ML20046C782
| ML20046C782 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 08/04/1993 |
| From: | Donnelly P CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| FRN-58FR21662 NUDOCS 9308120107 | |
| Download: ML20046C782 (2) | |
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g Consumers Patrick M Donnelly Plant Manager AUCHIGAN'S PROGRESS Big Rock Pomt Nuclear Plant,10269 US-31 North. Charlevoin. MI 49720 August 4, 1993 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
10 CFR 171 FISCAL YEAR 1994 ANNUAL FEE EXEMPTION REQUEST Pursuant to 10 CFR 171.11, for the reasons set forth herein, Consumers Power Company requests an exemption from the annual fee requirements of 10 CFR 171.15 for Big Rock Point. As stated in the Federal Register notice which published the annual fee rule, the NRC recognizes the problem that some licensees of smaller reactors may have in paying substantially increased fees and, therefore, has provided for fee exemptions. The NRC has previously granted exemptions in response to this annual request by letters dated July 23, 1992; July 16, 1991; September 28, 1990; May 12, 1989; March 29, 1988; and April 15, 1987.
By letter dated July 28, 1993 the NRC granted a partial exemption by reducing the annual fee from FY 1993 rate of $2,939,000 to $249,815. This amount equated to 8.5% of the plant's annual fee.
In support of this request, Consumers Power submits the following:
1.
Big Rock Point is the holder of NRC License No. DPR-06, dated May 1,1964.
The Plant is tne oldest operating General Electric boiling water reactor and the oldest operating commercial nuclear generating plant in the United States. Big Rock Point's-operating license expires on May 31, 2000. This leaves less than seven years of plant operation remaining.
Because of Big Rock Polat's age, many of the generic costs underlying the annual fee rule are not relavant to Big Rock Point.
2.
In addition to being one of the oldest commercial reactors, Big iock Point is the smallest operating commercial nuclear generating plant in tne United States. Big Rock Point's output is 67 Mwe net. This output is more than one order of magnitude less than the average modern vintage commercial generating plant.
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BIG ROCK POINT PLANT 10 CER 171 ANNUAL FEE EXEMPTION REQUEST i
August 4, 1993 3.
A surcharge in the form of an annual license fee incrementally increases Big Rock Point's cost of electrical production by_ a significantly larger amount than for a newer, larger generating plant. An increase of this magnitude is unreasonable for a generating plant of this small size. The impact of this surcharge is approximately 12 times as great as it is for a typical modern vintage plant.
Even without increased licensee fees, recent industry analyses have shown Big Rock Point's operating costs on a kilowatt-hour basis to be the highest in the industry.
4.
Big Rock Point's small size and rural location is less of a potential hazard to public health and safety than most other commercial nuclear generating pl ants.
Plant age, size and location have also been recognized by the NRC in other regulatory contexts. These include the emergency planning zone, insurance and backfitting rules.
5.
The NRC previously has granted partial fee exemptions for Big Rock Point for fiscal years, 1987, 1988, 1989, 1990, 1991, 1992 and 1993.
The basis for granting these exemptions essentially remains unchanged from those considered in the previously granted exemptions.
6.
Comparison of the previously approved fees for Big Rock Point to the fees previously charged newer, larger reactors equates to approximately 8.5% for Big Rock Point. Nothing has changed to warrant adjustrents to this percentage.
Because Big Rock Point's kilowatt-hour output is small and the plant _is old, the cost-benefit of the annual fee should be recognized.
As stated in the Federal Register notice which published the annual fee rule, it is not the intent of the NRC to promulgate a fee schedule at such a level that smaller, older reactors would find it in their best economic interest to shutdown.
In conclusion, notwithstanding the uncertainty of ongoing congressional action on NRC fee collection, Consumers Power Company desires that a partial fee exemption be granted which requests Big Rock Point to pay not more than 8.5% of the amount charged a typical boiling water reactor, n
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n Patrick M Donnelly Plant Manager CC: Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point