ML20073P683

Comment Opposing Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery

ML20073P683
Person / Time
Site:	Pilgrim
Issue date:	05/13/1991
From:	Gina Davis BOSTON EDISON CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-56FR14870, RULE-PR-170, RULE-PR-171, RULE-PR-71 56FR14870-00465, 56FR14870-465, BECO-91-067, BECO-91-67, NUDOCS 9105220222
Download: ML20073P683 (2)

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George W. Davis sew vee Preso et - Nuci ., BECo 91- 067 U.S. Nuclear Regulatory Commission "' " Y I3' Document Control Desk Hashington, DC 20555 License DPR-35 Docket 50-293 Comments on the NRC Proposed Rule on Revision of Fee Schedules; 100% Fee Recovery Boston Edison Company endorses the nuclear power industry comments offered to the NRC by the May 13, 1991 Nuclear Management and Resources Council (NUMARC) letter entitled, " Proposed Rule - Revision of Fee Schedules; 100% Cost Recovery, 56 Federal Register 14870, Request for Comments".

As with any change in an established process, the implementation dynamics are not totally predictable and remain to be worked out during the transition period. One hundred percent NRC budget fee recovery from nuclear industry fees vice the U.S. Treasury presents uncertainties with respect to future legislative oversight roles and the NRC budget review and approval process.

Ensuring cost-effective expenditures and NRC staff workloads of proven cost-benefit is necessary for nuclear power to remain as a viable alternative to other power generations forms. As such, the NRC budget preparation process should include opportunities for public comment and input. He recommend wording be added to the beginning of $171.13 " Notice", to require the yearly proposed NRC budget request be published in-the Federal Register at least-90 days prior to the request being forwarded for legislative approval. -This will allow licensees, ratepayers, and consumers an opportunity for input early in the NRC budget planning cycle, yet allow the NRC to continue to meet the statutory mandate of Public Law 101-508.

a i Similarly, an additional provision should be included in the rule to enable

annual audits of NRC expenditure practices by a select team of industry elected representatives. This will afford utility managers an opportunity to more closely monitor and scrutinize the implementation of the NRC budget once

approved, and in turn provide the capability to justify and explain these a costs to their state regulatory commissions.

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G. H. Davis JDK/cic/5810 cc: See Page 2 9105220222 910513 h)

. PDR PR j 170 56FR14870 PDR

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BOSTON EDISON COMPANY U.S. Nuclear Regulatory Commission Page 2 cc: Mr. R. Eaton, Project Manager Division of Reactor Projects - I/II Office of Nuclear Reactor Reguiation Mail Stop: 1401 U. S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, MD 20B52 U. S. Nuclear Regulatory Commission Region I 9 475 Allendale Road King of Prussia, PA 19406 Senior NRC Resident Inspector Pilgrim Nuclear Power Station w - - - _ - - - - - , _ _ - - - -------- -- - -"--- --- - - - ' -