Containment Systems Branch (Please see attachment).

Ms. Reba Diggs of your organization has explained NRC's methodology; assigning a cost to either Unit 1 or Unit 2 or splitting the cost between the two units, but MP&L docs not understand the rationale used in assigning some of the costs exclusively to Unit 2.

There was insufficient information provided in the NRC's August 14, 1985 response regarding charges to Unit 2 in the category of NRR professional staff hours ($74,100). For the reasons set forth above that contractor charges have been questioned, MP&L belieyes similar adjustments may be warranted for staff charges. While MP&L does not necessarily contest, at least at this time, the 1,900 professional staff hours charged to Unit 2, MP&L would appreciate a breakdown similar to the one provided for contractual costs.

Accordingly, MP&L requests that you determine that the enclosed payment is the just payment due and/or that a corrected Bill for Collection be issued with respect to the portion of Revised Bill D0192 not paid, and that an extension of the payment deadline be granted until fifteen days after final determination is made, should a final determination be made that additional payment is due. MP&L further requests that interest from the date of mailing the original bill not become due and payable in that the claims set forth above appear to have merit and will cause the NRC to question whether the amount originally billed is correct and because, based in our reading of the applicable provisions, interest may not be assessed on that part of the bill paid. MP&L believes that such action is appropriate and timely in that NRC transmitted the necessary information for MP&L to review the basis for the bill only when it transmitted a revised bill.

Yours truly, n& r

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L. F. Dale Director PJR/JCC:bms Attachment cc:

Mr. J. B. Richard (w/a)

Mr. O. D. Kingsley, Jr. (w/a)

Mr. R. B. McGehee (w/a)

Mr. N. S. Reynolds (w/a)

Mr. H. L. Thomas (w/o)

Mr. R. C. Butcher (w/a)

Mr. James M. Taylor, Director (w/a)

Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.

20555 J16AECM85082601 - 2

Attachnznt to AECM-85/2-0017' Bill-No. D0192 l

Proposed Adjustments i

Grand Gulf Unit 2 Contractual Costs (MAEC-85/0273)

A.

PROPOSED ADJUSTMENT FOR SPECIFIED CONTRACTS f

FIN #

AMOUNT SUBJECT i

'B 2327

$ 39,027.00 Emergency Operating Procedures i

i A 3349' 6,000.00 Seismic & Dynamic Qualification 4

A 6415 154.122.00 Equipment Qualification a

A 3730 2,312.00 Equipment Qualification A 6588 7,807.03 Equipment Qualification i

A 3346, A 3396

'54,800.00 Containment Systems i

A 1301, A 0422. A 1308 30,200.00 Degraded Core-Hydrogen Control NRC Unit 2 Total for the

$294.268.03 Above FIN #'s 1

l MP&L Suggested Unit 2 Total 147,134.00 (Believed to be Common j

Unit Activities) l I

i

-Grand Total (Due From

$725,343.00 Revised Bill No. D0192, i

dated August 14, 1985) i j

Less Adjustment 147,134.00 l

-MP&L' SUGGESTED GRAND TOTAL DUE

$578,209.00 4

r i

B.

EXPLANATION OF PROPOSED ADJUS_TMENT l

The NRC response of August 14, 1985 which accompanied revised Bill No.

I D0192 provided the distribution of contractual charges to Unit 2 and the e

subject areas associated with each contract. Based on MP&L's review of these subject areas, there is reason to believe that _the work for contracts specified in Section A above was performed to support the NRC staff's - review of both ' Unit ~ 1 and 2.

In that these are " common unit" charges MP&L proposes that credit for 50% of these costs be made ~to the l

revised bill.

[

J16ATTC85082601

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_ _ _ =. -

s.

Attach =snt to,

~ AECM-85/2-0017 For example, work performed under FIN B2327.was in the area of emergency operating procedufe (E0E) reilew. Specific procedures have not been 4

developed for Unitf2 as'yet...It would,seem appropriate that any. resources 1

devoted to EOP rpyiew would be applicable to both Grand Gulf units.-

l Lf..

In the area of equipment qualification, it is MP&L's understanding that l

i equipment qualifipation information specific to Unit 2 has not been submitted for review. Submittals to date,' primarily in the plant's Final Safety Analysis Rep 9rt, have either been applicable to both units or l

specific to Unit 1.';

Similar argument would apply to contractor activities associated with c

Containment System Branch review efforts.

1 In summary, based on the information provided thus far, MP&L believes that the charges specified in Section A above are common unit reviews and that

' appropriate adjustment to the revised bill should be made.

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