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Category:Rulemaking-Comment
MONTHYEARML24023A6042024-01-22022 January 2024 Comment (011) from Jennifer Uhle on Behalf of the Nuclear Energy Institute on PR-50, 51, and 71 - Increased Enrichment of Conventional and Accident Tolerant Fuel Designs for Light-Water Reactors ML23296A0792023-10-18018 October 2023 Comment Period Extension Request from the Nuclear Energy Institute on PR-50, 51, and 71 - Increased Enrichment of Conventional and Accident Tolerant Fuel Designs for Light-Water Reactors ML23177A2492023-06-23023 June 2023 Comment (012) from Thomas Basso on Behalf of the Nuclear Energy Institute on PR-50 - American Society of Mechanical Engineers Code Cases and Update Frequency ML23171B0032023-06-15015 June 2023 Comment (011) from Thomas Basso on Behalf of the Nuclear Energy Institute on PR-50 - American Society of Mechanical Engineers Code Cases and Update Frequency ML23123A4072023-05-0202 May 2023 Comment (0018) from Jennifer Uhle on Behalf of the Nuclear Energy Institute on PR-51 - Renewing Nuclear Power Plant Operating Licenses - Environmental Review ML23095A0372023-04-0404 April 2023 Comment (001) from Mark A. Richter on Behalf of the Nuclear Energy Institute on PR-50 - American Society of Mechanical Engineers Code Cases and Update Frequency ML23093A1882023-03-31031 March 2023 Comment (003) from Dr. Jennifer L. Uhle on Behalf of the Nuclear Energy Institute on PR-170 and 171 - Revision of Fee Schedules; Fee Recovery for Fiscal Year 2023 ML23080A1862023-03-17017 March 2023 Comment (001) from Douglas E. True on Behalf of the Nuclear Energy Institute on PR-30, 40, 50, 70 & 72 - Alternatives to the Use of Credit Ratings ML23062A7162023-03-0303 March 2023 Comment (006) from Frances Pimentel on Behalf of Nuclear Energy Institute on PRM-50-124 - Licensing Safety Analysis for Loss-of-Coolant Accidents ML23031A3022023-01-30030 January 2023 Comment (006) from Tony Brown on Behalf of the Nuclear Energy Institute on PR-50 - Reporting Requirements for Nonemergency Events at Nuclear Power Plants ML22333B0322022-11-28028 November 2022 Comment (014) from the Nuclear Energy Institute on PR-71 - Harmonization of Transportation Safety Requirements with IAEA Standards ML22243A2572022-08-31031 August 2022 Comment (115) of Doug True on Behalf of Nuclear Energy Institute (NEI) on PR-53 - Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors ML22243A1972022-08-30030 August 2022 Comment (092) from Bruce Montgomery of the Nuclear Energy Institute on PR-20, 26, 50, 51, 52, 72, 73 and 140 - Regulatory Improvements for Production and Utilization Facilities Transitioning to Decommissioning ML22087A0522022-03-24024 March 2022 Comment (003) of Jennifer Uhle on Behalf of Nuclear Energy Institute on PR-170, 171 - Fee Recovery for Fiscal Year 2022 ML22025A2332022-01-21021 January 2022 Comment (01) of Janet Schlueter on Behalf of Nuclear Energy Institute on PR-11, 25 and 95 - Access Authorization Fees ML21309A5782021-11-0505 November 2021 Comment (080) of the Nuclear Energy Institute and the U.S. Nuclear Industry Council on PR-53 - Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors ML21288A1302021-10-14014 October 2021 Comment (004) of Dr. Jennifer L. Uhle on Behalf of the Nuclear Energy Institute on PR-52 - NuScale Small Modular Reactor Design Certification ML21287A1462021-09-30030 September 2021 Comment (008) of Nuclear Energy Institute on PRM-50-119 - Access to the Decommissioning Trust Fund for the Disposal of Large Components ML21274A0702021-09-28028 September 2021 Comment (062) of Douglas True on Behalf of the Nuclear Energy Institute on PR-53 - Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors ML21265A4442021-09-15015 September 2021 Comment (007) of Marcus Nichol on Behalf of the Nuclear Energy Institute on PR-2,21,26,50,51,52,55,73 - Alignment of Licensing Processes and Lessons Learned from New Reactor Licensing ML21244A3312021-08-31031 August 2021 Comment (061) of Marcus Nichol on Behalf of Nuclear Energy Institute on PR-53 - Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors ML22133A2292021-08-30030 August 2021 EPFAQ 2021-001 Clarification of Section 4.3 of NUREG-7002, Criteria for Development of Evacuation Time Estimate Studies, Regarding Acceptable Error And/Or Confidence Interval ML21203A2252021-07-21021 July 2021 Comment (006) of Martin O'Neill on Behalf of Nuclear Energy Institute on ANPR-51 - Categorical Exclusions from Environmental Review ML21197A1032021-07-16016 July 2021 Comment (056) of Marcus Nichol on Behalf of the Nuclear Energy Institute on PR-53 - Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors ML21196A4982021-07-14014 July 2021 Comment (054) Submitted by Nuclear Energy Institute on Behalf of Multiple Stakeholders as Unified Industry Position on PR-53 - Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors ML21168A0952021-06-15015 June 2021 Comment (002) from the Nuclear Energy Institute on PRM-37-2 - Advance Tribal Notification of Certain Radioactive Material Shipments ML21166A1192021-06-14014 June 2021 Comment (045) of David Young on Behalf of Nuclear Energy Institute (NEI) on PR-53 - Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors ML21145A1722021-05-25025 May 2021 Comment (004) of Thomas Basso on Behalf of Nuclear Energy Institute on PR-50 - American Society of Mechanical Engineers 2019-2020 Code Editions ML21144A2892021-05-20020 May 2021 Comment (024) of William Gross on Behalf of Nuclear Energy Institute Regarding PR-26 - Fitness for Duty Drug Testing Requirements ML21144A1642021-05-14014 May 2021 Comment (005) of Marcus Nichol on Behalf of the Nuclear Energy Institute on PR-2,21,26,50,51,52,55,73 - Alignment of Licensing Processes and Lessons Learned from New Reactor Licensing ML21095A1002021-04-0101 April 2021 Comment (006) from the Nuclear Energy Institute on PR-50 - Approval of American Society of Mechanical Engineers' Code Cases ML21083A2882021-03-24024 March 2021 Comment (005) of Jennifer Uhle on Behalf of Nuclear Energy Institute on PR-15, 170 & 171 - Revision of Fee Schedules; Fee Recovery for Fy 2021 ML21068A3572021-03-0909 March 2021 Comment Period Extension Request of Marcus Nichol on Behalf of the Nuclear Energy Institute on PR-2,21,26,50,51,52,55,73 - Alignment of Licensing Processes and Lessons Learned from Nr Licensing ML21068A0972021-03-0808 March 2021 Comment (004) of Douglas True on Behalf of Nuclear Energy Institute (NEI) on PR-30, 40, 50, 70, and 72 - Alternatives to the Use of Credit Ratings ML21042B8892021-02-11011 February 2021 Comment (016) of Marcus Nichol on Behalf of Nuclear Energy Institute (NEI) on PR-53 - Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors ML21048A3602021-02-0101 February 2021 Comment (004) of Ellen C. Ginsberg on Behalf of the Nuclear Energy Institute on PR-1 - NRC Enforcement Policy ML21061A0442021-01-0707 January 2021 Comment (03) of Douglas True on Behalf of Nuclear Energy Institute (NEI) on Proposed Evaluation Policy Statement ML20363A2272020-12-23023 December 2020 Comment (004) of Marcus Nichol on Behalf of Nuclear Energy Institute (NEI) on PR-53 - Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors ML20289A6322020-10-15015 October 2020 Comment (001) of David Young on Behalf of the Nuclear Energy Institute on PRM-50-123- Public Protective Actions During a General Emergency ML20267A3262020-09-22022 September 2020 Comment (194) of Marcus Nichol on Behalf of Nuclear Energy Institute on PR- 50, 52- Emergency Preparedness for Small Modular Reactors and Other New Technologies ML20233A5892020-08-10010 August 2020 Comment (03) of Hilary Lane on Behalf of Nuclear Energy Institute (NEI) on PRM-50-121 - Voluntary Adoption of Revised Design Basis Accident Dose Criteria ML20128J3402020-05-0606 May 2020 Comment (01) of James E. Slider on Behalf of the Nuclear Energy Institute on PR-Chap 1- Retrospective Review of Administrative Requirements ML20077K3382020-03-16016 March 2020 Comment (003) from Jennifer Uhle on Behalf of the Nuclear Energy Institute on PR-170 and 171 - Revision of Fee Schedules; Fee Recovery for Fiscal Year 2020 ML19338D2552019-12-0202 December 2019 Comment (017) of William Gross on Behalf of the Nuclear Energy Institute Regarding PR-026 - Fitness for Duty Drug Testing Requirements ML19325C8352019-11-19019 November 2019 Comment (043) of Janet Schlueter from the Nuclear Energy Institute on PR-061 - Greater-Than-Class-C and Transuranic Waste ML19228A1842019-08-15015 August 2019 Comment (07) of Michael Tschiltz on Behalf of Nuclear Energy Institute on PR-50, 52, 73 - Physical Security for Advanced Reactors ML16068A2522019-07-30030 July 2019 Mitigation Beyond-Design-Basis Events Proposed Rule Comment (9) - NEI (Annotated) Original Submission Dated February 9, 2016 (ML16041A445) ML19178A3312019-06-27027 June 2019 Comment (01) of Michael D. Tschiltz on Behalf of Nuclear Energy Institute (NEI) on PRM-171-1 - Petition of Southern Nuclear to Revise Part 171 - Nuclear Power Plant Licensee Fees Upon Commencing Commercial Operation ML19149A4742019-05-28028 May 2019 Comment (06) of Janet Schlueter on Behalf of Nuclear Energy Institute (NEI) on PR-71 - Harmonization of Transportation Safety Requirements with IAEA Standards ML19123A1302019-05-0303 May 2019 Comment (25) from Nima Ashkeboussi on Behalf of NEI on PR-40 Regarding Ground Water Protection at Uranium in Situ Recovery Facilities 2024-01-22
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Page 1 of 1 PR-170 and 171 85 FR 9328 3 As of: 3/17/20 9:18 AM Received: March 16, 2020 PUBLIC SUBMISSION Status: Pending_Post Tracking No. 1k4-9fl6-v87b Comments Due: March 19, 2020 Submission Type: Web Docket: NRC-2017-0228 Revision of Fee Schedules: Fee Recovery for FY 2020 Comment On: NRC-2017-0228-0002 Revision of Fee Schedules; Fee Recovery for Fiscal Year 2020 Document: NRC-2017-0228-DRAFT-0004 Comment on FR Doc # 2020-03054 Submitter Information Name: Jennifer Uhle General Comment See attached file(s)
Attachments 03-16-20_NRC_NEI Comments on FY20 Proposed Fee Rule https://www.fdms.gov/fdms/getcontent?objectId=0900006484449d5f&format=xml&showorig=false 03/17/2020
JENNIFER L. UHLE Vice President, Generation and Suppliers 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8164 jlu@nei.org nei.org March 16, 2020 Ms. Annette Vietti-Cook Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemaking and Adjudications Staff Submitted via Regulations.Gov
Subject:
Industry Comments on Fiscal Year 2020 Proposed Fee Rule (NRC Docket ID NRC-2017-0228)
Project Number: 689
Dear Ms. Vietti-Cook:
On behalf of the Nuclear Energy Institutes (NEI)1 members, we provide the following comments for the U.S.
Nuclear Regulatory Commission (NRC) staffs consideration as it finalizes the fiscal year 2020 fee rule.
We appreciate the public meeting held by Ms. Cherish Johnson and other NRC staff on March 5, 2020 to discuss the FY 2020 proposed fee rule and its underlying basis and assumptions. This meeting included informative presentations from the Office of the Chief Financial Officer (OCFO) as well as presentations by the Office of Nuclear Reactor Regulation and Office of Nuclear Material Safety and Safeguards. The staff was very supportive and this meeting provided an effective forum for addressing stakeholder questions.
In prior year comments, we have identified a lack of transparency in the basis for the budget as an area of concern. We acknowledge that several steps have been taken to improve both the types and clarity of information provided in the fee rule work papers and Congressional Budget Justification. There has been a marked improvement in the level of detail provided to stakeholders on the NRC budget, however, we urge that additional steps be taken. In particular, we believe that additional detail should be provided on budgeted work activities, including a level of planned effort for each activity, how this level compares with the prior year, and the rationale for the change. Such detail would enable licensees to better evaluate and understand significant budget changes. Additional information should be provided to enable a better 1
The Nuclear Energy Institute (NEI) 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. NEI's members include 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.
Ms. Annette Vietti-Cook March 16, 2020 Page 2 understanding of which actions are recovered through service fees and which actions are recovered through annual fees. We also believe that stakeholders would benefit greatly from an expansion on the narrative discussion in the fee rule work paper explaining significant increases/decreases in product line budget items.
Over the past five years, Part 170 service fee collections have decreased by over 35%. This increases the percentage of NRC budget that must be recovered through annual fees. The percentage of the Operating Plant budget that is derived from annual fees (currently at 69%) continues to increase and is up from 58%
in FY 2013. The high percentage of activities covered by annual fees places an increased importance on transparency of indirect services covered under Part 171 fees. We encourage a continued focus on enhancing transparency.
The anticipated continued reduction in Part 170 service fee collections places a strong obligation on the NRC to ensure that staffing levels and budgets are properly aligned to reflect smaller projected workloads. The NRC should take all necessary steps to continue and expedite its efficiency efforts.
The proposed FY20 annual fee reduction for Fuel Cycle Facilities of approximately 26% is most welcome given that this small, shrinking, yet diverse fleet has seen a growing annual fee trajectory for nearly two decades. This topic has been heavily discussed through a series of public meetings in 2017-2018, in which over 20 unique comment letters from the fuel cycle industry were submitted to the NRC, highlighting the paramount importance of right-sizing this business line. A proposed 26% reduction in annual fees allows licensees to focus resources on items of true safety and security significance. We also appreciate NRC taking into consideration that FY20 will represent a smaller projected workload, based on several factors, leading to a proposed overall business line reduction of 22.6%.
However, we note that annual fees for Category I Fuel Cycle Facilities (listed under Category High-Enriched Uranium Fuel) still exceed operating power reactor fees by roughly half a million dollars ($4.9M vs. $4.5M, respectively). We continue to encourage the NRC to adjust the Category I Fuel Cycle Facility regulatory effort, and in turn fees, to be commensurate with the facility risk profile.
We note that the proportion of annual fees to the overall proposed FY20 budget is approximately 78%.
Given this proportion, we continue to emphasize the need for the NRC staff to work with industry in an open and transparent fashion regarding the prioritization of annual fee expenditures. This has been an outstanding industry request for the last several years, and we hope to engage with NRC staff on this item in the near term.
Furthermore, it is imperative that the OCFO staff take into consideration NMSS ongoing Fuel Cycle Smarter Program initiative, which will likely identify further reductions in FY21 fee-billable inspection hours. For planning purposes, a commensurate business line reduction in FY21 should closely reflect any final Smarter Programs inspection decisions (final reports are anticipated in Spring 2020). In the absence of such adjustments, fuel cycle facilities will experience an unnecessary increase in annual fees for FY21.
Ms. Annette Vietti-Cook March 16, 2020 Page 3 The proposed fee rule includes a revision to 10 CFR Part 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. NEI supports the changes to 10 CFR 171 that specifies that annual fees would be assessed after the licensee has successfully completed power ascension testing for holders of both Part 52 and Part 50 licenses.
Please contact me if you have any questions regarding these comments.
Sincerely, Jennifer Uhle c: Ms. Cherish Johnson, NRC/CFO