ML25181A797
| ML25181A797 | |
| Person / Time | |
|---|---|
| Site: | 99902028, Nuclear Energy Institute |
| Issue date: | 06/30/2025 |
| From: | Mccallum J Nuclear Energy Institute |
| To: | Grieves J Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| Download: ML25181A797 (1) | |
Text
Julianne McCallum Project Manager, New Nuclear Phone: 202.815.6640 Email: jgm@nei.org June 30, 2025 Jonathan Grieves Deputy Director Division of Advanced Reactors and Non-Power Production and Utilization Facilities U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
NEI Recommendations on the Development of the Advanced Reactor Oversight Program (AROP)
Project Number: 689
Dear Mr. Grieves:
On behalf of the Nuclear Energy Institute (NEI)1 and its members we are pleased to provide input on the development of the U.S. Nuclear Regulatory Commissions (NRCs) Advanced Reactor Oversight Program (AROP). We commend the NRCs proactive efforts to inform advanced reactor regulatory oversight through review of SECY 13-0137 and NEIs July 2024 proposal for Rapid High-Volume Deployable Reactors in Remote Areas (RHDRA) Appendix 23 (ML24213A337).
As the industry moves toward deployment of diverse and novel reactor technologies, it is critical that the regulatory framework for operational oversight evolve in tandem. The Commission noted in Staff Requirements Memorandum SECY 10-0121 that [n]ew reactors with these enhanced margins and safety features should have greater operational flexibility for a stronger focus on safety-significant issues and efficient use of NRC resources. To this end, NEI recommends a foundational revision to the structure and scope of the Reactor Oversight Program (ROP) in developing the AROP. The AROP should be built on a results-oriented architecture rather than prescriptive process-based inspection requirements. This flexibility will be essential in accommodating a wide spectrum of reactor designs and safety strategies, many of which introduce technologies or operational concepts that the NRC may not have previously encountered in the inspection space.
1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic regulatory and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
Mr. Jonathan Grieves June 30, 2025 Page 2 Nuclear Energy Institute NEI recommends that the AROP prioritize performance indicator evaluation over burdensome process compliance enforcement. The proposed model relies on licensee monitoring of key identified operational and performance indicators and appropriate reporting to the NRC. Where programmatic performance indicators indicate degradation or leading indicators indicate emergent concerns, targeted on-site NRC reviews would be triggered. Conversely, routine on-site inspections would be minimized if the data continues to demonstrate effective performance.
This approach preserves the current enforcement model, including the ability to issue findings from inspections as appropriate. However, inspection findings should be contingent upon the confirmation that data-driven indicators justify further NRC engagement. As the program evolves, it should remain adaptable and focused on outcomes, ensuring the oversight process remains efficient, scalable, and aligned with the NRCs safety mission. The enclosed flowchart is a high-level overview of this proposed approach.
The proposed approach would make more effective and efficient use of NRC and licensee resources in providing reasonable assurance of adequate protection of the public health and safety. It would also align with the direction in the ADVANCE Act and recent Executive Orders, including EO-14300, Ordering the Reform of the Nuclear Regulatory Commission.
To facilitate collaboration and alignment on the path forward, NEI requests a public workshop that includes NRC, industry and other stakeholders in the summer of 2025. There is historical precedent for constructive in-person workshop discussions, including the ROP revision process in 2000, which benefited from a workshop in the fall of 1998 to align on the overarching philosophy and defining principles, as noted in SECY-99-007. Similarly, in 2024, the team leading the development of the Advanced Reactor Construction Oversight Process (ARCOP) hosted several in-person workshops to advise NRC Staff on scalability and technology-inclusiveness. This session would serve as a forum to explore the proposed AROP structure, share technical insights, and discuss implementation considerations.
We appreciate the NRCs leadership in advancing innovation in the regulatory space. NEI and its members remain committed to ensuring that advanced reactor oversight mechanisms are risk-informed, performance-based, and fit for purpose in an evolving nuclear landscape.
Please feel free to contact me at jgm@nei.org should you require additional information or wish to discuss these recommendations further.
Sincerely, Julianne McCallum Project Manager, New Nuclear c:
Zachary Hollcraft, IRIB/DRO/NRR/NRC Phillip McKenna, DRO/NRR/NRC
Mr. Jonathan Grieves June 30, 2025 Page 3 Nuclear Energy Institute Cornerstones of Safety Agency Response Management Conference Monitor License Actions NRC Inspections Additional Regulatory Actions Assessment Process (Action Matrix)
Enforcement Communications Public Meetings
- Press Releases
- NRC Website
- PDR/ADAMS Assessment Reports Inspection Plans Inspection Findings Performance Indicators Significance Determination Process Supplemental Inspections Event Response (SI/AIT/IIT)
Performance Indicator Thresholds Performance Indicators PROPOSED ADVANCED REACTOR OVERSIGHT PROCESS Periodic Trend