ML20059N499
| ML20059N499 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 09/28/1990 |
| From: | Beckman W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9010160120 | |
| Download: ML20059N499 (2) | |
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@MEM Consumers i
l POW 8r wiiii m t seekm.n 1%nt Manager 1
AMEN 8EAWE P M ME i
Dig Rock Point Nuclear Plant,10269 US 31 North, Charlevolm MI 49720 September 28, 1990 t
Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIC ROCK POINT PLANT -
10CFR171 FISCAL YEAR 1991 ANNUAL FEE EXEMPTION REQUEST i
Pursuant to 10CFR171.11, for the reasons set forth herein, Consumers Power Company requests an exemption from the annual fee requirements of 10CFR171.15 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 May 12, 19898 March 29, 19881 and April 15, 1987. The May 12, 1989 NRC letter granted a partial exemption for Big Rock Point by reducing the annual fee from the FY 1989 rate of $1,118,000 to $95,030. This amount equated to 8.5% of the plant's annual fee.
In support of this request, Consumers Power Company submits the following:
1.
Big Rock Point is the holder of NRC License No. DPR-6, dated May 1, 1964.
The plant is the oldest operating General Electric boiling water reactor and one of the oldest operating commercial nuclear generating plants in the United States.
Big Rock Point's operating license expires on May 31, 5
2000. This leaves'less than 10 years of plant operation remaining.
l Because of Big Rock Point's age, many of the generic costs underlying the l-annual fee rule are not relevant to Big Rock Point.
t 2.
In addition to being one of the oldest cosunercial reactors, Big Rock Point i
is the smallest operating commercial nuclear generating plant in the United States.
Big Rock Point's output is 67 MWe net. This output is l:
more than one order of magnitude less than the average modern vintage commercial generating plant.
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 newer, larger generating plants. An increase of this magnitude is unreasonable for a generating plant of this small size. The j
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j Big Rock Point Plant 10CFR171 Annual Fee Exemption Request September 28, 1990 impact of this surcharge is approximately 12 times as great as it is for a typical modern vintage plant. Even without increased licenses fees, recent industry analyses have shown Big Rock Point's operating costs on a i
kilowatt-hour basis to be among 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 plants. 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.
Over the last several years, Big Rock Point performance has been at or above industry averages in SALP ratings, capacity factor and availability.
This has resulted in less WRC regulatory effort being spent on Big Rock Point.
6.
The NRC previously has granted partial fee exemptions-for Big Rock Point for fiscal years, 1987, 1988, and 1989. The basis for granting these ex6mptions essentially remains unchanged from those considered in the previously granted exemptions.
7.
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 adjustment 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 shut down.
l In conclusion, notwithstanding the uncertainty of ongoing congressional action on NRC fee collection, Consumers Power Company requests that a partial fee exemption be granted which requires Big Rock Point to pay not more than 8.5%
of the amount charged a typical boiling water reactor.
To ensure compliance l
with the requirements of 10CFR171.19 Consumers Power Company requests this exemption be grated prior to the first quarterly installment due date.
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W L Beckman Plant Manager a
CC Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point Director, Office of Administration and Resources Management, NRC Document Control Desk, Washington, DC, NRC l
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