ML18115A062
| ML18115A062 | |
| Person / Time | |
|---|---|
| Site: | 07003098 |
| Issue date: | 04/24/2018 |
| From: | Vexler A Global Nuclear Fuel |
| To: | Craig Erlanger Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| M180087 | |
| Download: ML18115A062 (2) | |
Text
M180087 April 24, 2018 Mr. Craig Erlanger, Director Division of Fuel Cycle Safety, Safeguards, and Environmental Review Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Comments on Fuel Cycle Facility Fee Matrix
References:
- 1) NRC Fuel Facility Fee Matrix Options for Improvement Meeting,12/13/17
- 2) NRC Fuel Facility Budget Related Topics and Fee Matrix Meeting, 3/27/18
Dear Mr. Erlanger:
Global Nuclear Fuel - Americas, LLC (GNF-A) is writing in response to the NRCs effort to re-allocate annual fees for individual fuel cycle facility licensees.
The public meetings held on December 13, 2017 and March 27, 2018 were useful to discuss NRCs methodology and potential alternative approaches to the fee matrix and requested shareholder feedback. I support NRCs earlier decision that, given ongoing discussions and related NRC efforts, no sudden changes to the fee matrix will occur in the FY18 fee rule.
Although the public meetings were primarily focused on potential alternatives to the fee allocation methods, GNF-A has immediate concerns regarding NRCs total budget for the Fuel Facilities Business Line in todays market driven economic environment. Consistent with the agencys Principles of Good Regulation, it is incumbent upon the NRC to identify additional efficiencies that can better prioritize and most importantly reduce total costs, including indirect generic activities which currently account for an astounding 2/3 of the business line budget. NRC staff has provided little transparency on the programmatic breakdown of these indirect generic activities in terms of cost, scope, and schedule.
NRC noted during the December public meeting that the current matrix of effort factors has been used since 1999, with corresponding annual fees distributed across each facility fee category based on arbitrary predicted regulatory efforts. It should also be noted in 1999 annual fees totaled $16.1M for 11 operating fuel cycle facilities. At present day, annual fees have nearly doubled, to close to $30M, while the licensee base has shrunk over 30%. The Fuel Facilities Business Line budget is too large given there are Global Nuclear Fuel Amir V. Vexler, Chief Executive Officer Global Nuclear Fuel - Americas 3901 Castle Hayne Road Wilmington, NC 28402 USA T 910-819-1964 Amir.vexler@ge.com
US NRC ll'-'1180087 April24, 2018 Page 2 only ?-remaining operating fuel cycle licensees each with a reduced regulatory work load and relatively low risk profile. Furthermore, for the GNF-A low enriched fuel manufacturing facility, the annual fee has more than tripled from $900K in FY08 to the proposed fee of $2.8 MM for FY18.
lin addition, the fuel cycle facilities currently experience an NRC staff to operating facility ratio of approximately 16:1. Conversely, commercial nuclear reactors have a ratio of approximately 15:1, yet the risk profile is significantly lower for a fuel cycle facility versus a reactor when one considers a variety of safety and security factors. This historical disproportionality, which is not risk-informed, should be promptly addressed by further reducing the Fuel Facilities Business Line budget (i.e. staff and contractor support).
While the staff has discussed addressing industry concerns with the current 1 0-5-1 approach to fee allocation within the Fuel Facilities Business Line, the proposed 3-2-1 option is yet another arbitrary method to allocate annual fees. Neither option is based on actual data from NRC facility-by-facility resource expenditures. A much better option is to abandon the current fee matrix and phase in over several years a revised annual fee approach based on the proportion of what is actually spent regulating each licensee. The annual fee should be calculated from the NRC level of support effort provided to each licensee using percentages of direct billed hourly charges. This approach would also enable NRC to recognize and eliminate the commercial licensees subsidizing government activities at the MOX facility.
As opposed to changing the fee matrix, NRC's focus should be directed towards the appropriate re-baselining of agency activities and the reduction in overall agency budget (including the Fuel Facilities Business Line) consistent with actual needs.
Sincerely,
/I c - *: r j t_ '--
Amir'"'Vexler
Attachment:
None Cc:
M. Dapas, NRC NMSS Office Director M. Wylie, NRC Chief Financial Officer R. Johnson, NRC NMSS T. Naquin, NRC NMSS M. Lesser, NRC Rll AVV 18-002