ML20207B460
| ML20207B460 | |
| Person / Time | |
|---|---|
| Issue date: | 08/13/1986 |
| From: | Holloway C NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Fonner R NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| Shared Package | |
| ML19303E617 | List: |
| References | |
| FRN-51FR24078, RULE-PR-171 AC30-2-12, NUDOCS 8612010053 | |
| Download: ML20207B460 (1) | |
Text
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At30-A UNITED STATES K
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AUG 13 sgE MEMORANDUM FOR: Robert L. Fonner Office of the General Counsel FROM: C. James Holloway, Jr. , Acting Director License Fee Management Staff, ADM
SUBJECT:
ADDITIONAL COMMENT LETTER ON PROPOSED PART 171 l
On July 30, 1986, we forwarded to you a list of the comenters on proposed Part 171 and a sumary of the 58 coments. With this memo-randum, we also provided two additional comment letters (Philadelphia Electric Company and Yankee Atomic Electric Company). We have now received a letter from Wolverine Power Supply Cooperative, Inc., dated July 24, 1986, and a July 29, 1986 letter from Shaw, Pittman, Potts &
Trowbridge which simply adds Yankee Atomic to the list of utilities that their July 16, 1986 coments represent. With the Philadelphia Electric, Yankee Atomic and Wolverine comments, we now have 61 letters from '
commenters.
It is our understanding that you will inform us as to whether the paper to the Commission and final Part 171 discussion should include 58 vs. 61 comments. In Trip Rothschild's opinion, all should be included.
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jC. James Holloway, J g/ Acting Director l
f License Fee Management Staff Office of Administration
Enclosure:
Wolverine Letter of,7/24/86 cc w/ encl:
T. Rothschild, 0GC P. Norry, ADM M. Springer, ADM P. Rowe, ADM R. Smith, OGC R. Scroggins, RM R. Shumway, RM S. Smith, RM N. Beeson, RM 8612010053 861121 N$51hR24078 PDR g, t i
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WOLVERINE POWER SUPPLY COOREIRdTIVE, INC.
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Lando W. Zech, Jr. 6 Chairman U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C. 20001
Dear Mr. Zech:
Wolverine Power Supply Cooperative, Inc. is an approximate 15 percent owner, with The Detroit Edison Company, in the Fermi 2 Nuclear Power Plant located near Monroe, Michigan.
strongly opposes adoption of a new U.S. Nuclear Regulatory Wolverine Commission rule titled "NRC Proposed Rule, 10 CFR Part 171" because it would impose yet another financial burden upon rural electric generation and transmission cooperatives that maintain minority ownership in nuclear plants.
Presently; the estimated completion cost of the Fermi 2 plant is estimated at $4 billion - or nearly four times the projected cost at the time Wolverine invested in the plant. The cost of Fermi power is already much higher than alternative fuel sources available at our other generating plants.
Under 10 CFR Part 171, Wolverine and other minority owners, would annually be responsible for their ownership percentage of approximately $1.1 million in proposed NRC user fee costs. In view of the fact no identifiable additional services would be provided under this proposed rule, this charge is more properly labeled a tax rather than a user fee.
Wolverine provides wholesale electric service to seven member systems who serve approximately 400,000 consumers in 35 Michigan counties. Those seven member systems and their consumers are already burdened with electric rates that are approximately 15*5 higher than those from competing investor-owned utilities. The
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PROVIDING GENERATION AND TRANSMISSION FOR:
Cherryland Rural Electric Cooperatise Association (Grawn). O & A Electric Cooperatise (Newa>go), Oceana Electric Cooperatise (Hart).
Preque Isle Electric Cooperatise. Inc (Onawa)). Top O' Michigan Rural Electric Co. (Boyne City). Tri-County Electric Cooperaine (Portland).
and Western Michigan Electric Cooperatise (Scottsille) ee. knowledged N c,,,, N .
t density in the rural areas Wolverine serves is slightly more than six meters per mile of line, while Wolverine's municipal investor owned counterparts average nearly 40 meters per mile and of line.
Adoption charge to many of of this rule would prove to be an unnecessary those rural consumers who are already overburdened. NRC adoption of 10 CFR Part 171 is not in the best interest of the rural consumers Wolverine's system. receiving electricity through If you should have any questions or comments concerning this matter or would like to discuss this issue in more detail, please do not hesitate to contact me.
Very truly yours, WOLVERINE POWER SUPPLY COOPERATIVE, INC.
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Ra on R. Cristell Executive Vice President and General Manager RRC:am xc: B. Bergland, NRECA - R. Kuhl, MECA G&T Mgrs, w/ Minority Ownership in nuclear plants.
J. Taylor, Dairyland L. Hobart, APPA - Brad Koch, NRECA 0200C h
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