ML20064G525

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Fiscal Year 2020 Proposed Fee Rule Meeting Slides
ML20064G525
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Issue date: 03/05/2020
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FY 2020 Proposed Fee Rule Public Meeting March 5, 2020 2:00 p.m. - 4:00 p.m.

Ground Rules Facilitator 2

FY 2020 Proposed Fee Rule Cherish Johnson Chief Financial Officer

PUBLIC MEETING AGENDA

Notice of Meeting on the FY 2020 Proposed Fee Rule March 5, 2020, 2:00 P.M. to 4:00 P.M.

NRC One White Flint North Commissioners Hearing Room 11555 Rockville Pike, Rockville, MD Time Topic Speaker 2:00 P.M. Establish Ground Rules for Meeting Facilitator 2:05 P.M. Opening Remarks Cherish Johnson 2:15 P.M.

Fee Rule Comments

  • In scope comments:

o Focused on methodology for calculating fees o Changes to fee regulations o Fee schedules

  • Out of scope comments:

o General comments on agency efficiencies o Changes to regulatory process o Public participation in budget formulation

  • Use the appropriate venue 5

FY 2020 Budgetary Considerations Jason Shay, Director Office of the Chief Financial Officer Division of Budget

FY 2020 Budgetary Considerations FY 2019 FY 2020 FY 2020 Major Program Enacted Enacted Total Authority

$M* FTE $M* FTE $M* FTE Nuclear Reactor Safety $459.4 1919.0 $426.7 1815.0 $447.6 1815.0 Nuclear Materials and Waste Safety $131.0 515.0 $120.2 481.0 $126.1 481.0 Corporate Support $292.9 609.0 $279.4 611.0 $292.6 611.0 Integrated University Program $15.0 0.0 $16.0 0.0 $16.0 0.0 Subtotal $898.3 3043.0 $842.3 2907.0 $882.3 2907.0 Office of the Inspector General $12.6 63.0 $13.3 63.0 $13.3 63.0 Total* $911.0 3106.0 $855.6 2970.0 $895.6 2970.0

  • $M includes FTE costs as well as contract support and travel. Numbers may not add due to rounding.
  • The FY 2020 Enacted Budget is based on Public Law 116-93Further Consolidated Appropriations Act, 2020, enacted on December 20, 2019.
  • The FY 2020 Enacted budget is $855.6 million, which includes 2,970 FTE. This represents a decrease of $55.4 million when compared to the FY 2019 Enacted Budget. In the appropriation, the NRC was directed to use $40 million in authorized prior-year carryover in FY 2020.

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Budget Trend U.S. Nuclear Regulatory Commission FY 2014 - FY 2021 Budget 1,100 4,000 3,500 1,000 3,000 Dollars in Millions 900 2,500 FTE 2,000 800 1,500 700 1,000 FY 2014 FY 2015 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2021 Enacted Enacted Enacted Enacted Enacted Enacted Enacted Request Integrated University Program ($M) 15.0 15.0 15.0 15.0 15.0 15.0 16.0 0.0 High-Level Waste ($M) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Authorized Carryover ($M) 0.0 34.2 0.0 23.0 15.0 20.0 40.0 0.0 Program and Corporate ($M) 1,040.9 1,000.3 987.1 902.1 907.0 896.0 839.6 863.4 Total Budget $(M) 1,055.9 1,015.3 1,002.1 917.1 922.0 911.0 855.6 863.4 Total FTE 3,799.7 3,778.5 3,595.0 3,396.0 3,186.0 3,106.0 2,970.0 2,868.0 8

FY 2020 Fee Overview Christine Galster, Senior Accountant Office of the Chief Financial Officer Division of Budget License Fee Policy Team

Statutory and Regulatory Framework

  • Independent Offices Appropriation Act (IOAA) of 1952:

o Regulations promulgated under 10 CFR Part 170 o Implementing guidance OMB Circular A-25 o Fees for direct services to licensees o Billed as hours expended at the NRC professional hourly rate

  • Omnibus Budget Reconciliation Act of 1990 (OBRA-90), as amended:

o Regulations promulgated under 10 CFR Part 171 o Recover through annual fees other budgetary resources not recovered under IOAA o Recover approximately 90% of annual budget authority LESS excluded activities and fee relief activities limited to 10%

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Statutory and Regulatory Framework (Cont.)

  • Annual Appropriation:

o Provides appropriated amount; approximates amount for fee recovery; and approximates the Net Appropriation amount not recovered through fees.

o Specifically excludes certain activities from fee recovery.

o Authorizes an amount of carryover funds from prior year for current year use.

  • Nuclear Energy Innovation & Modernization Act (NEIMA) of 2018:

o Effective FY 2021 and thereafter; repeals OBRA-90.

o Regulations promulgated under 10 CFR Part 171.

o Limits power reactor annual fees at the FY 2015 annual fee amount as adjusted each year thereafter for inflation.

o Recover, to the maximum extent practicable, 100% of budget authority:

LESS activities NEIMA designated as excluded from recovery.

LESS any fee-relief activities identified by the Commission.

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Budget and Fee Recovery Amounts for FY 2020 Proposed Rule

[Dollars in Millions]

Total Budget Authority $ 855.6 Less IG-DNFSB, WIR, GHLS, Intl, and ARI (Excluded Items) - 46.6 Balance $ 808.9 Fee Recovery Rate for FY 2020 x 90.0%

Total Amount to be Recovered For FY 2020 $ 728.1 Adjustments (Part 171 Collections) + 0.4 Adjusted Recovery Amount $ 728.5 Less Estimated Part 170 Billings - 230.6 Part 171 Fee Collections Required $ 497.9 Total Fee-Relief Activities (FY 2020 proposed fee rule): $ 79.2M Less 10% of the total NRC FY 2020 budget (less non-fee items): - 80.9M Fee-relief adjustment (credit) to be allocated to all licensees annual fees $ - 1.7M 12

Hourly Rate Methodology Mission Direct Program Salaries and Benefits $314.6M Mission Indirect Program Support 110.8M Agency Support: Corporate Support and IG 291.5M Subtotal: $716.9M Less: Offsetting Receipts - 0.0 Total Budgeted Resources Included in Professional Hourly Rate $716.9M Mission Direct FTEs: 1,701 FTEs Mission Direct FTEs Productive Hours: 1,510 Hours Professional Hourly Rate $279 Full Cost FTE Rate = Subtotal divided by Mission Direct FTE $ 421,471

  • Methodology based on OMB circular A-25 User Charges
    • Budget included in Hourly Rate calculation excludes Direct Program Contract Costs generally billed to licensees separately.

13

10 CFR Part 170 Professional Hourly Rate Calculation Budget Resources

= Professional Hourly Rate Mission Direct FTE Converted to Hours FY 2020 Proposed Rule:

$716.9 million

= $279 hourly rate (1,701 x 1,510 )

Productive Hours Total hours = 2087 Less:

Direct FTE Productive

  • Training hours Hours
  • Holiday hours
  • Vacation hours
  • Travel hours 14

Budget Allocation For Fees CROSSWALK OF BUSINESS LINES ALLOCATION TO FEE CLASSES*

Business Line License Fee Class Operating Reactors Power Reactors, Test and Research Reactors, Import/Export New Reactors Power Reactors Fuel Facilities Fuel Facilities Nuclear Materials Users Materials Users, Import/Export Spent Fuel Storage and Transportation Spent Fuel Storage/Reactor Decommissioning, Transportation Decommissioning and Low-level Waste Spent Fuel Storage/Reactor Decommissioning, Uranium Recovery Reconciling Items

  • Budget resources excluded from fee calculations (non-fee)
  • Mission Indirect Program Support resources
  • Business Line resources allocated to other fee classes/fee relief categories
  • Budget resources allocated from other Business Lines
  • Utilization of a full costed FTE rate
  • Appropriation revisions Delineates where the majority portion of a Business Lines direct resources are allocated for a fee class.

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Business Lines vs. Fee Classes Percentage of Budgeted Resources for FY 2020 BUSINESS LINE BUDGETS FEE CLASS BUDGETS TOTAL $855.6M TOTAL $728.1M Other Nuclear 7% Fuel Facilities Material Users Nuclear Material 3% 4%

Users 7% Other 7%

Fuel Facilities 2%

Operating Reactors 40%

Corporate Support Power Reactors 33% 86%

New Reactors 10%

Inspector Genera 16

Reconciliation: Operating and New Reactors Business Lines vs. Fee Class Budget FY2020 Congressional Budget Operating and New Reactor Justification (Requested) Business Lines (Dollars in thousands)

Contract ($,K) FTE Product Lines Event Response 8,645 45.0 Generic Homeland Security 100 8.0 International Activities 120 22.0 Licensing 18,604 505.0 Oversight 20,373 586.0 Rulemaking 525 47.0 Mission Support/Supervisors 3,420 401.0 Research 40,173 175.0 Training 4,994 35.0 Travel 15,548 0.0

$ 112,502 1,824.0 FTE rate $184,000 times 1,485 FTEs &

$188,000 times 339 FTEs (includes Salaries and Benefits only) $336,972 Total Business Line Budget $ 112,502 $336,972 = $ 449,474 17

Reconciliation: Reactor Business Lines vs. Fee Class Budget FY 2020 Proposed Fee Rule Power Reactor Fee Class (Dollars in Thousands) (Proposed Fee Rule)

Deductions from BL resources Contract ($,K) FTE Reconciling Items Event Response5 (2,756.0) 0.0

  • Exclusion/Non-Fee Items1 Generic Homeland Security1 (100.0) (8.0)
  • Indirect resources2 International Activities1 (120.0) (22.0)
  • Resources allocated to other fee Licensing3,5 (6,911.0) (29.0) classes/fee relief categories3 Oversight3,5 (5,997.6) (9.5)
  • Resources allocated from other Research1,5 (13,438.0) (37.0) Business Lines4
  • Carryover/Appropriation Rulemaking 3 - (1.3) Reductions5 Mission Support/Supervisors2,5 (3,420.0) (390.0)

Training3,5 (86.0) (0.6)

Travel2 (15,548.0) 0.0

($48,376.6) (497.4)

Increases from Other resources Oversight4 5.7 0.0 Rulemaking4 0.0 0.4 State/Tribal/Federal Programs4 0.0 0.8 Training4 102.0 0.2

$107.7 1.4 BL resources w/ fee rule allocations $ 64,233.1 1,328.0 FTE fully costed rate $421,471 times 1,328 FTEs (includes Salaries, Benefits, indirect resources and agency support) $559,713.5 Total Fee Class Budget $ 64,233.1 $559,713.5 = $ 623,946.60 18

Reconciliation: Reactor Business Lines vs. Fee Class Budget Reconciliation Summary (Dollars in thousands)

Contract ($,K) FTE FTE ($) Total Total Business Line Budget (CBJ) $ 112,502 1,824.0 $ 336,972.0 = $ 449,474.0 Includes S&B only Total Fee Class Budget $ 64,233.1 1,328.0 $ 559,713.5 = $ 623,946.6 Includes S&B, Indirect and Agency support (Full cost)

Adjustments* $ (48,268.9) (496.0) $ 222,741.5 $ 174,472.6

  • Allocation Adjustments 19

10 CFR Part 171 Annual Fee Calculation: Power Reactor Fee Class

[Dollars in Millions]

  • Termination of Three Mile Island, Pilgrim and Indian Point Unit 2 by Final Fee Rule publication.

20

10 CFR Part 171 Annual Fee Calculation: Fuel Facilities Fee Class

[Dollars in Millions]

FY 2016 FY 2017 FY 2018 FY 2019 FY 2020P Budgeted Resources $40.5 $33.9 $35.2 $30.0 $23.2 Part 170 Estimated Billings (11.7) (9.6) (9.2) (7.3) (6.8)

Adjustments 2.8 4.1 1.7 1.8 1.7 Part 171 Annual Fees 31.6 28.4 27.7 24.5 18.1 Number of Licensees 9 9 7* 7 7 Average Annual Fee Change -6.1% -6.9% 1.3% -12.4% -26.0%

  • Centrus Energy Lead Cascade decommissioned and GE Vallecitos reclassified.

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Utilization of Carryover Funds FY2019 FY2020 Budget Business Line / Fee Rule Carryover Carryover Funding Carryover Funding Allocation Change (+/-)

$20M $40M Operating/New Reactor BL 10,401,000 20,921,000 10,520,000 Power Reactor Fee Class 10,401,000 20,361,000 9,960,000 Indirect Hourly Rate 0 560,000 560,000 Spent Fuel Storage/Transportation BL 2,383,000 1,466,000 -917,000 Spent Fuel Storage/RD Fee Class 1,583,000 422,000 -1,161,000 Transportation Fee Class 800,000 1,044,000 244,000 Nuclear Materials User BL 0 2,918,000 2,918,000 Nuclear Materials User Fee Class 340,000 340,000 Fee Relief 2,101,000 2,101,000 Indirect Hourly Rate 477,000 477,000 Decommissioning/Low Level Waste BL 562,000 1,070,000 508,000 Spent Fuel Storage/RD Fee Class 500,000 522,000 22,000 Fee Relief 62,000 548,000 486,000 Fuel Facilities BL 22,000 440,000 418,000 Corporate BL 6,632,000 13,185,000 6,553,000 22

Budget Overview:

Operating and New Reactors Business Lines Russell Felts, Deputy Director Office of Nuclear Reactor Regulation Division of Reactor Oversight

Product Lines within the Operating and New Reactors Business Lines Mission Direct Mission Indirect Resources Excluded Resources (74%) Resources (21%) from the Fee Base (5%)

  • Licensing
  • Mission Support
  • Generic Homeland Security and Supervisors
  • Oversight
  • Travel
  • International Activities
  • Research
  • Advanced Reactor Regulatory Infrastructure
  • Event Response
  • Rulemaking
  • Training 24

Operating and New Reactors Business Lines Activities Licensing Oversight

  • License Amendments
  • Inspections (including risk-informed)
  • Design Certifications
  • Allegations & Investigations
  • Combined Operating Licenses
  • Event Evaluation
  • Environmental Reviews
  • Construction Oversight
  • Topical Reports
  • Vendor Oversight
  • Digital I&C Modifications
  • Vogtle Units 3 and 4 ITAAC closeout
  • Vogtle Units 3 and 4 License Amendments 25

How are the Budgets Developed?

  • Workload Forecasting:

o Identification of significant workload drivers o Analysis of historical data and trending o Communications with stakeholders

  • Estimate Level of Effort:

o Estimate level of effort for major projects o Yearly recurring activities 26

Operating Reactors Business Line -

Changing Workload

  • Decreases:

o Plant closures o Fukushima Near Term Task Force activities o Decommissioning Transition Rulemaking o Efficiencies gained from the merger of the Office of Nuclear Reactor Regulation and the Office of New Reactors

  • Increases:

o Accident Tolerant Fuels 27

New Reactors Business Line -

Changing Workload

  • Decreases:

o Delayed application submittals o Near completion of the NuScale DC review and Clinch River early site permit o Licensing activity for Vogtle Units 3 and 4 o Efficiencies gained from the merger of the Office of Nuclear Reactor Regulation and the Office of New Reactors

  • Increases:

o Advanced reactor regulatory infrastructure (excluded) 28

Budget Overview:

Fuel Facilities Business Line Andrea Kock, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards

Fuel Facilities Business Line: Product Lines Mission Direct Mission Indirect Resources Excluded Resources (57%) Resources (24%) from the Fee Base (19%)

  • Licensing
  • Mission Support
  • Generic Homeland and Supervisors Security
  • Oversight
  • Travel
  • International Activities
  • Event Response
  • Rulemaking
  • Training 30

Fuel Facilities Business Line Activities Licensing: Oversight: Rulemaking:

  • Development and
  • Development and
  • Rulemaking activities maintenance of the maintenance of the and associated Program Oversight Program guidance development
  • License
  • Inspections Amendments
  • Decommissioning
  • Security funding Plans
  • Security Plans
  • Environmental Reviews 31

How is the Fuel Facilities Business Line Budget Developed?

1. Workload Forecast:
  • Number of licensed facilities, letters of intent, communications with stakeholders and external awareness
  • Analysis of historical data
2. Type of Work:
  • Security, Environmental and Safety
  • Type of Licensing Action
  • Complexity
3. Inspection Work:
  • Scope of frequency of inspections
  • Number and type of operating facilities
4. Historical Resource Utilization 32

Fuel Facilities Business Line -

Changing Workload Decreases:

  • Decline in workload associated with submissions of license amendment and renewals.
  • Efficiencies gained due to enhancements made to the Fuel Facilities licensing and inspection programs
  • Rulemaking activities
  • Termination of the construction for Mixed-Oxide Fuel Fabrication Facility 33

Fees Transformation Anthony Rossi, Team Lead Office of the Chief Financial Officer Division of Budget License Fee Policy Team

Fees Transformation Initiative

  • Follow on from Project AIM recommendations
  • Goal: increase transparency, timeliness and equity in the fee setting and billing process
  • Developed over 40 process and policy improvement options
  • Fees Transformation Accomplishments:

https://www.nrc.gov/about-nrc/regulatory/licensing/fees-transformation-accomplishments.html 35

Fees Transformation Initiative (Cont.)

FY 2020 Initiatives:

  • Uranium recovery flat fee pilot initiative:

o Complete: Maintaining the current fee billing structure.

o Congressional Report: January 9, 2020 (ADAMS Accession No. ML20010D684).

  • Transition to an electronic billing system (eBilling):

o In process: Went live on October 1, 2019 o Full implementation: October 2020 o Sign-up: https://www.nrc.gov/docs/ML1926/ML19269B690.pdf

  • Process Improvement: Small business size standards rulemaking:

o In process: Survey underway, with a requested due date of April 30, 2020 (85 FR 6225).

Survey can be completed electronically (NRC.gov) or via postal mail.

What will the NRC do with the survey results?

36

Policy Changes Anthony Rossi, Team Lead Office of the Chief Financial Officer Division of Budget License Fee Policy Team Mike King, Director Office of Nuclear Reactor Regulation Vogtle Project Office

Proposed Policy Changes for FY 2020 Remove the fee exceptions in § 170.21, footnote 1 and

§ 170.31, footnote 2:

  • Fairness and equity in the NRCs fee rules
  • Ensures licensees pay for services consistent with IOAA, OBRA-90, and OMB Circular A-25 38

Proposed Policy Changes for FY 2020 (Cont.)

Amending § 171.15 regarding the assessment of annual fees for 10 CFR Part 52 combined license holders and future 10 CFR Part 50 power reactor licensees:

  • Petition for Rulemaking (PRM): PRM-171-1 was received from the Southern Nuclear Operating Company on February 28, 2019.
  • PRM-171-1 Request: NRC revise its regulations in 10 CFR Part 171 related to the start of the assessment of annual fees for combined license (COL) holders licensed under 10 CFR Part 52.

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Proposed Policy Changes for FY 2020 (Cont.)

  • Stakeholder Comments: five public comments received all in support of the proposed change.
  • Future Effort: Consider expanding the scope of this approach to apply to other 10 CFR Part 50 licensees, beyond power reactor licensees.

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10 CFR Part 52 Power Reactor Licensees Proposed Policy Change (Cont.)

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10 CFR Part 50 Power Reactor Licensees Proposed Policy Change (Cont.)

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Nuclear Energy Innovation and Modernization Act (NEIMA)

Jason Shay, Director Office of the Chief Financial Officer Division of Budget

NEIMA On January 14, 2019, the Nuclear Energy Innovation and Modernization Act or NEIMA was signed into law. NEIMA impacts the following areas in the NRCs Congressional Budget Justification (effective FY 2021):

  • Corporate Support - NEIMA caps the NRCs corporate support costs at 30 percent of the annual budget request for FY 2021, stepping down to 28 percent in FY 2025 and beyond, to the maximum extent practicable.
  • Operating Power Reactors Annual Fee - NEIMA caps the operating power reactor licensee annual fee to the amount established in the FY 2015 final fee rule, adjusted for inflation, to the maximum extent practicable.
  • Requested Activities - NEIMA requires anticipated expenditures for requested activities of the Commission to be identified in the annual budget justification.
  • Accurate Invoicing - NEIMA requires the appropriate review and approval prior to issuance of invoices; the development and implementation of processes to audit invoices to ensure accuracy, transparency, and fairness, and the modification of regulations to ensure fair and appropriate processes to provide licensees and applicants an opportunity to efficiently dispute or otherwise seek correction of errors in invoices for those fees.

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Corporate Support Corporate Support Budget FY 2014 - FY 2021 400.0 $30.0 346.1 350.0 336.3

-3% $20.0

-9% 305.0 300.1 296.4 292.9 300.0 -2% -1% 279.4

-1% 271.4 Annual Change (Millions)

-5% $10.0

-3%

Total $ (Millions) 250.0

$0.0 200.0

($3.7) ($8.0)

($9.7) ($4.9) ($10.0)

($3.4) 150.0

($13.6)

($20.0) 100.0 50.0 ($30.0)

($31.3) 0.0 ($40.0)

FY 2014 FY 2015 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2021 Request Total $M Annual Change ($M)

  • Since FY 2014, the Corporate Support budget has decreased by approximately $74.7 million, or approximately 22 percent.

45

Estimated FY 2021 Operating Power Reactor Annual Fee Estimated FY 2021 Operating Power Reactors Annual Fee

$M*

FY 2021 Operating Power Reactors Allocation 628.0 Estimated Part 170 Fee Collections 188.3 Estimated Part 171 Allocations 439.7 Generic Transportation Resources Allocated 0.5 Adjusted Part 171 Allocations1 440.2 Generic Low-Level Waste Surcharge 3.9 Part 171 Billing Adjustments 1.5 Total FY 2021 Annual Fee2 $445.5 FY 2021 Annual Fee per Operating Power Reactor3 $4.8 FY 2015 Annual Fee per Operating Power Reactor Adjusted for Inflation4 $5.4 Delta: FY 2021 Annual Fee - FY 2015 Annual Fee Adjusted for Inflation ($0.6)

  • Numbers may not add due to rounding.

1Adjusted amount after generic transportation resources allocation.

2Sum of Adjusted Part 171 Allocations, Generic Low-Level Waste Surcharge, and Part 171 Billing Adjustments.

3Assumes 93 operating power reactors 4Based on 1.5 percent Consumer Price Index increase per fiscal year.

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Requested Activities

  • NEIMA requires NRC to identify anticipated expenditures for requested activities in its annual budget justification
  • NEIMA defines requested activities as the processing of applications for:

o Design certifications or approvals o Licenses o Permits o License amendments o License renewals o Certificates of compliance o Power uprates o Any other activity requested by a licensee or applicant439 o )

  • NEIMA limits movement of resources for requested activities during the year of execution, to the maximum extent practicable 47

NEIMA: Accurate Invoicing

  • Ensure appropriate review and approval prior to the issuance of invoices
  • Develop and implement processes to audit invoices to ensure accuracy, transparency, and fairness
  • Modify regulations to ensure fair and appropriate processes to provide licensees and applicants an opportunity to efficiently dispute or otherwise seek review and correction of errors in invoices for those fees
  • entF2021 Change to fee recovery framework and 48

Q&A 49

Public Comments Submission The deadline for submitting comments for this rulemaking is March 19, 2020.

ADDRESSES: You may submit comments by any of the following methods (unless this document describes a different method for submitting comments on a specific subject):

Federal Rulemaking Website: Go to https://www.regulations.gov and search for Docket ID NRC-2017-0228. Address questions about NRC dockets to Carol Gallagher; telephone: 301-415-3463; e-mail: Carol.Gallagher@nrc.gov. For technical questions contact the individual listed in the FOR FURTHER INFORMATION CONTACT section of this document.

E-mail comments to: Rulemaking.Comments@nrc.gov. If you do not receive an automatic e-mail reply confirming receipt, then contact us at 301-415-1677.

Fax comments to: Secretary, U.S. Nuclear Regulatory Commission at 301-415-1101.

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Public Comments Submission (Cont.)

Mail comments to: Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Rulemakings and Adjudications Staff.

Hand deliver comments to: 11555 Rockville Pike, Rockville, Maryland 20852, between 7:30 a.m. and 4:15 p.m. (Eastern Time) Federal workdays; telephone:

301-415-1677.

For additional direction on obtaining information and submitting comments, see Obtaining Information and Submitting Comments in the SUPPLEMENTARY INFORMATION section of this document.

FOR FURTHER INFORMATION CONTACT: Anthony Rossi, License Fee Policy Team Lead, Office of the Chief Financial Officer, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, telephone: 301-415-7341, e-mail:

Anthony.Rossi@nrc.gov.

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CFO Closing Remarks 52

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