ML20141G353
| ML20141G353 | |
| Person / Time | |
|---|---|
| Site: | Satsop, Washington Public Power Supply System |
| Issue date: | 01/06/1986 |
| From: | Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Miller W NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| GO1-86-0002, GO1-86-2, GO3-86-004, GO3-86-4, NUDOCS 8601100153 | |
| Download: ML20141G353 (5) | |
Text
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,p Washington Public Power Supply System 3000GeorgeWashingtonWay P.O. Box 968 Richland, Washington 99352-0968 (509)372-5000 January 6, 1986 G01-86-0002/G03-86-004 Docket Numbers:
50-460/50-508 William 0. Miller, Director License Fee Management Staff Office of Administration U.S.- Nuclear Regulatory Comission Washingtor. D.C. 20555
Dear Mr. Miller:
Subject:
SUPPLY SYSTEM NUCLEAR PROJECTS WNP-1 and WNP-3 U.S. NRC BILLINGS FOR OPERATING LICENSE REVIEWS AND INSPECTION FEES
References:
a)
NRC Letter, William 0.
Miller to D.
W.
Mazur, dated December 28, 1984.
b)
Supply System Letter, G. C.
Sorensen to NRC, "U.S.
NRC Bill Nos. 00119 and D0120 dated December 26,1984", dated January 17, 1985.
c)
Supply System Letter, G. C. Sorensen to NRC, " Notice of Impending Audit", 85-JJW-394, dated September 13, 1985.
d)
NRC Letter, William 0. Miller to G.
C.
Sorensen, dated September 27, 1985.
As indicated by reference (a), the first bills for accumulated operating ifcense (0L) review costs for WNP-1 and WNP-3 were $518,385 and $1,394,355, respectively.
The Supply System noted in reference (b) that the payments were made on a provisonal basis.
As a Municipal Corporation of the State of Washington, we have certain requirements pertaining to documentation and verification of expenditures of public funds.
We indicated in reference (b) that we planned to perform an audit in the fall of 1985 to review documenta-tion and calculations in support of the billings.
When informed via reference (c) of our plans to audit, you responded by reference (d) that NRC records are not subject to audit by non-Governmental entities.
Reference (d) did, however, provide supporting documentation which was the basis for the billings.
You stated that if we believed an error exists in the computation, that fact, with supporting evidence should be presented to your office in writing.
pa%M@e
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William O. Miller G01-86-0002/G03-86-004 Page 2 January 6, 1986 We have reviewed the supporting documentation and have, in fact, discovered what we believe to be an error in the billings for WFP-3 (Bill No. D0-120).
WNP-3 received a construction permit (CP) in April 1978 Your documentation shows that we were billed for 9,135 hours0.00156 days <br />0.0375 hours <br />2.232143e-4 weeks <br />5.13675e-5 months <br /> of NRR staff time in the years 1974-1978 Staff time during this period would have been included in the fee which was paid upon receipt of the CP (April 11, 1978).
It is our under-standing that the first OL billing was to be for the period from the date of issuance of the CP (April 11, 1978) to June 23, 1984 According to your documentation it appears that we were overbilled 9,135 manpower hours for NPR OL review.
Should you find merit in this claim, please reimburse the Supply System the appropriate amount.
Our review also resulted in some questions regarding details of the bill-ings.
Those questions are delineated in the attached table.
Please review them and inform us of your disposition.
If you have any questions please contact D.
W.
Coleman, WFP-3 Project Licensing Manager, (206) 482-4428, Ext. 5436 Very truly yours, d7A1W G. C.
rensen, Manager Regulatory Programs DWC/tn Attachment cc: Mr. J. A. Adams, NESCO Mr. R. M Boucher, Pacific Power & Light Company Mr. W. L. Bryan, Washington Water Power Company Mr. J. Crnich, Ebasco - Elma Ebasco, Elma Mr. J. R. Lewis, Bonneville Power Administration Mr. P. V. Myers, Puget Sound Power & Light Company Mr. N. S. Reynolds, Bishop, Liberman, Cook, Purcell & Peynolds Mr. D. Smithpeter, BPA Mr. B. D. Withers, Portland Genral Electric Company Document Control Desk - U.S. NPC
m SUPPLY SYSTEM REVIEW QUESTIONS OPERATING LICENSE REVIEW BILLINGS FOR WNP-1 AND WNP-3
'WNP o _ NRR Review (Contractor)
The following contractor costs are identified:
Contractor Amount INEL
$ 1,754 PNL 8,000 ZGAGB 205 BNL 1,753
?
3,783 INEL 34,098 Total WNP-1 NRR Review Costs 14.9.593 (Contractor) Questioned A.
For.each of these please:
1.
Describe the work performed.
2.
Identify or describe the deliverable product received from the Contractor.
3.
State why the costs are charged to WNP-1 in, view of the limited NRC technical review on WNP-1 since July 1982.
The only NRC reviews that have been perfomed on WNP-1 since Mid-1982 that the Supply System is aware of concern requests for application of ASME III code cases, QA changes reported to the NRC as required by 10CFR50.55(f)(3) and a recent review of WNP-1 against Regulatory Guide 1.97 Rev.
2.
If additional reviews have been perfomed that justify the above costs, please identify them.
B.
Specifically, please:
1.
Identify the Contractor "ZGAGB".
2.
Identify the Contractor for which the $3,783 is billed.
o NRR Review (Staff)
IN QUESTION A handwritten summary of "WNP-1" Hearing Changes" is 539.5 provided.
It is our understanding that we are not to be billed for the cost of contested hearings.
i SUPPLY SYSTEM REVIEW QUESTIONS OPERATING LICENSE REVIEW BILLINGS FOR WNP-1 AND WNP-3 j
WNP-1 (Cont'd)
NUMBER OF HOURS o NRR Review (Staff) (Cont'd)
IN QUESTION The suonary includes several items of CP costs which 287.5 appear to be inappropriate charges for an OL review.
- We understand " TAC" is time spent in review, evaluation, 694.5 and preparation of ifcensing actions for unanticipated events at operating facilities. Such charges appear to be inappropriate for a project with a status such as WNP-1.
1977 This is an inappropriate charge for WNP-1 2
Reactor Operator Exams 1982 This is an inappropriate charge 2
Post ACRS (0L) 1983 This is an inappropriate charge 1
Post ACRS (0L) 1984 This is an inappropriate charge 54.5 Post ACRS (OL)
Total WNP-1 NRR Review (Staff) Hours
~~~~~~~~~
1. 581. 0 Questioned WNP-3 o NRR Review (Contractor)
The following contractor costs are identified:
Contractor Amount BNL
$ 1,753
?
6,071
?
18,722
$26.546 Total WNP-3 NRR Review Costs
~ ~ ~ ~ ~ ~ ~ ~ ~
(Contractor) Questioned
SUPPLY SYSTEM REVIEW QUESTIONS OPERATING LICENSE REVIEW BILLINGS FOR WNP-1 AND WNP-3
.WNP-3 (Cont'd) o NRR Review (Contractor) (Cont'd)
A.
For each of these please:
1.
Describe the work performed.
2.
Identify or describe the deliverable product received from the Contractor.
B.
Specifically, please:
1.
Identify the Contractors for which the $6,071 and $18,722 were billed.
NUMBER OF HOURS o NRR Review (Staff)
IN QUESTION 1981 The Supply System knows of no hearing in 20 Hearing (CP) 1981.
It is also our understanding that staff time in support of contested hear-ings is not a permissible charge for OL fees.
1981 The Supply System did not submit the WNP-3 38 Acceptance FSAR until June 1982. The acceptance Review (0L) review by NRR could not have begun until after that date.
1982 The WNP-3 draft environmental statement was 3
FES (0L) not issued until January 1984. Charges for the final environmental statement appear to be premature in 1982.
1983 The date of docketing for the WNP-3 OL app 11-37 Acceptance cation was August 1982. All NRC acceptance Review (0L) review questions were received prior to the end of 1982. Acceptance review charges in 1983 do not seem appropriate.
1983 As indicated above, it is our understanding 39 Hearings (OL) that staff time in support of contested hearings is not a permissible charge.
Total WNP-3 NRR Review (Staff) Hours
~ ~ ~ ~ ~ ~ ~137 Questioned