ML20137Z886

Forwards Activity Codes Included for & Excluded from License Fee Recovery Through 840623

ML20137Z886
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/12/1985
From:	Holloway C NRC OFFICE OF ADMINISTRATION (ADM)
To:	NRC OFFICE OF ADMINISTRATION (ADM)
Shared Package
ML20137Z576	List: ML20137Z571 ML20137Z886 ML20137Z904
References
NUDOCS 8512110436
Download: ML20137Z886 (12)

Text

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/ APR 121985 MEMORANDUt1 FOR: Files THRU: William 0. Miller, Chief License Fee Management Branch, ADM FR0i4: C. James Holloway, Jr., Assistant Chief License Fee Management Branch, ADM

SUBJECT:

IE-HQ AND REGIONAL OFFICE PROFESSIONAL STAFF HOUR DATA Part 170 of the Commission's regulations was revised effective June 20, 1984. Section 170.12(b) provides that for each application for which the review charges are based on full costs and the application has been pending with the Comission for six months or longer, the first bill for accumulated costs would be sent to the applicant after the rule became effective. For construction permit applications, the bill would include the professional staff hours and contractual costs expended from the date the application was filed through June 23, 1984. For operating license applications under review, the bill would include professional staff hours and contractual services costs from the date the construc-tion permit was issued through June 23, 1984. The date of June 23, 1984, was used for the end of the reporting period instead of June 20, 1984, the effective date of the rule, because professional staff hours .

are reported to the Regulatory Information Tracking System (RITS) on a weekly basis and can be pulled from the computer only in weekly incre-ments.

In order to complete the initial billings required by 170.12(b), a detailed analysis and review was performed of professional staff hour computer data provided by IE-HQ and the Regional Offices relating to 55 cases (Enclosure 1) undergoing review. The data provided to LFMB was used in the initial fee billings. Specifically, the activity codes used by the professional staff in IE-HQ and the Regions to charge hours to the specific dockets were reviewed. In each of the cases, a deter-mination was made as to whether the hours shown in the computer report should be included or excluded from license fee recovery for the period through June 23, 1984. Those activity codes which were include'l for license fee recovery are listed in Enclosure 2. Activity codes which were excluded from fee recovery are shown in Enclosure 3. The activity codes included for and excluded from license fee recovery will change for those inspections conducted on or after June 24, 1984. A separa~te 8512110436 851206 PDR ADOCK 05000322 O PDR

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Files II memorandun to files was written for each individual case showing the professional staff hours and contractual services costs expended by IE-HQ and the Regional Offices for the various activity codes.

A review of the activity codes in Enclosure 2 shows that only the professional staff hours through June 23, 1984, relating to the mutine inspection program have been included for fee recovery. When the March 23, 1976, fee schedule became effective, the NRC assessed fees for the first time for routine inspections only. For fee purposes, construc-tion appraisal team (CAT) inspections, integrated design inspections (IDI), emergency pre appraisal team (PAT)paredness inspections and (EP)systematic inspections, allegations, appraisal performance of licensee performance (SALP) were not considered routine inspections and thus were outside the scope of fee recovery. In fact, the Comnission indicated on page52461(170.3 Definitions) of the Proposed Notice of Rulemaking, dated Noveriber 22, 1982 (effective June 20,1984) that " Inspections include . . . non-routine inspections such as reactive inspections, investigations, incident / accident response, performance appraisal inspections, enforcement activities, special emergency preparedness inspections and systematic appraisal of licensee perfonnance." It was the intent when the March 23, 1978, fee schedule was developed that CAT, PAT, IDI, and EP inspections, allegations, and SALP were clearly outside the scope of the routine inspection program and would not be recovered through inspection fees. This matter was discussed on September 18, 1984, with the Director and Deputy Director, ADM3 and it was agreed that in determining the costs to be assessed for those reactors undergoing operating license review under the fee schedule effective June 20, 1984, any costs relating to the types of inspections mentioned above would not be included in the license fees assessed for the period through June 23, 1984. The costs for those kinds of inspections conducted on or after June 24, 1984, for CP or OL applications under revfew could be recovered since the revised fee schedule permits recovery of costs for both routine and non-routine inspections.

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C. James Holloway, Jr., Assistant Chief License Fee Managssent Branch Office of Administration

Enclosures:

As stated DISTRIBUTION:

APPROVED: Actual Manpower File (each case in Encl. 1)

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Enclosure 1 Inspection and Enforcement and Regional Office Construction Permit and Operating License Reviews

1. Beaver Valley 2 27. Midland 1

2. Bellefor.te 1 28. Hidland 2

3. Bellefonte 2 29. Millstone 3

4. Braidwood 1 30. Nine Mile Point 2

5. Braidwood 2 31. Palo Verde 1

6. Byron 1 32. Palo Verde 2

7. Byron 2 33. Palo Verde 3 c

8. Callaway 1 34. Perry 1

9. Catawba 1 35. Perry 2

10. Catawba 2 36. River Bend 1

11. Clinch River 37. River Bend 2

12. Clinton 1 38. Seabrook- 1

13. -Comanche Peak 1 39. Seabrook 2

14. Comanche Peak 2 40. Shoreham

15. Diablo Canyon 1 41. Skagit/Hanford 1

16. Diablo Canyon 2 42. Skagit/Hanford 2

17. Fermi 2 43. South Texas 1

18. Grand Gulf 1 44. South Texas 2

19. Grand Gulf 2 45. Susquehanna 2

20. Harris 1 46. Vogtle 1

21. Harris 2 47. Vogtle 2

22. Hope Creek 1 48. Waterford 3

23. Limerick 1 49. Watts Bar 1

24. Limerick 2 50. Watts Bar 2

25. Marble Hill 1 51. WNP-1

26. Marble Hill 2 52. WNP-2

53. WNP-3

54. Wolf Creek 1

55. Zimmer I

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Enclosure 2 INSPECTION AND ENFORCEMENT AND REGIONAL OFFICE CONSTRUCTION PERMIT AND OPERATING LICENSE REVIEWS Activity Codes Included For License Fee Recovery Through 6/23/84 Routine Inspection Program - The routine inspection program consists of scheduled inspection activity.

Activity Codes Description of Activity Codes

. 1TA Off-site routine safety inspection effort 1TO All other routine safety inspection effort ITV Preparation for routine safety inspection 1TW On-site routine safety inspection effort ITX In-office routine safety inspection effort ITY Preparation for routine safety inspection report writing ITZ Routine safety inspection report writing 2TA Off-site routine environment inspection 2TO All other routine environmental inspection effort 2TW On-site routine environmental inspection effort -

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2TX In-office routine environmental inspection effort 3TA Off-site routine safeguards inspection effort 1/

3TO Routine safeguards inspection effortM 3TW On-site routine safeguards inspection effort 1/

3TX In-office routine safeguaros inspection effort 1 O Included for operating license fee recovery since professional staff effort was expended on or after 3/23/78, the date of the revised rule pennitting the recovery of safeguards costs.

Activity Codes Description of Activity Codes APD Routine documentation API Routine on-site /off-site inspection APP Routine inspection preparation DOC Routine documentation PAP Routine preparation PPI Routine inspection Other Activities Included For Fee Recovery BC Emergency Preparedness licensing review BH Quality Assurance ReviewsE/

J90 Review comment and assistance to licensing LEP Licensing-emergency preparedness LOA Licensing other activities LRA Licensing reactor activities NSS Part 50-security plans OLA Operator Licensing Activities PFE Power facility initial exam PSA Performing security activities PSR Licensing action - power reactor, plant specific QAT Quality Assurance reviewsEl 110 Safety CP activities U Included for operating license fee recovery if review was of Chapter 17 of the FSAR and not a topical report review.

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, Activity Codes Description of Activity Codes 131 Power facility initial exams 135 Training Program Review relating to initial operator e.vams 140 Safety review of partial power application Operator Licensing Initial hot and cold operator exams 1

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Enclosure 3 INSPECTION AND ENFORCEMENT AND REGIONAL OFFICE CONSTRUCTION PERMIT AtiD OPERATING LICENSE REVIEWS Activity Cooes Excluded From License Fee Recovery Through 6/23/84 Activity Codes Description of Activity Codes AIK1 Program development and other support AEP Inspection program management and administration AFE Allegation follow-up effort AFI Freedom of information ALR ACRS operating license review (reported separately)

ANT Non-technical training A0A Other administrative APA Honitor case review APL ACRS Monitor Case Progress (reported separately)

ARD Reactive documentation ARI Reactive on-site /off-site inspection ARP Reactive inspection preparation ASl Inspector support to other offices AST Inspector support to other offices AT Travel - inspection related ATV Travel BA1 Normal enforcement activities BA2 Escalated enforcement activities BB Systematic assessment licensee performance (SALP)

BD1 Emergency response support activities BD2 Response to events / incidents

Activity Codes Description of Activity Codes BE Technical support for investigations BF-Laboratory technician activities BG Contract monitorship BH Quality Assurance Reviewsl/

BJ Allegation follow-up B00 Training BR) Reactive preparation BTA Off-site inspection training effort BTW On-site inspection training effort BZX In-office regional training C00 Travel C01 Docket Travel COT Code unknown D00 Professional meetings DPP Program development, coordination and assessment DR1 Reactive documentation EPG Emergency response support EPI Emergency preparedness inspection EVA Event analysis EVC Event correspondence

/ t Excluded from fee recovery since reviews covered by a topical report.

3 Activity Codes Description of Activity Codes HLE Escalated enforcement H00 Absence JAC Assist NRR - caseload forecasting JA0 Commission Information Requests JMO Management supervision JHK Principal correspondence JNO Management assistance JNP Management - information systems JNR Planning / forecasting J0L Budget J0M Administrative support i

J00 Indirect and overhead JQO Cicrical support J- 80 Overhead review, comment, assistance to operations LKB F0IA - document search '

LKM F0IA - other related activities NMS N!!SS related activity Gild Office management direction PAA Administrative support PB1 Providing public information PCl Providing Congressional information PDA Program development and appraisal PEl Enforcement