M190130, Comment (1) of Michelle Catts on Behalf of GE-Hitachi Nuclear Energy Americas, LLC, on Nuclear Power Plant Licensee Fees Upon Commencing Commercial Operation
| ML19198A316 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/10/2019 |
| From: | Michelle Catts GE-Hitachi Nuclear Energy Americas |
| To: | Office of Administration, NRC/SECY/RAS |
| References | |
| 84FR26774 00001, M190130, NRC-2019-0084, PRM-171-1 | |
| Download: ML19198A316 (3) | |
Text
Page 1 of 1 SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 As of: 7/12/19 10:36 AM ADD: Victoria Huckabay Received: July 10, 2019 Status: Pending_Post PUBLIC SUBMISSION COMMENT (1)
PUBLICATION DATE: Tracking No. 1k3-9ayd-trnq 6/10/2019 Comments Due: July 10, 2019 CITATION 84 FR 26774 Submission Type: Web Docket: NRC-2019-0084 Nuclear Power Plant Licensee Fees Upon Commencing Commercial Operation Comment On: NRC-2019-0084-0003 Nuclear Power Plant Licensee Fees Upon Commencing Commercial Operation Document: NRC-2019-0084-DRAFT-0006 Comment on FR Doc # 2019-12082 Submitter Information Name: Michelle Catts Address:
3901 Castle Hayne Road P.O. Box 780 Wilmington, NC, 28402 Email: Michelle.Catts@ge.com General Comment See attached letter Attachments M190130 Comments to Proposed Rulemaking - Petition to Amend 10 CFR 171.15 Reactor Licenses and Independent Spent Fuel Storage Licenses https://www.fdms.gov/fdms/getcontent?objectId=0900006483d75ba2&format=xml&showorig=false 07/12/2019
Michelle P. Catts Senior Vice President, Regulatory Affairs 3901 Castle Hayne Road P.O. Box 780 Wilmington, NC 28402 USA T 910-200-9836 M190130 Michelle.Catts@ge.com July 10, 2019 Secretary, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
Subject:
Comments to Proposed Rulemaking - Petition to Amend 10 CFR 171.15, Reactor Licenses and Independent Spent Fuel Storage Licenses
References:
- 1) Vogtle Electric Generating Plant Units 3 and 4 Petition to Amend 10 CFR 171.15, "Reactor Licenses and Independent Spent Fuel Storage Licenses (PRM-171-1, Docket ID NRC-2019-0084)
Dear Sir or Madam:
GE-Hitachi Nuclear Energy Americas (GEH), LLC, hereby submits comments in support of the referenced petition submitted by Michael Meier on behalf of Southern Nuclear Operating Company, and suggests additional comments on the proposed change. The petitioner requested revision of 10 CFR Part 171, the Nuclear Regulatory Commission (NRC) Annual Fees regulation, to change the timing of when annual license fees for holders of a combined license under 10 CFR Part 52 commence, to coincide with a licensee's commercial operation, rather than upon a 10 CFR 52.103(g) finding. In a letter dated June 27, 2019, the Nuclear Energy Institute (NEI) expressed support for the subject petition. GEH joins NEI in strongly endorsing the subject petition, further observes that the conditions set forth in the petition should apply equally to reactors licensed under 10 CFR Part 50, and suggests additional conforming changes to § 171.15, Annual fees: Reactor licenses and independent spent fuel storage licenses.
Attached are GEHs specific comments for the proposed rule language.
Please contact me at (910) 200-9836 if you have any questions or would like to discuss this matter further.
Sincerely, Michelle P. Catts Senior Vice President, Regulatory Affairs c: Mr. Fred Brown, NRO, NRC Dr. Patricia Holahan, NMSS, Division of Rulemaking Ms. Maureen Wylie, OCFO NRC Document Control Desk
Attachment:
- 1. GEH Comments
M190130 U.S. NRC Page 2 of 2 Attachment 1 Proposed Revision The following proposed changes to §§ 171.15(a) and in addition, 171.15(e)(1) (with additions underlined and highlighted, and deletions struck) align with the reasons for the rulemaking and the analysis of the proposed changes discussed in the Southern Nuclear Operating Company Petition PRM-171-1.
§ 171.15 Annual fees: Reactor licenses and independent spent fuel storage licenses.
(a) Each person holding an operating license for a power, test, or research reactor; each person holding an operating license issued under 10 CFR part 50 or a combined license under part 52 of this chapter, after the facility for which such license was issued has been declared available for commercial operation under applicable standards of the licensee or the state regulatory commission with jurisdiction over the facility;the Commission has made the finding under 10 CFR 52.103(g); each person holding a part 50 or part 52 power reactor license that is in decommissioning or possession only status, except those that have no spent fuel onsite; and each person holding a part 72 license who does not hold a part 50 or part 52 license and provides notification in accordance with 10 CFR 72.80(g), shall pay the annual fee for each license held during the Federal fiscal year in which the fee is due. This paragraph does not apply to test or research reactors exempted under § 171.11 (a).
(e)(1) Each person holding an operating license for an SMR issued under 10 CFR part 50 or a combined license issued under 10 CFR part 52 after the facility for which such license was issued has been declared available for commercial operation under applicable standards of the licensee or the state regulatory commission with jurisdiction over the facility;the Commission has made the finding under 10 CFR 52.103(g), shall pay the annual fee for all licenses held for an SMR site. The annual fee will be determined using the cumulative licensed thermal power rating of all SMR units and the bundled unit concept, during the fiscal year in which the fee is due. For a given site, the use of the bundled unit concept is independent of the number of SMR plants, the number of SMR licenses issued, or the sequencing of the SMR licenses that have been issued.