ML20215D791
| ML20215D791 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 10/07/1986 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8610140298 | |
| Download: ML20215D791 (3) | |
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$N huc a licensing htKNNEAN5 PROGRES5 General Offces: 1945 West Pernali Road, Jackson, MI 49201 (517) 788-1626 October 7, 1986
- Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
ANNUAL FEE FOR POWER REACTOR OPERATING LICENSES UNDER 10CFR171 -
REQUEST FOR ADDITIONAL GUIDANCE A Federal Register notice (Vol 51, No 181, dated 9/18/86, page 33224) pub-lished a new final rule (10CFR171) which levies an annual fee on all licensed power reactors. This fee is in addition to the fees already imposed under 10CFR170. As stated in the notice, the Nuclear Regulatory Commission (NRC),
in recognition of the problem that some of the smaller reactors may have in paying increased fees, has provided for fee exemptions.
It also states that it in 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. This submittal is to notify the NRC that Consumers Power Company intends to submit an exemption request for relief from the annual fee require-ment for Big Rock Point.
The new rule does allow exemptions. However, very little guidance is provided in terms of what would be an acceptable basis for granting relief. Some of the factors Consumers Power Company intends to consider include:
Actual licensing costs Over the last four years licensing costs under 10CFR170 have averaged approximately $118,000.00. The new fee is an eight-fold increase.
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Director, Nuclear Reactor Regulation 2
Big Rock Point Plant Annual Fee for Power Reactor Operating Licenses Under 10CFR171 October 7, 1986 Cost of production per kilowatt-hour Big Rock Point is already near the most expensive in terms of overall cost of production when compared with all other Consumers Power Company generating facilities.
State of Michigan Public Service Commission (PSC) regulatory climate The new fee cannot be passed on to our customers under our current rate order without filing a new rate case, Also, intervenors are presently contesting that Big Rock Point should not be maintained in the rate base due to high operating costs.
Age of Big Rock Point The plant is old.
It has been operating for over 24 years and only 14 years of operation remain under the operating ifcense.
Size of Big Rock Point The plant is small.
It is rated at 240 MW thermal /75 MW electrical.
Past SALP performance Big Rock Point has received above average SALP ratings over the last several years. This has resulted in less NRC regulatory effort being spent on the plant.
As published, the rule does not provide significant guidance on what is an acceptable basis for exemption, nor does it provide any guidance on what or how to calculate what an acceptable fee reduction amount would be.
Consumers Power Company requests that additional guidance be provided in these two areas. To ensure that we are not in noncompliance with lovenist unu to ensure that no interest or other penalties are incurred, we also request that the additional guidance be provided in a timely matter so that we may file a formal exemption request by November 19, 1986. After we file our exemption request, we intend to withhold payment of the new annual fee until the exemption request is acted upon by the NRC.
OC1086-0165-NLO2
Director, Nuclear Reactor Regulation 3
Big Rock Point Plant Annual Fee for Power Reactor Operating Licenses Under 10CFR171 October 7, 1986 Our position has been discussed with the Big Rock Point Project Directorate.
This submittal is being made at his request. He has concurred with Consumers Power Company's position and has agreed to provide the requested additional guidance.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point OC1086-0165-NLO2 L