ML15120A564
| ML15120A564 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 04/29/2015 |
| From: | Pietrangelo A Nuclear Energy Institute |
| To: | Stephen Burns NRC/Chairman |
| References | |
| LTR-15-0241 | |
| Download: ML15120A564 (1) | |
Text
ANTHONY R. PIETRANGELO Senior Vice President and Chief Nuclear Officer 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202. 739.8081 arp@nei.org nei.org April 29, 2015 The Honorable Stephen G. Burns Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
~I NUCLEAR ENERGY INSTITUTE
Subject:
Industry Support for Rulemaking to Develop a Variable Annual Fee Structure for Small Modular Reactors; SECY-15-0044 Project Number: 689
Dear Chairman Burns:
On behalf of the nuclear industry, the Nuclear Energy Institute (NEI) 1 expresses support for the NRC staff's plans to develop a variable annual fee for small modular reactors (SMRs), as discussed in SECY-15-0044.
We encourage the Commission to approve the staff's plans to draft a proposed rule in 2015. This is important to provide cl_arity in support of near-term business decisions regarding submittal of combined license applications for SMRs under 10 CFR Part 52-the first of which is anticipated in 2017.
The NRC assesses annual fees on licensees pursuant to 10 CFR Part 171 to recover generic and other regulatory costs not otherwise recovered under 10 CFR Part 170 as a means to meet the requirements of the Omnibus Budget Reconciliation Act of 1990, as amended (OBRA-90). The current Part 171 fee structure allocates these fees equally among the operating power reactor licensees; however, this approach would not be fair and equitable if applied to SMRs. SMRs incorporate enhanced design and safety features that are expected to result in lower generic regulatory costs associated with regulating this class of reactors. In addition, because SMRs are significantly smaller than large light water reactors and may include multiple modules at a single facility, SMRs would face a disproportionately high annual fee if assessed on a per-reactor basis at the uniform rate for large reactors.
1 N.EI is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEl's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.
NUCLEAR. CLEAN AIR ENERGY
The Honorable Stephen G. Burns April 29, 2015 Page 2 As discussed in SECY 15-0044, a revision to Part 171 "would address inequities of the current 10 CFR Part 171 fee structure relative to future SMRs and multi-module nuclear plants." The NRC's proposed approach is consistent with the industry's views expressed in an NEI white paper dated November 2, 2010 (ML103070148). Assessing an annual fee for SMRs based upon the total thermal power output of the facility would establish a fair and equitable fee structure and meet the requirements of OBRA-90.
We support the NRC staff's plans to proceed with a proposed rule in 2015 and complete a final rule by February 2016, and look forward to participating in the rulemaking process.
If you have any questions, please contact me or Marc Nichol (mrn@nei.org; 202-739-8131).
Sincerely, Anthony R. Pietrangelo c:
- The Honorable Kristine L. Svinicki, Commissioner, NRC The Honorable William C. Ostendorff, Commissioner, NRC The Honorable Jeff M. Baran, Commissioner, NRC Ms. Maureen E. Wylie, CFO, NRC Mr. Mark A. Satorius, EDO, NRC Mr. Glenn M. Tracy, NRO, NRC Mr. Michael E. Mayfield, NRO/DARR, NRC Mr. Joseph Colaccino, NRO/DARR, NRC NRC Document Control Desk
CHAIRMAN Resource From:
Sent:
Subject:
Attachments:
April 29, 2015 PIETRANGELO, Tony <arp@nei.org>
Wednesday, April 29, 2015 2:27 PM Industry Support for Rulemaking to Develop a Variable Annual Fee Structure for Small Modular Reactors; SECY-15-0044 04-29-15_NRC_Industry Support for Rulemaking to Develop a Variable Annual Fee Structure for Small Modular Reactors; SECY-15-0044.pdf The Honorable Stephen G. Burns Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Industry Support for Rulemaking to Develop a Variable Annual Fee Structure for Small Modular Reactors; SECY-15-0044 Project Number: 689
Dear Chairman Burns:
On behalf of the nuclear industry, the Nuclear Energy Institute (NEI) expresses support for the NRC staff's plans to develop a variable annual fee for small modular reactors (SMRs), as discussed in SECY-15-0044. We encourage the Commission to approve the staff's plans to draft a proposed rule in 2015. This is important to provide clarity in support of near-term business decisions regarding submittal of combined license applications for SM Rs under 10 CFR Part 52-the first of which is anticipated in 2017.
The NRC assesses annual fees on licensees pursuant to 1 O CFR Part 171 to recover generic and other regulatory costs not otherwise recovered under 10 CFR Part 170 as a means to meet the requirements of the Omnibus Budget Reconciliation Act of 1990, as amended (OBRA-90). The current Part 171 fee structure allocates these fees equally among the operating power reactor licensees; however, this approach would not be fair and equitable if applied to SMRs. SMRs incorporate enhanced design and safety features that are expected to result in lower generic regulatory costs associated with regulating this class of reactors. In addition, because SMRs are significantly smaller than large light water reactors and may include multiple modules at a single facility, SMRs would face a disproportionately high annual fee if assessed on a per-reactor basis at the uniform rate for large reactors.
As discussed in SECY 15-0044, a revision to Part 171 "would address inequities of the current 1 O CFR Part 171 fee structure relative to future SMRs and multi-module nuclear plants." The NRC's proposed approach is consistent with the industry's views expressed in an NEI white paper dated November 2, 201 O (ML103070148). Assessing an annual fee for SMRs based upon the total thermal power output of the facility would establish a fair and equitable fee structure and meet the requirements of OBRA-90.
We support the NRC staff's plans to proceed with a proposed rule in 2015 and complete a final rule by February 2016, and look forward to participating in the rulemaking process.
1
If you have any questions, please contact me or Marc Nichol (mrn@nei.org; 202-739-8131).
Sincerely, Anthony R. Pietrangelo Senior Vice President and Chief Nuclear Officer Nuclear Energy Institute 1201 F Street NW, Suite 1100 Washington, DC 20004 www.nei.org P: 202.739.8081 M: 202.439.2511 E: arp@nei.org TAKE THE NE/ FUTURE OF ENERGY QUIZ, WWW.NEl.org/futureofenergy WORLD NUCLEAR FUEL CYCLE CONFERENCE (CO-ORGANIZED WITH WNA} / 21-23 APRIL 2015, PRAGUE, CZECH REPUBLIC/ REGISTER TODAY FOLLOW US ON I 0h~1(0i0h~~
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