ML24130A167
| ML24130A167 | |
| Person / Time | |
|---|---|
| Issue date: | 09/11/2024 |
| From: | NRC/Chairman |
| To: | |
| Casey Smith, NRR/DANU | |
| Shared Package | |
| ML24130A155 | List: |
| References | |
| SRM-OGC240314-3, CORR-24-0049 Revised | |
| Download: ML24130A167 (14) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION ORGANIZATIONAL MANAGEMENT ASSOCIATED WITH ADVANCED REACTOR LICENSING FOR FIRST-OF-A-KIND NUCLEAR REACTORS
A Report to Congress
U.S. Nuclear Regulatory Commission August 2024
Enclosure INTRODUCTION:
The U.S. Nuclear Regulatory Commission (NRC, agency) developed this report as required by the Consolidated Appropriations Act, 2024 (Pub. L. No. 118-42)1 (the Act), which included the Energy and Water Development and Related Agencies Appropriations Act, 2024 as Division D. Senate Report 118-722 on the Energy and Water Development Appropriations Bill, 2024, and directs the NRC to submit to Congress a report providing an overview of the NRCs organizational structure to include the following:
options on how to improve organizational management to review advanced reactor license applications for first-of-a-kind nuclear reactors. The report shall review and assess the NRCs existing organizational structure and identify potential gaps in the current organizational licensing approach. The report shall also make recommendations to improve organizational management, such as establishing a dedicated review team with the leadership, expertise, capacity, and orientation to enable the issuance of a license in a timely, efficient, and safe manner.
For this report, the NRC refers to organizational management as planning, coordinating, and overseeing various elements within an organization to achieve its goals and objectives.
Organizational management underpins every aspect of the NRCs operations and involves directing and guiding resources, people, and processes to ensure efficient operations and optimal performance. The effective implementation of organizational management is crucial to the NRC in fulfilling its mission of ensuring the safe use of radioactive materials for beneficial civilian purposes while protecting people and the environment. The NRC periodically reviews and analyzes its organizational management to ensure that it is appropriately positioned to handle changes in workload, including increases in advanced reactor licensing work. This report is consistent with the recently passed Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy (ADVANCE) Act to position the NRC as a more agile, efficient, and forward-looking regulatory body, capable of supporting the rapid development and deployment of advanced nuclear technologies.
NRC staff (the staff) performed a self-assessment of its organizational management.
This assessment concluded that the NRC is prepared to conduct licensing reviews for the early advanced reactor applications. However, potential gaps were identified with the NRCs ability to conduct an increasing number of license application reviews for multiple reactor types simultaneously. The staff concluded the gaps can be addressed with the proposed actions in this report that will also leverage the flexibilities and direction provided in the ADVANCE Act.
The staff recommends actions be taken in three focus areas: Organizational Structure ;
Technical Capacity and Capability ; and Licensing Review Processes. The staffs recommendations in each focus area propose activities to augment and adapt the NRCs organizational management to prepare for changes in workload demand and the evolving advanced reactor landscape, building on the successes, lessons learned, and areas of need identified from the ongoing licensing reviews.
Consolidated%20Appropriations%20Act&text=This%20bill%20provides%20FY2024%20appropriations,inclu ding%20several%20public%20health%20programs.
2 https://www.congress.gov/congressional-report/118th-congress/senate-report/72
2 DISCUSSION:
Focus Area 1: Assessment of Current Organizational Structure License application reviews of advanced reactors are currently led by the Division of Advanced Reactors and Non-Power Production and Utilization Facilities (DANU) and the Division of New and Renewed Licenses (DNRL) within the Office of Nuclear Reactor Regulation (NRR). DANU is responsible for the licensing of non-light water power reactors (non-LWRs),
and non-LWR research and test reactors, while DNRL is responsible for the licensing of light water small modular reactors. The two divisions work closely together to address common technical, policy, and licensing issues. To ensure prompt and consistent resolution of issues impacting advanced reactor licensing, DANU and DNRL report to a common Deputy Office Director for New Reactors. (see figure 1)
Figure 1. Current NRC Advanced Reactor Licensing Organization Structure
Both divisions are engaged in pre-application activities with prospective applicants, reviews of advanced reactor licensing actions, and continued development of a modern, risk-informed regulatory infrastructure for advanced reactors. DANU and DNRL collaborate on common policy, guidance, and technical topics. Each division assesses and augments staffing in critical disciplines to support dedicated teams with the necessary leadership, expertise, capacity, and orientation to focus on advanced reactor readiness and licensing activities.
Potential Gaps Although the existing organizational approach for licensing has been able to effectively perform advanced reactor licensing reviews for certain applicants (e.g., NuScale, Kairos Power, LLC (Kairos)), the current approach may not be ideal to efficiently review the expected increase in advanced reactor license applications. Given the forecasted increase in initial advanced reactor license applications, in combination with ongoing licensing activities such as license renewal reviews, the staff will need to explore possible organizational changes or alternative structures to continue to perform efficient licensing reviews in both areas. These alternative
3 organizational structures could include restructuring existing branches and/or divisions or the addition of new branches.
Recommendations to Address Potential Gaps The NRC initiated an Agile Strategic Planning Initiative in early calendar year 2024 to explore ways to better align NRRs office infrastructure (e.g., processes and procedures) and organizational structure to maximize organizational agility in anticipation of future, dynamic workload scenarios. Key elements of this process include adoption of a phased approach to implementing this initiative, allowing for regular updates and adjustments; stakeholder engagement; use of cross -functional review teams (i.e., core and interdisciplinary review teams); data-driven decision making to inform strategic decisions; flexibility and responsiveness to changing regulatory needs and technological innovations; and transparent communication (e.g., use of internal and external licensing dashboards for real-time milestone tracking).The NRC recommends leveraging the ongoing Agile Strategic Planning Initiative to respond to changes to the advanced reactor landscape and forecasted workload and direction in the recently passed ADVANCE Act. The agency may need alternative organizational models (e.g.,
restructuring of existing divisions or branches and/or adding additional branches) to augment licensing efforts and allow the staff to continue to deliver efficient reviews in the coming years.
Focus Area 2: Assessment of Technical Capacity and Capability The NRC currently has the necessary staff to effectively review the immediate advanced reactor initial license application workload. However, in the coming years, the number of advanced reactor applications is expected to increase substantially. As such, current technical staffing capacity may be insufficient, thereby creating a potential gap in NRCs ability to address anticipated future advanced reactor activities on aggressive review timelines. The NRC needs to consider ways to close the potential gap by increasing its technical capacity to meet the expected increase in workload.
Core and Interdisciplinary Review Teams DANU and DNRL use core and interdisciplinary review teams to maximize review and staffing efficiencies and focus on the most safety-significant and risk-significant design aspects during pre-application interactions and application reviews. Review teams are structured to provide a clear framework to focus reviews and delineate decision-making responsibilities.
Comprised of project managers, policy experts, and technical subject matter experts from various disciplines across the agency, these review teams apply a scalable, integrated approach to reviews and holistic evaluation of applications. The staff ensures that appropriate skill sets are available on each review team. Furthermore, review teams leverage the centralized leadership structures in DANU and DNRL to streamline decision making, which supports the staffs ability to establish aggressive review schedules and conduct efficient reviews.
Organizational knowledge management and knowledge transfer activities enable the implementation of insights gained from completed reviews to further refine and enhance the efficiency of future reviews.
Additional Technical Support In addition to core and interdisciplinary review teams, the NRC leverages expertise from private contractors and the U.S. Department of Energy National Laboratories to support its advanced reactor activities. Private contractors augment the staffs technical capacity to conduct near-term reviews of license applications and topical reports. The staff also leverages contracts with the national laboratories to support application reviews, guidance development, and rulemaking activities for advanced reactors. By leveraging private contractors and national
4 laboratories, the staff enhances its capability to efficiently regulate advanced reactors on aggressive review and project schedules.
Workforce Planning Relevant skill sets and staff capacity requirements are identified up to 5 years in advance of the anticipated need. NRC managers analyze current workforce demographics, assess future workforce requirements, and forecast demand for skills based on evolving organizational objectives and industry trends. This allows the identification of areas where specific expertise is lacking or needs to be augmented.
The staff has implemented strategies for enhancing advanced reactor licensing readiness to fulfill the near-term objectives of identifying work requirements, critical skills, and staff capacity requirements; assessing the staffs current advanced reactor review readiness; and closing gaps in technical knowledge. In anticipation of increases in advanced reactor licensing activities, over the past several years, NRR has added additional staff and managers to match the growing workload. As an example, in January 2022, a second advanced reactor licensing branch and a second advanced reactor technical branch were created and staffed, along with a special assistant position, a senior level advisor position, and an additional senior executive leadership position. To address hiring challenges and retain existing staff, NRR has also increased the use of incentive tools, including recruitment, relocation, and retention incentives, and waivers of pension offset for rehired annuitants. These initiatives have been successful in increasing advanced reactor staffing levels as well as maintaining critical expertise. Additional hiring and retention tools provided by the ADVANCE Act will allow the staff to continue to enhance its readiness for this increased workload. The staff is currently evaluating these tools and will provide a report to Congress in January 2025 on plans for their implementation.
Staff Training and Knowledge Management The NRC recognizes the continuing need for and value of staff training and knowledge management in support of advanced reactor activities and technical disciplines. On an ongoing basis, technical review leaders and senior staff provide training to new and junior staff, promoting consistency and best practices in advanced reactor regulatory activities.
As personnel transition to new roles or depart from the agency, staff and resources are adjusted to ensure reviews continue on-schedule and with limited interruption. Significant information is also available on technical, policy, and regulatory issues associated with licensing advanced reactor designs to support such transitions. The staff is consolidating existing documents and training materials to make them more accessible and searchable and developing additional knowledge management resources, as needed.
Improved Budget Formulation Process The staff uses data derived from budget modeling to make informed decisions across various aspects of agency operations, including staffing. The NRC has enhanced its budget formulation process to allow for the allocation of appropriate staffing and resource levels.
Recent improvements in budget models consider insights gained from historical interactions with prospective applicants and successful project execution that are more reflective of the latest generation of nuclear plants (e.g., TVA Clinch River Early Site Permit ; Kairos Hermes 1 and 2 Construction Permits; and NuScale Design Certification). Further, the NRC considers a variety of factors to assess the confidence in assumptions related to when an application will be submitted, when in the fiscal year the resources would be applied, and how resources and staffing would be reassigned if plans change. This data-driven approach enables the staff to make strategic decisions. Additionally, the NRCs enhanced budget modeling has allowed the
5 agency to adapt to changing economic conditions, legislative requirements, and operational needs, ensuring it remains agile and responsive in its decision-making processes.
Potential Gaps Through analyzing the current workforce and comparing it to future needs, the NRC can identify skill gaps so that short-term and long-term strategies can be developed to enable the agency to recruit, retain, and develop a skilled and diverse workforce with the competencies and agility to address both current and emerging needs and workload fluctuations. Although the NRC can support the current licensing workload, the agency has already been challenged with meeting hiring goals. There is also a need to reduce the time-to-hire for new employees to help attract the best and brightest.
Recommendations to Address Potential Gaps To effectively manage its capacity to meet future needs, the staff recommends continuing its multifaceted approach to hiring, including attending career hiring fairs, utilizing the agencys direct hire authority, and developing job postings tailored to specific expertise requirements. These strategies have allowed the NRC to increase its visibility to highly qualified candidates, leverage expedited hiring processes, target high-demand roles, and reduce bottlenecks so that essential roles are filled efficiently. The staff will also explore how best to implement the new authorities granted to the NRC by the ADVANCE Act to further enhance recruitment and retention efforts.
For near-term capacity augmentation, the staff recommends continuing to utilize additional strategies on an as-needed basis, including using term-limited contract staff, retaining retirement-eligible staff with critical skill sets, and leveraging contracting support from private contractors and national laboratories. Term-limited staff could support emergent regulatory issues and address temporary surges in workload. Retaining retirement-eligible staff supports ongoing licensing and framework activities while also providing opportunities for ongoing training and knowledge management. Private contractors and national laboratories provide specialized expertise in nuclear technology and regulation that can be leveraged to review near-term license applications and develop necessary guidance documents to support future application development and reviews. The staff will modify contracts and establish new agreements with the necessary experts as the workload changes. These strategies are in place and can be implemented to provide support for critical projects where their unique skills can have the most impact.
For the longer term, the staff will need to reinvigorate a Strategic Workforce Planning process to ensure the resources are available to meet the expected increased demand in licensing actions. This includes not just advanced reactor licensing applications, but also licensing actions for the current light water reactor fleet and fuel cycle facilities.
Focus Area 3: Assessment of Licensing Review Processes The NRC has established regulatory frameworks and review processes to support the efficient reviews of ongoing and expected near-term advanced reactor initial license applications. The processes have been demonstrated through completion of the Kairos Hermes 1 construction permit application (CP) review ; the Kairos Hermes 2 CP and Abilene Christ ian University Molten Salt Research Reactor CP reviews, which are nearly complete ; and the Kemmerer Power Station, Unit 1 CP review, which uses the TerraPower Natrium sodium fast reactor technology, and is well underway. Also, the Commission recently approved the use of simplified hearing procedures to reduce the time and resources needed for uncontested mandatory hearings.
6 As new technologies and new deployment models are considered by developers, the NRC may need to explore alternative licensing approaches to adequately address potential gaps in its regulatory framework and review processes. The staff is identifying and addressing potential policy issues for rapid-deployment models of micro-reactors and is preparing a technology-inclusive, risk-informed regulatory framework for commercial nuclear reactors.
These activities are crucial for the NRC to remain able to support rapid-deployment models and effectively review both first-of-a-kind technologies and subsequent nth-of-a-kind license applications.
Enhanced Approaches to Advanced Reactor Licensing Reviews As part of its efforts to modernize and optimize licensing reviews of advanced reactors, the NRC is updating the regulatory framework to include regulations and guidance to support safety-focused, risk-informed licensing reviews for these new and emerging technologies. This includes initiatives such as the ongoing development of the Risk-Informed, Technology-Inclusive Regulatory Framework for Commercial Nuclear Plants (Part 53) rulemaking and the March 2024 publication of the Technology-Inclusive Content of Application Project and Advanced Reactor Content of Application Project guidance documents. 3 Additionally, the staff has adopted various strategies to execute safety-focused-reviews of advanced reactor applications efficiently and predictably, as described below.
The staff is taking actions to prioritize and address licensing and deployment considerations related to micro-reactors, including factory-fabricated micro-reactors. The staff is also working on possible policy issues related to licensing of nth-of-a-kind factory-fabricated micro-reactors, including options for maximizing standardization of design and operational programs and alternative environmental review approaches to support shorter deployment timeframes.
Early Pre-application Engagement The NRC encourages the earliest possible engagement among applicants, vendors, other government agencies and the NRC for the prompt identification of potential policy, licensing, or technical issues associated with an advanced reactor design or application. The staff encourages developers to prepare regulatory engagement plans. These plans provide structure to pre-application engagement and describe a prospective applicants detailed plans to engage with the NRC on tangible regulatory products during the development of an application for a license, certification, or approval of an advanced reactor design. The staff finalized additional pre-application guidance for advanced reactors in March 2024 as part of the Advanced Reactor Content of Application Project ( ML23277A139) to provide information to advanced reactor developers on the benefits of robust pre-application engagement to optimize application reviews, including schedule benefits and reduced business risks.
Pre-application engagement provides all interested parties, including the public, an opportunity to gain familiarity with the safety, environmental, and security characteristics of advanced reactor designs and applications. This engagement also provides an opportunity for the staff to consider the regulatory implications of specific design, siting, and programmatic elements; address key licensing, technical, and policy issues; discuss novel safety concepts; describe licensing processes, set expectations for the preparation of high-quality license applications, and inform the NRCs budgeting process. These pre-application engagements also contribute toward improving the stability and predictability of the licensing and regulation of advanced reactors, and supporting thorough application acceptance reviews, which are
7 conducted to ensure each application contains complete information to facilitate an efficient licensing review. To further improve the value of pre-application engagement, NRC staff offers applicants pre-application readiness assessments of draft applications before formal submittals to the NRC. These readiness assessments allow the staff to (1) identify any required information that is missing from the application, (2) identify technical or regulatory issues that may complicate the acceptance or technical review of the application, and (3) become familiar with the content of the application, particularly in areas where the applicant plans to propose new concepts or novel design features. Since the issuance of the office instruction in July 2020, numerous applicants have requested, and the staff has performed, these readiness assessments. Developers have effectively used the staffs feedback to address gaps in the technical and regulatory content of applications and to provide further clarity on new and novel concepts. The enhanced applications enabled the staff to establish and work to aggressive review schedules.
Obtaining Information During Application Reviews The staff has implemented process improvements and efficiencies to conduct reviews of applications, including improvements to its use of regulatory audits to ensure that the staff understands the information in the application as well as tools to obtain information needed to make regulatory findings, such as requests for additional information (RAIs), and requests for confirmation of information (RCIs).
Regulatory audits provide a mechanism for the staff to engage in real-time with applicants. Regulatory audits improve the efficiency of the staffs review of an application by facilitating early opportunities for the staff to gain understanding of the unique features of the design, verify information in the application, and identify whether the applicant may need to submit additional information for docketing to support a regulatory finding. Audits bolster more direct communication between an applicant and the staff conducting the review of the application. The staff leverages both in-person and hybrid discussions, site visits, and the exchange of draft information to move efficiently through a review. The staff has increased its use of regulatory audits, which has contributed to more timely issue resolution by either eliminating the need for RAIs and RCIs or enhancing the focus of such requests to ensure there is a clear safety and regulatory nexus.
Review Tools and Coordination Strategies The staff uses a variety of tools and coordination strategies to promote predictable, effective, and transparent review processes. For example, electronic reading rooms are used to facilitate the staffs review of information belonging to prospective and current applicants. These secure internet portals allow the staff to perform pre-application readiness assessments or regulatory audits virtually, saving significant time and cost for these activities. The staff has also developed a suite of internal and external licensing dashboards that provide timely and relevant information to decisionmakers, while providing increased transparency to members of the public on the status of advanced reactor reviews. In addition, the NRCs Technical Review Package software tool has been modernized to increase the efficiency of application reviews. To further enhance the visibility and accountability for licensing reviews, staff have initiated a pilot program to improve licensing project reporting. This program focuses on understanding variances in planned versus actual costs and schedule on a more real-time basis. This will help improve the ability to identify and address licensing review issues sooner.
NRR staff and managers responsible for the licensing projects coordinate with the NRCs Advisory Committee on Reactor Safeguards and other partner organizations within the NRC to ensure common understanding of priorities and enhance review efficiency. This coordination supports alignment on review scopes and schedules; identification and resolution of key
8 technical, licensing, and policy issues; timely receipt of input on licensing documents; and ongoing awareness of review status.
Environmental Review Processes: Enhancing Efficiency The staff is applying process improvements to advanced reactor environmental reviews, such as improving access to information using hybrid audits and expanded use of RCIs and, expanding use of incorporation by reference to eliminate duplicative information. These strategies have already proven successful in reducing the length and improving the readability of the Kairos Hermes 1 test reactor environmental impact statement (EIS). A proposed Generic Environmental Impact Statement for new reactors was also recently approved for publication by the Commission (ML24108A200); this will be issued for public comment later this year. The staff will continue to apply its experience, including past reviews, to determine the scope of reviews and focus on site-specific-issues and new and significant information. The staff also discusses strategies for streamlining its alternatives analysis process in the enclosure to SECY-23-0068, Evaluation of the U.S. Nuclear Regulatory Commissions Process for Selecting Reasonable Alternatives for National Environmental Policy Act Reviews, dated August 10, 2023 (ML23180A262). The staff has received and anticipates receiving additional new advanced reactor licensing applications in the near-term, which will enable the staff to implement the recently developed guidance and strategies on a diverse range of licensing scenarios. The staff is also implementing the requirements of the Fiscal Responsibilities Act, which requires streamlined National Environmental Policy Act reviews, including mandatory page limits for environmental review documents, as well as time limits for environmental reviews.
The staff is continuing to identify and implement efficiencies in subsequent advanced reactor environmental reviews. On September 13, 2023, the staff delivered SECY-23-0080, Environmental Review Approach for the Kairos Power, LLC, Hermes 2 Construction Permit Application (ML23214A165), to the Commission. The paper informed the Commission of the staffs intent to prepare an environmental assessment (EA) to determine whether a finding of no significant impact (FONSI) is justified or whether an EIS is necessary, to fulfill the NRCs obligations under the National Environmental Policy Act as part of the Hermes 2 environmental review. Because the staff had recently completed an EIS for the Hermes 1 reactor at the site, the staff began the environmental review for Hermes 2 with an EA and concluded that a FONSI was warranted. As a result, the Hermes 2 project required fewer resources and a shorter review schedule. More information on the status of the Hermes 2 environmental review can be found on the NRCs Hermes 2 website. 4
Leveraging Lessons Learned The staff documents best practices and lessons learned from ongoing and completed advanced reactor reviews and applies them to subsequent reviews. For example, in March 2022, the staff issued Lessons Learned from the U.S. Nuclear Regulatory Commission Staffs Review of the NuScale Design Certification Application ( ML22088A161). This report highlights best practices from the NuScale review process including the applicants engagement in pre-application activities to familiarize the staff with the design, development of a list of highly challenging issues, and staff efforts to streamline the safety evaluation report. Recently, the staff issued an interim lessons-learned report on the ongoing review of the NuScale standard design approval application (ML23345A079). In this report, the staff identified licensing review enhancements that will be implemented during the remainder of the standard design application
4 https://www.nrc.gov/reactors/non-power/new-facility-licensing/hermes2-kairos.html
9 review as the agency continues to adapt and modernize its advanced reactor licensing approaches.
As discussed earlier, the staff uses core and interdisciplinary review teams to maximize efficiencies and focus on the most safety-significant and risk-significant advanced reactor design aspects during pre-application interactions and application reviews. Further, advanced reactor review teams directly apply lessons learned from one review to the next. For example, staff familiarity with the Kairos Hermes design and the review of the Hermes 1 CP application facilitated establishing a 14-month review schedule for the Hermes 2 CP application review. The staffs finished its review ahead of schedule and completed the safety review in just over 10 months due to its familiarity with the design.
Potential Gaps While the NRC has demonstrated its ability to effectively complete recent and ongoing advanced reactor reviews, the staff will continue to identify ways to enhance its review processes and regulatory frameworks to prepare for future first-of-a-kind designs and rapid-deployment strategies. To ensure there is a clear and predictable regulatory framework, the staff will continue to identify and address policy issues with the Commission, continue necessary rulemaking efforts, and develop guidance that is technology-inclusive and risk-informed. The staff will need to ensure the regulatory framework adequately incorporates emergent policy issues to support a clear and predictable licensing review process. Additionally, the NRC needs to better develop and consistently rely on evidence-based performance metrics to improve internal agency performance and demonstrate improved efficiency.
Recommendations to Address Potential Gaps The NRC recommends continuing activities to enhance its regulatory framework to support the licensing of advanced reactors, including the preparation of rulemakings (e.g.,
Part 53), development of technology-inclusive, risk-informed, and performance-based guidance, and the identification and resolution of policy issues (e.g., rapid deployment of factory-fabricated micro-reactors). As part of this effort, the staff will continue to develop both near-term and longer-term strategies for addressing novel issues, identifying areas where issues can be addressed through the NRCs existing regulatory frameworks and other areas where it may be more appropriate to pursue rulemaking or guidance development.
To assist in the prioritization and development of policy topics, guidance documents, and rulemakings, the staff will continue to leverage its various communication and outreach tools to engage with stakeholders, including prospective applicants, industry groups, and non-governmental organizations. The NRCs periodic advanced reactor stakeholder meetings provide valuable, recurring forums for the staff to discuss important advanced reactor regulatory topics. Going forward, such meetings will provide the staff insights on the most important issues to address nth-of-a-kind factory-fabricated micro-reactor licensing. The staff will continue to engage with individual stakeholders, as needed, including technology developers, in drop-in meetings and focused public meetings. Such meetings support an open exchange on NRC activities and staff processes as well as application details, including submission timelines and technical content. The staff will continue to publish the status of its current advanced reactor activities, including guidance development, rulemaking activities, and licensing reviews on dashboards on the agencys advanced reactor readiness public website. 5
The flexibilities provided by the ADVANCE Act will also better position the agency as a more agile, efficient, and forward-looking regulatory body, capable of supporting the rapid
5 https://www.nrc.gov/reactors/new-reactors/advanced.html
10 development and deployment of advanced nuclear technologies while maintaining the core aspect of its mission to ensure safety. The staff will implement changes to licensing processes and the regulatory framework as necessary to meet the requirements of the ADVANCE Act. The staff will also develop and implement performance metrics to better measure the gains in efficiencies expected by the Commission, stakeholders, and the provisions of the ADVANCE Act.
SUMMARY
AND CONCLUSIONS:
The increased interest in advancing commercial nuclear projects will drive growing demand for staff resources. This is evident in the staffs current pre-application activity with more than 15 vendors with first-of-a-kind designs, in addition to the ongoing licensing reviews for advanced reactors. The number and variety of designs will require the staff to continue to innovate work processes and adapt the organization to ensure the NRC can continue to effectively implement its licensing mission.
The staff concluded the potential gaps identified in this self-assessment can be addressed with the proposed actions in this report that leverage flexibilities and direction provided in the ADVANCE Act. The NRC can implement the recommendations in this report and does not require additional legislative support to implement.
In its assessment, the staff identified that additional staff and management capacity will likely be needed to continue to improve upon generic and project-specific schedules for the known and forecasted, overlapping advanced reactor licensing reviews. Corresponding changes to the organizational structure will also likely be necessary to match the demand. The staff will continue to monitor the expected advanced reactor licensing workload and will take needed steps to adjust.
The staff has the necessary technical capacity to effectively review the current advanced reactor initial license application workload. Continued focus will be needed to ensure the necessary skillsets remain available to meet the anticipated additional workload. The staff will continue its multifaceted approach to recruitment and retention and plans to explore how best to implement the new authorities granted to the NRC by the ADVANCE Act. Strategies to leverage private contractors and U.S. Department of Energy national laboratories to supplement staff capacity will also contribute to the NRCs ability to efficiently review applications.
The staffs current licensing processes and regulatory infrastructure have been developed using best practices and lessons learned to enhance approaches to application reviews. The staff has consistently met or exceeded current project schedules by adapting its processes to meet identified needs and commensurate with the pace of industry activities.
Further, the staffs use of core and interdisciplinary review teams and other innovations in its organizational management has resulted in a marked improvement in review schedules.
However, the current application of core teams may not be sustainable to support the anticipated high-volume, rapid-deployment licensing of advanced reactors, and further refinement to how core teams are implemented will be needed.
The staff will continue to monitor and assess current licensing approaches and the effectiveness of its organizational management practices to continue to ensure efficient execution of advanced reactor activities. In addition, the staff will continue near and long-term efforts to ensure it has the adequate workforce and organizational structure to support optimal decision making in advanced reactor activities. This will ensure that the NRC continues to have the leadership, expertise, capacity, and orientation to enable the review of advanced reactor licenses in a timely, and efficient manner while providing reasonable assurance of adequate protection of the public health and safety.
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