ML25153A016
| ML25153A016 | |
| Person / Time | |
|---|---|
| Issue date: | 06/06/2025 |
| From: | Hipolito Gonzalez NRC/NRR/DORL/LPL1 |
| To: | Jamie Pelton Division of Operating Reactor Licensing |
| References | |
| EPID G-2024-AGN-0033 | |
| Download: ML25153A016 (1) | |
Text
June 6, 2025 MEMORANDUM TO:
Jamie Pelton, Acting Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:
Hipólito González, Chief /RA Richard Guzman for/
Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF MAY 22, 2025, COMMENT-GATHERING PUBLIC MEETING ABOUT U.S. NUCLEAR REGULATORY COMMISSIONS IMPLEMENTATION OF SECTION 505 OF THE ADVANCE ACT OF 2024 (EPID G-2024-AGN-0033)
On May 22, 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 workshop their approach to Section 505 of the Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy (ADVANCE) Act of 2024 regarding nuclear licensing efficiency with members of the nuclear industry.
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 The meeting notice and agenda are located at Agencywide Documents Access and Management System (ADAMS) Accession No. ML25113A087. The NRC staffs presentation slides are available at ML25141A107. A list of meeting attendees is provided in the enclosure.
CONTACT: Jack Minzer Bryant, NRR/DORL 301-415-0610
The NRC staff started the meeting with introductions and then described the new NRC Mission Statement and how it maintained current NRC goals while driving towards efficiency. The NRC staff introduced the main provisions of Section 505 and how the intent of the act is being implemented not only in NRR, but also in the Office of Nuclear Material Safety and Safeguards (NMSS) and throughout the agency. The NRC staff facilitated discussion in a workshop style on the following initiatives, which were introduced during the previous NRC public meeting on section 505 of the ADVANCE Act held on March 24, 2025 (ML25085A385):
Preapplication Engagement Draft Safety Evaluations (SEs) with Holes and Supplemental Information Streamlining Safety Evaluations Data Tools for Driving Efficiency Expanding the Use of LIC-206 During opening remarks, an individual from the Union of Concerned Scientists (UCS) expressed concern with implementation of efficiencies, while still ensuring safety.
The Pre-application Engagement presentation and discussion focused on enhancing the effectiveness and efficiency of pre-application engagement as part of the NRC's broader licensing initiatives under Section 505. An NRC staff member introduced the session by outlining internal guidance for project managers, including checklists and recommendations to better prepare for pre-application meetings. External criteria were also shared, emphasizing the importance of pre-application meetings for complex, unique, or precedent-deviating applications, while identifying scenarios where such meetings might not be necessary.
Additionally, NRC staff explained how their technical reviewers are tasked with providing input on discussion topics before pre-application meetings to ensure early identification of technical concerns. The follow-on workshop discussion also proposed potential metrics to evaluate the effectiveness of pre-application meetings, such as tracking whether applications were accepted without the need for supplemental information.
Representatives from the Nuclear Energy Institute (NEI) and the Tennessee Valley Authority provided positive feedback on a recent pre-application meeting, praising the NRC staffs thorough review and inclusion of relevant technical staff (ML25108A105). They also highlighted staff flexibility in rescheduling of the meeting to ensure staff had time to evaluate information prior to the meeting. Stakeholders suggested expanding audit-style discussions prior to pre-application meetings to facilitate more refined applications and emphasized the importance of timely submission of pre-application materials. Industry representatives supported tracking metrics, including the number of non-accepted applications, and recommended conducting root cause analyses to identify areas for improvement. A member from UCS raised concerns about the potential for informal resolutions during pre-application discussions to lack public transparency, highlighting the importance of documenting all necessary information formally.
Suggestions were made to optimize communication tools and processes, such as modernizing electronic portals to facilitate direct information exchange and providing clear flowcharts or numbering systems for pre-application steps on the NRCs website. Stakeholders also discussed the challenges of relying on outdated precedents and recommended periodic reevaluation to ensure their continued relevance. Additionally, industry representatives emphasized the need for applicants to provide clear documentation of risk significance, safety margins, and defense-in-depth measures to assist NRC staff in streamlining reviews. Industry representatives recommended that NRC provide direct feedback during pre-application
meetings, even if objections exist, to help applicants avoid submitting proposals unlikely to be accepted.
The presentation on the Draft Safety Evaluation (SE) with Holes concept was led by an NRC representative from the Division of Safety Systems. It focused on improving efficiencies in licensing reviews by frontloading documentation and leveraging supplemental information tools.
The presenter emphasized that the draft SE with holes concept is not new but has been reinforced through recent NRC staff management actions. This process involves early documentation of the safety evaluation, identifying gaps or holes in the information needed to make a regulatory finding, and ensuring that requests for additional information (RAIs) are technically and legally justified. The NRC staff representative highlighted the importance of internal alignment meetings during the acceptance review stage, where technical staff can coordinate their efforts, refine hours estimates, and confirm resource needs. Additionally, milestones for completing the draft SE with holes were added to the NRC's project management system to track progress. The goal was to align the depth of reviews with the safety significance of the issues and promote schedule certainty.
The subsequent discussion involved NRC staff and stakeholders from industry groups, utilities, and associations. Members of NEI shared positive feedback on the role of project managers in coordinating audits and ensuring alignment among technical reviewers. They recommended expanding audit processes to enable earlier and more collaborative dialogue between NRC staff and licensees, which could help clarify application details and reduce the need for RAIs.
Industry participants noted the importance of high-quality applications to minimize supplemental information requests and emphasized the need for licensees to improve timeliness in responding to RAIs. A representative industry suggested modernizing the RAI process by allowing quicker exchanges of information, such as through informal calls or electronic submissions, rather than formal letters, which may be administratively burdensome.
The NRC staff acknowledged the industry's concerns about resource allocation and highlighted efforts to track and trend the use of RAIs and request for confirmatory information (RCIs). The representative noted that RCIs, which are quicker to resolve, were being used more frequently since management emphasized their efficiency. However, metrics were still being developed to assess the relative impacts of RAIs and RCIs on review schedules. A member of UCS raised concerns about the transparency of the audit processes, cautioning that informal resolutions during audits might reduce public visibility compared to formal RAI responses. The NRC staff clarified that audit reports document discussions and outcomes, and all information necessary for regulatory findings is placed on the public docket.
Industry representatives proposed that audits become the standard approach for resolving technical issues, with RAIs used only when necessary. They noted that audits allow real-time interaction between technical experts and licensees, facilitating quicker resolution of complex issues. Another industry representative from NEI emphasized the importance of ensuring that audit processes are flexible and scalable, ranging from simple phone calls to detailed in-person discussions. Stakeholders also discussed the benefits of electronic tools and portals to streamline communication and reduce administrative overhead. A representative from the Idaho National Laboratory suggested using resident inspector-style communication as a model for audits, given its success in resolving issues efficiently at operating plants.
The presentation on Streamlining Safety Evaluations (SEs) was delivered by an NRC staff member from the Division of Operating Reactor Licensing, who discussed efforts to improve the efficiency and clarity of SEs while maintaining transparency and public trust. The presentation
began with a historical overview of past initiatives, including the creation of boilerplate templates for operating reactor SEs and subsequent efforts to harmonize SE templates across NRC divisions. This harmonization resulted in consistency in section titles, a "bottom line up front writing style, and the elimination of lengthy narratives in favor of concise citations and references. The NRC staff outlined the major components of an SE, such as the introduction, technical evaluation, and regulatory findings, and sought feedback on potential improvements.
Specific ideas included using bullets instead of narratives to summarize evaluation criteria, mirroring the structure of applications in the technical evaluation section, and reducing repetitive text through references or incorporation by reference. Additionally, the NRC staff highlighted ongoing efforts to pilot artificial intelligence (AI) tools to assist in SE drafting, specifically for power uprates and license renewal reviews.
A representative from industry expressed strong support for the initiative and highlighted the value of templates in improving consistency and predictability. They suggested considering the use of AI to automate repetitive sections of SEs, such as summarizing application details or regulatory criteria, and noted that some companies are already experimenting with AI for drafting applications. Another representative from a utility echoed this sentiment and encouraged the NRC to explore AI applications further, including tools to process large volumes of information and identify key insights efficiently. They noted that AI tools are already being used in corrective action programs and data analysis within the industry.
A representative from The Breakthrough Institute (TBI) recommended revisiting the structure and usability of the NRCs public SE fee estimator tool suggesting that it could include examples of particularly efficient SEs to help applicants align their submissions with best practices. They also proposed integrating more intuitive data visualizations into the tool to improve accessibility for less experienced applicants. Other participants suggested creating a streamlined checklist or template for licensees to use when developing SE inputs, which could help ensure that submissions align with NRC staff expectations and reduce the need for back-and-forth communication.
A member from UCS raised concerns about the use of AI in regulatory processes, cautioning against the risk of AI-generated errors or hallucinations and emphasizing the importance of maintaining public transparency and human oversight. NRC staff reassured participants that any AI tools used would include strict governance and would always keep humans in the loop to ensure quality control. The same representative also noted the importance of ensuring SEs do not appear to be rubber-stamped and remain focused on safety and thorough regulatory oversight.
The discussion also touched on the potential for NRC and industry collaboration to streamline the SE process further. An industry representative suggested that licensees could assist by providing more concise and focused applications, reducing the volume of information the NRC needs to process. They also proposed that the NRC consider using structured electronic submissions to pre-populate SE templates automatically, saving time on manual drafting.
Several stakeholders emphasized the importance of balancing efficiency with transparency, ensuring that SEs remain accessible and understandable to public audiences.
The presentation on Using Data Tools to Drive Efficiency was delivered by representatives from the NRCs Division of Operating Reactor Licensing and focused on leveraging data analytics and visualization tools to improve licensing efficiency and accountability. The NRC presenters shared success stories, including an 18% reduction in schedules and a 6% reduction in staff hours for license amendment reviews after transitioning from generic one-year timeline
to a data-informed schedule based on historical trends. They highlighted the power of data-driven decision-making in enhancing the predictability and efficiency of licensing actions.
Metrics and performance indicators were outlined, including leading and lagging indicators such as tracking adherence to estimated completion schedules and monitoring the development of draft SEs with holes. The presenters emphasized the importance of data integrity and shared dashboards and tools used internally to track licensing milestones, identify at-risk actions, and monitor resource utilization. The NRC presenters also highlighted a recently implemented metric to reduce duration and resources on reviews by a minimum of 10-15% based on historical data and pointed out that the anticipated reduction is being documented in acceptance review letters.
During the discussion, stakeholders from industry groups, utilities, and associations expressed strong support for the NRCs efforts to adopt a data-driven culture. An industry representative commended the granularity of the tools and dashboards, noting that they provide clear accountability and transparency. They inquired about how NRC staff are incentivized to maintain the fidelity of data inputs, with NRC representatives explaining that data stewards in each division ensure consistency and accuracy. NRC staff management also emphasized the importance of integrating data tools into daily operations to build a culture of accountability and continuous improvement.
A representative from the Nuclear Innovation Alliance (NIA) provided feedback on the public fee estimator tool, suggesting that its usability could be improved with clearer data visualizations, examples of efficient applications, and more intuitive navigation. They noted that some stakeholders might find it challenging to interpret the ranges provided and suggested including explanations of why certain applications required more hours than others. Several industry participants echoed this sentiment and recommended expanding the fee estimator tool to include additional details, such as high and low ranges, and examples of applications with minimal resources required.
Utility representatives highlighted the importance of modernizing communication tools to streamline interactions between licensees and NRC staff. They suggested that electronic portals could be used to facilitate submissions, noting that providing draft inputs directly in the portal could reduce administrative overhead and improve efficiency. The NRC staff explained that updates to the electronic submission tool are underway.
A member of UCS emphasized the importance of maintaining public transparency in the use of data tools. They cautioned against relying solely on dashboards for internal decision-making and stressed the need to ensure that external stakeholders can access meaningful metrics. The NRC staff highlighted their commitment to publishing relevant metrics and tools, such as the fee estimator, on the public website and acknowledged the need for continuous refinement based on stakeholder feedback.
A presentation on Expanding the Use of LIC-206 (ML19263A645) was delivered by NRC staff.
It focused on implementing a graded approach to licensing reviews to align the depth and scope of technical evaluations with the safety and risk significance of the issues under review. LIC-206, an office instruction initially created to guide integrated review teams, was highlighted as a foundation for expanding efficiency in licensing processes. The NRC staff presenters introduced enhancements to Appendix C of LIC-206, which includes a checklist and grading tool to help technical reviewers determine the necessary scope of their evaluations. The proposed graded approach categorizes reviews into three levelslimited, typical, and comprehensivebased on the safety and risk significance of the licensing action. Each category is associated with specific estimated review hours and schedules, allowing the NRC to better allocate resources and ensure efficiency while maintaining a focus on safety. The presenters emphasized that the
process would be driven by data, with tools such as Standardized Plant Analysis Risk (SPAR) models and risk insights used to confirm safety margins and risk significance.
A representative from a utility shared their positive experience as a test case for the graded approach, noting that the NRCs use of risk insights and streamlined communication during their application review significantly reduced staff hours and expedited the timeline. They highlighted the importance of open dialogue between technical reviewers and licensees to ensure clarity and alignment on safety margins and risk significance. Another utility representative emphasized the need for licensees to provide concise and focused applications, including clear documentation of risk insights, defense-in-depth measures, and regulatory margins, which could assist the NRC staff in effectively applying the graded approach.
A representative from industry expressed strong support for the initiative and proposed that industry stakeholders collaborate with the NRC staff to identify specific types of applications that fit into each category and align expectations for review hours and submission details accordingly. Additionally, they raised the possibility of exploring a streamlined format for safety evaluations associated with limited reviews, such as using tables or charts to present regulatory margins and defense-in-depth measures concisely.
A representative from NEI highlighted the importance of transparency and consistency in applying the graded approach. They suggested that the NRC provide examples of completed reviews in each category to help licensees better understand the expectations and align their submissions accordingly. They also emphasized the need to ensure that the process accounts for regulatory complexities, such as precedent deviations and site-specific conditions, without compromising efficiency.
A member of UCS raised concerns about the potential for the graded approach to reduce the depth of technical reviews in cases of limited or typical classifications. They emphasized the importance of maintaining rigorous safety evaluations and ensuring that risk significance is properly assessed. The NRC staff clarified that the graded approach does not compromise safety but instead focuses resources on areas of greatest safety significance. They noted that the process includes safeguards to reassess reviews if new information or deviations from precedent arise during the evaluation.
The discussion also explored opportunities for collaboration to refine LIC-206 further. Several stakeholders proposed holding a workshop to define specific categories of licensing actions, establish commensurate levels of review detail, and align metrics for efficiency gains. The NRC staff committed to piloting the graded approach with select licensing actions to assess its effectiveness and gather feedback before full implementation. They emphasized that this initiative is part of a broader four-pronged approach to improving licensing efficiency, which includes best practices, clear roles and responsibilities, and accountability measures.
At the end of the meeting, the NRC staff gave closing remarks.
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 May 22, 2025 Name Affiliation Aaron McCraw U.S Nuclear Regulatory Commission (NRC)
Ada Bowie NRC Adam Donell Constellation Energy Adam Stein The Breakthrough Institute (TBI)
Adrienne Brown NRC Ahsan Sallman NRC Alissa Neuhausen NRC Amanda Leatherman NRC Amber Aboulfaida Tennessee Valley Authority (TVA)
Amitava Ghosh NRC Andrea Russell NRC Andy Imboden NRC Anthony Schoedel Westinghouse Art Zaremba Duke Energy Audrey Klett NRC Ayesha Athar NRC Baris Sarikaya Constellation Energy Beth Wetzel NRC Bill Rautzen NRC Billy Gleaves NRC Blake Purnell NRC Brett Titus Nuclear Energy Institute (NEI)
Brian Taylor NRC Brian Lee NRC Brittany M. Lutz Nuclear Innovation Alliance (NIA)
Carla Roque-Cruz NRC Carol Moyer NRC Carolyn Fairbanks NRC Chaitali Chattopadhaya NRC Ching Ng NRC Christian Ramos Constellation Energy Christopher Cooper Unknown Christopher Bailey Florida Power & Light (FPL)
Cindy Montgomery NRC Clint Ashley NRC DaBin Gibbs NRC Daniel King NRC David Gennardo NRC David Drucker NRC Deann Raleigh Unknown Deric Tilson TBI Derek Scully NRC Derek Smith Unknown Dinesh Taneja NRC Dong Zheng NRC Doug Broaddus NRC Drew Childs NRC Drew Richards PWROG Eben Allen NRC Ed Miller NRC Edwin Lyman The Union of Concerned Scientists Ekaterina Lenning NRC Emma Haywood NRC Ewa Muzikova Unknown Gabrielle Schreier General Electric (GE)
Grace Pennington NRC Hannah McLatchie NRC Hanry Wagage NRC Hipo Gonzalez NRC Hiruy Hadgu NRC Ian Jung NRC Ian Tseng NRC Ilka Berrios NRC Inseok Baek NRC James Gaslevic NRC James Morris Pacific Gas and Electric Company James Barstow Constellation Energy Jared Nadel NRC Jason Christensen Idaho National Laboratory Jennie Rankin NRC Jennifer Beaton NRC Jeremy Groom NRC Jill Shepherd NRC Jo Ambrosini NRC John Dufner TVA John Hughey NRC John Matrachisia NRC John Budzynski NRC John Valverde NRC Jonathan Evans NRC Jonathan Marcano NRC Joy Jiang TBI Juan Arellano NRC Julie Hough Dominion Energy Keith Tetter NRC Kevin Hsueh NRC Kimberly Green NRC Kimberly Hobbs Constellation Energy Kristopher Cummings NuScale Laurel Bauer NRC Lauren Helstosky Dominion Energy Lauren Bryson NRC Leah Parks NRC Liam O'Donoghue NRC Lisa Simpson Constellation Energy Lisa Williams Unknown Lois James NRC Lydiana Alvarado Unknown Mahesh Chawla NRC Marieliz Johnson NRC Marlayna Doell NRC Martin Stutzke NRC Matt Hendrickson Unknown Maureen Conley NRC Michael Orenak NRC Michael Mazaika NRC Michael Marshall NRC Michelle Kichline NRC Michelle Vega Rodriguez NRC Michelle Hayes NRC Nate Jordan NRC Nathan Clark Unknown Nathan Chapman GE Nicole Good STARS Alliance Nicholas Hansing NRC Patrick Koch NRC Pattrick Simpson Constellation Energy Paul LaFlamme NRC Philip McKenna NRC Phyllis Clark NRC Rachael Davis NRC Ray Schiele TVA Richard Fu NRC Richard Guzman NRC Robert Pascarelli NRC Roberto Torres NRC Ross Wagner NRC Russell Felts NRC Summer Sun NRC Sam Bina NRC Sarah Cole NIA Scott Ferrara Idaho National Laboratory Sean Meighan NRC Shane Jurek Public Service Enterprise Group Shanlai Lu NRC Shayan Sinha Dominion Energy Sheila Ray NRC Sherry Andrews Duke Energy Sheryl Sanchez NRC Stephan Moen Unknown Steven Alferink NRC Surinder Arora NRC Syed Haider NRC Tanya Smith NRC Ted Smith NRC Teko Foli NRC Terri McLaughlin NRC Theresa Howell Unknown Thomas Buffone NRC Timothy Enfinger GE Todd Hilsmeier NRC Tony Sierra NRC Tracy Radel NRC Travis Tate NRC Varoujan Kalikian NRC Victoria Anderson NEI Vince Voltaggio NRC Wendy Brost Unknown William Roggenbrodt NRC William Orders NRC Yeon Kim NRC Youssef Rokes NRC Yuken Wong NRC Zach Turner NRC Zhian Li NRC
ML25153A016 NRR-106 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL1/LA NRR/DORL/LPL1/BC NAME JMinzerBryant KEntz (KZeleznock for)
HGonzález (RGuzman for)
DATE 05/30/2025 06/02/2025 06/04/2025 OFFICE NRR/DORL/D (A)
NAME JPelton DATE 06/06/2025