ML25153A070
| ML25153A070 | |
| Person / Time | |
|---|---|
| Issue date: | 06/04/2025 |
| From: | James Downs NRC/NMSS/DFM/FFLB |
| To: | Lav S NRC/NMSS/DFM/FFLB |
| References | |
| Download: ML25153A070 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 MEMORANDUM TO:
Samantha C. Lav, Chief Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards FROM:
James R. Downs, Senior Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF MAY 14, 2025, PUBLIC MEETING - FUEL FACILITY LICENSING BEST PRACTICES SUMMIT On May 14, 2025, the U.S. Nuclear Regulatory Commission (NRC) staff held a public meeting to discuss best practices for licensing fuel facilities. The meeting notice is available in the NRCs Agencywide Documents Access and Management System (ADAMS) Accession Number ML25127A260. This hybrid meeting, which had 32 in-person attendees and roughly 80 virtual attendees, was held at NRC Headquarters and via teleconference using the Microsoft Teams platform. The agenda and attendance list are enclosed.
During the meeting, the NRC staff used a slide presentation (ML25125A231) to aid the discussion of the best practices for licensing fuel facilities. The NRC staff discussed best practices for each of the five stages of licensing: pre-application, submittal of an application, acceptance review, technical review, and issuance. The noted best practices have been shown to facilitate the licensing process and more efficiently utilize resources for both the NRC and applicants - however, the NRC staff was clear that the best practices are not regulatory requirements and that conforming is not mandatory to receive an NRC license. After the discussion between the NRC staff and industry representatives on the best practices for each stage of licensing, the NRC staff provided members of the public with the opportunity to ask questions and provide feedback.
Toward the end of the meeting, representatives from the Nuclear Energy Institute (NEI) used a slide presentation (ML25127A280) to provide feedback on the potential improvements discussed during the public meeting held on April 10, 2025, regarding the Materials Licensing Efficiencies and Processes (M-LEAP) efforts related to fuel facilities (ML25112A270). The NRC staff was generally aligned with NEIs prioritization of the long-term potential improvements and the effort to enact the improvements as available resources will allow.
CONTACT: James R. Downs, NMSS/DFM 301-415-7744 June 4, 2025 Signed by Downs, James on 06/04/25
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Throughout the discussion of best practices, the NRC staff and industry representatives shared experiences that illustrated success and identified potential improvements during each phase of the licensing process:
Pre-application An industry representative shared how his pre-application engagements from earlier in 2025 were more robust than he previously had experienced - it was noted that NRC staff provided more detailed feedback than in previous pre-application engagements and clear direction was received by the applicant for enhancing the submittal.
Industry representatives requested that the NRC staff provide a greater level of detail in publicly available meeting summaries, so that future applicants also have actionable directions.
Submittal of an application The NRC staff noted that when an exemption is approved to bifurcate the safety and environmental submittals, the staffs review on the first portion of the submittal is limited until both portions of the submittal are received.
Industry representatives noted that Title 10 of the Code of Federal Regulations, Section 70.22, requires detailed information (e.g., a full description of the applicant's program for control and accounting or an enrichment applicant's security program) that can be challenging for the applicant to provide at the time a license application is submitted - a time when the project is often still being designed. The NRC staff emphasized that applications can be supplemented after the initial submittal to provide greater detail, but some level of detail is needed regarding those requirements in order for the NRC staff to accept the application for detailed technical review.
Acceptance review The NRC staff clarified that the sub-bullets on slide 11 (i.e., examples supporting that 60-days is a tight metric for acceptance reviews) are only meant to illustrate that the timeline is challenging - the staff confirmed that most reviews do not have requests for supplemental information (RSIs).
Industry representatives suggested that: (1) RSIs should be rare, (2) robust pre-application reviews should lead to more efficient acceptance reviews, (3) the NRC should provide publicly available guidance to the NRC staff on how to conduct acceptance reviews, and (4) continuity of the NRCs review team throughout the licensing process is a best practice.
The NRC noted that application quality is a significant contributor to whether RSIs are needed.
Technical review The NRC staff and industry representatives agreed that good communication is the key to addressing requests for additional information (RAIs) quickly and that the timeframes listed on slide 14 for RAIs are challenging (i.e., 30 days for response, measured from the
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date that draft RAIs are provided, with clarification calls requested within 3 days and scheduled within one week of draft RAI being provided).
Issuance Industry representatives noted that the NRCs expected implementation of a new program to address controlled unclassified information (CUI) may necessitate a shift back to paper copies of sensitive licenses and licensing documents being mailed to licensees - some licensees do not have the computer systems to processes CUI that is emailed.
Industry representatives also recommended that the NRC staff evaluate the value of NRC licenses containing specific dates of licensing basis documents being tied down in license conditions.
Enclosure:
Meeting Agenda and Attendance List
ML25153A070 OFFICE NMSS/DFM/
FFLB NMSS/DFM/
FFLB NMSS/DFM/
FFLB NMSS/DFM/
FFLB NAME JDowns JGoodridge SLav JDowns DATE 06/03/2025 06/03/2025 06/04/2025 06/04/2025
Enclosure MEETING AGENDA AND ATTENDANCE LIST MAY 14, 2025, PUBLIC MEETING -
FUEL FACILITY LICENSING BEST PRACTICES SUMMIT AGENDA Time Topic Speaker 1:00 PM Opening Remarks NRC and Industry Licensing Best Practices - Pre-Application NRC and Industry Questions and answers Public Licensing Best Practices - Submittal of an Application NRC and Industry Questions and answers Public Licensing Best Practices - Acceptance Review NRC and Industry Questions and answers Public Licensing Best Practices - Technical Review NRC and Industry Questions and answers Public Licensing Best Practices - Issuance NRC and Industry Additional Feedback - Potential Improvements Discussed During the Public Meeting on April 10, 2025 NRC and Industry Closing remarks NRC 4:00 PM Adjourn ATTENDANCE LIST Name Affiliation Alexis Sotomayor-Rivera NRC Amy McKenna NRC Amy Minor NRC Andrea Jennetta International Nuclear Associates, Inc. - Fuel Cycle Week Andrea Johnson NRC Ashby Bridges General Matter Ashley Morris Nuclear Fuel Services Benjamin Karmiol NRC Bob Sanders Honeywell Brandon Bout NRC Brandon Hanson Framatome Brian Wagner NRC Brittany Lutz Nuclear Innovation Alliance Bryson Roberson ClearPath Camille T. Zozula Westinghouse Electric Company Carolyn Fairbanks NRC Caylee Kenny NRC Celimar Valentin Rodriguez NRC Chad Oelstrom NRC Chandi Davidson Global Nuclear Fuel - Americas
2 Name Affiliation Christine Saah Nazer NRC Cinthya Roman NRC Clinton McGill NRC Cynthia Taylor NRC Dallas M. Gardner Nuclear Fuel Services Dan Watts Centrus / ACO Daniel Ashworth BWXT Nuclear Operations Group Daniel Forsyth NRC Dante Johnson NRC Dave Gasperson NRC David Tiktinsky LIST Deric Tilson The Breakthrough Institute Diana Diaz Toro NRC Diana Woodyatt NRC Doug Weaver General Matter Douglas Diethrich NRC Eben Allen NRC Eliezer Goldfeiz NRC Eric C. Michel NRC Faris Badwan Orano USA Gerond George NRC Grace Pennington NRC Greg Core Nuclear Energy Institute (NEI)
Gregg Goff NRC Greta Knowles NRC Haimanot Yilma NRC Hector Rodriguez NRC Isaac Johnston NRC James Downs NRC James Drabble NRC James Hammelman NRC Jana Bergman Curtiss-Wright Jannette Worosilo NRC Jason Piotter NRC Jeanette Arce NRC Jennfier Wheeler TRISO-X Jesse Carlson NRC Jill Shepherd NRC Jimmy Chang NRC John Russell NRC Jonathan Marcano Lozada NRC Jonathan Rowley NRC Joseph Goodridge NRC Joy Jiang The Breakthrough Institute Juan Lopez NRC
3 Name Affiliation Justin Raudabaugh NRC Kelly Sullivan NRC Kimyata Morgan-Butler NRC LaDonna Suggs NRC Langston Lewis NRC Lindsey Cooke NRC Lisa Dimmick NRC Lou McKown NRC Martin M Ortiz Gonzalez NRC Matt Bartlett NRC Matthew Doyle NRC Meg Day NRC Mike Call NRC Mitchell Dehmer NRC Nicole Cortes NRC Noel Pitoniak NRC Norma Garcia Santos NRC Osiris Siurano-Perez NRC Patrick Donohue NRC Peter Vescovi Orano USA Peyton Doub NRC Ravi Penmetsa NRC Richard Skokowski NRC Robert Mathis NRC Robert Sun NRC Samantha Lav NRC Scott Murray NEI Sean Patterson Honeywell Shana Helton NRC Stacey Imboden NRC Stephen G. Subosits Westinghouse Electric Company Stephen Poy NRC Steven Pope Information Systems Laboratories Tekia Govan NRC Thomas Vukovinsky NRC Tim Knowles Global Laser Enrichment Tim Tate Framatome William Deric Tilson The Breakthrough Institute Wyatt Padgett Urenco USA Yawar Faraz NRC Yilia Vega Claudio NRC Zee St Hilaire NRC