ML20137Z904

Forwards Summary of Results of Review of Plant Computer Printouts Provided by IE & Regions.Emergency Preparedness Insps Considered Nonroutine Insps Under 780323 Fee Schedule & Outside Scope of License Fee Recovery

ML20137Z904
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	10/23/1984
From:	Holloway C NRC OFFICE OF ADMINISTRATION (ADM)
To:	NRC OFFICE OF ADMINISTRATION (ADM)
Shared Package
ML20137Z576	List: ML20137Z571 ML20137Z886 ML20137Z904
References
NUDOCS 8512110442
Download: ML20137Z904 (9)

Text

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. Activity Codes Description of Activity Codes Pls Perfonning information systems support activities PlV Investigation PPil Performing personnel management activities PPS Performing special studies PPT Providing & preparing for testimony PRI Reactive on-site /off-site inspection

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PRM Petitions for rulemaking PRS Administrative support to other NRC offices PTG Support to IE HQ & other regional offices PTP Program third party QAT Quality assurance topical report RAH Regional assessment HQ RlH Respond to inquiries RT1 Incident / accident response

'RPE Regional office professional effort SLP Systematic assessment of licensee performance (SALP)

SR0 Support to regional offices '

'SR1 Site public relations SSS Support of special studies STA Support for technical assistance STF Support for problem facility ICA Inspection construction appraisal 101 Integrated design inspection es12110442 851206 DR ADOCK 050 2

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Activity Codes Description of Activity Codes IDV Independent design verification IMO Technical report review - standards INF INP0 follow-up 10R Inspection - other 10U Safety - review of operating experiences IPA Inspection performance appraisal 10A Off-site safety investigation effort lu0 Safety investigations lUW On-site safety investigation effort LUX In-office safety investigation effort IVO Safety inquiry activities lWO Safety enforcement lYO Safety specification technical studies 2VO Environmental inquiry activities 3UX In-office safeguards investigation effort 3UW On-site safeguards investigation effort 4UZ Part 21 recJest, review, and evaluation 4WD Part 21 - enforcement action 7VO Agreement state t non licensee inquiry activities 100 Safety activities not case related 115 Safety CP hearings 125 OL safety hearings 134 Certification ex?A

Activity Codes Description of Activity Codes 1321 Power facility replacement exam 1322 Power facility requalification exam 200 Environmental activities not case related 215 Environmental CP hearings 3TA Off-site routine safeguards inspection effortU 3TO Routine safeguards inspection effortU 3TW On-site routine safeguards inspection effortU 3TX 2 In-office routine safeguards inspection effort _/

No name Professional staff hours had either no name No act. code or no activity code listed in the computer Unidentified time printout so it was excluded from licensee fees.

U- Excluded from fee recovery since professional staff effort was expended before 3/23/78,

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UNITED STATES SI%g%

jf , NUCLEAR REGULATORY COMMISSION 3

• e j WASHINGTON D.C. 20655 OCT 2 31984 ME'MDRANDUM FOR: Files FROM:

C. James Holloway, Jr., Assistant-Chief. License Fee Management Branch, ADM

SUBJECT:

IE-H4 AND REGIONAL OFFICE PROFESSIONAL STAFF HOURS AND CONTRACTUAL SERVICES COSTS - SHOREHAM Enclosure 1 sununarizes the results of our review of the Shoreham computer printouts (Enclosure 2) provided by IE-HQ and the Regions. Of the 37,474.5 professional regular hours expended by IE-HQ and the regional staffs through June 23, 1984, 29,936 hours0.0108 days <br />0.26 hours <br />0.00155 weeks <br />3.56148e-4 months <br /> have been included for fee re-covery purposes. A total of $36,152 was expended for contracts. Of this amount, $20,552 was included for fee recovery. The remainder was expended for follow-up and annual emergency preparedness inspections. Emergency preparedness inspections are considered as non-routine inspections under 2 the March 23, 1978 fee schedule and thus fall outside the scope of license fee recovery.

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C ames lloway, J ., Assistant Chief  !

'l cense Fee Management Branch Office of Administration

Enclosures:

As stated a

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J SU N RY - SHOREHAM Regional Offices and IE Headquarters Professional Regular Hours Fiscal Year Include For Fees Exclude From Fees Totals Regional Offices 105.5 15.0 120.5 FY 1973 348.5 56.0 404.5 1974 1,303.0 217.0 1,520.0 1975 2,126.5 264.0 2,390.5 1976 2,053.5 307.0 2,360.5 1977 2,128.5 452.5 2,581.0 1978 1,775.0 600.5 2,375.5 1979 2,436.5 2,034.5 4,471.0 1980 1 ,701.5 177.5 1,879.0 1981  !

5,001 . 5 566.5 5,568.0 -

1982 1,060.5 6,596.5 1983 5.536.0 l 5,608.5 3,837.0 1,771.5 l 1984 (Thru 6/23/84) l 28,353.0 7,522.5 35,875.5 TOTAL REGIONS:

IE Headquarters

- 14.0 14.0 FY 1980 510.0 - 51 0.0 i 1983 1,073.0 2.0 1,075.0 1984 (Thru 6/23/84) 1,583.0 16.0 1,599.0 TOTAL IE HEADQUARTERS:

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! 29,936.0 7,538.5 37,474.5 GRAND TOTAL Al.L HOURS:

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-l Shoreham - Summary j IE Headquarters and Re,1 tonal Offices f

t Professional Staff Hours By Activity Codes loclude for Fes Ascovery FY 1973 FY 1974 FY 1975 FY 1976 FY 1977 FY 1978 FY 1979 FY 1980 FY 1981 lonal FY 1982 FY 1983 FY 1984 Totals ices Activity Codes ITV 12.0 1.0 16.0 - - - - - - - -

29.0 ITW 42.0 96.0 482.0 732.5 800.0' 962.5 80.5 - - - -

ITI 3.195.5 11.0 87.0 145.5 218.0 171.0 161.0 24.0 - - - - -

817.5 ITY 7.0 - - - - - - - - - - -

7.0 ITZ 33.5 7.0 24.0 - - -

64.5 ITO -

157.5 592.0 1.108.0 1.012.5 927.5 96.5 - - - - -

3*.894.0 ZTW - -

9.5 16.0 15.0 32.0 - - - - -

fix 72.5 6.0 - - - - - - -

2T0 -

6.0 28.0 52.0 53.0 45.5 - - - - - -

178.5 ITA - - - -

2.0 - - - - -

00C - -

2.0 484.5 837.5 303.5 1.408.5 1. 04 5.0 I PAP - -

4.079.0 293.0 392.5 337.5 729.0 402.0 PPI - -

2.154.0 796.5 1.206.5 1.060.5 2.864.0 4.029.0 -

9.956.5 131 - -

Sf.0 16.0 68.0

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Shoreham - Summary .

IE headquarters and Regional Offices Professional Staff Hours By Activity Codes Include For Fee Recovery FV 1973 FY 1974 Fy 1975 FY 1976 FY 1977 FY 1978 FY 1979 FY 1980 FY 1981 FY 1982 FY 1983 FY 1984 Totals 135 - - - - - - - - -

APO - - - - -

8.0 -

8.0 A#I - - - - -

955.0 955.0 APP - - - - -

2.317.5 2.317.5 kN - - - - -

538.5 538.5 10.0 10.0 Subtotal 105.5 348.5 1.303.0 2.126.5 Regions 2.053.5 2.128.5 1.775.0 2.436.5 1.701.5 5.001.5 5.536.0 3.837.0 28.353.0 IE Headeuarters LAA - - - - - - - - - -

510.0 1.073.0 1.583.0 Topal Included 106.5 348.5 1.303.0 For Fees 2.125.5 2.053.5 2.128.5 1.775.0 2.436.5 1.701.5 5.001.5 6.046.0 4.910.0 29.936.0 Enclude From Fee Secovery s C00 15.0 34.0 182.0 259.0 298.0 343.5 328.0 386.5 JNK 117.5 398.0 473.0 -

4.0 - - - - -

2.8 34.5 IWO -

18.0 13.0 -

4.0 27.0 2.0 - - - -

100 - -

22.0 5.0 - -

50.0 1u0 - - -

27.0 9.0 27.0 3.5 - - -

luA - - - -

39.5 6.0 - - - - -

IUW - - - -

6.0 17.0 - - - -

luz - - - - '

17.0 11.0 - - - - - -

11.0 s

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[ IE Headquarters and Regional Offices Professional Staff Hours By Activity Codes Enclude Fres Fee Recovery FY 1973 FY 19Z4 FY 1975 FY 1976 FY 1977 FY 1978 FY 1979 FV 1990 FY 196) FY 1983 FY 1984 FY 1982 Totals JMD - - -

37.0 60.0 - - - -

105.0 JON - - - - -

151.0 304.5 2.0 457.5 J00 - - - - - -

5.0 9.0 - - - -

14.0 PAA - - - - - -

16.0 - - - - -

16.0 i PFT - - - - - -

3.0 15.0 - - - -

18.0 Pal - - - -

3.0 90.5 24.0 32.0 319.0 -

468.5 Piv - - - - - -

12.0 554.0 8.0 47.0 91.5 -

712.5 RTI - - - - - -

32.0 - - - - -

32.0 Blu - - - - - -

8.0 - - - - -

8.0 AST - - - - - - - 17.0 - - - -

17.0 841 - - - - - - -

198.0 8.0 33.5 51.5 -

291.0 000 - - - - - - -

32.0 - - - -

32.0 COT - - - - - - -

6.0 - - - -

6.0 Dal - - - -

258.0 12.0 55.0 38.5 -

363.5 000 - - - - - - -

16.5 - - - -

16.5 PAA - - - - - - -

77.5 8.0 - - -

85.5 Ph1 - - - - - - -

2.0 - - - -

2.0 Sal - - - - - - - - -

1.0 9.0 -

10.0 1321 - - - - - - - - - -

58.0 24.0 82.0 PEI - - - - - - - - - -

20.0 -

20.0 AA0 - - - - - - - - - - -

326.0 326.0 ARJ - - - - - - - - - - -

559.5 559.5 AAP - - - - - - - - - - -

74.0 74.0 e

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IE Heedguarters and tegtonal Offices Professtenal Staff Hours By Activity Codes Esclude Free Fee Recewery FY 1973 FY 1974 FY 1975 FY 1976 FY 1977 FY 1978 FY 1979 FY 1980 FY 1981 FY 1962 FY 1983 FY 1984 Totals AST - - - - - - - - - - -

14.0 14.0 Asl - - - - - - - -

1.0 1.0 AT - - - - - - - - - - -

500.0 500.0 SA2 - - - - - - - - - - -

9.0 9.0 at - - - - - -

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- - - - - 64.0 64.0 802 - - - - - - - - - - .- 10.0 10.0 AE - - - - - - - - - - -

155.0 155.0 l SJ - - - - - - - - - - -

33.0 33.0 STid - - - - -

21.0 - - - - - -

21.0 Subtotal .

Anglens 15.0 56.0 217.0 264.0 307.0 452.5 600.5 2.034.5 177.5 566.5 1.060.5 1.771.5 7.522.5

' IE Needeuarters

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155 - - - - - - -

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- - - - 2.0 2.0 PSI - - - - - - 14,0 - - - -

14.0 Total tacluded 15.0 56.0 217.0 264.0 307.0 452.5 600.5 2.048.5 177.5 from Fees 566.5 1.060.5 1.773.5 7.538.5 Ramo TOTAL ALL NOURS 120.5 404.5 1.520.0 2.390.5 2.360.5 2.581.0 2.375.5 4.485.0 1.879.0 5.568.0 7.106.5 6.683.5 37.474.5 a

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• SHOREHAM IE-HQ CONTRACTS l

FIN # Description Amount B-2191 Technical Assistance for $ 15,600.00 E Emergency Preparedness Inspections B-1302 Technical Assistance for 20,551.99 Non-Destructive Evaluation .

$ 36,151.99 l

M Amount excluded from fee recovery since Emergency Preparedness inspections were considered as non-routine inspections under the March 23, 1978 fee schedule.

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ENCLOSURE 1

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PPC PROCEDl!Rl5 FOR EX1L ADING PAYMLN1 DATES OF LICENSE FEE Bitt IhGS Fees are billed in accordonce with the schedules and staff hour rates contained in 10 CFR Part 170. Interest on the amount billed accrues from the date on which notice of the debt is maileo, but may not be charged if the amount due is paid within 30 days af ter saio date. 31 U.S.C. (3717.

If the 30 day period is extended, interest will be waived provided the debt is paid before the expiration of the extended period. The 30 day period may be extended, at NRC's discretion, in accordance with the following procedures,

1. The Division of Accounting and finance, Office of Resource Management, Nuclear Regulatory Commission, before expiration of the 30 day period, must receive the debtor's written request for an extension of the period. The request must explain why the debt is incorrect in fact or in law. 10 C.F.R. 515.31. If the request is not received withiri the 30 day period, it will automatically be denied.

2. The debtor's explanation must have merit for the NRC to extend the 30 <

day period. A request is deemed to have merit if it causes the NRC to

, question whether the amount originally billed is correct.

A. If the explanation has merit, the NRC will notify the debtor in writing that the request is granted and that the 30 day period will be -

extended to a date certain, which shall be tated on a revised bill and shall be approximately 15 days efter the date the revised bill is mailed. The a amount on the revised bill shall constitute a final determination of the existence or amount of the debt. A final determination by NRC for this purpose need not await the outcome of litigation or further administrative review. Further extensions of the date stated on the revised bill will not be granted. If the amount on the revised bill is not paid on or before the )

date stated on the bill, interest from the date of mailing the origia.al bill f, will become due and payable.

B. NRC may, at its optiun, request a meeting with the debtor's '

representatives to receive further evidence or arguments supporting the debtor's contentions. i C. A request for an extension may be granted either with respect to 4 the entire amount originally billed or with respect to a portion of the 1 amount originally billed. In the latter case the remainder of such amount d

remains due end payable as originally billed. If not paid on or ,1 before that datE, interest from the date of mailing the original bill Will become due and payable.

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.D. If the debtor's explanation does not have merit and does not cause the NRC to question whether the amount originally billed is correct, the request will be denied. Failure cf NRC to notify a debtor before the end of ,

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the 30 day period that a request for an extension has been denied will not  !

, constitute grounds for a waiver 6t interest.

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The assertion that the bill is unsuppurted by a sufficiently detailed breakdown of dates, hours, rates, and other data does not constitute an explanation of why the amount billeo is incorrect in fact or in law. If the debtor views information furnished with the bill as insufficient for the

~oose of a request for an extension, the debtor should seek the necessary

.ntorination as soon as possible in order that a request for extension can be submitted within the 30 day period.

3.

_ If an extension of the 30 day period is granted and the amount originally billed remains unchanged, such extension shall be stated on the revised bill as provided in 2A above.

4.

_NRC records in support of billed fees are not subject to audit by non-Governmental entities. However, copies of records desired by a debtor can be made available to the debtor if they are reproduced at the debtor's expense.

See 10 C.F.R. 69.14 entitled Charges for Production of Records.

5.

The rate of interest assessed shall be the rate of the current value of funds to the United States Treasury (i.e., the Treasury tax and loan account rate), as prescribed and published by the Secretary of the Treasury in the Federal Register and the Treasury Fiscal Requirements Manual Bulletins annually or quarterly, in accordance with 31 U.S.C. s3717. See 4 C.F.R.

$102.13(c).

s 6.

NRC is required to assess a penalty charge, not to exceed 6 percent a  ;

year, on any portion of a debt that is delinquent for more than 90 days, 4 C.F.R. %102.13(e).

charges at the rate of 6 percent a year.The NRCshall This charge hasbe determined calculated on or it shall asj]

that after the 91st day of delinquency, but shall accrue from the date that the debt became delinquent.

A debt is considered " delinquent" if it has not been paid by the revised bill. date specified in NRC's initial bill or by the date stated in the 4 C.F.R. 9101.2(b) 7.

NRC will promptly refund to a debtor any amount which is later determined to be an overpayment, including interest, if any, which was paid by the debtor on such amount.

a license fee which was paid to NRC and is later refunded.NRC is not authoriz l

8. .

Requests for extensions of the 30 day period should be submitted to the .

Division of Accounting and Finance, Office of Resource Management, U.S.

Nuclear Regulatory Commission, Washington, D.C. 20555. Telephone requests for extensions will not be considered. Payment should be made as indicated on the original or revised bills.

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. . . ; armameer LONG ISLAND LIGFQ3MS COMPANY SHOREHAM NUCL. EAR POWER STATION P.o. sox eie, NORTH CULlNTRY A IN , N.Y 11792 '

pl JOHN D. LEONARD, JR.

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SNRC-1218 Mr. William O. Miller, Chiej License Fee Management Branc'1 Office of Administration U.S. Nuclear Regulatory Com aission e _

Washington D.C. 20555 ,

Bill Number D0191

• Operating License neview Fee Shoreham Nuclear Power Station Docket No. 50-322

Dear Mr. Miller:

This letter will confirm recent telephone conversations between members of my staff anc. Ms. Reba Diggs, NRC Office of Ahrinia .

tration, regarding our review of the background records provieled-in support of the NRC Operating License review costs of

$4,172,350.00 through June 23, 1984. Of the seven review element costs and their substantiating records, two elements cannot be j reconciled with the background records provided; NRR Subcontract )

Costs of $966,512.0J and 28,353 Region Manhours. Therefore, we would appreciate r<. viewing and discussing, with appropriate NRC- '

personnel, the tollowing requests for additional information, including written documentation where available:

1. Review information for the accumulation of $966,512.00 ,

for NRR Subcontractor costs.f The previously provided background material'does not indicate how thyt total- I was derived. '

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2. Any additional information associated with subcontrac-tor costs for both NRR and I&E HQ, such as invoices,  !

purchase orders, etc., which will show what services were contracted and the basis for consultant billings to the NRC.

nformation regarding the 28,353 professional staff 3.

manhours hours expended by the regions, (i.e., which elements of work efforts were considered billable and which were considered non-billable, and why). The data l

package previously provided does not explain how the staff hours were established.

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4. Any additional supporting documentation for profes-sional staff hours expended, such as time cards, work summary sheets, etc. and the criteria used for I segregating billable and non-billable hours. j S. An explanation of the interest and penalty calculations I billed to Long Island Lighting.

f K'e would appreciate the opportunity to meet with members of your staff to discuss the above questions. Please feel free to contact Mr. John Morin at (516) 929-8643 to arrange a mutually convenient date. We would suggest sometime during the week of December 1, 1985.

Very truly yours, f,{

dIt Leonard, Jr. .

Vice President, Nuclear Operations JPM/ll cc: J. A. Berry R. Caruso R. Diggs w

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