ML23089A260

Framatome, Inc. - 2023 Fee Increase for Fuel Cycle Licensees; License No. SNM-1227; Docket No. 70-1257

ML23089A260
Person / Time
Site:	Framatome ANP Richland
Issue date:	03/30/2023
From:	Travis Tate Framatome
To:	Shana Helton Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
TJT-23-007
Download: ML23089A260 (1)

Text

framatome TJT-23-007 March 30th , 2023 U.S. Nuclear Regulatory Commission Ms. Shana Helton, Director, Office of Nuclear Material Safety and Safeguards Attn: Document Control Desk Washington, D.C. 20555 Ms. Shana Helton:

Subject:

2023 Fee Increase for Fuel Cycle Licensees; License No. SNM-1227; Docket No. 70-1257 The FY23 proposed fee rule describes an 18.5% annual fee increase for all operating fuel cycle facilities, except for the approximate 203% increase proposed for the uranium conversion plant which is expected to restart operations later this year.

For background, the fuel cycle business line budget and annual fees decreased each of the prior four fiscal years (FY19-22) to reflect the reduced number of operating facilities (7-8 during this period) and corresponding workload more accurately. The budget decrease was the result of considerable dialogue and information exchange between industry and NRC; and we appreciated NRCs efforts to right size the business line at that time. However, despite the number of operating facilities remaining steady at 8 in FY23, NRC proposes a significant annual fee increase.

Based on discussions during NRCs March 21,2023 public meeting and review of the Federal Register Notice (FRN), we have several concerns with this very unexpected outcome: 1) while NRC states that increased salaries and benefits are the primary cause for annual fee increases across the agency, this generic factor is not yielding significant annual fee increases for any other business line;

2) the specific bases for the 18.5% annual fee increase articulated in the FRN is not adequate or clear. Specifically, the discussion on page 13364 identifies several contributing factors; almost all of which are licensing or inspection activities that would be billable under Part 170 (not Part 171) to specific applicants or licensees.

Based on the information provided in the FRN and at the public meeting, Framatome does not currently understand the basis for the proposed 18.5% annual fee increase. Additionally, Framatomes budget for CY 2023 was finalized by June of 2022. Thus, funding an 18.5% FY23 fee increase is not currently budgeted and can only be fulfilled by making difficult resource decisions while maintaining operational safety and security.

The impact of such NRC decisions on its licensees should not be casually dismissed. Therefore, as one of the entities who pay for the agencys services, Framatome requests a re-evaluation and explanation by NRC as to the basis for this increase prior to finalizing the FY23.

framatome TJT-23-007 If you have questions about this request, please contact me by phone at (509) 375-8550.

Cordially, Timothy J. Tate Manager, Environmental Health Safety and Licensing cc: U.S. Nuclear Regulatory Commission, Region II Attn: Eric Michel, Chief Fuel Facility Branch 2 Marquis One Tower, 23 T85 245 Peachtree Center Avenue N.E., Suite 1200 Atlanta, GA 30303-8931