ML25141A107

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May 22, 2025 Public Workshop Presentation Slides
ML25141A107
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Issue date: 05/22/2025
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ADVANCE Act Section 505 Nuclear Licensing Efficiency NRR Initiatives Workshop May 22, 2025

Meeting Logistics

  • Comment gathering public meeting with designated question and answer sessions
  • Attendees mics & cameras and meeting chat feature are disabled
  • During the Q&A sessions, use Teams raise hand feature, and NRC staff will enable you to unmute your mic
  • In-person attendees must disable/mute their laptop mics & speakers 2

If attendees would like their names listed in the publicly available meeting summary attendance record, please email NRC staff listed on the meeting notice.

Agenda (times are approximate)

Time Topic 9:00 AM

Introductions

9:05 AM Opening Remarks 9:10 AM Overview of Section 505 and NRR Initiatives 9:25 AM Pre-Application Engagement 10:30 AM Draft SE with Holes & Supplemental Information 11:30 AM Break 1:00 PM Streamlining Safety Evaluations 2:05 PM Data Tools for Driving Efficiency 3:10 PM LIC-206 4:15 PM Open Discussion 4:55 PM Closing Remarks and Adjourn 3

Opening Remarks from Core Team

  • Jessica Hammock, Executive Technical Assistant
  • One part of NRCs overall implementation of the ADVANCE Act.
  • NRCs public website has additional information about our overall implementation of the Act and plans for other upcoming and past public meetings related to the Act (QR codes on later slide)
  • Use the Contact Us form on the website for general questions, comments, and ideas on the ADVANCE Act (Later slide) 4

Overview of ADVANCE Act Section 505 and NRR Initiatives Jamie Pelton

NRC Mission Statement 6

The NRC protects public health and safety and advances the nations common defense and security by enabling the safe and secure use and deployment of civilian nuclear energy technologies and radioactive materials through efficient and reliable licensing, oversight, and regulation for the benefit of society and the environment.

ADVANCE Act, Section 505 7

1) 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;
2) maintain the techniques and guidance by periodically assessing and, if necessary, modifying those techniques and guidance; and
3) obtain approval from the Commission if establishment or modification of the techniques and guidance involves policy formulation.

Preapplication Engagement 8

  • Vital to the efficiency, predictability, and timeliness of licensing reviews
  • Allows for the review and pre-approval of topics prior to an application
  • Promotes the resolution of challenging technical topics to prevent in schedule delays
  • NRC staff are always open to suggestions to increase the efficiency and effectiveness of pre-application engagement.

Division of Operating Reactor Licensing Pre-Application Meeting Guide 9

  • NRC staff job aid that captures how we currently do work
  • Recommends tools and best practices
  • Describes mechanics of setting up, conducting, and summarizing a meeting
  • Contains checklists and templates

Considerations for When to Have a Preapplication Meeting 10 When to Have a Meeting

- technically complex, unique, significant scope

- significant changes from licensing basis

- deviations from NRC-approved or accepted methods, precedents, or review standards

- substantive fleet actions

- first-of-its-kind or new analytical approaches

- risk-informed applications

- digital instrumentation and control related

- power uprate amendments When Not to Have a Meeting

- several precedents or an approved TSTF traveler with no significant deviations

- no complex or unique issues

- insufficient time to incorporate NRC staff feedback

- lack of preparedness for substantive discussion (e.g., proposal is conceptual and lacks details, or no presentation material)

Preapplication Meeting - Early Engagement 11

  • Goal - Consistency in the quality of dialogue at the pre-application meeting
  • Licensee communicate scope of requested action in sufficient detail with PM
  • PM generate tasking to solicit input from staff
  • Staff develop customized feedback and make publicly available
  • Licensee consider staff input in the development of their presentation
  • Slides are available to staff in advance of meeting

Preapplication Meeting - Potential Metrics 12

  • Goal - Quantitative measurement of individual pre-application meeting effectiveness
  • Operating reactors - Number of actions that are non-accepted or non-accepted with opportunities to supplement
  • Operating reactors - Key issues identified at the PAM as documented in the meeting summary
  • New/advanced reactors - Number of hours expended by staff prior to docketing of application

Prospective Applicant Guide 13

  • Set of new webpages that contain basic information for prospective applicants with no previous NRC interactions.

https://www.nrc.gov/reactors/new-reactors/advanced/new-app.html

  • Provides general administrative information, application guidance, and topics the NRC would like prospective applicants to identify prior to contacting the NRC.
  • Goal is to increase early-interaction efficiency for prospective applicant and the NRC staff.

Q&A

Break

Draft Safety Evaluation (SE) with Holes and Supplemental Information 16 Derek "Rick" Scully Safety and Plant Systems Engineer Containment and Plant Systems Branch Division of Safety Systems

Team Goals/Composition 17 In support of Section 505 of Advance Act:

  • Team created to look at improving efficiencies:
  • Taking holistic approach (RPS, Overall Schedule, etc.)
  • Draft SE with Holes development
  • Use of Supplemental Information gathering tools
  • Request for Additional Information (RAI)
  • Request for Confirmatory Information (RCI)
  • Regulatory Audits
  • Team Composition
  • Various Business Lines
  • Branch Chiefs
  • Technical Staff
  • Project Management Staff

Draft SE with Holes 18 Several NRR Office Instructions discuss development of "Draft SE with Holes" before requesting additional information Reinforced via recent licensing efficiencies memorandum To carry out this expectation, the R-LEAP team:

Added RPS Milestones to support concept Internal Alignment Meetings Draft SE with Holes Developed Evaluated Overall Schedule Defined "Draft SE with Holes" and its purpose Developing guidance

  • Includes examples
  • Connection to RAIs/RCIs/Audits Conducting "Rollout Sessions" with staff

Goals of "Draft SE with Holes" Initiative 19

  • To begin early development of the safety evaluation and identify gaps/missing information in the application needed to make a required safety finding,
  • To maximize schedule certainty while also potentially decreasing the length of the review schedule and amount of resources needed to complete the review,
  • To avoid issuing RCIs/RAIs that are not needed to make a regulatory finding,
  • To minimize the chance that information needs are missed while drafting initial RAIs, RCIs, or audit questions (i.e., ensure no requirements are missed),
  • To minimize the chance that additional information needs (i.e., late RAIs, and RCIs) are identified after the due date for RAI, RCIs, has passed that may extend the duration of the review,
  • To avoid duplicative effort and minimize rework,
  • To identify if an audit is needed/what information is needed during an audit, and
  • To confirm that all technical areas in the submittal are evaluated.

RAIs/RCIs 20

  • Developing RAI/RCI guidance Best practices as to when to use each Reinforce "3 part" structured construction of questions Job Aid/Desk Guide being developed Ensuring Office Procedures accurately reflect current practices
  • Performing Roll Out Sessions with Staff Interactive Business Line Specific

Regulatory Audits 21

  • Developing Audit Best Practices Discuss different "types" of Audits How Audits can be used for different business lines/projects How Audits/RAIs/RCIs can be used together Job Aid/Desk Guide being developed Ensuring Office Procedures accurately reflect current practices
  • Performing Roll Out Sessions with Staff Interactive Business Line Specific

Issues that Challenge Schedule 22

  • Licensee controlled issues:

Quality of Applications/Submittals RAI/RCI Response Time Timely Scheduling of RAI/RCI Clarification Calls Quality of RAI/RCI Responses

Q&A

Break

Data Tools Driving Efficiency 25 18% reduction in schedule 6% reduction in staff hours This is the power of Data and Metrics to Modify Behavior

Data Tools Driving Efficiency - Data Stories 26

  • Metric for estimated completion schedule is 80% of reviews completed between 75% and 115% of the estimated schedule
  • Missed last quarter:
  • 34% of the licensing actions in FY25 Q2 (Jan-Mar) were outside the band
  • Of the 34%, 31 reviews were completed in less than 75% of the estimated schedule and 2 reviews were completed in greater than 115% of the estimated schedule

Data Tools Driving Efficiency - Data Stories Are we improving?

27 Trends for Repeatable Reviews 9% reduction in number of days to complete the review 11% reduction in number of hours to complete the review

Data Tools Driving Efficiency - Data Stories Are we improving?

28 Not including TSTF 425 and 505 18% reduction in number of days to complete the review 52% reduction in number of hours to complete the review

Data Tools Driving Efficiency - Data Stories Does the number of Review Hours Increase with longer Schedules?

29 15% reduction in number of days to complete the review 18% reduction in number of hours to complete the review

Data Tools Driving Efficiency - Data Stories Does the number of Review Hours Increase with longer Schedules?

30 8% reduction in number of days to complete the review 11% reduction in number of hours to complete the review

Data Tools Driving Efficiency - Metrics 31

Data Tools Driving Efficiency - Leading & Lagging Indicators 32

  • A new 10% reduction metric is being implemented with the goal of driving a 10% decrease in both licensing action schedules and resources.
  • Draft Safety evaluation
  • The SE with Holes milestone should help prevent additional rounds of RAIs by identifying all the areas in need of additional information.
  • The SE with Holes milestone will also shorten the schedule for licensing actions where RAIs are not needed.

Data Tools Driving Efficiency - Workload Management 33

Data Tools Driving Efficiency - Milestone Tracking 34

  • Used as an accountability tool
  • Indicates where milestones are missed.
  • This shows that a milestone may be missed or data was not updated.
  • Used in conjunction with the Data Stewards, the open milestone dashboard helps to maintain accurate data or may indicate reviews that are experiencing challenges.

Data Tools Driving Efficiency - 6 Factor Formula 35

  • We analyzed licensing actions complete within the last 5 years to compare project aspects that result in higher project schedule and resource utilization.
  • Determined 6 factors that historically increase the resource and schedule utilization:
  • number of RAI rounds,
  • number of associated branches,
  • number of associated documents, number of milestone date changes, and number of milestones completed after their initially scheduled date.
  • This allows us to shift focus to projects with potential overages earlier in project life.

Data Tools Driving Efficiency - EASE Tool 36 The EASE Tool provides a resource for project managers and technical reviewers to find precedence, estimate resources, and estimate schedules.

The tool contains easy to use search functions and outputs a list of similar projects with data and links to RPS.

Data Tools Driving Efficiency - Fee Estimator 37 The Fee Estimator tool uses data similar to that shown in the EASE tool. This tool gives a range of expected resources that a licensing action can be expected to take.

The broader categories can be selected in order to give more specific bands based on the planned licensing action. (Example:

License Amendments)

This allows for greater regulatory certainty to licensees when planning licensing action requests.

Q&A

Break

Streamlining SEs 40

  • BLUF: We plan on initiating an SE streamlining effort and would like your feedback on what we should focus on moving forward.
  • History: There have been efforts in the past, such as The SE streamlining team, and later SE harmonization, that are related to streamlining SEs. Aspects of these efforts are intended to be codified in LIC-101, along with results of the ADVANCE Act initiatives.
  • Each Office/Division has existing means to train their staff on writing SEs, but our next step is to figure out a way to streamline the production of the SE.

Streamlining SEs History - Operating Reactor Licensing 41

  • SE streamlining resulted in and addition to LIC-101: A template for a typical SE and instructions for preparing an SE is provided in the DORL boilerplates under ADAMS Package Accession No. ML20136A161.
  • SE harmonization efforts did not result in a consistent SE format across licensing actions; however, several improvements resulting from the efforts are planned for office instructions.
  • eSE: An example of a streamlined SE for non-proprietary proposed alternatives.

42 Proposed Harmonized SE Template Sections Applicable to License Amendment Safety Evaluation?

Applicable to Topical Report Safety Evaluation?

Applicable to 50.55a Request Safety Evaluation?

Table Of Contents Optional Optional Optional 1.0 Introduction Yes Yes Yes 2.0 Evaluation Criteria Yes Yes Yes 3.0 Technical Evaluation Yes Yes Yes 4.0 Limitations and Conditions No Yes, when there are limitations and conditions on the use of the of the topical report No 5.0 Emergency Situation Yes, when emergency situations exist or are invoked No No 6.0 Exigent Circumstances Yes, when exigent circumstances exist or are invoked No No 7.0 Final No Significant Hazards Consideration Yes, when (1) a hearing is requested, (2) action is an emergency or exigent amendment, or (3) the amendment will be issued prior to the expiration of the hearing request period No No 8.0 State Consultation Yes No No 9.0 Disposition of Public Comments Yes, when NRC receives applicable comments No No 10.0 Environmental Consideration Yes No No (*May change with rulemaking) 11.0 Conclusion Yes Yes Yes 12.0 References Optional Optional Optional 13.0 Abbreviations Optional Optional Optional 14.0 Principal Contributors Yes Yes Yes

Streamlining SEs - Questions for Discussion 43

  • Cover Letters: Staff has traditionally leaned towards some type of cover page because packaged documents need something to tie them together.
  • Do you have suggestions on the best way to package licensing actions (letter, form, something else)? Issues with eSEs?

Streamlining SEs - Questions for Discussion 44

  • Regulatory Evaluation: Staff has considered using only bulleted lists of review criteria instead of narratively describing how or why the review criteria are applicable.
  • Do you have feedback on this type of format change?
  • Do you have other suggestions for the regulatory evaluation section?

Streamlining SEs - Questions for Discussion 45

  • Technical Evaluation:
  • Organizational considerations: Does industry have preferences?
  • Mirroring licensees application
  • By evaluation criteria
  • Grouping related changes
  • Improving regulatory finding components
  • Reducing long quotes and RAI history
  • Use of bullets to summarize regulatory findings

Streamlining SEs - Advanced Reactors 46

  • Streamlining perspectives
  • Templates and content guide contain streamlining guidance
  • Concise, clear, and consistent
  • Safety-focused commensurate with risk or safety significance
  • SE templates are further developed as draft SEs for review use at the beginning of new licensing application reviews (e.g., TerraPower Kemmerer 1 and X-energy Long Mott Generating Station construction permit applications)

Q&A

Break

49 Four-Pronged Approach and Expanding the Use of LIC-206 (Graded Review Approach)

ADVANCE Act, Section 505 Public Workshop May 22, 2025 Accelerating Licensing, Anchored in Safety Agenda Four-Pronged Approach:

50 (I) Approach to grade operating reactor licensing reviews (Updates in LIC-206, Appendix C) (DORL Handbook)

(II) Best Practices and Process Efficiencies (NRR staff and licensees)

(III) Roles and Responsibilities (for all levels of NRR Staff and Management)

(IV) Expectations and Contributions to Ensure Success Four-Pronged Approach for Conducting Efficient Operating Reactor Licensing Reviews, While Maintaining a Safety Focus

51

  • A Tiger Team of staff from the technical divisions in NRR, led by DRA, in partnership with DORL, is proposing a new graded review process for the operating reactor licensing action reviews. We are seeking industry and public feedback on this proposed approach.
  • This process will be documented in an update to LIC-206, Integrated Risk-Informed Decision-making for Licensing Reviews, Appendix C and the DORL Handbook (planned for Summer 2025).
  • The new graded review process will be applied to all technical reviews for license amendment requests, exemption requests, and relief requests, but will exclude LR/SLR and EPU reviews, with the NRR 15% review hours reduction and schedule metric/backstop (planned for implementation in Fall 2025).
  • With implementation of the 4-pronged approach, including the graded review approach, staff expect to see further efficiencies and reductions to review hours and schedules, beyond the NRR 15% review hours reduction and schedule metric.
  • This is one of the many initiatives that are underway, to best position the office in meeting the mandates of the ADVANCE Act, Section 505; the recent executive orders; as well as our new mission statement, in conducting our licensing reviews in an efficient manner, while still ensuring that our safety focus is met.

BLUF - Proposed Graded Review Approach

52 LIC-206 App. C Draft-Individual Technical Reviewer (TR) Checklist/

Review Grading Tool (Example LIC-206 App. C TR Checklist Item)

The TR Checklist/Grading tool will be applied by each technical reviewer for their assigned scope of review in RRPS. Note, Figure 2 is an abbreviated set of criteria and does not include all the details provided in the draft LIC-206 update, which are also included in the following slides.

53 Proposed Graded Approach - Criteria

54 Proposed Graded Approach - Criteria, Contd.

55 Proposed Graded Approach - Criteria, Contd.

56 Proposed Graded Approach - Criteria, Contd.

57 LIC-206 App. C Draft - Case Study: Diablo Canyon Integrated Leak Rate Test (ILRT) License Amendment Request (LAR)

58 LIC-206 App. C Draft - Case Study: Diablo Canyon ILRT LAR, Contd.

59 Next Steps Upcoming Meetings and Deliverables:

  • Summer 2025: Public Workshop with Industry on Graded Review Approach
  • Late Summer 2025: Workshops with NRR staff to Implement Graded Review Approach
  • Fall 2025: Issue LIC-206 Update and Implement Graded Review Approach/Process

Q&A

Break

62

Be Engaged!

63

Closing Remarks

Abbreviations 65

  • 10 CFR 50.69 - Title 10 of the Code of Federal Regulations, Section 50.69
  • AI - artificial intelligence
  • DI&C - digital instrumentation and controls
  • FTE - full-time equivalent
  • GALL - generic ageing lessons learned
  • IEEE - institute of electrical and electronics and engineers
  • ISG - interim staff guidance
  • KM/KT - knowledge management/knowledge transfer
  • LEPT - licensing efficiency, predictability, and timeliness
  • M-LEAP - Materials Licensing Efficiencies and Processes
  • NEI - Nuclear Energy Institute
  • NFPA - National Fire Protection Association
  • NMSS - Office of Nuclear Material Safety and Safeguards
  • NRR - Office of Nuclear Reactor Regulation
  • RAI - request for additional information
  • RCI - request for confirmation of information
  • RIDM - risk-informed decision-making
  • R-LEAP - Reactor Licensing Efficiencies and Processes
  • RPS - Reactor Program System
  • SE - safety evaluation
  • SRP - standard review plan
  • WBL - Web-Based licensing
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