NRC-88-0192, Comment Opposing Proposed Rule 10CFR170 & 171 Re Proposed Rev of Fee Schedules.Asks That NRC Allow Licensees to Be Fiscally Responsible by Publishing Revised Fee Schedule Applicable for Following Yr Vs Current Yr

Comment Opposing Proposed Rule 10CFR170 & 171 Re Proposed Rev of Fee Schedules.Asks That NRC Allow Licensees to Be Fiscally Responsible by Publishing Revised Fee Schedule Applicable for Following Yr Vs Current Yr

ML20151K822
Person / Time
Site:	Fermi
Issue date:	07/26/1988
From:	Goodman L DETROIT EDISON CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
CON-NRC-88-0192, CON-NRC-88-192, FRN-53FR24077, RULE-PR-170, RULE-PR-171 53FR24077-00012, 53FR24077-12, AC80-2-29, NUDOCS 8808030291
Download: ML20151K822 (1)

Text

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DOCKET NUMBER ,

{E170 ni lN ^

PROPOSED RULE YFK g ,

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• 7e Detroi.t - .. - u.,

Edison wm=""~ '88 JLL 27 P3 :31 oa-- -

UrmOCKL M i 4+ 02l July 26, 1988 B3 ant - NRC-88-0192 Secretary U. S. Nucioar Regulatory Commi=sion Attn Docketing and Service Branch Washington, D. C. 20555

Reference:

Fermi 2 NRC License No. 50-341 NRC Docket No. NPF-43 1 i

Subject:

Proposed Revision of Fee Schedulos The proposed Revision of Feo Schedities was published in the Federal Register, Vol. 53, No. 123 on June 27, 1988 for comment. The proposed rule change applies to Fiscel Year 1988, even though tho (

l fiscal year is nearing completion. The increase in costs is significant. The timing of the proposed rulo is such that the '

increase for 1988 could not be budgeted. In future years this will continue to be a problem. As a fiscolly responsibic organization, such retrofit increases in fees are difficult to manage.

It would be preferabic if this rule change and annual charges apply to r the following year, rather than to the current almost past fiscal ,

year. This would entail payments based on the previous year's NRC  !

1 budget, but would permit licensees to better preparc for the expenso. ,

a The proposed rule did not address how the tetrofit costs would bc

{

b illed . Will it be a lump sua for the first 3 quarters of fiscal year

19887 Will it bo added to the 4th quarter invoico? This needs to be ,

' addressed. -

t We recognize that Congress had mandated that the NRC collect a i

significant portion of its budget through foes. What we ask is that ,

i the NRC in turn allow us to be fiscally responsible by pubilshing a  !

revised fue schedule applicable for the following year vs. the current  !

4 year.

1 [

,, Sincerely, [

. 8800030291 000726 .

[

i h5 R24077 PDR /.:-- 0 '

L. S. Goodman Director Nuclear 1.icensing i cc Mr. A. 3. Davis '

{ Mr. R. C. Knop  ;

i Mr. T. R. Quay f i Mr. W. C. Rogers  ;

i Shaw, Pittman, Potts & Trowbridge

{

{ 2300 N. Street N.W., Washington, D. C. 20037 t