ML20077C989

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

ML20077C989
Person / Time
Site:	Comanche Peak
Issue date:	05/21/1991
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-56FR14870, RULE-PR-170, RULE-PR-171, RULE-PR-71 56FR14870-00486, 56FR14870-486, TXX-91188, NUDOCS 9105240123
Download: ML20077C989 (2)

Text

DOCKET NUMBER FROPOSED RULE N '/6 / 74 F /W [5 (5% M iv e90)

, M.- Log # TXX 91188 c;I'- l CZ File # 10009 ' '

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r = 71 W,Y 21 P329 ltlELECTRIC

_.(- J, l i l M ilhave J. Cahill. Jr. l Esrcunn s*wr besulew Secretary of the Commission U. S. liuclear Regulatory Commission Atto: Docketing and Service Branch Washington. D. C. 20555

SUBJECT:

COMAf1CHE PEAK STEAM ELECTRIC STATION (r.PSES)

DOCKET N05. 50 445 AND 50-446 COMMENTS ON PP0 POSED RULE - 10CfR PARTS 71: 170; 171 REVISION OF FEE SCHEDULES: 100% TEE REC 0VERY TEDERAL REGISTER VOL $6. NO. 71. 14870 Ge n t 1 erre n :

In response to the Subject request TV Electric hereby provides the following comments.

TV Electric generall.v enaurses the comments submitted by NUMARC on behalf of the nuclear industry and would .ibe to tale this opportunity to highlight certain of the that submittel's comments which we believe to be particular?y noteuorthy.

We agree with the NUMARC general comment whirh observes that Public Law 101 508. section 6101, subtitle B. subsection (c)(2) allows the NRC to collect an amount which genroximates 100 percent of the budget authority. Clearly the Commission has the statutory authority to remove f rom the fee basis those costs f or which a reasonable association cannot be established between the regulatory service provided and the recipient licensee. The Commission should exercise this authority when considering the f ee basis for such costs as those associated with educational institutions, activities rendered to other federal Agencies or other activities which can be characterized as having a broad national interest.

We concur with the NilMARC r.omment and proposal regarding the deferral of ihe collection of the balance due for the 1991 10CFR171 annual fee urt.I calendar year 1992, divided evenly on a per quarter basis. Such action will allow utilities to adequately plan for the necessary cash flow required to satisfy tne fee rather than having to male short term decisions which may be at the expense of o'.her 1991 budgeted Operations and Maintenance activities.

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9105240123 910521 PDR PR 170 06FR14070 PDR

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400 Nonh Ohve Street L B. 81 Dallas, Tenas 752ce

TvX 91188 Page 2 of 2 Finally, we believe in concert with NUMARC that provisions must be provided within the rule to allow for public comment and input during the NRC's budget preparation process. Issues such as:

- Percent of FTE's considered as overhead, general and administrative.

- Cost of contract services, cost-effectiveness of generic programs.

elimination of duplicities between NRC and industry sponsored initiatives and 1

NRC staffing growth.

These issues should be subject to formal opportunities for input from both the utilities and the ratepayers responsible for covering the Commission's budget.

This should also include the requirement to provide each utility with a detailed accounting, to the extent required by the responsible Public Utilities Commission and accounting practices, to convey both and understanding and basis for the allocations of the 10CFR170 and 171 fees.

Sincerely,

,$s i i William J. Cahill, J .

RGS/grp c Mr. R. D. Martin, Region IV Resident inspectors, CPSES (2) l Mr. J. W. Clifford, NRR l

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