ML23093A114
| ML23093A114 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 03/30/2023 |
| From: | Travis Tate Framatome |
| To: | Shana Helton Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| NRC-2021-0024, PR-170, PR-171, TJT-23-007, 88FR13357 00001 | |
| Download: ML23093A114 (1) | |
Text
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 NRC s 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 NRC s 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, Framatome s 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 agency s services, Framatome requests a re-evaluation and explanation by NRC as to the basis for this increase prior to finalizing the FY23.
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