ML25352A336
| ML25352A336 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 12/12/2025 |
| From: | Facemire J Nuclear Energy Institute |
| To: | Carroll C Office of Nuclear Reactor Regulation, NRC/OCFO, Document Control Desk |
| References | |
| Download: ML25352A336 (0) | |
Text
Jon Facemire Senior Project Manager Phone: 202.256.0190 Email: jwf@nei.org December 12, 2025 Mr. Christopher Carroll Chief Financial Officer (Acting)
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Fee Exemption Request for NEI 25-08, Revision A, Graded Approach to Seismic Hazard Analysis and Corresponding Site Investigations for Licensing Nuclear Power Plants Project Number: 689
Dear Mr. Carroll:
On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI)1 requests a waiver of fees associated with the U.S. Nuclear Regulatory Commission (NRC) staff's review and endorsement of NEI 25-08, Revision A, Graded Approach to Seismic Hazard Analysis and Corresponding Site Investigations for Licensing Nuclear Power Plants. This document presents a regulatory and technical approach to assess appropriate site characterization to support seismic hazard analysis for the advanced reactor fleet, offering a methodology that is technology-inclusive and aligned with modern risk-informed safety practices.
NEI believes this fee waiver is warranted pursuant to 10 CFR 170.11(a)(1)(ii), as the NRCs review of NEI 25-08, Rev A will "assist the NRC in generic regulatory improvements or efforts." Specifically, this document:
Establishes a structured process to utilize preliminary estimates of seismic hazard and margin at a given site to define the scope of site characterization appropriate for a given reactor design at a given site.
Builds upon the NRC guidance in SECY-25-0052 encouraging a graded approach to site characterization.
Meets the intent of Section 206 of the ADVANCE Act to leverage the availability of historical site-specific environmental data; and supports action ID5 from the Regulatory Issues for Nuclear Facilities at Brownfield and/or Retired Fossil Fuel Sites report to Congress which states Provide guidance on a graded approach to site 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 operational 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. Christopher Carroll December 12, 2025 Page 2 Nuclear Energy Institute characterization for advanced and microreactor designs using bounding site parameters as part of the screening analysis for external hazards.
Aligns with the intent of Executive Order 14300 Section 5(e): Establish a process for high-volume licensing of microreactors and modular reactors.
Supports greater regulatory efficiency and consistency by clarifying specific criteria by which appropriate site characterization methods can be prescribed.
The screening process and associated site characterization requirements outlined in NEI 25-08, Rev A reflects extensive stakeholder input and builds upon insights from current regulatory guidance, operating experience, and advances in USGS knowledge of seismic hazard information. Its industry-wide applicability will contribute meaningfully to the NRCs ongoing efforts to modernize site characterization expectations for new reactor designs.
If you have any questions or require additional information, please contact me at jwf@nei.org or 202-256-0190.
Sincerely, Jon Facemire Senior Project Manager cc:
Jeremy Groom, NRR Jon Grieves, NRR Michael Wentzel (NRR/DANU)
Hannah McLatchie, NRR Allen Fetter, NRR NRC Document Control Desk