ML25043A103
| ML25043A103 | |
| Person / Time | |
|---|---|
| Issue date: | 03/03/2025 |
| From: | Hipolito Gonzalez NRC/NRR/DORL/LPL1 |
| To: | Pelton J Division of Operating Reactor Licensing |
| Klett A, NRR/DORL/LPL1 | |
| References | |
| EPID G-2024-AGN-0033 | |
| Download: ML25043A103 (13) | |
Text
March 3, 2025 MEMORANDUM TO:
Jamie Pelton, Acting Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:
Hipólito González, Chief /RA/
Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF JANUARY 23, 2025, INFORMATION PUBLIC MEETING ABOUT NRCS IMPLEMENTATION OF SECTION 505 OF THE ADVANCE ACT OF 2024 (EPID G-2024-AGN-0033)
On January 23, 2025, the U.S. Nuclear Regulatory Commission (NRC or the Commission) staff from the Office of Nuclear Reactor Regulation (NRR) held a public meeting to inform external parties of the implementation of Section 505 of the Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy (ADVANCE) Act of 2024 regarding nuclear licensing efficiency.
Section 505 of the ADVANCE Act (Section 505) requires the NRC to:
establish techniques and guidance for evaluating applications for licenses for nuclear reactors to support efficient, timely, and predictable reviews of applications for those licenses to enable the safe and secure use of nuclear reactors maintain the techniques and guidance by periodically assessing and, if necessary, modifying those techniques and guidance obtain approval from the Commission if policy formulation is needed to accomplish these provisions This public meeting focused on the objectives, attributes, and measures for licensing efficiency, predictability, and timeliness (LEPT) and various initiatives in place to meet Section 505.
The meeting notice and agenda are located at Agencywide Documents Access and Management System Accession No. ML25022A145. The NRC staffs presentation slides are available at ML25022A123. A list of meeting attendees is provided in the enclosure. Before the meeting, two members of the public provided written comments, which are available at ML25023A211 and ML25023A216.
CONTACT: Audrey Klett, NRR/DORL 301-415-0489
The NRC staff provided an overview of its approach for addressing the provisions of Section 505 of the ADVANCE Act. Section 505 provides for establishing and implementing techniques and guidance that support safety, security, and efficiency in licensing reviews. NRC staff opening remarks discussed the various initiatives in place to improve agency efficiency, such as establishing clear and transparent interactions with the industry, improving project management capabilities and tools (including metrics), and risk-informing and right-sizing resources on inspection and differing professional opinion reviews. The NRC staff also discussed collaboration between its reactor and material licensing programs.
To accomplish the Section 505 provisions in the near term, NRC staff plans to leverage initiatives (and their working groups) that already are either establishing, clarifying, or revising techniques and guidance for licensing. For more longer-term actions, NRC staff plans to leverage its workload management and data analysis infrastructure and develop other tools, as needed, to assess techniques and guidance, to identify resource impacts, and to help identify and address future needs. To periodically assess NRCs techniques and guidance, the NRC staff plans to use quantitative data-driven measures and qualitative measures, such as feedback, surveys, and meetings.
The NRC staff discussed a conceptual framework for how LEPT objectives relate to NRCs mission. The purpose of the framework concept is to generate discussion about the meaning of, and measures for, efficiency, predictability, and timeliness in licensing and to foster a work culture that integrates efficiency into NRCs safety framework. The NRC staff emphasized NRCs safety and security mission and that incorporating the LEPT provisions of the ADVANCE Act into its work would not compromise safety and security. The NRC staff discussed proposed definitions for efficiency, predictability, and timeliness; objectives and goals for LEPT strategies; attributes and behaviors to support LEPT strategies; and possible measures for LEPT strategies. The NRC staff stated that it is considering this conceptual framework to assist with implementing Section 505 provisions and requesting and evaluating any feedback about Section 505 implementation.
The NRC staff has initiatives in place that are establishing, clarifying, or revising licensing techniques and guidance and meet the objectives of Section 505. Those initiatives include the creation of the reactor licensing efficiencies and processes (R-LEAP) team to find improvements in the efficiency, timeliness, and predictability of licensing processes. The R-LEAP team is currently focusing on LEPT strategies for preapplication meetings, safety evaluations, and metrics and is considering feedback from external parties. Other NRR initiatives include the following:
promoting the integration of risk information in NRRs decision-making process through outreach, workshops, and knowledge management identifying and evaluating enhancements to NRR Office Instruction LIC-206 to leverage risk tools and risk insights to grade reviews commensurate with their safety significance hosting a knowledge management workshop to share experiences with the development, review, and implementation of risk-informed categorization and treatment of structures, systems, and components in accordance with 10 CFR 50.69 maintaining a modern, risk-informed regulatory infrastructure with reduced uncertainty that will continue to enable the expanded safe use of digital technologies preparing for power uprate reviews using a strategy that will support licensee schedules while maintaining reasonable assurance of public health and safety
establishing a team and guidance for the safe and efficient reauthorization of power operations of a decommissioning reactor facility that seeks to transition back to an operational reactor facility developing a generic risk-informed evaluating process for very low risk significant licensing actions containing only qualitative risk insights developing refinements to the risk-informed process for evaluations (RIPE) based on feedback from recent implementation establishing efficiencies in license renewal reviews The NRC team working on Section 505 is tracking and integrating licensing-related initiatives and directions from various sources and coordinating with NRCs Office of Nuclear Material Safety and Safeguards (NMSS) to share licensing practices. The NRC staff discussed a recent example of initiative progress and consideration of feedback from public meetings and workshops: the recent issuance of a memorandum (ML24278A002) from the NRR Office Director to NRR Division Directors conveying leaderships expectations for implementing near-term actions that align with NRCs commitment to fulfill the ADVANCE Act. These expectations included having more transparency in NRCs organizational structure, highlighting the importance of preapplication meetings, promoting safety-focused risk-informed reviews being accomplished in an integrated manner, and developing draft safety evaluations before sending requests for additional information.
The NRC staff indicated that the working groups for the various initiatives may hold workshops and public meetings in the future, as needed.
After the NRC staffs presentation, the NRC staff held question-and-answer sessions for the industry and public. The topics discussed included the following:
Representatives from the Nuclear Energy Institute (NEI) inquired about the timeframe for implementing and tracking Section 505 deliverables, whether NMSS will issue a licensing efficiencies memorandum similar to NRRs memorandum, and whether the public will have an opportunity to learn the details of the initiatives before the NRC submits a report to its Executive Director for Operations (EDO). The NRC staff noted that feedback can be provided via NRCs ADVANCE Act website and at future public meetings. The NRC staff noted the timeframe for implementation includes a report due to NRCs EDO in July 2025, which may outline both near-term and long-term strategies and that the strategies would include periodic assessments.
The NRC staff indicated that the report would be made public. NRCs reports to Congress include summaries of past accomplishments, ongoing work, and planned activities. The NRC staff further noted that NMSS plans to issue a licensing efficiencies memorandum similar to the NRR memorandum. The NRC staff noted that the efficiency initiative teams and the Section 505 team may have public meetings or workshops. NEI staff commented that the LEPT framework concept appears to have the right topics and that it looks forward to more details, workshops, and actionable items.
An individual from Micro-Utilities informed the NRC staff that he previously provided comments to the NRC (ML24366A097) and asked how the NRC uses risk insights, judges the risk importance of our actions, and considers risk for advance reactors given the lack of operating experience for those reactors. The NRC staff discussed that it uses qualitative risk insights and quantitative risk from probabilistic risk assessments to inform its licensing decisions. The NRC staff discussed various licensing processes, such as its risk-informed process for evaluation (RIPE) and guidance from the NRR office instruction LIC-206, which provides for the use of
integrated review teams consisting of risk analysts and technical reviewers. The NRC staff noted that it is working on strategies for establishing and meeting reliability targets especially for passive system reliability, research and development programs, consideration of margins and defense in depth, and modernized licensing process for advanced reactors. The NRC staff also discussed its use of existing programs, such as risk-informed completion times for out-of-service components and the maintenance rule (10 CFR 50.65).
Staff from PSEG asked if any Section 505 deliverables, such as metrics, training, and job aids, will be publicly available, commented that RIPE, which improves efficiency, appears to be underutilized by the industry, and recommended that NRC and industry collectively understand why RIPE is not more routinely used and to see if changes are needed. The NRC staff indicated that it is still evaluating metrics and intends to have more open dialogue with the industry and public about Section 505 deliverables. The NRC staff indicated that RIPE can be used voluntarily by the industry and that the NRC staff issued guidance that changed the threshold for entering RIPE. The NRC staff noted that the volume for utilization cases is low and indicated that additional applications may be needed to further evaluate RIPE.
An individual from NANO Nuclear asked how NRCs generic licensing tools, such as requests for additional information, overlap or intersect with advanced and new reactor licensing. NRC staff noted that its R-LEAP team membership consists of NRC staff from multiple divisions, including NRC staff working on advance reactor licensing. The R-LEAP team is collaborating across divisions and offices, including NMSS, and is looking at best practices.
An individual from The Breakthrough Institute commented on the importance of defining what it means for the NRC staff to consult because uncertainty about what communications constitute consulting limits the effectiveness of preapplication engagement. He commented that NRC staff is hesitant to provide answers or feedback during public meetings because of this; however, the NRC staff needs to be clear on what it needs in applications to support efficiency. He also commented that regarding risk-informed decision-making, while it is valuable to focus on areas most critical to risk, there is a different understanding of uncertainty with varying applications between NRC staff and the NRCs Advisory Committee on Reactor Safeguards (ACRS). He also noted that NRC is hosting a symposium about artificial intelligence (AI) on March 13, 2025, and questioned the efficiency of NRCs ADVANCE Act public meetings because they have had slightly different formats. The NRC staff noted the observations.
An individual from Southern Company inquired about the status of NRCs preapplication meeting guidance and its contents. The NRC staff discussed preapplication guidance under development and the licensing efficiency memorandum that would address pre-application engagement, preparation, communications, parity in management levels present at meetings, and recommendations for when to hold a preapplication meeting.
An individual from the New York Department of Public Service raised a concern about how promoting efficiency could affect safety culture in that people may be less included to raise questions to not slow down processes. He asked if NRC leadership will be trained on this and suggested comparing safety culture impacts of deregulation on the commercial industry. The NRC staff noted that safety and security remain at the forefront of the NRCs mission, and that the NRC staff recently held a training session with outside risk experts to reinforce commitment to this core value. The NRC staff is also examining and monitoring its differing views program to maintain balance between safety significance and resources and to ensure decision-makers consider NRC staff concerns.
An individual from ClearPath expressed appreciation for NRC staff stating that our efficiency plans are not to conduct business as usual hope that the LEPT framework concept becomes business as usual, similar to NRCs use of metrics. He asked how the NRC will approach licensing efficiency for new reactors when there is no specific guidance available. In response, the NRC emphasizes the importance of preapplication dialogue, especially for novel projects, and the role of core teams and audits in ensuring efficiency. NRC staff mentioned ongoing efforts to update licensing guidance with a focus on documenting margin savings and incorporating lessons learned. Additionally, a tiger team is working on updating the guidance to improve overall processes.
An individual asked if the NRC plans to focus on criticality hazards in plants, as opposed to reactor meltdowns, based on lessons learned and the difference in risk profiles. The NRC staff emphasized that preapplication engagement has been beneficial and encouraged the industry to continue using it. The NRC staff also stated that its fuel facilities branch is prioritizing work, using centers of excellence, and developing an approach to streamline processes that identifies and uses precedents.
An individual from Vermont public service suggested that NRC make efforts to ensure that NRR regulations are properly communicated to NMSS when working with shutdown facilities and to clarify what constitutes a high-quality submittal. The NRC staff indicated that NMSS and NRR are collaborating to ensure the rules for shutdowns between reactor and fuel facilities are clear and well-defined.
An individual from C-10 provided several suggestions, including incorporating climate change data from the April 2024 U.S. Government Accountability Office report into NRCs risk models, improving access to recordings and transcripts of presubmittal meetings, and being cautious about reducing the scope of public communications during the licensing process because licensee responses are important for the publics education. She also sought clarification on whether the ADVANCE Act would be shifting to performance-based versus risk-informed regulation, wanted to see more data analysis on violations and corrective actions, and recommended evaluating when the public can request meetings, especially when not all application details are available. In response, the NRC staff indicated that its division of engineering and external hazards leads the evaluation of climate change impacts on external hazards. The NRC staff mentioned that listservs [distribution and notification lists] exist for public meeting notifications and that [non-sensitive] information needed for licensing decisions is docketed and publicly available. The NRC staff indicated that both performance-based and risk-informed regulatory approaches continue to be elements of Commission policy and that additional information about these approaches can be found in SECY-98-144 and its associated staff requirements memorandum and NUREG/BR-0303, which are available on NRCs public website. The NRC staff indicated that it is expanding its use of data analysis to track schedules and resources more effectively. The NRC staff also noted that public involvement is governed by regulations and urgency of a requested action.
An individual asked whether NRC is working with the States regarding new bills related to reactor construction. The NRC staff mentioned that NRC has state liaison officers that coordinate with the States.
An individual from Union of Concerned Scientists raised concerns that pushing for efficiency could lead to cutting corners and asked what safeguards are in place to ensure that safety and security are maintained. He also emphasized the importance of not giving the impression that outcomes are prejudged and highlighted the applicants responsibility to ensure the quality of its
application, particularly through tighter acceptance reviews. The NRC staff emphasized that safety and security are NRCs top priority and the importance of having a credible regulator that the public can trust to make safety decisions. The NRC staff indicated that streamlining processes and timelines will not come at the expense of safety. The NRC staff noted that this public meeting was an example of transparency and that part of improving efficiency involves enhancing communications about application expectations. The NRC staff also indicated that it is focusing on higher safety priorities and looking at processes and public workshops to ensure better public understanding.
Individuals expressed concern that the NRC is increasing its workload while facing a severe workforce shortage and hiring freeze. The NRC staff indicated that it is following its normal budget process for resources. An individual also raised questions about the technical bases for approvals, particularly for advanced technologies that are often proprietary, making them difficult for the public to access. She also highlighted that, for spent fuel, the financial responsibility falls on the public. The NRC emphasized its goal of making communications public but noted that regulations do allow for the protection of proprietary information when necessary.
An individual noted that he provided comments to NRC staff prior to the meeting. The NRC staff stated it would enter the comments into ADAMS (ML25023A216). Another individual asked how NRC was considering an NEI suggestion about increasing the use of AI for preparing and reviewing submittals and how the NRC would avoid hallucinations (errors or false outputs) from AI. The NRC staff stated that it is evaluating the suggestion but is currently prioritizing preapplication meetings, safety evaluations, and requests for additional information. The NRC staff indicated that AI use case proposals have been submitted to the Commission. The NRC emphasized that AI may be used as a tool but the fundamental standards for verification would remain unchanged; submittals would still be verified against regulations.
At the end of the meeting, the NRC staff gave closing remarks. The industry representatives expressed anticipation for additional details and actionable items.
The enclosure provides the attendance list for this meeting.
Enclosure:
List of Attendees
Enclosure List of Attendees U.S. Nuclear Regulatory Commission Public Information Meeting on NRCS Implementation of Section 505 of the ADVANCE Act January 23, 2025 Name Affiliation Aaron McCraw U.S. Nuclear Regulatory Commission (NRC)
Abbie Bennett S&P Global Adam Stein The Breakthrough Institute Addison Hall Dominion Energy Aida Rivera-Varona NRC Aixa Belen NRC Alan Blind Unknown Alfred Meyer Unknown Alison Brown Florida Power & Light (FPL)
Alvin Leong U.S. Department of Energy (DOE)
Amanda J. Spalding Westinghouse Amber Donley NRC Amber Vendel Aboulfaida Tennessee Valley Authority (TVA)
Andrew Bowman Westinghouse Andrew Mauer Nuclear Energy Institute (NEI)
Andrew Zach EPW (Senate)
Andy Hon NRC Andy Imboden NRC Annie Ramirez NRC Anthony Leshinskie Vermont April Thomas NRC Audrey Klett NRC B. Cizin PSEG Bill Noval Holtec Blake Purnell NRC Brett Titus NEI Brian R. Stander Nebraska Public Power District Brittany Lutz Nuclear Innovation Alliance Bryson Roberson Unknown Camille T. Zozula Westinghouse Carlos Sisco Winston & Strawn Caty Nolan NRC Chace Allen Holtec Cheryl Ann Gayheart Southern Nuclear Chris Markley NRC Name Affiliation Christopher E. Cooper NYSERDA (New York)
Clifford Chapin DPS (New York)
Clinton Hobbs NRC Colleen Coffey DOE Dan Denis Structural Integrity Associates Daniel C. Beachy Dominion Energy Daniel Ju NRC Daniel King NRC David Bryant CDA (Massachusetts)
David H. Tiktinsky Boston Government Services David Rahn NRC Deann Raleigh Curtiss Wright Dennis Earp Jr.
Duke Energy Dennis M. Moore Constellation Nuclear Derek Scully NRC Diana Diaz Toro NRC Dinesh Taneja NRC Dr. Deb Luchsinger preferred licensing services Duane R Avery II Constellation Nuclear Ed Miller NRC Edwin Lyman Union of Concerned Scientists Elena Herrera Torres NRC Emily Portanova Entergy Enrique Melendez Asensio Consejo de Seguridad Nuclear Eric Bowman NRC Eric Oesterle NANO Nuclear Ernest F. Bates Southern Nuclear Gordon Robert Williams TVA Grace Pennington NRC Greg Core NEI Haimanot Yilma NRC Hannah E. Pell Constellation Nuclear Hannah McLatchie NRC Harry Balian Unknown Heath Baldner NAC International Herschel Specter Micro-Utilities Hipólito González NRC Hunter Broadaway Arkansas Ian Jung NRC J. Beau Eckermann TVA Jack Giessner NRC Jack Minzer Bryant NRC Jack Parrott NRC Name Affiliation Jackie Harvey NRC Jaison Monachan NRC James Andrachek Westinghouse James D. Reilly Venable James Petro NextEra Jamie Marquess Coleman Southern Nuclear Jamie Pelton NRC Jan Mazza Holtec Jared Nadel NRC Jason Albert Christensen Idaho National Laboratory Jason Jennings PSEG Jeffrey Bartelme Shine Fusion Jennifer Beaton NRC Jennifer Pema DOE Jesse S. Brown Constellation Nuclear Jill S. Monahan Unknown John Bozga NRC John Giddens Entergy John Klos NRC Jordan L. Vaughan Duke Energy Joseph McManus Westinghouse Joy Jiang The Breakthrough Institute Julie H. Hough Dominion Energy Justin Wearne Unknown Kalene Walker Unknown Kari Osborne Southern Nuclear Kenneth Erwin DOE Kenneth M. Thomas Pacific Northwest National Laboratory Kenneth Mack FPL Kevin Krause LARA (Michigan)
Kiera Zitelman National Association of Regulatory Utility Commissioners Kimberly Dawn Hulvey TVA Kinya Nakamura Unknown Laurel Bauer NRC Lauren Nist NRC Lauren Quinones Navarro NRC Levander, Matthew NextEra Lindsey Renee Grissom Southern Nuclear Lisa A. Simpson Constellation Nuclear Lisa L. Williams Energy Northwest Lisa Matis Tetra Tech Lora K. Drenth Constellation Nuclear Luis Betancourt NRC Name Affiliation Luke Haeg NRC Maddie Blalock EPW (Senate)
Maggie Chauhan NRC Maribel Valdez FPL Marty Murphy Curtiss Wright Matthew Warren IBEW Megan Wright NRC Meghan Thorpe-Kavanaugh PSEG Michael C. Costello DHS (Wisconsin)
Michael Hallman Unknown Michael Mahoney NRC Michael Richardson Pacific Gas and Electric Company Michael Richardson Unknown Michelle Albert NRC Mike Annon Becht Mike Franovich NRC Mike King NRC Mike True Dominion Energy Mohammed Aljallad Unknown Nicole Good STARS Alliance Nikki Gilanshahi NRC Niko McMurray ClearPath Otto W. Gustafson Entergy Patricia Skibbee Unknown Patrick Joseph Asendorf TVA Patrick R. Simpson Constellation Nuclear Paul Loza Westinghouse Paul Lusardi Holtec Phil Lashley Vistra Corp Phil Niebaum NRC Philip Couture, III Entergy Philip McKenna NRC Rachael Davis NRC Rachel A. Luebbe Constellation Nuclear Ralph Caruso Unknown Raymond Burski arc Clean Technology Ricardo Lantigua NRC Richard Bright NRC Richard Guzman NRC Richard M. Garcia Energy Northwest Rob Sweeney Unknown Robert Sun NRC Robin Ritzman Curtiss Wright Name Affiliation Rossnyev Alvarado NRC Ruben Papraniku DEP (New Jersey)
Russell Douglas Wells TVA Ryan K. Lighty Morgan Lewis Sam Bina NRC Sam Miranda Unknown Sara L. Scott Xcel Energy Sarah Abramson C-10 Sean Meighan NRC Shana Helton NRC Shane Jurek PSEG Shao Lai NRC Shaun Matthews FPL Shayan Sinha Dominion Energy Spencer Klein NEI Spencer Toohill Unknown Stephen Philpott NRC Stephenie Pyle Unknown Steve Catron Certrec Steven Dolley S&P Global Steven Hamrick FPL Steven Pope ISL Surinder Arora NRC Suzanne Ani NRC Tasha E. Stephens Duke Energy Terri McLaughlin NRC Theo Edwards NRC Tim Siefer American Electric Power Timothy G. Williamson NOV Todd Hilsmeier NRC Todd Smith NRC Tom Boyce NRC Tom R. Byrne Duke Energy Tomas Bardauskas Unknown Tony Nakanishi NRC Tony Sierra NRC Trace Orf Unknown Tracy Land Arkansas Travis Iskierka-Boggs NRC Tyler Hammock NRC Undine Shoop NRC Vic Cusumano NRC Wendi E. Para Constellation Nuclear Name Affiliation Wesley Steh X-energy William T. Jessup NOV Yeon Kim NRC Yi-Lun Chu NRC Zach Turner NRC
ML25043A103 NRR-106 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DORL/LPL1/BC NAME AKlett KEntz HGonzález DATE 2/13/2025 2/13/2025 2/13/2025 OFFICE NRR/DORL/D (A)
NAME JPelton DATE 3/3/2025