ML20206G335
| ML20206G335 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 05/03/1999 |
| From: | Gabe Taylor SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-64FR15876, RULE-PR-170, RULE-PR-171 64FR15876-00026, 64FR15876-26, RC-99-0092, RC-99-92, NUDOCS 9905070176 | |
| Download: ML20206G335 (2) | |
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l May 3,1999 t
9 1%Y -5 Ali :13 RC-99-0092 OP-l RE
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900KET NUMBER t
Secretary.
,GPOSED RULE hk M*d/
U. S. Nuclear Regulatory Commission
[/( /ff7{f Washington, DC 20555-0001 Attention: Rulemakings and Adjudications Staff Gentlemen:
Subject:
VIRGIL C. SUMMER NUCLEAR STATION j
DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 COMMENTS ON PROPOSED RULE l
PROPOSED REVISIONS TO 10 CFR PARTS 170 AND 171 i
REVISION OF FEE SCHEDULES; 100% FEE RECOVERY, j
FY 1999 (64FR15875, April 1,1999) j South Carolina Electric & Gas Company (SCE&G) has reviewed the proposed notice of rule;naking. We fully endorse the comments prepared and submitted on behalf of the commercial nuclear power industry by NEl.
Additionally, we submit the following comments:
Shiftina ot Fees From 10CRF171 to 10CFR170:
The NRC plans to expand the fee structure of 10CFR170 (i.e. hourly fees) to include incident investigations, performance assessments and evaluations (except those for which the licensee volunteers at the NRC's request and which the NRC accepts), reviews of reports and other.submittals (such as Financial Assurance submittals, FSAR revisions and responses to Confirmatory Action Letters). These items were formerly under the fee structure of 10CFR171.(i.e. annual fees).
SCE&G agrees in part with this proposed rulemaking. Billing by the hour for
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services provided by the NRC would mean the licensee pays for only the services it t
receives while allowing the NRC to fully recover 100% of its operating cost, as mandated by law. However, as more services are shifted from annual fees or flat rates based on average review times to hourly rates, the opportunity for inefficiencies in these reviews and billing abuse becomes greater. An analogy is hiring a consultant without having the contractual ability to review time sheets or work progress for invoicing. There needs to be a cap on the hourly fees for a fiscal year to allow licensees to make budget forecasts as w61 as a cap on the increase 1
in total fees from year to year.
9905070176 990503 PDR PR 170 64FR15876 PDR Q()I NUCLEAR EXCELLENCE - A SUMMER TRADITIONI
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1 Secr:t:ry, U. S. Nucirr Regulatory Commission PR 990007 RC-99-0092 l
Page 2 of 2 l
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Also, the trend needs to move toward lower NRC fees. For a mature industry such as nuclear power, where the performance and safety record has increased significantly over l
the years, the regulatory fee burden should be decreasing.
Increase in Professional Hourly Fees:
i I
The proposed hourly billing rate of $141.00 per hour is extremely high. A typical multi-disciplined engineering consulting firm bills from $88.00 per hour forjunior level engineers to $139.00 per hour for firm principals. The proposed NRC professional hourly rate for all reviews and inspections under the jurisdiction of 10CFR170 equates to the billing rate of a consulting firm principal for every hour expended.
Capturino 100% of the Cost of the Project Manaaer:
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The NRC plans to fully recover the cost of time expended by Project Managers, except time spent on generic activities such as rulemaking and leave time. SCE&G firmly believes the licensee should not pay for training and administrative time and other time not directly attributable to a specific plant issue.
Soent Fuel Storace / Decommissionino Fee:
j SCE&G does not maintain an Independent Spent Fuel Storage Facility (ISFSF) for the V. C.
Summer Nuclear Station nor do we pay 10 CFR 72 fees for such. We have the adequate capacity in our Spent Fuel Pool (SFP), considering rack modifications, and do not plan to build an ISFSF for at least 15 years. However, under tile proposed rulemaking, will be obligated to pay fees for continuing to store spent fuel in the SFP until such time that an ISFSF is needed, without any realized services or benefits for those fees. In succinct terms, the NRC is mandating that we pay the ISFSF fees of other licensees. This is a fee that we feel is not appropriate for our customers to pay.
Additionally, had the DOE honored its court affirmed obligation to take possession of spent
. fuel by January,1998, this fee would not be an issue.
If you have any questions please call at your convenience.
l Very truly yours, i
I l
Gary J. Taylor DLJ/GJT/dr c:
J. L. Skolds NSRC W. F. Conway RTS (PR 990007)
R.R.Mahan File (811.02,170.001)
P., J. White DMS (RC-99-0092)
L.M.Padovan
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