ML25156A101

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20250428 Public Mtg AA Fn RIS Meeting Summary
ML25156A101
Person / Time
Issue date: 04/28/2025
From: Baxter B
NRC/NSIR/DPCP/AAFPB
To:
Shared Package
ML25156A073 List:
References
ML25156A073, 20250475
Download: ML25156A101 (1)


Text

1 U.S. Nuclear Regulatory Commission Public Meeting Summary April 28, 2025

Title:

Public Meeting on Regulatory Issue Summary (RIS) related to Personnel Access Authorization Requirements for Non-Immigrant Foreign Nationals Working at Nuclear Power Plants Meeting Identifier: 20250475 Date of Meeting: April 28, 2025 Location: Webinar - Microsoft TEAMS Category of Meeting: Information Meeting with a Question-and-Answer (Q&A) Session.

Purpose of the Meeting: The purpose of this meeting was for the NRC staff to meet directly with stakeholders to discuss an updated version of the NRCs draft regulatory issue summary (RIS) addressing personnel access authorization requirements for non-immigrant foreign nationals working at nuclear power plans. The intent of this draft RIS is to remind licensees of the requirement in 10 CFR 73.56(d)(3), Verification of true identity, thatprior to granting or reinstating unescorted access or certifying unescorted access authorization to non-immigrant foreign nationals for the purpose of performing worklicensees shall validate that the foreign nationals claimed non-immigration status is correct, and that verifying employment eligibility is an important component of the required validation.

General Details: The meeting began at 2:02 p.m. EST. The meeting was attended by 55 individuals, including NRC licensee personnel; personnel representing NRC licensee contractors and vendors; representatives from the Nuclear Energy Institute (NEI); two teleconference attendees; and NRC personnel, including a court reporter. A list of attendees is included as an attachment to this meeting summary. The meeting ended at 2:52 p.m. EST.

Summary of Presentations: The NRC staffs presentation provided a brief overview of the regulatory history, operating experience, draft/revision history, and key messaging associated with the matter addressed by the RIS, along with a more in-depth discussion of the changes from previous draft versions of the RIS and a discussion of next steps towards the NRCs issuance the final RIS and an update to Enforcement Guidance Memorandum (EGM) 001, Rev. 4 (currently set to expire on June 30, 2025).

No NRC stakeholders made formal presentations during the meeting, but meeting attendees did provide questions during the open discussion period of the meeting, to which the NRC staff responded.

The meeting was transcribed, and the meeting transcription is available via the NRCs Agencywide Document Access and Management System (ADAMS) under the following Accession Number ML25156A111.

Action Items/Next Steps:

The NRC plans to revise EGM 20-001 to include updated language that reflects the NRCs clarified guidance regarding employment eligibility verification requirements.

2 Specifically, the EGM will be revised to clarify that licensees are not required to verify what type of work an individual is authorized to perform, when confirming the individuals employment eligibility as part of the process of validating the individuals non-immigration status. The EGM will also be renewed/extended for a period of time to allow licensees to make any necessary changes to their programs/processes to conform with the NRCs requirements, as clarified in the RIS.

The NRC plans to revise the relevant NRC inspection guidance in NRC Inspection Procedure 71130.01, Access Authorization, to provide clarity regarding expectations for NRC inspectors when verifying the steps taken by licensees conducting identity verification of non-immigrant foreign nationals.

Licensees using or planning to use the U.S. Citizenship & Immigration Services (USCIS)

Systematic Alien Verification for Entitlements (SAVE) database to conduct validation steps will need to establish a memorandum of understanding (MOU) with the NRC if they do not already have one in place. The NRC maintains a template to facilitate this process, and licensees are encouraged to reach out to NRC staff if assistance is needed/desired. (Additional guidance on the use of the SAVE database and development of an MOU is included in Enclosure 1 to the Draft RIS). Licensees may also elect to procure the services of a contractor or vendor to conduct employment verification (e.g., using the E-Verify system, which is administered by USCIS and the U.S. Social Security Administration).

Additional Resources Additional information is available via ADAMS under the following Accession Numbers:

ML25100A202 - Meeting notice for the April 28, 2024, public meeting ML25115A197 - Presentation slides from the April 28, 2024, public meeting ML25083A260 - Draft NRC Regulatory Issue Summary 2025-XX, Personnel Access Authorization Requirements for Non-Immigrant Foreign Nationals Working at Nuclear Power Plants ML24212A201 - Draft comment-resolution document, addressing stakeholder comments received on the a the previous version of the Draft Regulatory Issue Summary, published on June 13, 2022 ML24166A021 - Enforcement Guidance Memorandum 2020-001, Rev. 4, Enforcement Discretion not to Cite Certain Violations of 10 CFR 73.56 Requirements

3 LIST OF ATTENDEES 04/28/2025 Meeting to Discuss The Regulatory Issue Summary (RIS) related to Personnel Access Authorization Requirements for Non-Immigrant Foreign Nationals Working at Nuclear Power Plants Name Affiliation 1

Kara Rhoades Ameren 2

Grant Eskelsen Balch & Bingham LLC 3

Jeff Sharkey Balch & Bingham LLC 4

Amanda Myers Constellation 5

Jennifer Woodhouse Constellation 6

Jonathan Duval Constellation 7

Sandra Peacock Constellation 8

Sondra Massey Constellation 9

Tracy Knisely Constellation 10 Ryan Wong Constellation 11 Raleigh, Deann Curtiss Wright 12 Allen Fulmer Dominion Energy 13 Cynthia Bomyea DTE Energy 14 Erick Owens Sr DTE Energy 15 Teddy Reed Duke Energy 16 David Cummings Duke Energy 17 Matthew Deignan Entergy 18 Jones, Anna Vinson Entergy 19 Steven Chambliss Entergy 20 Brenda Stephens Evergy 21 Monique Hart Evergy 22 Sonya Jones Evergy 23 Michael Covert Luminant 24 Matt Miller Neal R. Gross (Court Reporter) 25 Johnny Rogers NEI 26 Susan Perkins NEI 27 Dawn Odom NextEra 28 Eugene Berlett NextEra 29 Robert Smith NextEra 30 Steven Hamrick NextEra 31 Avery Cope Southern Nuclear 32 Michael Palmer Talen Energy 33 Zachary Baze TVA 34 Esther Andrews TVA 35 Meredith Millhorn Boatman TVA 36 Patrick Asendorf TVA

4 37 Russell Thompson TVA 38 Tempee Suratt Wagner TVA 39 Brad Baxter U.S. NRC 40 Brian Zaleski U.S. NRC 41 David Furst U.S. NRC 42 Justin Vazquez U.S. NRC 43 Niry Simonian U.S. NRC 44 Peter Lom U.S. NRC 45 Phyllis Clark U.S. NRC 46 Shannon Rogers U.S. NRC 47 John Pfabe Urenco 48 Alex Baumann Westinghouse 49 Elaine Mcfadyen Westinghouse 50 Anderson, Kenzie Xcel Energy 51 Danielle Johnson Xcel Energy 52 Kenneth Lewter Xcel Energy 53 Lindsay Peters Xcel Energy 54 Jeremy Tanner Xcel Energy 55 Heather 56 teleconference attendee 57 teleconference attendee

ML25156A073; ML25156A101 OFFICE NSIR/DPCP/RSB NSIR/DPCP/AAFPB NAME BBaxter JVazquez DATE Jun 9, 2025 Jun 11, 2025