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LTR-25-0263 Douglas True, Sr. Vice President & Chief Nuclear Officer, Nuclear Energy Institute, Ltr Industry Recommendations on Accelerating NRC Reform
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Site:	Nuclear Energy Institute
Issue date:	07/31/2025
From:	True D; Nuclear Energy Institute
To:	David Wright, Annie Caputo, Crowell B, Marzano M; NRC/Chairman, NRC/OCM/AXC, NRC/OCM/BRC, NRC/OCM/MJM
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NUCLEAR ENERGY INSTITUTE July 31, 2025 1201 F Street NW* Suite 1100 Douglas True Washington, DC 20004 Sr. Vice President & Chief nei.org Nuclear Officer The Honorable David Wright, Chairman The Honorable Annie Caputo, Commissioner The Honorable Bradley Crowell, Commissioner The Honorable Matthew Marzano, Commissioner U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Industry Recommendations on Accelerating NRC Reform

Dear Commissioners:

Phone: 925.998.8810 Email: det@nei.org The Nuclear Energy Institute (NEl)1, on behalf of its members, appreciates the opportunity to provide the enclosed report outlining specific recommendations to implement the May 23, 2025, Executive Order 14300, "Ordering the Reform of the Nuclear Regulatory Commission." This Executive Order (EO) marks a critical opportunity to transition the NRC to a more deployment-oriented, risk-informed, and performance-based framework that fully enables the next era of U.S. nuclear innovation, essential for American energy independence, resilience, and security.

We are encouraged by the progress the NRC has made under the ADVANCE Act and other modernization initiatives.

However, to effectively respond to EO 14300 and meet the nation's surging demand for reliable electricity, the agency must pursue more substantial reforms and accelerate its efforts. The enclosed report is provided to assist the Commission as it directs, reviews and approves the staffs efforts to implement the EO.

We believe our recommendations will maintain safety while significantly increasing the effectiveness and efficiency of the agency. NEI and the industry.stand ready to work with the NRC to ensure the success of these transformational efforts.

]aefely, ooe@aj__

Sr. /Jice President & Chief Nuclear Officer Enclosure cc:

Michael King, Acting Executive Director for Operations 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. NEl's 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.

POWERING OUR CLEAN ENERGY FUTURE

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JULY-2 0 2 5 PREFACE For over a decade, the Nuclear Energy Institute (NEI) has called for significant reform of the Nuclear Regulatory Commission (NRC) to enable the growth of nuclear energy in the U.S. Last year, Congress underscored this imperative through the ADVANCE Act, and President Trump reinforced it with his May 23, 2025, Executive Order (EO}, "Ordering the Reform of the Nuclear Regulatory Commission." This report presents the industry's recommendations for the most impactful reforms needed to enable the NRC to meet the urgent national demand for more safe, reliable nuclear power.

The U.S. nuclear industry supports the EO's call for near-term action and recommends the NRC adopt a deployment-oriented, risk-informed, and *performance-based approach that enables efficient deployment of advanced reactors, microreactors, power uprates, and fuel facilities. and the long-term operation of the existing fleet.

The NRC plays an essential role in ensuring nuclear safety and public trust; this effort is not about replacing the agency but transforming and modernizing it to meet the demands of today and the future. As the NRC transforms, it should continue to exemplify excellence in nuclear regulatory practice while maintaining its global reputation for safety and oversight. Through thoughtful, risk-informed modifications, the Commission can fulfill its safety mandate while becoming an effective and efficient facilitator of U.S. energy security, economic growth, and technological leadership.

This document has been extensively vetted with NEI member companies representing all aspects of the nuclear value chain including regulatory experts, nuclear technology vendors, current and future plant operators, and suppliers. The recommendations represent a comprehensive set of changes and pathways to implementation that can enable the transition from the regulatory framework of today to an efficent framework of tomorrow that ensures safety. If implemented, our recommendations will effect significant'change in a manner that maintains as stable a regulatory framework as possible. Within the larger set of recommendations, the following key areas of reform require particular focus:

Streamline Licensing Actions by enhancing the efficiency of NRC reviews and meeting licensee schedules Streamline Oversight and Inspection by eliminating unnecessary inspection to reflect licensee performance Enhance Safety Focus by using risk insights and eliminating unnecessary regulatory requirements and processes Accelerate Environmental Reviews by removing unnecessary delays impacting urgent grid and industrial needs Reform Hearing Process by providing for stakeholder participation white maintaining project timelines Modernize Security Framework by restoring requirements to a level that is appropriate for a commercial facility

ACCELERATING NRC REFORM INDUSTRY RECO:--1MENDATIONS J ULY 2025 Accelerate Deployment Pathways by right-sizing requirements and streamlining approval processes The recommendations are grouped into eight areas cit high-level changes. Each high-level change is briefly summarized in a Tier 1 overview. More detail regarding the supporting changes needed to achieve the Tier 1 reforms is provided in the associated Tier 2 documents. The details outline the specific regulations or policies that must be revised, the technical justification for each change, and any necessary statutory amendments requiring legislative action.

Commitment to Safety and Risk-informed Innovation The industry's commitment to safety is unwavering, as demonstrated by decades of high performance. Nothing in our recommendations would diminish the high standards that protect the public, workers, and the environment. In fact, recommended reforms such as streamlining environmental reviews, simplifying hearings, and modernizing oversight will improve safety by directing resources toward issues of risk significance.

It is critical that modernization efforts do not divert attention from other high-priority Commission work. Balancing reform initiatives with the continued execution of essential responsibilities will be critical to maintaining program effectiveness. A more responsive regulatory process is a pathway to sustaining safe and reliable operation.

Implementation Pathways To ensure reforms are timely, NEI urges the NRC to use exemptions, interim enforcement policies, and enforcement guidance memoranda while*rulemaking proceeds toward the November 2026 completion date, enabling licensees and applicants to benefit from policy changes that require rulemaking, without delay. Any reforms identified that do not require rulemaking should be implemented immediately by the NRC staff.

Organizational Reform to Support Implementation Successfully transforming the N RC requires the effective organization of its robust technical capabilities. A well-staffed and strategically structured agency is critical to ensuring a smooth and efficient transition. To implement these reforms, the NRC should consider organizational adjustments that enhance responsiveness and agility-enabling the growth of nuclear energy while maintaining the agency's global standard for regulatory excellence. Specifically, NEI recommends:

Accelerating decision-making and increasing management focus and accountability by flattening organizational hierarchies; Issuing 90% of Staff Requirements Memoranda within 6 months and 100% within 12 months by revising Commission voting processes; Improving the consistency and efficiency of oversight by eliminating the regions;

ii

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JULY 2025 Focusing sufficient resources on deployment priorities by establishing a dedicated office for new reactor licensing; Increasing the cohesiveness of the regulatory process by integrating and streamlining the security and enforcement functions; Enhancing the focus on mission critical functions by streamlining the Office of Nuclear Regulatory Research, the Office of Investigations, and the Office of the Inspector General.

iii

ACCELERATING NRC REFORM INDUS-1RY R::COMMENDATIO\\JS JULY 2025 Preface....................................................................................................... i Tier 1: High-level Reforms Reform New Nuclear Licensing................................................................... 1 Reform NRC Licensing................................................................................ 3 Reform Nuclear Security Regulation............................................................ 6 Reform and Modernize the Reactor Oversight Process.................................. 8 Reform Radiation Protection Standards..................................................... 1 O Eliminate Administrative Reporting Requirements.........................-............. 13 Modernize the Nuclear Fuel Cycle Facility Regulatory Environment............. 16 Reform Decommissioning Funding & Execution......................................... 19 Tier 2: Supporting Improvements Reform New Nuclear Licensing Create High Volume Licensing Path............................................................................... 23 Restrict Late-Stage Licensing and Approval Delays......................................................... 26 Modernize Siting Criteria............................................................................................... 31

iv

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JUL Y 2025 Ensure Reactor Safety Assessments Focus on Credible, Realistic Risks.......................... 34 Approve DOE/DOD Tested Designs................................................................................ 37 Reform NRC Licensing Establish Fixed Licensing Schedules.............................................................................. 40 Streamline NRC Hearings.............................................................................................. 43 Modern Environmental Review Process.......................................................................... 48 Crosscutting Regulatory Improvements......................................................................... 51 Streamline License Renewal Regulations....................................................................... 57 Enable More Digital l&C Deployment With and Without Prior NRC Approval..................... 59 Modernize Operator Licensing Program.......................................................................... 61 Reform License Durations............................................................................................. 65 Optimize Reactor Restarts............................................................................................. 69 Align Transportation Regulations.................................................................................... 71 Reform the Advisory Committee on Reactor Safeguards................................................. 74 Reform Nuclear Security Regulation Update the Design Basis Threat..................................................................................... 76 Redesign Force-on-Force Inspection Program................................................................ 78 Remove Prescriptive Security Requirements.................................................................. 81 Right-Size Cybersecurity Standards............................................................................... 84 Modernize AA/FFD Program Requirements..................................................................... 87 Reform & Modernize the Reactor Oversight Process Overhaul the ROP Framework......................................................................................... 91 Align Inspections Based on Safety Significance.............................................................. 96 Eliminate Low Value Work in Other NRC Processes........................................................ 99

V

ACCELERATING NRG REFORM INDUSTRY R!:COMMENDATIONS JULY 2025 REFORM NEW NUCLEAR LICENSING Executive Summary Establish the organization and processes for new reactor licensing to accelerate deployment in more locations, enable scalability, and enhance design certainty.

Enable high-volume licensing for microreactors and modular reactors Immediately implement a framework for qualifying reduced-risk reactors Eliminate barriers and establish processes to drive licensing for previously approved standardized designs in less than six months.

Create a pathway to use general licenses for eligible reactors or components, including pursuit of statutory changes where necessary.

Restrict late-stage licensing and approval delays Set strict criteria for NRC-imposed changes during construction and licensing actions required during construction under Part 50.

Allow licensees to implement design changes prior to NRC approval to avoid construction delays under Part 52.

Streamline reactor siting and remove population-based restrictions Revise siting rules to enable risk-informed placement near higher population areas Streamline the early site permit (ESP) process and extend the 20-year limit Simplify and align environmental reviews through interagency coordination, so only one report is generated Ensure reactor safety assessments focus on credible, realistic risks Establish clear probability thresholds for events and hazards to be considered in a reactor's design Establish guidance on addressing unlikely events with defense-in-depth Expedite NRC approval of DOD/DOE-tested reactor designs Harmonize NRC, Department of Energy (DOE), and the Department of Defense (DOD) regulatory approaches Require NRC licensing of reactor designs previously approved/tested by DOD or DOE in six months or less

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JULY 2025 Limit NRC licensing reviews to statutorily required considerations unique to NRC licensing Outcomes Enables rapid deployment of new reactors Enables flexibility to site qualifying reactors where they are needed Eliminates dual regulatory pathways Provides effective and efficient plant construction without delays Timing and Implementation Immediate actions via policy and exemption authority Full codification by November 2026 through the wholesale regulation review rulemaking

2

ACCELERATING NRG REFORM INDUSTRY RECOMMENDATIONS JULY 2025 REFORM NRC LICENSING Executive Summary Reform the NRC's licensing processes by setting fixed timelines, reducing regulatory overhead, and aligning reviews with safety significance to ensure timely decisions while maintaining safety and public trust.

Establish fixed licensing schedules Enable faster deployment, supports investment certainty, and improves NRC accountability Cap fees and enforce firm deadlines:

o s:12 months for nth-of-a-kind (NOAK) Construction Permit (CP), Operating License (OL), and Combined License (COL) application reviews o

s:18 months for first-of-a-kind (FOAK) CP, OL, and COL application reviews Align review timelines with safety significance Streamline NRC hearings Focus contested hearings on material issues by refining intervention standards, requiring supporting evidence with proposed contentions, and providing for expedited Commission review of Atomic Safety and Licensing Board (ASLB) admissibility decisions.

Assign NRC staff with relevant technical expertise to decide the merits of admitted contentions in individual licensing proceedings in parallel with the staff's application review, ensuring that issues are evaluated by qualified personnel and decisions are subject to Commission oversight.

Eliminate procedural inefficiencies by removing mandatory disclosures, limiting late-filed contentions and motion practice, and adopting paper,-only hearings governed by fixed schedules.

Advocate for legislation to remove the mandatory uncontested hearing requirement applicable to CPs, limited work authorizations (LWA), COLs, and ESPs.

Modernize environmental reviews Finalize and codify New Reactor Generic Environmental Impact Statement (GEIS) in 1 o CFR Part 51 Institute use of environmental assessments and categorical exclusions as default approaches Eliminate low-value, duplicative analyses; focus on foreseeable impacts Crosscutting regulatory improvements Reduce unnecessary regulatory burden

3

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JU LY 2025 Expand the use of risk-informed, performance-based regulation agency-wide Modernize and align NRC processes with industry standards Support innovation and deployment of advanced technologies Streamline license renewal Introduce a performance-based audit/inspection path in lieu of application review Focus reviews on safety-critical programs; eliminate duplication Cut renewal time and staff hours by greater than 50%

Enable more digital instrumentation and control (Dl&C) deployment with and without prior NRC approval Establish clear, risk-informed regulatory guidance that will streamline licensing of Dl&C systems requiring NRC approval Limit NRC licensing reviews to Dl&C systems that present credible risks Expand the use of Dl&C qualitative assessments Eliminate the default assumption that common cause failure (CCF) cannot be addressed by a licensee without prior NRC approval Improve the ability of licensees to implement modern, reliable technology without costly, inefficient NRC review Modernize operator licensing program Remove duplication and streamline operator licensing program requirements Focus NRC resources on oversight of examination administration Increase regulatory flexibility while maintaining accreditation requirements Standardize operator licensing by reactor type Reform license durations Eliminate expiration dates for reactor permits, licenses, and design approvals (including CPs, Ols, ESPs, standard design approvals (SDA), design certifications (DC), COLs, Certificates of Compliance (COC) and LWAs) through legislative changes, where needed.

Utilize exemption authority to renew ESPs until rulemaking is complete Optimize reactor restarts Streamline restart inspections Use historical performance and existing data to grade the licensing and inspection efforts Institutionalize lessons learned

,p Nuclear Energy Institute Inc.

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ACCELERATING NRC REFORM INDUS*RY Rt:COMMENDATIONS

, ULY 2025 Align transport regulations Modify regulations to align with international shipping standards Eliminate duplication of requirements with Department of Transportation (DOT)

Simplify Certificate of Compliance renewal procedures Restructure the Advisory Committee on Reactor Safeguards (ACRS)

Limit ACRS scope to novel, safety-significant technologies Impose firm timelines; avoid duplicative reviews of previously approved designs and technologies Use ACRS as expert advisors Outcomes Enables faster deployment, supports investment certainty, and improves NRC accountability Significantly reduces the scope and burden of adjudicatory hearings while avoiding changes that could increase the risk of federal court challenges to licensing decisions.

Reduces delay and duplication, while aligning with National Environmental Policy Act (NEPA) reform mandates Modernizes NRC regulations to improve efficiency, effectiveness, and focus on safety Eliminates duplicative work and retains a focus on safety Enables faster deployment of modern technology while preserving safety Removes duplication and streamlines operator licensing program requirements Reduces duplicative work, lowers cost, and ensures sustained reactor operation Delivers the fastest path to new nuclear on the grid with consistent NRC oversight Aligns NRC's rules for regulating the transportation of radioactive material to increase the efficiency of the international and domestic shipping process Accelerates licensing timelines and improves resource use while preserving safety Timing and Implementation Immediate actions via policy and exemption authority Full codification by November 2026 through the wholesale regulation review rule making Legislative changes will be needed for NRC structural changes

5

ACC ELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JULY 2025 REFORM NUCLEAR SECURITY REGULATION Executive Summary Reform security regulations to ensure protection against credible threats using pertormance-based standards.

Re-baseline the Design Basis Threat (DBT) and adversary characteristics to reflect credible threats Align with protection levels used across the nation's critical infrastructure Limit the DBT to realistic tactics and durations and discontinue the assumption of an omniscient insider.

Account for technological advancements in post-9/11 counterterrorism and intelligence capabilities Eliminate NRC-led force-on-force (FOF) exercises for operating plants Implement a licensee-led FOF process Focus the FOF exercise on credible threats and tactics Eliminate prescriptive and outdated security rules to enable flexible, risk-informed protection programs consistent with other critical infrastructure Modernize security regulations and guidance and eliminate obsolete mandates Abide by the reasonable assurance standard for prevention of significant core damage and spent fuel sabotage Maximize use of and reliance on existing on and off-site resources in protective strategies Modernize cyber security requirements:

Remove low risk requirements Credit physical security programs and insider threat mitigation programs Focus protections on assets directly related to the prevention of significant core damage, spent fuel sabotage and prevention of significant reactivity changes (per Federal Energy Regulatory Commission (FERC)/North American Electric Reliability Corporation (NERC) requirements with NRC as the sole regulator under FERC-NRC Memorandum of Understanding (MOU}

6

ACCELERATING NRC REFORM INDUSTRY RECO:V:MENDATIO'.'-JS JU LY 2025 Modernize Access Authorization/Fitness-for-duty program requirements to eliminate legacy low-value requirements Expedite the access authorization of nuclear workers by eliminating low-value administrative requirements Eliminate low-value testing and auditing requirements that do not have a measurable impact on the fitness-for-duty program Eliminate unnecessary work and documentation in N RC processes Outcomes Focus on reasonable assurance of adequate protection of safety-significant items Develop a performance-based security framework and eliminate low-impact requirements and non-essential activities Proposed Timing and Method Immediate actions via policy and exemption authority Full codification by November 2026 through the wholesale regulation review rulemaking

7

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS J U L Y 2025 REFORM AND MODERNIZE THE REACTOR OVERSIGHT PROCESS Executive Summary Eliminate low value work and reduce regulatory burden in the Reactor Oversight Process (ROP) framework and other processes Overhaul the ROP Shift regulatory focus on actual safety significance and plant performance Risk-inform and streamline existing NRC performance indicators (Pl)

Streamline the Significance Determination Program (SDP)

Develop a risk-informed model for advanced reactor oversight Align inspections based on safety significance Eliminate and streamline baseline inspection procedures Risk-inform the NRC inspection program and incorporate performance-based approaches Eliminate duplicative inspections Develop a risk-informed approach for grading the level of oversight needed that allows advanced reactors with demonstrated lower risk profiles to reduce or eliminate the number of resident inspectors.

Streamline or eliminate NRC processes Reduce scope and process in the Office of Investigations Streamline the allegation process Eliminate oversight of safety conscious work environment (SCWE)

Outcomes Resets inspection to a level that provides reasonable assurance of adequate protection Reduces NRC inspection workload and frees up resources for work in other areas Provides a more risk-inform program so effort is focused on safety-significant areas Reduces unnecessary burden

8

ACCELERATING NRC REFORM INDUSTRY RECOMMENDA T1ONS J ULY 2025 Proposed Timing and Method Immediate actions via policy and exemption authority

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ACCELERATING NR REFORM IN DUSTRY RECOMMENDATIONS JULY 2025 REFORM RADIATION PROTECTION STANDARDS Executive Summary Modernize current radiation protection regulatory framework Eliminate 'as low as reasonably achievable' (ALARA) as a regulatory requirement and establish in guidance dose optimization above a specific dose threshold Eliminate redundant dose limits and overlapping criteria Eliminate requirements that limit program optimization & flexibility Eliminate the need for NRC pre-approval to use modern dose models Prioritize revisions to relevant guidance documents Outcomes Reduction of unnecessary burden Facility design flexibility and optimization Why This Matters Existing rules are overly restrictive, and the application of ALARA is inconsistent. Updating the framework improves efficiency, flexibility, clarity, and supports deployment of modern nuclear technologies while maintaining safety. The current application of radiation protection standards at very low doses results in:

Overly conservative constraints, especially in licensing, decommissioning, and design Minimal or unclear safety benefits, particularly at doses already below 100 mrem/year Distorted perception of radiation risk Proposed Timing and Method Immediate actions via policy and exemption authority Full codification by November 2026 through the wholesale regulation review rulemaking

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ACCELERATING NRC REFORM INDUSTRY RECOM:v!ENDA",IONS JULY 2025 Specific Recommendations Area Proposed Change Basis Description Dose Limits Focus on the primary Well-defined overarching dose dose limits, and limits provide adequate eliminate redundant protection for workers and the limits/constraints (e.g.,

public. Redundant or more EPA40 CFR 190,10 CFR restrictive criteria below the 20.1301 (e), 10 CFR dose limits add complexity 20.1101 (d)).

and conservatism without improving safety outcomes.

ALARA Eliminate ALARA as a I ALARA's restrictive requirement and in implementation and negative guidance establish a connotations hinder ri~k-threshold for dose informed optimization.

"optimization" at worker doses above 2 rem/year.

In addition, clarify that 10 CFR 20 requirements are operational, notdesign requirements.

Radiological Increase the unrestricted Current requirements are Criteria for use criteria from 25 unnecessarily restrictive, License mrem/year to align with complicate facility design and Termination the public dose limit in drive overly conservative 10 CFR 20.1301 licensing and Remove 20.1406 and decommissioning reviews.

ALARA from Subpart E.

ALARA Design Delete 10 CFR Part 50, Appendix I utilizes outdated Objectives and Appendix I..

dose methodologies (i.e., ICRP Limiting

2) that are inconsistent with Conditions for the basis of Part 20.

Operations Dose Methods Allow voluntary use of Modern models improve updated dose accuracy and flexibility and are methodologies (e.g.,

endorsed by consensus NCRP, ICRP) without scientific bodies.

NRC pre-approval.

Benefit Improves clarity and efficiency in the regulatory framework while maintaining safety of workers and the public.

Elimination of 40 CFR 190 and 20.1301 (e) provides flexibility for co-location of multiple facilities and maintains safety.

Enables a more graded and risk-informed approach to facility design and program implementation.

Optimizes licensing, design, and decommissioning by removing unnecessary conservatism while maintaining public safety.

Reduces unnecessary design and program compliance requirements.

Allows use of updated methods and facilitates innovation without compromising safety.

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ACCELERATING NRC REFORM INDUSTRY RECOMMENDATION S J U LY 2025 A

Proposed Change 8

8 t*

rea O

as1s ene 1t escnpt1on Monitoring Remove "as a minimum" Current monitoring Eliminates the need for Requirements from 20.1502 and requirements require prospective dose establish guidance for a licensees to have prospective evaluations and reduces minimum recordable dose evaluations for unnecessary dose (e.g. 100 determining the need to monitoring.

mrem/year).

monitor doses below 10% of the limits.

High Radiation Refine regulatory Revising guidance will allow Facilitates optimization Areas (HRAs) guidance to increase greater flexibility and decrease of HRA controls and administrative flexibility resource needs while more effective use of associated with HRA maintaining safety.

resources.

controls and 20.1601 (c).

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ACCELERATING NRC REFORM INDUSTRY RECOMME:NDATIONS JULY 2025 ELIMINATE ADMINISTRATIVE REPORTING REQUIREMENTS Executive Summary Eliminate administrative reporting requirements Remove unnecessary reporting already available to the NRC Reduce licensee distraction from core safety and operational responsibilities Retain only those requirements that directly support NRC's mission Outcomes Focus licensee attention on safety Eliminate administrative, low-value work Reduce regulatory overhead and compliance costs Improve efficiency of NRC oversight and reviews Support a risk-informed, modern regulatory framework Why This Matters Transparency in nuclear operations and regulation contributes to public confidence in nuclear safety. However, the necessary transparency can be realized without the burdensome reporting and administrative paperwork required by the NRC's rE:Jgulations.

Proposed Timing and Method Immediate actions via policy and exemption authority Full codification by November 2026 through the wholesale regulation review rulemaking

13

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JULY 2025 References and Background NRC attempted to review all administrative reporting requirements beginning with its Retrospective Review of Administrative Regulations (RROAR) in 2017, in response to EOs in the firstTrump administration. 1 The effort took four years to submit a modest set of recommendations to the Commission in late 2021 (SECY-21-0110). The staff's proposal included rulemaking that would take several more years to complete. In 2020, NEI provided comments and recommendations to the NRC on the RROAR. 2 In 2018, NEI petitioned for the elimination of nonemergency notifications that are redundant to communications with the resident inspectors 3. The staff took almost six years to develop its response to the petition, which was submitted to the Commission in June 2024 (SECY-24-0049).

Specific Recommendations Reporting I Eliminate the following regulations and any other unnecessary reporting regulations identified following a comprehensive review:

1)

§19.13

2)

§20.1906(d),§20SubpartM,

3)

§26.203( el( 1), §26.203( e )(2), §26.417 (b )( 1 )-(b )(2),

§26.717(e), §26.719(b), §26. 719(c)(1 )-(c)(3)

4)

§37.57(a)-(b), §37.81(b)-(f)

5)

§50, Appendix E, Sec. IV.D.4, §50 App. H

6) §50.36a(a)(2), §50.54(a)(3), (p)(2), (q)(5), (w)(3),

§50.59(d)(2}, §50. 71 (b}, §50. 72(a)-(c), §50. 73, §50. 74,

§50. 75(f)(1 )-(2), §50. 78§, 50.82(a)(8)(v)

7)

§55.25, §55.46(d)(3), §55.53(g)

8)

§70.32, §70.38, §70.50, §71.17(c)(3), §72.44,

§72.48(d)(2), §72.70(c)(6), §72.75(b)-(d), §72.80(b),

§72.186, §72.248(c)(6) 9}

§73, Subpart T NRC reporting requirements impose a high administrative obligation on the industry and do not increase safety.

Reporting non-emergency events consumes operator time, diverting resources from higher-value activities.

NRC resident inspectors maintain full Eliminates low-value and outdated compliance processes.

1 Executive Order 13771: "Reducing Regulation and Controlling Regulatory Costs," issued: January 30, 2017; and Executive Order 13777: "Enforcing the Regulatory Reform Agenda," issued: February 24, 2017.

2 Letter from James E. Slider to Andrew G. Carrera, "Comments on the NRC's Retrospective Review of Administrative Requirements [85 FR 6103; Docket ID NRC-2017-0214]," dated May 6, 2020, ML20128J340.

3 Letter from Bill Pitesa to Annette L. Vietti-Cook, "Petition to Amend 10 CFR 50.72, 'Immediate notification requirements for operating nuclear power reactors,"' dated August 2, 2018, ML18247A204.

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ACCELERATING NRG REFORM INDUSTRY RECOMMENDATIONS

ULY 2025

,----:-, --rr-fArea

- f roposed,Cha11g~ Description Basis Benefit

_j I I

Ir-I *

1

10) §74, Subpart B l

11) §75. 7, §75.1 O(a)-(c), §75.11, § 75.34

12) §95.17(a)(1}, §95.19(c)(1)

awareness of plant activities.

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ACC ELERATING NRC REFORM INDUSTRY RECOMMENDATIONS J U LY 2025 MODERNIZE THE NUCLEAR FUEL CYCLE FACILITY REGULATORY ENVIRONMENT Executive Summary Modernize regulations to focus on safety and increase accountability amongst stakeholders Introduce accountability mechanisms for both applicant and regulator Rely on applicable precedent to increase regulatory efficiency and focus facility licensing reviews on novel issues Remove references to the mixed oxide (MOX) facility to clarify applicability of regulations Risk-inform the regulatory framework for fuel cycle facilities Apply broader security and oversight reforms in this report to fuel cycle facilities Outcomes Streamlined regulatory framework Enhanced regulatory efficiency Accelerated deployment Cost and time savings Proposed Timing and Method Immediate actions via policy and exemption authority Full codification by November 2026 through the wholesale regulation review rulemaking

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ACCELERATING NRC REFORM INDUSTRY RECOMMENDAT IONS JULY 2025 Specific Recommendations A

Proposed Change 8

8 t*t rea O

as1s ene 1 escnpt1on Regulation Modify staff guidance to NRC has reevaluated Reduced review Modernization increase the efficiency of previously established durations and reviews by using precedent positions and reduced the improved and focusing on novel issues.

efficiency of designs in implementation Establish strict schedules for licensing reviews.

schedules and design new licenses (18-month efficiency.

maximum) and license amendments (90% within 6 months: 100% within 12 months).

Regulation Remove baseline design Fuel facilities are not Provides flexibility for Review criteria (10 CFR 70.64).

id.entical in baseline design, applicants and and suitable design and enables more efficient facility information is and risk-informed available in licensing designs.

documents.

Regulation Establish staff limits for Limits can help focus effort Increased efficiency, Modernization licensing actions:

on what matters most to predictability, and Number of pages for safety.

accountability for both regulator and safety evaluation reports applicant.

Durations of audits based upon risk-significance Schedule and scope for acceptance and fin~l reviews.

Regulation Avoid a 9-month delay on This represents an Increases efficiency of Modernization construction activities from administrative delay and new capability date of application submittal does not affect the health or construction allowing for expedited nuclear material-related schedules.

construction timelines by impact on the environment. L removing 70.21 (f).

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ACCELERATING NRC REFORM INDUSTRY RECOMMEN DATIONS JUL Y 2025 Remove ambiguity regarding construction activities. In 70.23(a)(7), delete the section beginning with:

"Commencement of construction prior to this conclusion... "

Regulation Remove MOX facility related Modernization regulations for clarity.

Delete 70.23(a)(8), 70.23(b),

70.23 Footnote 2.

Fees Extend the applicability of reduced reviews fees required by Section 201 of the ADVANCE Act to encompass all actions associated with advanced reactor development and deployment.

Oversight Utilize licensee-performed Programs inspections and reporting of vendors to satisfy NRC vendor oversight goals.

Backfit Modify 10 CFR Part 71 and Protection for 1 O CFR Part 72 to provide transportation transportation and storage and used fuel licensees - COC holders - the storage same backfit protection that reactor operators and other licensees currently have.

Regulations should be clear and unambiguous.

for when construction can begin.

These regulations are Removes obsolete obsolete and obfuscate regulations and requirements.

enhances clarity.

Significant costs associated Reduced cost for with NRC review and regulatory approval represent a interactions.

significant barrier to licensing activities.

NRC vendor inspection Reduced cost for does not add value (e.g.,

inspection activities observing factory and greater efficiency acceptance testing) when completing activities.

staff could instead review test plans and results.

In recent years, NRC staff Reduced cost for have sought to impose regulatory interactions multiple reinterpretations of and improved 10 CFR Part 72 on COC I

rngulato,y certainty In holders. These issues have nsportation and consumed inordinate ed fuel storage.

resources without increasing safety.

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ACCELERATING NRG REFORM INDUSTRY RECOMMENDATIONS ULY 2025 REFORM DECOMMISSIONING FUNDING & EXECUTION Executive Summary Modernize current regulatory structure governing decommissioning funding and execution Reflect cost reductions achieved by recent projects in decommissioning cost estimates Permit excess funds in Decommissioning Trusts to be used for decommissioning efforts during operations Operationalize known opportunities to further reduce decommissioning costs Outcomes Achieved reductions in decommissioning costs are recognized in NRC's regulatory framework Definitions and timelines are updated for consistency with more efficient business practices Pending NRC.actions that would further reduce costs are completed Simplified radiological compliance would reduce timelines of unrestricted use of enable the decommissioned nuclear sites while ensuring safety NRC regulations allow withdrawals of excess funds from Nuclear Decommissioning Trusts for decommissioning efforts during operation Why This Matters Modernized decommissioning regulations will promote the identification of excess funds and allow their use in decommissioning activities during operation, increasing the safety and efficiency of decommissioning process.

Proposed Timing and Method Immediately approve pending decommissioning transition rule and industry guidance to enable additional decommissioning cost reductions without impacting safety Immediate actions via policy and exemption authority Full codification by November 2026 through the wholesale regulation review rulemaking

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ACCELERATING NRC REFORM INDUSTR Y RECOMMENDA TIONS JU L Y 2025 References and Background SECY-24-0011, "Final Rule: Regulatory Improvements for Production and Utilization Facilities Transitioning to Decommissioning," (3150-AJ59; NRC-2015-0070), January 31, 2024.

NEI 22-01 Revision 1, "License Termination Process" (ML25006A203), December 2024.

Specific Recommendations A

Proposed Change B

B t*

rea D

as1s ene 1t escnpt1on Permit access to Revise 10 CFR Based on more recent Enhances the Decommissioning Trust 50.82(a)(B)(i) to add experience with nuclear efficiency of the Funds (DTF) that provisions for licensees to decommissioning decommissioning exceed minimum value withdraw excess funds projects, it is known that process and reduces providing reasonable from DTFs to pay for other DTFs have funds in excess site contamination assurance of funding decommissioning of the requirements.

during operations.

for NRC-defined activities during Allowing use of these decommissioning.

operations and after funds during operation will shutdown and update accelerate I

formulas in related decommissioning and guidance for estimating reduce contamination at decommissioning costs the site.

Decommissioning a Revise 1 0 CFR Part The resources of operating Enables more shut-down reactor on 50.82(a)(3) to remove time reactors on site more than efficient work-flow an active plant site on constraints on provide for the safety of a management and the timeframe of the decommissioning co-located shut-down maintains safety last operating unit.

activities.

reactor. Bringing while further decommissioning reducing costs.

activities onto an operating site is disruptive and costly.

-~

Complete long pending Approve: 1) the pending These proposed changes Enables additional regulatory actions to rule (SECY-24-0011) to are supported by cost savings.

further reduce reduce decommissioning considerable industry decommissioning transition costs and 2) experience. Industry and costs submitted industry NRC staff agree that they guidance (NEl-22-01, Rev.

should be implemented.

1) to reduce license termination costs.

20

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS

JLY 2025 Area Proposed Change Description Decommissioning Cost Allow a generic Estimates decommissioning cost estimate to be approved for a reactor design (in advance of site-specific license).

Impose realistic Eliminate the use of "less radiological dose likely but plausible" compliance scenarios scenartosandscenarios for decommissioning that involve uses that will not occur once the site is released.

Basis Benefit Current estimates are not More accurate cost applicable to advanced estimates would reactors. A more detailed, minimize design-specific cost overfunding the trust estimate could be funds.

submitted to the NRC for I approval, improving the accuracy of the estimate and the efficiency of the process.

Recent NRC reviews of Achieves safe license termination plans unrestricted site have resulted in excessive release at reduced expenditures to assess cost and accelerated unrealistic future public timeframes.

exposure scenarios and pathways.

21

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIO N S JU Y 2025

22

ACCELERATING NRC REFORM INDUS","RY RECOMMENDATIONS

,ULY 2025 REFORM NEW NUCLEAR LICENSING*

CREATE HIGH VOLUME LICENSING PATH Executive Summary Enable high-volume licensing for microreactors and modular reactors Immediately implement framework for qualified reduced-risk reactors Eliminate barriers and establish processes to drive licensing for previously approved standardized designs in under six months Create a pathway to use general licenses for eligible reactors or components, including pursuit of statutory changes where necessary Outcomes Immediately facilitates rapid deployment of new reactors Provides regulatory certainty Why This Matters Deployment of 300 GWe of new nuclear will require a great deal of NRC licensing reviews that are not possible without a new paradigm for high-volume licensing, including the use of General Licenses.

Proposed Timing and Method Immediate implementation of reduced-risk pathway using exemptions as necessary to impose only the minimum amount of regulation necessary for NRC to fulfill its statutory obligations Initiate parallel expedited rulemaking to create a new framework for high-volume licensing for all advanced reactors, including pathways for the use of General Licenses, as appropriate.

23

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATI O NS JULY 2025 References and Background On July 31, 2024, NEI submitted to the NRG a proposal "Regulation of Rapid High-Volume Deployable Reactors for Remote Applications (RHDRA) and Other Advanced Reactors" (ML24213A337). On December 9, 2024, the NRG responded to the NEI proposal (ML24317A174). In July 2025, NEI is submitting a supplement to RHDRA to remove the condition of remote applications and to inherently encompass the applicability to "other advanced reactors." Going forward, the term "Rapid High-Volume Deployable Reactors (RHDRA)" means "any advanced reactors with characteristics of safety, standardization, the use of automatic features and/or incorporation of advanced technologies, regardless of size or power level, that meet one or more performance-based criteria established for the use of alternative approaches." RHDRA proposes alternative approaches in 35 topic areas that are significantly more efficient than the NRC's current regulatory framework.

A rulemaking for "Low Consequence Reactors" was initiated in July 2025 to provide for High-Volume licensing for advanced reactors and includes pathways for General Licenses. The proposed rule is expected in 1 Q2026, and a final rule by 4Q2026. The rulemaking effort aligns with the NEI RHDRA and enables RHDRA to serve as a foundational framework. The wholesale rulemaking effort should incorporate elements of the Low Consequence Rulemaking to the extent that they can be applied to any nuclear reactor.

There are several prior NRG and NEI papers that provide a basis for the RHDRA proposal, including: NEI papers in 2019'(ML24124A190), 2021 (ML21197A103), and NRC SECY 20-0093, SECY 24-0008 and SECY-25-0052.

Letter, ClearPath et. al to Nuclear Regulatory Commission, "Transformative Regulatory Reform for New Reactors," May 15, 2025 (endorsed by Kairos Power)

Specific Recommendations Area Proposed Change Description Basis Benefit Near-term reduced-If necessary for immediate Industry Identifies near-risk pathway implementation, identify a set of proposal on term pathway exemptions necessary to license reduced-Transformative for reduced risk reactors (e.g.,< 1 rem site boundary Regulatory regulatory dose) with the minimum amount of Reform burden in regulatory burden.

advance of rulemaking RHDRA Continue developing industry-proposed A successful Ensure the approaches that will serve as the basis for rulemaking will rulemaking will new regulations, and additional details on need industry meet industry methodologies that will serve as the basis input on novel needs of for new guidance, to enable the NRC concepts and diverse rulemakingto meet the needs for High-details business Volume licensing.

models

24

ACCELERATING NRC REFORM INDUSTRY RECOM M ENDATIONS JULY 2025 Area Proposed Change Description NRC Rulemaking Codify a new rule for high-volume licensing and the appropriate use of General Licenses based upon the NEI RHDRA proposal:

1)

NRC solicitation of stakeholder input

[July 2025]

2)

NRC issues proposed rule for comment [February 2026]

3)

Public Comment on the Proposed Rule [March 2026]

4)

NRC issues final rule for use

[November 2026]

Atomic Energy Act Pursue changes to the Atomic Energy Act, and other statutes, to enable high-volume licensing, including appropriate use of General Licenses.

NOAK Licensing Establish reduced timelines (6 months) and streamlined reviews for designs substantially similar to one with prior NRC approval at sites within the site parameter envelope.

Basis Benefit High-volume Enables licensing, meeting the 300 including GWeofnew General License, nuclear by will require 2050, including rulemaking.

new business models and applications Optimal Optimal high-licensing may volume need changes to licensing and statutes use of General Licenses High-volume Demonstrates licensing regulatory supported by efficiency regulatory efficiency 25

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JULY 2025 REFORM NEW NUCLEAR LICENSING RESTRICT LATE-STAGE LICENSING AND APPROVAL DELAYS Executive Summary Reform and modernize processes for changes during construction Set strict criteria for NRG-imposed changes during construction and licensing actions required during construction under Part 50.

Allow licensees to implement design changes prior to NRG approval to avoid construction delays under Part 52.

Outcomes Enables more rapid deployment of new reactors Supports innovation Frees up licensee and NRG resources from focusing on unimportant activities Ensures regulatory stability and avoids unnecessary delays Why This Matters Licensing actions during construction that are imposed by the NRG, or licensee-initiated changes that require prior NRC approval, can be a major source of schedule delays and cost overruns.

Proposed Timing and Method Immediate implementation through expedited process improvements, and where changes to the regulations are needed, by exemption until completion of the rulemaking. Integrate ongoing Part 50/52 Lessons Learned rulemaking into the wholesale regulation review with a completion date of November 2026.

o Enables continued construction without prior NRG approval of licensee-initiated changes to Tier 1, 2* and Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) o Establishes a strict standard to limit NRG-required changes after construction is underway

26

ACCELERATING NRC REFORM INDUSTRY RECOM!v'.ENDAT:ONS J ULY 2025 References and Background The NRG Part 50/52 Lessons Learned Rulemaking (ML24326A003) considers experience from the regulatory impacts of construction for Part 52 Combined Operating Licenses.

The proposed rule addresses numerous lessons learned to make Part 52 more efficient.

However, there are numerous changes, consistent with NEI prior comments (ML21144A164 and ML21265A444) that would be needed, but the NRG is not currently addressing, as noted in the table below.

Additional references with background on the regulatory impacts during construction related to change controls are documented by: NEI (ML18305B421), Southern Nuclear (ML22265A097), and NRG (ML23325A202). There are numerous key insights from this experience, including:

NRG caused delays to the deployment of Vogtle 3 & 4 due to several factors including re-design for the new rule on Aircraft Impact Assessments. NRG review included 215 Licensing Actions and over 143,000 inspection hours (ML22265A097).

The need for prior NRG approval of changes has disrupted work and increased licensing and engineering costs during construction and created an ongoing risk of delay.

Use of Tier 2* is unnecessary, does not improve safety, and should be eliminated for future design certifications.

The NRG staff interpretation that construction must conform to the licensing basis at all times makes construction under Part 52 inflexible and as a result more costly than it has to be -

without a corresponding safety benefit.

Reference List The NRG Part 50/52 Lessons Learned Staff Requirements on Proposed Rule Alignment of Licensing Processes and Lessons Learned from new Reactor Licensing (ML24326A003)

NEI letters on Part 50/52 Lessons Learned Rulemaking (ML21144A164 and ML21265A444)

NEI letter on the Assessment of Licensing Impacts on Construction - Experience with Making Changes during Construction under Part 52 (ML18305B421).

Southern Nuclear Company slides on Lessons Learned from Part 52 Implementation for NRC Public Meeting 9/27/2022 (ML22265A097)

NRC Part 52 Construction Lessons Learned Report (ML23325A202)

RG 1.237, "Guidance for Changes During Construction for New Nuclear Power Plants Being Constructed Under a Combined License Referencing a Certified Design Under 10 CFR 52"

27

ACCELERATING NRG REFORM INDUSTRY RECO M MENDATIONS J UL Y 2 0 25 Specific Recommendations Area Proposed Change Description Part 50/52 Immediately establish an NRC Lessons policy that minimizes NRC Learned involvement in changes during Rulemaking construction. Provide finality in Environmental Review in the CP, allowing changes only for "new and significant information."

Establish regulations on NRG involvement in changes during construction so that NRC required changes must be shown to be cost-beneficial, with costs stemming from construction delays explicitly considered.

Part 52 Develop an efficient Tier 1, 2*

Licensing and and ITAAC change process that Construction does not require NRC prior Modernization approval during construction and sunsets the Tier 1 and 2*

categories once operation begins Eliminate the Tier 2* category and eliminate the need to include unnecessary details in Tier 1 and to require ITAAC to address overly detailed aspects of the plant (resulting in hundreds of ITAAC instead of tens of ITAAC)

Eliminate ITAAC for non-safety related equipment or programs Eliminate docketed submittal of ITAAC closure Allow construction/

installation/testing to proceed in parallel to NRC approval Create a process to issue COLs that reference a DC or SDA with a known change or correction prior to the correction of the error. Establish a mechanism

Basis Benefit Codification is Ensure that NRG will not needed for durability unnecessarily delay and predictability construction or result in unnecessary resources to maintain schedule Less disruption of

Allow for NRG and licensee modernization of resources for Part 52 utilization licensing and for licensing and construction of construction new reactors Reduces time and No impact on cost for new safety nuclear Allows flexibility Risk-informs requirements during construction 28

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JULY 2025 A

Proposed Change 8

8 t*

rea O

. t*

as1s ene 1t escnp 10n to make that change/correction after COL issuance.

Revise applicability of Technical Specifications for graded approach during start up and commissioning Update Construction ROP (cROP) to utilize a low safety significance issue resolution process, limit significance of licensee-identified findings, and revise the SDP to ensure resources are focused on the most safety-significant issues Change duration of COL & OL from 40 to 60 years (Atomic Energy Act change)

Eliminate ACRS reviews for COLAs for standard plant designs already approved (Atomic Energy Act change)

Eliminate reportability requirements during construction prior to special nuclear material (SNM) onsite Eliminate/reduce security requirements prior to SNM being stored onsite Expand scope of allowable nuclear construction to start prior to COL approval Eliminate Pl reporting for 2 years post commercial operation date Eliminate plant walkthrough requirements for operator licensing for plants under construction Eliminate fitness-for-duty requirements for construction workers and a graded approach to Part 26 requirements Create a mechanism to enable the agency to pilot new approaches or processes for

29

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JU LY 2025 Area Proposed Change Description the first licensee as unanticipated challenges are identified.

Develop expedited and more efficient process for reviewing licensing actions with minimal safety significance LWA Expand the allowable activities under LWA to include activities such as placement of safety-related concrete or other inspectable, safety-related construction activities, prior to full NRC CP or COL approval.

Changes to Expand the list of activities that.d.Q Activities run constitute construction and Constituting allow for broader use of "at-risk" Construction construction to allow some construction activities to commence before full NRC construction permit (or COL) approval.

Basis Benefit Allows flexibility for Provides enhanced applicants.

efficiency of construction and enables expedited deployment timelines.

Allows flexibility for Provides enhanced applicants.

efficiency of construction and enables expedited deployment timelines.

30

ACCELERATING NRC REFORM I NDUSTRY qECOM:"IENDA-;*10NS JU LY 2025 REFORM NEW NUCLEAR LICENSING MODERNIZE SITING CRITERIA Executive Summary Streamline site licensing and remove population-based restrictions Revise siting rules to enable risk-informed placement near higher population areas Streamline the ESP process and extend their 20-year limit Simplify and align environmental reviews through interagency coordination, so only one report is generated Outcomes Enables deployment of advanced reactors for strategic applications Significantly reduces site characterization timelines Increases efficiency of NRC reviews Supports innovation through risk-informed regulation Improves consistency with federal modernization efforts Why This Matters These solutions will reduce time and costs to develop and review applications and enable deployment of new reactors near industrial sites, data centers, and Al applications.

Proposed Timing and Method Immediate implementation via expedited process improvements, and where changes to the regulations are needed, via exemption until completion of the rulemaking. This should include issuance of exemptions to extend current ESPs beyond their 20-year expiration dates. Integrate rulemaking into the wholesale regulation review with a completion date of November 2026.

References and Background NEI Proposal Regarding Use of Offsite Meteorological Data for Licensing and Emergency Planning (ML25098A278)

31

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATION S JULY 2025 In March 2025, NEI requested NRC endorsement by September 2025 on the use of offsite meteorological data, including data from airports, mesonets, or state environmental agencies, for reactor licensing and emergency planning in place of onsite meteorological towers.

NEI White Paper: Modernizing Population-Related Siting Requirements for Advanced Reactors (ML25171A127)

In June 2025, NEI submitted a white paper to the NRC advocating risk-informed siting requirements for advanced reactors. The letter recommends revisions to Part 100, proposed Part 52, and relevant guidance to support efficient deployment of advanced reactors.

NEI Guidance for Implementing the Requirements of 1 O CFR Part 52 for Early Site Permit (ESP)

Renewal (ML25167A250)

In June, NEI submitted a guidance document for NRC endorsement, proposing applicants update only information that has materially changed since initial application.

SECY-25-0052: Nth-of-a-Kind Microreactor Licensing and Deployment Considerations In September 2024, NRC staff published a draft white paper on NOAK micro reactor considerations, including scaling application requirements for seismic and other siting characteristics based upon reactor design site parameters.

Forthcoming NEI Proposal Regarding Use of United States Geological Services (USGS) and Alternative Approaches to Geotechnical/Seismic Site Characterization NEl's forthcoming submittal will include proposed alternatives to the NRC requirements for time consuming and unnecessarily expensive geotechnical site characterization and soil structural analyses using NRC Senior Seismic Hazard Analysis Committee {SSHAC) Level 2/3 process and extensive Appendix B quality assurance (QA) core borings. This detailed methodology will enable use of USGS data and processes for sites that meet consequence and seismic margin performance criteria, to avoid or minimize core borings that are commercial quality.

Specific Recommendations A

Proposed Change 8

8 1-rea D

as1s ene 1t escnpt1on Population Siting Revise the requirements in

§ 100.21 (h), § 53.530(c),

§ 100.1(d), § 100.21(a),

§ 100.21 (b), and the Introductory paragraph to

§ 53.530(c) to apply a risk-informed approach for grading population-related requirements to allow advanced reactors with demonstrated lower risk profiles to reduce or eliminate

Current language written for large LWRs limits the ability to site plants in a certain population density and distance from population centers. Demand for new reactors from industry requires co-siting near workplaces and workforces.

Reduces regulatory burden, operating costs, and enables industrial and other population-centered applications.

32

ACCELERATING NRC REFORM INDUS TRY RECOMMENDA TIONS J ULY 2025 Area Proposed Change Description the requirements for population density and distance from population centers.

Use of Offsite Develop regulatory guidance Meteorological to formally endorse the use of Data &

technically justified offsite Meteorological meteorological data sources Towers for initial licensing activities.

When meteorological towers are needed, reduce data collection period to 1 year.

ESP Renewal Grant exemptions to 1 O CFR 52.26 for ESP holders to extend licenses beyond their 20-year duration in the absence of compelling evidence that the permit is no longer valid. Amend regulation to eliminate expiration date of future ESPs.

Graded approach Develop guidance for a graded to site approach to site characterization characterization and utilize exemptions as needed. For.

example, for some designs existing U.S. Geological Survey data may be adequate, obviating the need for additional data. Adopt forthcoming NEI guidance on Geotechnical and Seismic site characterization methodology as part-of the guidance development.

Basis Benefit Regional meteorological Significantly reduces data have improved by time and cost of site orders of magnitude since characterization.

meteorological towers were Streamlines first envisioned over 50 licensing and years ago. Today, we rely on reduces this readily available data unnecessary time for critical forecasting and and costs without life-safety warnings, making it a robust and proven basis compromising for site assessments.

safety.

With enhanced modeling of meteorological patterns, data collection should be reduced to 1 year.

ESP renewals require Reduces licensing significant time and costs and time for resources to update ESP renewals.

application information, despite no impact to safety.

Siting requirements in Part Significantly reduces 100 involve extensive site time and cost of site characterizations of characterization.

features of a proposed site.

Reduces time and cost of application preparation 33

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JULY 202 5 REFORM NEW NUCLEAR LICENSING ENSURE REACTOR SAFETY ASSESSMENTS FOCUS ON CREDIBLE, REALISTIC RISKS Executive Summary Focus reactor safety assessments on credible, realistic risks Establish clear probability thresholds for events and hazards to be considered in a reactor's design Establish guidance on appropriately addressing unlikely events with defense-in-depth (DiD)

Outcomes Enables more rapid deployment of new reactors Supports innovation Ensures regulatory predictability and avoids unnecessary delays Why This Matters New designs are often challenged to reach ever-increasing standards of safety, often resulting in risk metrics that are orders of magnitude below the operating fleet, despite designs with larger safety margins.

Proposed Timing and Method Immediate implementation through policy changes informed by the criteria in the Licensing Modernization Project (LMP).

Near-term implementation through expedited process improvements, and where changes to the regulations are needed, exemptions should be used until the completion of the wholesale review rulemaking with a completion date of November 2026.

References and Background NRC Safety Goals for the Operations of Nuclear Power Plants -1986 Policy statement Commission direction as provided in SRM-SECY-10-0121 and SRM-SECY-24-0008 Aircraft Impact Rule Statements of Consideration (Federal Register Vol. 74, No. 112)

34

ACCELERATING NRG REFORM INDUSTRY RECOMMENDATIONS JULY 2025 In 2024, NEI submitted a proposal [ML24213A337] on rapid high-volume deployment of micro reactors (RHDRA) calling for reduced regulatory burden for smaller reactors with increased safety features. These considerations should inform a licensing framework that reduces unnecessary burden for applicants and licensees that meet the performance-based criteria described above.

In February 2025, NEI submitted comments [ML25051A092] on the Proposed Part 53 rulemaking, which should inform the final part 53 rule as well as pathways under Parts 50 and 52 for reduced regulatory burden for Physical Security, Access Authorization/Fitness for Duty, Operations Staffing, and other programs.

Specific Requirements Area Proposed Change Description Basis Benefit Threshold for Establish a risk-informed threshold, that ANS2.26 Reduces reduced if met, enables reduced regulatory 10 CFR 50.160, RG regulatory regulation requirements while still ensuring safety.

1.242, NEI 24-05 burden.for This threshold can be met if a reactor reactors with satisfies any of the following criteria:

NUREG-1537, RG 1.233, enhanced safety

1)

Site Boundary Emergency Planning SRP that meet any of Zone (EPZ). A facility qualifies for a Unmitigated Dose is the risk-informed and plume exposure pathway EPZ that evaluated using extreme performance-does not extend beyond the site bounding assumptions.

boundary in accordance with the There is precedent in based criteria requirements of 10 CFR 50.33(g)(2).

ANS 2.26 which linked

2)

Design basis accident (OBA) dose <1 that criteria to being able to use commercial rem in lieu of 25 rem in 10 CFR seismic design.

50.34(a)(1 )(ii)(D)(1) and (2)

a.

Dose calculated according to the standard review plan with design-specific modifications, LMP, or maximum hypothetical accident

b. Licensee would defend OBA based on design requirements.

3)

Unmitigated Dose< 25 rem in a simple, extreme bounding analysis specified in ANS 2.26.

Reduced For those plants that meet the threshold Part 53 comment, Reduces Unnecessary for reduced regulation (provided above):

RHDRA regulatory Regulatory

1.

Revise 10 CFR 100, 10 CFR 73, burden for Burden reactors with 10 CFR 55, 10 CFR 50, 10 CFR enhanced safety

35

AC ELERATING NRC REFORM I NDUSTRY RECOMMENDATIONS J U LY 2025 Area Proposed Change Description 52, and 10 CFR 53 draft rule consistent with the RHDRA proposal and NEI comments on the Part 53 rulemaking. This effort should address all areas identified in RHDRA, including meteorology, geology, physical security requirements, aircraft impact, emergency preparedness, NRC oversight, commercial codes and standards, quality assurance, and population-related siting standards.

2.

Reconsider the applicability of the DBT Thresholds The threshold for design-basis events for design should be 1 E-4/year frequency with basis events margin informed by 95th percentiles and defense in depth (DiD) consideration.

Mitigation of beyond design-basis (BOB) should consider events down to 1 E-6/year frequency with margin informed by 95th percentiles and OiD consideration. These thresholds need not be strictly quantitative with precedent from SRP, NUREG-1537, and existing guidance providing sufficient guidance for qualitative assessments on event likelihood.

Reviews should be risk-informed, with minimal resources expended on events below the thresholds (reduced review for single failure criterion, large-break loss-of-coolant accident (LLOCA).

Basis Benefit and establishes performance-based criteria Except where These thresholds phenomenologically should inform evident to apply to the staff reviews by design, consideration of limiting review "cliff edge" effects scope to credible should not be imposed events.

for BOB events.

36

ACCELERATING NRC REFORM INDUSTRY rU::COMl".ENDATIONS J ULY 2025 REFORM NEW NUCLEAR LICENSING APPROVE DOE/DOD TESTED DESIGNS Executive Summary Expedite NRC approval of DOD/DOE-tested reactor designs Harmonize NRC, DOE, and DOD regulatory approaches Require NRC licensing of reactor designs previously approved/tested by DOD or DOE in six months or less Limit NRC licensing review to statutorily required considerations unique to NRC licensing Outcomes Increased deployment flexibility Faster commercial deployment of advanced reactors Elimination of duplicative licensing Minimal differences between NRC, DOE, and DoD review scopes Why This Matters Harmonization of NRC, DOE, and DOD regulatory approaches is necessary to realize the full benefit of DOE/DOD advanced nuclear innovation and accelerated deployment options for new technologies in commercial applications.

Proposed Timing and Method Immediate implementation - Identify gaps between DOE/DOD authorization and NRC licensing that must be addressed in order to meet statutory requirements and define the process to quickly close these gaps for an expedited NRC review.

Long-term implementation - Implement common regulatory approaches for the NRC, DOE and DoD, including revisions to statutes as necessary, to enable NRC reciprocity or comity of all scope of designs or sites previously approved by DOE or DOD.

37

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JULY 2025 References and Background The Atomic Energy Act of 1954, as amended, including Sections 91 and 101, allows the President of the United States to authorize the DOD to manufacture, produce, or acquire any utilization facility for military purposes. 4 The AEA specifically does not require an NRC license for "the manufacture, production, or acquisition by the Department of Defense of any utilization facility... or for the use of such facility by the Department of Defense or a contractor thereof." 5 Army, Navy, and Air Force each separately operated nuclear power plants 1950s-1970s. 6 The Naval Reactors program was established by EO 12344 (42 U.S.C. 7158), "Naval Nuclear Propulsion Program, and exists as an Office within DOE under NNSA.

The Energy Reorganization Act of 1974 delegated the role of research, development, and demonstration of nuclear reactors and technologies to the predecessor of the Department of Energy while the regulation of commercial nuclear activities was delegated to the N RC.

However, DOE still maintains the authority to self-regulate nuclear facilities, governed by 1 O CFR Part 830, "Nuclear Safety Management," and a series of internal DOE Orders and Standards.

There are unclear boundaries between NRC, DOE and DOD regulatory authorities for reactors that would be used in part, and potentially fully, for commercial activities. Various permutations of owner/operator/use/grid connection are possible, mostly untested, and never in the modern political, legal, and regulatory environment. Therefore, it is unclear the conditions under which a reactor could utilize the DOE testing or DOD military regulatory pathways and at the same time be used for commercial purposes, including situations in which the reactor is connected to and providing power to the electric grid. 7 Specific Recommendations Area Proposed Change Description Basis Benefit Regulatory Jurisdiction Clarify the regulatory jurisdiction of the NRC, DOE, and DOD, for reactors authorized by DOE or DoD and also used for commercial purposes, especially when they are connected to the electric grid. Amend statutes as necessary to achieve intended goals of EOs (14301 and 14302).

4 See 42 U.S.C. §2121 (b)

Lack of clarity of jurisdiction Enables the use of DOE and DoD authorization.

5 This position is supported by an NRC letter to the Washington State Attorney General dated April 13, 2001.

See 42 U.S.C. §2121(b), and 42 U.S.C. §2140(b).

6 U.S. Army Engineer Reactors Group Fort Belvoir, Va, "An Introduction to the Army Nuclear Power Program,"

January 22, 1966.

7 Commercial entities regulated by DOE or DoD and tied to electricity grid may be subject to regulatory provisions of the Federal Power Act: 42 U.S.C. §2019 and provisions of 12 U.S.C. Chapter 12 Subchapter II

38

ACCELERATING NRC REFORM INDUST RY RECOMMENDATIONS JULY 2025 Area Proposed Change Description Expedited Establish NRC guidance for addressing gaps Licensing between NRC licensing and approval by DOE or DOD that eliminate duplicative reviews and minimize differences. Ensure NRC is engaging with DOE/DOE processes to ensure common understanding/alignment. Amend NRC regulations as necessary.

Reciprocity Establish common regulatory approaches for and Comity the NRC, DOE and DOD, including revisions to statutes as necessary, to enable NRC reciprocity or comity of all scope of systems, reactor designs or sites previously approved by DOE or DOD.

Basis Benefit Lack of clarity of More efficient and how to credit timely NRC licensing DOE or DOD of reactor designs or approvals for specific systems that NRC licensing have been approved for DOE testing and DOD use Separate Creates viable approval and pathways from DOE licensing testing and DOD use processes do to NRC licensing not support national energy goals.

39

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JULY 2025 REFORM NRC LICENSING ESTABLISH FIXED LICENSING SCHEDULES Executive Summary Establish fixed deadlines and fee recovery caps for licensing actions.

Enables faster deployment, supports investment certainty, and improves NRC accountability Cap fees and enforce firm deadlines:

s;12 months for NOAK CP, OL and COL application reviews s;18 months for FOAK CP, OL, and COL application reviews Align review timelines with safety significance Outcomes Enables rapid deployment of new nuclear power to the grid Ensures regulatory reviews are predictable, timely, and focused on safety Provides applicants with budget and schedule certainty, minimizing the potential for costly and disruptive overruns Why This Matters Achieving a nuclear power capacity of 400 GW in the U.S. by 2050 will not be attainable without definitive schedules and accountability in licensing processes. Operators and applicants depend on the certainty of regulatory reviews to secure investors and support for the reliable and affordable power nuclear provides.

Proposed Timing and Method Immediate implementation through an NRC policy directive and incorporation into the various parts of the CFR as part of the wholesale review with a completion date of November 2026.

40

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS

!ULY 2025 References and Background In 2024, NEI wrote a letter 8 to the NRC providing input on improvements to licensing and oversight programs directed by the ADVANCE Act.

NEI has submitted numerous comments and recommendations that would.enable the NRC to establish fixed aggressive yet realistic deadlines for new reactor licensing. This includes Part 50/52 Lessons Learned (ML21144A164 and ML21265A444), Part 53 (ML25051A092), RHDRA rapid licensing (MLML24213A337), and Combined License Reviews (ML25062A103}.

Specific Recommendations A

Proposed Change B

B t*

rea O

as1s ene 1t Licensing Schedule and Cost Caps escript1on Establish fee recovery caps for licensing actions 9 and fixed deadlines including a 12c month maximum for all licensing review unless otherwise noted:

New Licenses (Parts 30, 40, 50, 52, 70, 72): FOAK 18-month maximum, NOAK 9-month maximum Early site permits: 12-month maximum. A 9-month schedule for an ESP application that references a DC with site parameters that bound the site characteristics.

License Amendments (Parts 30, 40, 50, 52, 70, 72): 90%

within 6 months; 100% within 12 months:

Certificates of Compliance (Parts 71, 72, and 73): 9-month maximum for new applications and 3-months for amendments Arbitrary and continually shifting schedule and resource estimates are not indicative of a predictable, performance-based regulator that possesses the knowledge base and operating experience of the NRC.

Enables predictable and timely reviews that must be performed commensurate with the safety significance of the application.

8 Letter from Andrew Mauer (NEI) to U.S. NRC, "NEI Input on Improvements to Licensing and Oversight Programs," October 28, 2024, ML24302A311.

9 These fixed deadlines should also be adopted in the final rulemaking for 1 O CFR 53

41

ACCELERATING NRC REFORM IN DUSTRY RECO M MENDATI ONS J U LY 2025 Area Proposed Change Description Power Uprates: MUR-6 months; SPU-9 months; EPU-12 months License Renewals {Parts 40, 50, 52, 54, 70, 72): 12-month maximum License Transfers (Parts 50 and 52): 6-month maximum Changes to Implement changes to Regulatory regulations and guidance that Framework enable more efficient licensing, including: Part 50/52 Lessons Learned Rulemaking, Part 53, and the NEI RHDRA Process/ NRC NOAK Licensing.

Changes to Implement changes to NRC NRC project management and Processes other review practices to streamline reviews: e.g.,

project planning and tracking tools, escalation process for applicants, core team reviews, etc.)

Basis Benefit NRC regulatory framework Creates a rapid creates a barrier to achieving efficient, predictable greater levels of efficiency.

and repeatable licensing process NRC review practices create Ensures project a barrier to achieve greater management and levels of efficiency.

conflict resolution practices produce timely reviews.

42

/

ACCELERATING NRC REFORM INDUSTRY RECOMMENDA~" IONS JULY 2025 REFORM NRC LICENSING STREAMLINE NRC HEARINGS Executive Summary Significantly reduce the scope and burden of adjudicatory hearings while ensuring a focused, fair process and a robust record that allows the NRC to successfully defend its Licensing decisions in federal court Focus contested hearings on material issues by refining intervention standards, requiring supporting evidence with proposed contentions, and providing for expedited Commission review of ASLB admissibility decisions.

Assign NRC staff with relevant technical expertise to decide the merits of admitted contentions in individual licensing proceedings in parallel with the staff's application review, ensuring that issues are evaluated by qualified personnel and decisions are subject to Commission oversight.

Eliminate procedural inefficiencies by removing mandatory disclosures, limiting late-filed contentions and motion practice, and adopting paper-only hearings governed by fixed schedules.

Advocate for legislation to remove the mandatory uncontested hearing requirement applicable to CPs, LWAs, COLS and ESPs.

Outcomes Greater regulatory certainty through earlier issue resolution Faster decisions by minimizing legal filings and duplicative processes Lower cost by eliminating unnecessary disclosures and formal hearings Better use of NRC and applicant resources Why This Matters The current hearing process is overly formal and burdensome, with mandatory disclosures, repeated legal filings, and late-arising challenges that delay decisions and increase uncertainty.

Streamlining the process can improve licensing speed and predictability without compromising safety, environmental compliance, or the quality of agency decision-making.

Proposed Timing and Method Immediate implementation through the ongoing wholesale regulation review, with a completion date of November 2026. While rulemaking pmceeds, a revised Commission policy statement on

43

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JULY 2025 the conduct of adjudicatory proceedings can provide early direction on contention admissibility, standing, hearing schedules, and other topics. Continue to advocate for legislative change to eliminate mandatory uncontested hearings.

References and Background The NRC has broad discretion under the AEA, NEPA, and the Administrative Procedures Act to define appropriate procedures for contested matters, including through generic rulemaking, rules of particular applicability, and case-specific hearing orders. Courts have consistently affirmed that the AEA guarantees an opportunity for hearing, but not any specific format, and that NEPA imposes procedural-not substantive-obligations. Agencies may tailor processes to match the nature of the issues and the need for administrative efficiency.

Because NRC licensing decisions are reviewed under the Hobbs Act, judicial review proceeds directly to a U.S. Court of Appeals. Revised hearing procedures should not alter this pathway but should reduce administrative burden and avoid an increase in litigation over matters unrelated to nuclear safety or other material issues.

In 2024, NEI submitted a proposal recommending significant reductions in the complexity and duration of contested hearings for rapid high-volume deployable reactors in remote applications (RHDRA). While focused on RHDRA licensing, many of the proposed changes are adaptable to other licensing actions.

In NRG v. Texas (2025), the Supreme Court confirmed that only parties admitted under the NRC's intervention rules qualify as "parties aggrieved" eligible for judicial review under the Hobbs Act-affirming the agency's framework for intervention and contention admissibility.

NEI has identified opportunities to modernize and streamline the hearing process consistent with that decision.

Reference List NEI letter on NEI Proposal Paper "Regulations of Rapid High-Volume Deployable Reactors in Remote Applications (RHDRA) and Other Advanced Reactors," Appendix 6 - Simplification of Procedures for Contested Hearings (ML24213A337)

Idaho National Laboratory, Recommendations to Improve Nuclear Licensing, INL/RPT 84292, April 2025.

Specific Recommendations A

Proposed Change 8

B f't rea D

as1s ene 1 Contention Admissibility escnpt1on Issue a policy statement reinforcing application of existing strict admissibility standards, including that ASLBs must not reframe or supply bases for deficient contentions,

NRC has broad discretion under the AEA to define hearing procedures, including thresholds for what issues may be raised.

Courts have upheld the Filters meritless issues early, reducing unnecessary process and litigation risk.

44

ACCELERATING NRC REFORM INDUSTRY RECOMMENDAnONS J U LY 2025 Area Proposed Change Description and that NEPA contentions must satisfy scope and materiality requirements consistent with NEPA case law. Revise 10 CFR 2.309(f) as needed.

Standing Issue a policy statement eliminating the presumption of standing based solely on geographic proximity and clarifying that standing must be established for each proposed contention, reconsidering CLI-09-20 and related Commission precedent as needed. Revise 1 O CFR 2.309(d) as needed.

Early Revise 1 O CFR 2.311 (a) to Commission expand scope of interlocutory Review of appeals of contention Contentions admissibility rulings. Revise internal Commission procedures to ensure timely review.

Combined Revise 10 CFR 2.104, 2.105, Contention 2.309, and Subpart L to and establish the initial intervention Evidentiary stage as the primary opportunity Filings to present evidence for contentions.

Limit New Issue a policy statement and Amended clarifying that new or amended Contentions contentions must be filed within 30 days of public availability, that timeliness is measured from that date, and that

Basis Benefit NRC's use of intervention requirements. NEPAis procedural and affords substantial deference to both the scope and depth of environmental evaluations.

NRC has broad discretion Promotes consistency under the AEA to establish with judicial standing participation thresholds standards and ensures and courts have upheld the only parties with a NRC's intervention direct, articulable framework. Modern federal interest can intervene.

caselaw requires a showing of injury, causation, and redressability for each claim-supporting alignment with a contention-specific standing analysis.

The Commission has Avoids wasted discretion to define both resources on who may appeal and how improperly admitted quickly interlocutory contentions and appeals are resolved.

prevents delays caused by the reinstatement of valid contentions that were improperly excluded.

Courts affirm that agencies Promotes efficiency by may define when and how focusing the hearing a record is developed, and process at the outset have recognized that new and supporting evidence-such as staff predictable scheduling.

documents-does not justify reopening proceedings absent a genuinely new issue.

Courts have upheld NRC's Promotes timely issue authority to adopt resolution, limits abuse reasonable limits for late-of late filings, and filed contentions and ensures schedule balance fairness with discipline while timely issue resolution.

preserving a meaningful 45

ACCELERATING NRC REFORM IND USTRY RECOMMENDATIONS JULY 21;25 Area Proposed Change Description "materially different" information must present new issues-not new evidence or reinterpretations of existing information. Revise 10 CFR 2.309(c) as needed to codify these clarifications, authorize presiding officers to reasonably limit filing windows, and require consideration of delay and record contribution when evaluating good cause.

Eliminate Revise 1 O CFR 2.1203 to Mandatory eliminate mandatory Disclosures disclosures and formal discovery in Subpart L proceedings; rely on ADAMS and other NRC platforms.

Paper-Only Revise Subpart Land Appendix B Format &

to 10 CFR Part 2 make written Scheduling hearings the default format.

Establish fixed milestone schedules to structure written submissions and support early, orderly development of the record.

Merits Revise Subpart L to provide that Resolution by admitted contentions will be Staff referred to NRC staff for resolution on the merits. Staff may request additional information from the parties as needed, with an obligation for timely response. Resolution would be documented in an order issued with the staff's review documents and take effect immediately unless stayed. Conforming changes may be needed to 10 CFR 2.347,

Basis Benefit These changes align with opportunity to raise that case law and preserve new issues if due process.

warranted.

APA does not require Reduces burden on all discovery in informal parties; promotes adjudications.

transparency through centralized access to information.

The APA permits agencies Reduces complexity to tailor adjudicatory and cost, improves procedures. Subpart L scheduling currently defaults to a predictability, and complex written and oral streamlines hybrid process, but a adjudications without written-submission default compromising fairness.

better reflects informal hearing principles and promotes early resolution of contentions and evidence.

The Commission has Puts review in the authority to delegate the hands of most qualified presiding officer role. The individuals and allows APA and AEA permit staff to faster resolution of resolve issues in informal contentions without adjudications without procedural burdens of triggering separation-of-formal hearings.

functions or ex parte restrictions, so long as the process is fair and impartial.

46

ACCELERATING NRG REFORM l'.'-JDUSBY RECOM!v'.ENDA TI ONS J ULY 2025 Area Proposed Change Description 2.348, and 2.340 to reflect this process.

Commission Revise Subpart L to provide that Review of NRG staff orders resolving Staff contentions are treated as initial Decisions decisions under 1 o CFR 2.121 O and 2.1212, subject to petition for Commission review. These decisions would become final agency action 60 days after issuance unless the Commission modifies, sets aside, or stays the decision.

Basis Benefit Subpart L already Ensures parties can authorizes party-initiated raise concerns with petitions for Commission staff decisions and review of initial decisions.

promotes timely Extending this framework resolution. Maintains to staff merits decisions-Commission authority with a shorter timeline to review staff before finality-preserves determinations where fairness and enables appropriate and Commission oversight supports efficient without unnecessary delay.

judicial review.

47

ACCELERATING NRG REFORM I N D U STRY RECO M MENDATIONS JULY 2025 REFORM NRC LICENSING MODERN ENVIRONMENTAL REVIEW PROCESS Executive Summary Reduces delay and duplication, while aligning with NEPA reform mandates Finalize and codify New Reactor GEIS in 1 o CFR Part 51 Expand use of environmental assessments (EA) and categorical exclusions (CATEX)

Eliminate low-value, duplicative analyses; focus on foreseeable impacts Outcomes Simplifies a complex procedural process that doesn't provide commensurate benefit Creates immediate licensing certainty Facilitates continued operation, restarts, and new nuclear deployment Why This Matters These changes will accelerate licensing and reduce burdens on applicants while maintaining robust environmental protection and public participation in the NEPA process.

Proposed Timing and Method Immediate implementation through expedited process improvements and exemptions, where needed, until the wholesale regulation review rulemaking is completed by November 2026.

48

ACCELERATING NRC REFORM INDUSTRY RECOM:V:ENDATIONS J ULY 2025 References and Background Fiscal Responsibility Act of 2023 (FRA)- amends NEPA; sets time/page limits for EISs/EAs ADVANCE Act of 2024-Section 506 directs NRC to modernize reviews EO 14154 & EO 14300- require prioritization of efficiency and regulatory reform SECY-24-0046 - "Implementation of the Fiscal Responsibility Act of 2023 National Environmental Policy Act Amendments", May 30, 2024 (ML24078A013)

Specific Recommendations Area Proposed Change Description Basis Benefit Environmental Review

1)

Finalize New Reactor GEIS and codify in Part 51

2)

Expand use of EAs/Finding of No Significant Impacts (FONSls)/mitigated FONSls and codify changes

3)

Develop and codify categorical exclusions for all categories of licensing actions determined by the NRC not to have individually or cumulatively significant environmental impacts, potentially including, for example, subsequent license renewals (SLR), power uprate license amendments, certain advanced reactor licensing actions, and site decommissioning.

4)

Eliminate analysis of "need for power" and limit alternatives analysis

5)

Focus on direct/proximate impacts only to the maximum extent practicable 10

6)

Minimize duplication via applicable methods, including tiering (e.g.,

from GEIS), adoption or incorporation by reference of other agencies' analyses, interagency Statutory and executive mandates, legal precedent, and NRC staff recommendations Faster, more predictable licensing; reduced costs; better alignment with national energy goals 10 Amy Howe, Supreme Court limits scope of environmental review, SCOTUSblog (May. 30, 2025, 11 :23 AM),

https://www.scotusblog.com/2025/05/supreme-court-limits-scope-of-environmental-review/

49

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS J ILY 2025 Area Proposed Change Description MOUs, EIS/EA templates, and applicant-prepared draft EISs/EAs

7)

Implement a graded approach for environmental reviews of micro-reactors and other qualifying low-consequence reactors that reflects resource requirements and reduced risk of radiological release, consistent with that described in SECY-25-0052

8)

Eliminate alternative site analysis NRC Policy on Establish NRC organizational policy on Referencing the use of incorporation by reference External (IBR) from relevant state and federal Environmental agency environmental analyses.

Analyses

Basis Benefit J

Environmental impact IBRwould statements and reduce review assessments require project time significant time and and costs by costs and are often reducing duplicated with various duplicative agencies engaged in the work.

project.

50

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS

uLY 2025 REFORM NRC LICENSING CROSSCUTTING REGULATORY IMPROVEMENTS Executive Summary Modernize NRC regulations to improve efficiency, effectiveness, and focus on safety.

Reduce unnecessary regulatory burden Expand the use of risk-informed, performance-based regulation agency-wide Support innovation and deployment of advanced technologies Outcomes Faster, more predictable licensing decisions Streamlined and clearer regulatory requirements More efficient deployment of advanced fuels and technologies Improved NRC focus on safety-significant issues Why This Matters Alignment with NRC's licensing modernization efforts is instrumental in facilitating the expansion of American nuclear energy Proposed Timing and Method Immediate implementation through expedited process improvements, and exemptions, where needed, until completion of the wholesale regulation review rulemaking by November 2026.

51

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIO N S JULY 2025 References and Background NEI Letter, McCullum to Helton, Interim Enforcement Policy (IEP) for Enforcement Discretion for General Licensee Adoption of Certificate of Compliance Holder Generated Changes, 90 Federal Register 14,917, April 7, 2025 (Docket ID NRC-2025-0064), April 25, 2025.

NEI letter, "Nuclear Energy Institute (NEI) Input on Recent Executive Orders," February 10, 2025.

Specific Recommendations Area Proposed Change Basis Benefit Description Risk-informed Revise the following Certain low-risk and low-Eliminates regulatory Change regulations:

safety-significant burden to obtain NRC Processes

1) 10 CFR 50.59 changes cannot be review and approval for implemented without minor changes

2) 10 CFR 70.72 NRC review and approval.

3) 10 CFR 72.48 including elimination of 10 CFR Part 72.48 (c)(2)(viii)

4) 50.54(a), 50.54(p), 50.54(q)

In-progress Revise 10 CFR 50.46 to adopt a NRC requirements Increased Enrichment Rulemaking risk-informed approach.

impose unnecessary rule with the risk-Implement increased burden related to informed 50.46 would enrichment of conventional postulated LOCAs.

enable more realistic and accident tolerant fuel LLOCAs are not operational margins for designs for operating reactors significant contributors to advanced fuels and and enable extension of overall plant risk per power uprates.

burnup limits.

NUREG/CR-6932.

Revise 50.36 to apply risk insights to limiting conditions of operation (LCO).

Offsite Revise requirements in 10 CFR Allowing States to self-The proposed change emergency 50.47, 10 CFR 50.54, and certify the adequacy of would enhance the preparedness Appendix E to provide an their EP programs would efficiency of federal (EP) programs option for States to certify be analogous to NRC's oversight and significantly offsite EP adequacy directly to approach to Agreement reduce the costs that a the NRC. This option would be States, which grants licensee incurs to in addition to the current States regulatory maintain offsite EP method where FEMA provides authority over users of programs, all while certification to the NRC. The certain radioactive ensuring the ability to current FEMA method should materials.

protect public health and be retained for use by safety is maintained.

52

ACCELERATING NRC REFORM INDUSTRY RECOMMENDA~'IONS i ULY 2025 Area Proposed Change Description licensees lacking State support for direct certification.

Coordinate with FEMA to achieve conforming changes to 44 CFR 350-354 (i.e., FEMA's regulations applicable to nuclear power plants).

Revise the MOU between the NRC and FEMA ~o reflect these changes.

Part52 For licensed plants, convert Tier 1 and Tier 2* to Tier 2 upon commercial operation Aircraft Impact Eliminate 1 O CFR 50.150 so Assessment new plants do not need to design for aircraft impact.

QA Revisions to Part 50 Appendix B to allow use of nationally and internationally recognized QA standards, like ISO-9001, to provide reasonable assurance that the component will perform its safety function, instead of demonstrating compliance with current criteria.

Part 21 Simplify Part 21 reporting so vendors provide-the information to the NRC and utilities.

Basis Benefit States understand the adequacy of their EP programs well enough to make valid certifications to the NRC.

Allows changes to units Enhanced efficiency of licensed under Part 52.

construction The aircraft impact Significant reduction in assessment has caused analysis, schedule and significant delays in design burden without a licensing and significant reduction in safety.

expense for designs that rely on robust barriers to prevent damage from a postulated aircraft impact.

The TSA has adequately protected against the potential hijacking of a large commercial aircraft.

NRC QA requirements Expands the supply chain hinder new suppliers entering the supply chain Reporting chain is not Clarifies the reporting clear and adds requirements and complexity to the process simpli!ies the process 53

ACCELERATING NRG REFORM INDUSTRY RECOMMENDATIONS J ULY 2025 Area Proposed Change Description Part 53 Reissue proposed Part 53 as part of the wholesale regulatory review rulemaking and adopt industry recommendations.

50.55a Eliminate the in-service inspection and testing program update requirement.

Revise 50.55a to remove NRG restrictions of American Society of Mechanical Engineers and Institute of Electrical and Electronics Engineers code cases and adopt the standards committee interpretations without exceptions.

Streamline code endorsement through an expedited rulemaking process.

Grant generic implementation for subsequent licensees after an alternative or relief request is approved for a code case.

Analytical Accelerate NRC review and Methods approval of advanced codes and methodologies submitted via topical reports.

10CFR110 The NRG should take all necessary steps to ensure that export licensing under 1 O CFR Part 110 is administered efficiently, predictably, and transparently.

Basis Benefit Part 53 is required by Modify Part 53 to provide NEIMA an efficient and effective regulation Consensus-based Streamlined licensing and standards reflect broad reduced costs through technical expertise, consistent, predictable promote safety through requirements.

proven engineering Efficiency and improved practices, and enable focus on safety-regulatory efficiency by significant issues, and aligning requirements enhanced credibility by with industry-accepted leveraging widely norms, reducing accepted, expert-vetted redundant review and customization.

standards.

NRC review of analytical Accelerates the adoption methods should be of improved analytical accelerated to enable methods by the industry faster licensee adoption of advanced methods.

This request is grounded By improving the in the same rationale as timeliness and certainty EO 14299 Section 8(b),

of Part 11 O licensing, the which directs DOE to NRC will help ensure U.S.

process Part 810 nuclear suppliers can applications within 30 compete on equal footing days in order to advance with state-owned U.S. national interests in enterprises that face few sustaining global nuclear comparable delays in energy leadership that securing export depends on a strong approvals.

commercial presence in international markets.

54

ACCELERATING NRC REFORM INDUSTRY REC0MMENDAT!ONS JULY 2025 Area Proposed Change Description International Expand regulatory assistance Regulatory activities in key markets and Assistance align this assistance with the overall U.S. government strategy to promote exports in near-and mid-term markets, including under intergovernmental agreements.

International Expand bilateral and Regulatory multilateral regulatory Cooperation cooperation activities to enhance the efficiency of licensing and export of U.S.

nuclear technologies in key global markets.

Non-Safety Reduce regulatory burden for Related non-Safety Related SSCs.

Special Treatments External Revise guidance and Hazards implementation practices for the Process for Ongoing

Basis Benefit Section 8 of EO 14299, The NRC is considered "Deploying Advanced the global gold standard Nuclear Technologies for for nuclear regulation and National Security,"

markets considering U.S.

focuses on promoting the technologies value export of U.S. advanced cooperation with the reactor technologies and NRC. Enhancingthis the NRC's Office of cooperation.will bolster International Programs U.S. nuclear export (OIP) helps to forge these efforts.

relationships.

Section 8 of EO 14299, Licensing by national "Deploying Advanced safety regulators Nuclear Technologies for represents a significant National Security,"

cost and market barrier to focuses on promoting the U.S. nuclear reactor export of U.S. advanced exports. By cooperating reactor technologies and with foreign regulators in the NRC's OIP plays an key markets for near-and important role in this midterm deployment, the area.

NRC can accelerate reviewtimelines and reduce licensing costs for U.S. exporters especially in markets where the regulator is less mature.

"Important to safety" and Enhances the safety "safety-significant" SSCs focus of the regulatory that do not rise to the framework.

safety-related threshold should receive significantly less regulatory oversight compared to SR SSCs.

Treatment should be at the owner's discretion unless a performance issue is identified.

For new reactor design, treatment should only be required if cost-benefit criteria are satisfied.

The current A transparent hazard implementation of analysis improves POANHI does not 55

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JULY 2025 A

Proposed Change B.

8 t*t rea D

as1s ene 1 escnpt1on Assessment of Natural Hazard Information (POANHI) to achieve the objectives of SRM for SECY-16-0144 while ensuring the process is efficient, transparent, ands leverages available and relevant data. Only credible risks should be evaluated.

leverage all available data and has produced conclusions without the necessary stakeholder engagement.

predictability for all stakeholders.

56

ACCELERATING NRG REFORM INDUSTRY RECOM!"ENDATIONS JULY 2025 REFORM NRC LICENSING STREAMLINE LICENSE RENEWAL REGULATIONS Executive Summary Eliminates duplicative work and retains a focus on safety Introduce a performance-based audit/inspection path in lieu of application review Focus reviews on safety-critical programs; eliminate duplication Cut renewal time and staff hours by greater than 50%

Outcomes Establishes a more efficient pathway for renewing operating reactor licenses Directs industry and NRC resources to elements of the renewal process that demonstrate safety Re[ieves significant administrative.investment associated with the application process Eliminates duplication of effort and redundant processes Why This Matters Achieving a nuclear power capacity of 400 GW in the U.S. by 2050 will not be attainable without the continued operation of the current fleet. A performance-based audit/inspection option will provide a more focusM pathway to license renewal approval.

Proposed Timing and Method Immediately begin guidance development on how an audit/inspection-centric approach could facilitate much more streamlined license renewal approvals for operating reactors. Use exemptions as needed and codify the changes in the wholesale regulation review with a completion date of Novemqer 2026.

Immediate implementation of removing the term limits on SNM facility licenses through exemptions and codify the changes in the wholesale regulation review with a completion date of November 2026.

57

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JU L Y 2025 References and Background On May 30, 2025, NEI sent the NRC a letter 11 detailing the justification for modernizing the regulatory framework governing the licensing terms of certain SNM facilities Specific Recommendations Area Proposed Change Basis Benefit Description Operating Revise the following Initial license renewal Focuses both industry Reactor Alternate regulation and associated approvals establish the and NRC resources on Renewal Path guidance as needed:

framework for managing aging.

the most important

1) 10 CFR 54 Subsequent renewals should aspects of continued focus on the effectiveness of operation.

programs and any emergent gaps.

LR/SLR Aging Revise NRC's policy and The Maintenance Rule is a Reduces significant Management processes to increase proven, risk-informed, site resource Program efficiency by allowing performance-based expenditure imposed Implementation augmented Maintenance requirement that significantly by implementing Rule activities to fulfill the overlaps the scope of license separate programs to requirements of the renewal components subject ensure structures, applicable overlapping to aging management. Its systems, and Aging Management activities should be fully components are Programs in the period of leveraged and credited toward adequately extended operation.

meeting aging management maintained.

requirements associated with license renewal.

SNM Facility Revise the following The facilities already undergo Removing Renewals regulations and regular inspections and unnecessary associated guidance as continuous compliance administrative actions needed:

monitoring that are supported enables placing

1) 10 CFR 40 by thorough annual Integrated resources on higher-Safety Analysis update value licensing and

2) 10 CFR 70 requirements.

oversight activities.

11 Letter from Greg Core (NEI) to U.S. NRC ADVANCE Act Lead, "NEI Input on Modernizing License Terms for SNM Facilities," May 30, 2025, ML25155B238.

58

ACCELERATING NRC REFORM INDUSTRY RECOM"lENDAY:ONS J ULY 2025 REFORM NRC LICENSING ENABl-E MORE DIGITAL l.&C DEPLOYMENT WITH AND WITHOUT PRIOR NRC APPROVAL Executive Summary Enables faster deployment of modern technology while preserving safety Establish clear, risk-informed regulatory guidance that will streamline licensing of Dl&C systems requiring NRC approval Limit NRC licensing reviews to digital l&C systems that present credible risks Expand the use of Dl&C qualitative assessments Eliminate the default assumption that common cause failure {CCF) cannot be addressed by a licensee without prior NRC approval Improve the ability of licensees to implement modern, reliable technology without costly, inefficient NRC review Approve industry guidance document, Outcomes Improve the efficiency of NRC licensing reviews Accelerate the deployment of Dl&C systems Enable a modern, risk-informed approach to licensing Dl&C Why This Matters

-Existing.l&C protection and control systems are reaching obsolescence and increasingly subject to random failures due to aging. Implementing Dl&C systems can enhance plant safety and reliability through increased access to plant data and self-diagnostic capabilities. However, NRC licensing guidance restricts a licensee's ability to implement Dl&C technology in protection and engineered safeguards applications without prior approval due to an assumption that Dl&C systems have embedded CCFs. This assumption restricts licensees from making certain changes to systems without NRC approval under 10 CFR 50.59 so license amendments must be submitted, unnecessarily impeding digital modernization. Clear, risk-informed guidance must also be developed to streamline licensing of Dl&C systems that require NRC approval.

59

A CELERATIN NRC REFORM I NDU STRY REC OM MENDATIO N S JULY 2025 Proposed Timing and Method Immediate implementation through expedited policy and process improvements.

References and Background The NRC published RIS-2002-22, Supplement 1, which provides for a means to qualitatively assess digital CCF; however, the document restricts Reactor Protection System (RPS) and Engineered Safety Actuation System (ESFAS) digital modifications from its use.

Additionally, the Commission approved a revised Dl&C CCF policy, SRM-SECY-22-0076, which allows for risk-informed processes to address digital CCF in addition to the prescriptive policy requiring diversity (SRM-SECY-93-087). The new policy and its associated staff review guidance relies on an analysis that assumes that a CCF exists within the Dl&C system.

Specific Recommendations Area Proposed Change Description Basis Benefit Licensing Revise RIS-2002-22, Supplement 1 to remove A digital CCF is Allows more Process the restriction on RPS and ESFAS.

considered a beyond efficient Remove Dl&C CCF policy (SRM-SECY design basis event and deployment of 0076) and revise staff review guidance may not present a Dl&C systems.

(NUREG-0800, Chapter 7, Branch Technical credible, realistic risk.

Establishes a Position 7-19) to remove the assumption that clear, risk-digital CCF exists in Dl&C systems in informed Dl&C defense-in-depth analysis. Allow for risk-approval informed approach to determine if a digital process.

CCF concurrent with a Design Basis Event is a credible, realistic risk using CCF likelihood consistent with other BDBEs.

Approve NE! 20-07 to license Dl&C systems where digital CCF presents a credible, realistic risk.

Licensing Remove 1 0 CFR 50.55a(h) which 10 CFR 50, Appendix A Allows the use Process incorporates by reference outdated safety General Design Criteria of modern criteria standards. Instead, rely on 10 CFR provides adequate standards for 50, Appendix A General Design Criteria requirements for the the design of (GDC).

design of protection and Dl&C systems.

reactivity control systems, including CCF.

60

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JULY 2025 REFORM NRC LICENSING MODERNIZE OPERATOR LICENSING PROGRAM Executive Summary Modernize requirements for issuing, maintaining and utilizing operator licenses Remove duplication and streamline operator licensing program requirements Focus NRC resources on oversight of examination administration Increase regulatory flexibility while maintaining accreditation requirements Standardize operator licensing by reactor type Outcomes Eliminates duplicative requirements Leverages accreditation and reduces process overlap Enables improved timelines for new reactor applicants Why This Matters Enhances the efficiency of the process while maintaining reasonable assurance of adequate protection standard.

Proposed Timing and Method Immediate implementation through expedited process improvements, and by exemption, where necessary, until completion of the wholesale regulation review rulemaking by November 2026.

61

ACCELERATING NRC REFORM I ND USTRY RECOMMENDATIONS

.I L Y 2025 References and Background NUREG-1021, Rev. 12, "Operator Licensing Examination Standards for Power Reactors" RG 1.134, Rev. 4, "Medical Assessment of Licensed Operators or Applicants for Operator Licenses at Nuclear Power Plants" RG 1.149, Rev. 4, "Nuclear Power Plant Simulation Facilities for Use in Operator Training, License Examinations, and Applicant Experience Requirements" Proposed Rule: Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors DRO-ISG-2023-01, Operator Licensing Programs Draft Interim Staff Guidance 1 O CFR 53 Specific Recommendations A

Proposed Change B

B t*

rea O

asIs ene It escr1ptIon Operator Modify the following Operator licensing Prevents need for Licensing regulations:

decisions should be exemption which could

1)

§ 50.120(b)(1 )(i), (ii) to fo"cused on written exam delay new builds coming eliminate 18-month and simulator operating online.

requirement test performance.

Eliminates overly

2)

§ 50.54 (m)(2)(iv) to Plant walkthrough and restrictive guidance for eliminate direct redundant requirements oversight.

supervision of fuel should be eliminated.

Enables senior operators handling activities Current regulatory to oversee fuel handling

3)

§ 55.21 to include requirements do not credit activities from the other medical technology advancements Control Room or other professionals qualified used in industry training location.

to perform medical programs.

Reduces NRC staff exams burden allowing focus on

4)

§ 55.40(b) to also allow oversight of exam administration and facility licensees to elimination of proctor and grade unnecessary activities to operating tests make an operator license

5)

§ 55.45(b) eliminate decision.

reference to plant Proficiency requirements walkthrough are part of licensee

6)

Revise§ 55.46 and training programs.

update RG 1.149to Eliminates duplication expand the allowable simulation facilities with other regulations that can be used for (e.g., part 26).

training, evaluation

62

ACCELERATING NRC REFORM INDUSTRY RECOMMENDAT'.ONS JULY 2025 Area Proposed Change Description and administration of operating tests.

7)

Revise§ 55.47(a)(1) and update NUREG-1021 to eliminate or extend the 2-yeartime limit to allow for a waiver of examination requirements for an operator previously licensed at the same facility.

8)

§ 55.53(b) to allow license by reactor type

9)

§ 55.53(c) to include reactor type and qualified to operate 1 O) 55.55(a) to eliminate the 6-year expiration date Eliminate the following regulations:

1)

§ 55.53 (e), (f)(2), (g)

2)

§ 55.53 (j)(k) for power reactors Streamline associated regulatory guidance including: NUREG-1021 rev.

12, "Operator Licensing Examination Standards for Power Reactors."

Use of Shift Revise Commission Policy Technical Advisor Statement 50 FR 20892, May 21, 1985, "Engineering Expertise on Shift," to increase flexibility when utilizing non-degreed Senior Reactor Operators (SROs)/Shift Managers to fill the dual role when completing systematic approach to training (SAT)

Basis Benefit Eliminates overly restrictive simulation facilities requirements and reduces NRG staff burden when assessing approved simulation facilities.

Credit mature training Allows greater flexibility programs focused on in fulfilling the engineering principles and independent STA role and accident mitigation and enhances operational analysis.

efficiency while maintaining robust engineering expertise on shift.

63

ACCELERATING NRC REFORM I NDUSTRY RECO M MENDATION',

JU L Y 2025 Area Proposed Change Description based training requirements.

Use of NRC Eliminate the need for NRG Knowledge/ Ability KIA catalogs to simplify (K/A) Catalogs operator licensing exam writing.

Risk-informed Develop an operator Operator licensing framework for Licensing advanced technologies that is reflective of risk profile.

Include a pathway to generally licensed reactor operators (GLROs) informed by the Part 53 Proposed Rule and NEI comments on the Proposed Rule. It may require a legislative change.

Basis Benefit Credit mature systematic Streamlines the operator approach to training-licensing exam based training programs.

development process while maintaining training effectiveness and regulatory oversight NRC's risk-informed Eliminates unnecessary approaches should be requirements for new extended to operator reactor operating license licensing.

applicants.

64

ACCELERATING NRG REFORM INDUSTRY RECOM'."\\ENDATIONS I ULY 2025 REFORM NRC LICENSING REFORM LICENSE DURATIONS Executive Summary Reduces duplicative work, lowers cost, and ensures sustained reactor operation Eliminate expiration dates for reactor permits, licenses, and design approvals (including CPs, OLs, ESPs, SDAs, DCs, COLs, CoCs and LWAs) through legislative changes, where needed.

Utilize exemption authority to renew early site permits until rulemaking is complete Outcomes Eliminates unnecessary administrative effort and cost associated with license renewal Leverages NRC oversight activities to ensure ongoing license compliance Frees up NRC licensing resources to focus on other high priority resources for deployment of new and advanced reactors Why This Matters Expiration dates and associated renewal processes require unnecessary, time-intensive, and costly engagement with the NRC. These interactions and associated costs are unnecessary in light of ongoing NRC oversight.

License renewal applications divert NRG resources from a focus on licensing new and advanced reactors and create unnecessary work.

Proposed Timing and Method Codification into the wholesale regulation review with a completion date of November 2026.

65

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS JULY 2025 References and Background In May 2025, 12 NEI submitted a white paper describing how removing the license terms for special nuclear material facilities aligns with the spirit of Section 505 of the ADVANCE Act. No action has been taken in response to this paper.

SECY-22-0052, 13 "Proposed Rule: Alignment of Licensing Processes and Lessons Learned from New Reactor Licensing," proposed numerous changes to regulations to ensure consistency and promote efficiency in new reactor licensing. Part of this proposed rulemaking was to eliminate the expiration date for DCs recognizing the unnecessary regulatory burden without commensurate safety benefit. In November 2024, 14 the Commission approved select items of the proposed rulemaking that did not address the expiration of DCs. It did however, approve extending the duration of manufacturing licenses to 40 years.

COMDAW-24-0001, 15 "Revising the Duration of Design Certifications," requested the Commission to separate the question of DC duration from SECY-22-0052 into a stand-alone voting issue. In November 2024, 16 the Commission approved extending the duration of design certifications to 40 years.

Specific Recommendations A

Proposed Change 8

B t*

rea D

. t*

as1s ene 1t escnp 10n Reactor and Certificate of Compliance Duration 17 Revise§ 54.31 to eliminate the license renewal duration Revise§ 50.51 to eliminate the license duration NRC oversight ensures ongoing compliance with regulatory requirements, and a specific license renewal application offers no safety benefit. Other regulatory processes ensure safety-significant regulatory Modernizes regulatory process to be performance-based and specific to reactor design.

Revise § 52.104 to eliminate the license duration after 103(g) finding Supports NRC focus on industry efforts to license and deploy 12 Letter from NEI to U.S. NRC ADVANCE Act Lead, "NEI Input on Modernizing License Terms for SNM Facilities," May 30, 2025, ML251558238.

13 SECY-22-0052, "Proposed Rule: Alignment of Licensing Processes and Lessons Learned from New Reactor Licensing (RIN 3150-Al66)," June 6, 2022, ML21159A055.

14 SRM-SECY-22-0052, "Staff Requirements - SECY-22-0052 - Proposed Ruel: Alignment of Licensing Processes and Lessons Learned from New Reactor Licensing (RIN 3150-Al66)," November 20, 2024, ML24362A003.

15 COMDAW-24-0001, "Revising the Duration of Design Certifications," June 4, 2024, ML24156A066.

16 SRM-COMDAW-24-0001, "Staff Requirements - COMDAW-24-00001 - Revising the Duration of Design Certifications," November 14, 2024, ML24319A209.

17 It is recognized that if these recommendations are adopted they may impact related recommendations to streamline license renewal.

66

ACCELERATING NRC REFORM INDUSTRY RECOM M ~NDATIONS J uLY 2025 I

Area Proposed Change Description Revise§ 52.26 and§ 52.33 to eliminate ESP duration Revise§§ 52.173 / 52.181 to eliminate manufacturing license duration Revise§§ 72.3, 72.42(a),

72.212(a)(3), 72.230(b), 72.238, and 72.240 to eliminate references to license duration Design Revise §§ 52.55 and 52.61 to Duration eliminate expiration of design certifications Revise§ 52.147 to eliminate expiration of standard design approvals Exemption Issue exemptions to extend ESP Authority terms,eltherbyexpedlted action on applicant exemption requests or through the exercise of the NRC's sua sponte exemption authority. NRC should use its exemption authority under§§ 50.12, 52. 7 to address an outdated regulation

(§ 52.29) not required by statute or necessary as a practical matter.

License Revise § 70.38 to remove license Duration expiration for special nuclear material (SNM) licenses that have an integrated safety analysis under§ 70.62.

License Revise § 72.238 to eliminate Duration expiration of dry cask storage certificates of compliance

Basis Benefit changes may be imposed, if new reactors and needed.

designs.

Updates regulations to reflect performance, operating experience, and current practices of the nuclear industry.

Certified and standard Ensures ongoing designs do not require availability of NRC-ongoing oversight and approved reactor maintenance like an designs and operating facility. As such, eliminates costly any duration for design applications to validity is administrative.

maintain validity of the Other regulatory processes design.

ensure safety-significant regulatory changes may be imposed.

Exemptions are already Provides scalable and allowed under NRC rules; consistent path to the ESP 20-yearterm and reduce burden update requirement are not tied to any statutory requirement; this would be consistent with N RC's allowing CP extensions.

Facilities are inspected by Because a license NRC on a defined frequency renewal is not that confirms compliance.

required, the NRC staff can be directed to other areas.

Licensees could save between $1 M--$1.5M per license renewal.

Changes to the safety basis Reduces are communi.cated through administrative, low routine FSAR updates. Aging value activity, and management is continually allows resources to be 67

ACCELERATING NRC REFORM INDUSTRY RECO MMEN DATIO NS JULY 2025 Area Proposed Change Description License Revise § 72.42 to remove license Duration expiration dates for licensees that have complied with requirements for time limited aging analyses and have an aging management program

Basis Benefit addressed through oversight reallocated to higher and corrective action value work.

programs.

Aging management is Refocuses on and continually addressed reallocates resources through oversight and to safety-significant corrective action programs.

issues.

68

ACCELERATING NRG REFORM INDUSTRY RECOMMENDATIONS

,ULY 2025 REFORM NRC LICENSING OPTIMIZE REACTOR RESTARTS Executive Summary Optimize NRC inspection and licensing processes for reactor restarts Deliver fastest path to new nuclear on the grid Streamline restart inspections Use historical performance and existing data Institutionalize lessons learned Outcomes Efficient and rapid licensing with no delays in return to operation Consistent and predictable implementation of the restart process across licensees.

NRC inspection and licensing efforts are limited to new, safety-significant issues Effective Restart Panel interaction Elimination of low-value work to NRC and licensee Why This Matters Reactor restarts are the fastest and most economical way to achieve new nuclear power on the grid Proposed Timing an_d Method Immediate implementation: Institutionalize NRC policy, guidance, and practices to maximize the NR.C's effectiveness in enabling reactor restarts.

o Revise Inspection Manual Chapter 2562, "Light-Water Reactor Inspection Program for Restart of Reactor Facilities following Permanent Cessation of Power Operations" References and Background Inspection Manual Chapter 2562 (ML25017A231), "Light-Water Reactor Inspection Program for Restart of Reactor Facilities following Permanent Cessation of Power Operations," April 24, 2025

69

ACCELERATING NRC REFORM INDUSTRY RECO M MENDATIONS JULY 2025 Holtec Letter to NRC (ML23072A404) "Regulatory Path to Reauthorize Power Operations at the Palisades Nuclear Plant" March 13, 2023 Constellation Letter to NRC (ML24310A104) "Regulatory Path to Reauthorize Power Operations" November 4, 2024 (Three Mile Island, Unit 1)

70

ACCELERATING NRC REFORM INDUSTRY RECOMM ENDATI ONS JULY 2025 REFORM NRC LICENSING ALIGN TRANSPORTATION REGULATIONS Executive Summary Aligns NRC's rules for regulating the transportation of radioactive material with international and domestic standards and improves efficiency Modify the regulations to align with international shipping standards Eliminate duplication of requirements with Department of Transportation (DOT)

Simplify Certificate of Compliance renewal procedures Outcome More efficient transportation licensing process Why This Matters The transport of radioactive materials is an international endeavor. Fuel for operating and advanced reactors originates and can be processed in many parts of the world. Aligning NRC requirements with international standards provides a more efficient and transparent process.

Proposed Timing and Method Complete current rulemaking (SECY-24-0069), immediately revise guidance and revise 1 O CFR Part 71 as part of the wholesale regulation review rulemakingwith a completion date of November 2026 and update relevant guidance.

DOT initiated separate regulatory reform rulemakings in June 2025 to increase government efficiency, and NRC's wholesale regulation review rulemaking should proceed independently.

71

ACCELERATING NRC REFORM INDUSTRY RECOMMENDAT ON8 JUL'( 2025 References and Background IAEA safety standards are updated at most ~very two years, driven by recommendations for changes by IAEA member states. Upon the completion of that process, the updated standards are

_adopted to varying degrees by member states. Similarly, the NRC and the U.S. DOT cooperatively perform rulemakingto align with the new standards. The most recent rulemaking effort by the NRC to harmonize with IAEA's SSR-6 began in 2016. Thorough documentation supporting that rulemaking is available via the staff's submission of the final rule in 2024 (SECY-24-0069 18). NEI submitted comments on the draft rule in 2022. 19 Not all comments from industry were incorporated into the final rule.

Specific Recommendations Area Proposed Change Basis Description Regulatory Institutionalize transportation Unnecessarily long Modernization rulemaking schedule of 24 rulemaking efforts months to maintain alignment introduce uncertainty and with international radioactive the potential for domestic material transportation safety regulations to significantly standards trail international standards Regulatory Eliminate 1 O CFR 71.5(a)(1)

Remove the guidance Modernization and (2) contained in the rule to Regulatory Guide, if necessary Regulatory Eliminate the first sentence of This regulation requires a Modernization 10 CFR 71.S(b) licensee to follow DOT regulations even if the DOT regulations are not applicable to a shipment Regulatory Align lifting and tie-down 10 CFR 71.45(b)(3) already Modernization standards with international provides the necessary standards requirement for tie-downs Eliminate 10 CFR in the international standard 71.45(b)(1) 18SECY-24-0069: https://www.nrc.gov/docs/ML2408/ML2408M1Z0.html 19 https://www.nrc.gov/docs/M L2233/ML22333B032. pdf

Benefit Increased efficiency in the international business of radioactive material transportation Increased flexibility of transportation activities Removal of unnecessarily burdensome requirements will increase efficiency in packaging design and approvals Removal of unnecessary requirements will increase efficiency in packaging design and approvals 72

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS J U LY 2025 Area Proposed Change Description Regulatory Align general license limits Modernization and packaging requirements for fissile material with international standards Revise 1 O CFR 71.22(c),

(d), (e) to align with Paragraphs 674 & 675 of IAEA SSR-6, 2018 edition Regulatory Clarify Certificate of Modernization Compliance (CoC) renewal procedures by removing discussion of a "consolidated application."

Delete 10 CFR 71.38(c)

Basis Benefit International standards Alignment with provide appropriate international standards regulations for general will enhance regulatory licenses for fissile material efficiency of radioactive transportation material transport The concept of a Increased efficiency in cons'olidated application is renewing CoCs too vague and can introduce inefficiencies depending on the interpretation 73

ACCELERATING NRC REFORM INDUSTRY Rl'COMMENDATIONS J U L Y 2025 REFORM NRC LICENSING REFORM THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS Executive Summary Shrinks licensing timelines and improves resource use while preserving safety Increase ACRS accountability and limit ACRS scope to novel, safety-significant technologies Impose firm timelines; avoid duplicative reviews of known designs Use ACRS as expert advisors Outcome Immediate reduction in licensingtimelines Increased licensing predictability Effort reset to levels that provide reasonable assurance of adequate protection Why This Matters Nuclear safety is our number one priority, but safety is not increased by redundant reviews.

Focusing ACRS reviews on truly safety-significant issues will lead to faster, more predictable licensing actions.

Proposed Timing and Method Immediate implementation through Commission direction. Amend regulations regarding ACRS hearings and reports, to reflect the statutory minimum requirements, and use exemptions as necessary until the rulemaking is final. Make any necessary amendments to the ACRS Charter.

74

ACCELERATING NRC REFORM 1:-JDUSTRY RECOMMENDA1"!0NS jLJLY 2025 References and Background AEA Sec. 29 (42 USC 2039) - "There is established an Advisory Committee on Reactor Safeguards consisting of a maximum of fifteen members appointed by the Commission for terms of four years each. The Committee shall review safety studies and facility license applications referred to it and shall make reports thereon, shall advise the Commission with regard to the hazards of proposed or existing reactor safety standards, and shall perform such other duties as the Commission may request. One member shall be designated by the Committee as its Chairman. The members of the Committee shall receive their necessary traveling or other expenses while engaged in the work of the Committee. The provisions of section 2203 of this title [regarding outside compensation] shall be applicable to the Committee."

AEA Sec. 182b. (42 USC 2232) - Review of applications by Advisory Committee on Reactor Safeguards; report: "The Advisory Committee on Reactor Safeguards shall review each application under section 2133 or section 2134(b) of this title for a construction permit or an operating license for a facility, any application under section 2134(c) of this title for a construction permit or an operating license for a testing facility, any application under subsection (a) or (c) of section 2134 of this title specifically referred to it by the Commission, and shall submit a report thereon which shall be made part of the record of the application and available to the public except to the extent that security classification prevents disclosure."

Specific Recommendations A

Proposed Change 8

8 t*

rea O

. t*

as1s ene 1t ACRS escnp 10n Reduce scope to statutory minimum.

Define what is "truly novel or noteworthy" per the EO.

Implement timelines for reviews. ACRS report should be in parallel with, not series to the NRC Final Safety Evaluation Report.

Improve communication and engagement between NRC staff and ACRS.

Improve ACRS operations and management.

ACRS reviews are lengthy and often redundant to staff reviews, representing a high administrative burden on the industry for low safety value.

ACRS reviews should be reserved for truly novel or noteworthy aspects of new reactors.

Eliminates low-value reviews and provides for faster, more safety-focused and predictable licensing actions and lowers review fees.

75

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIO N<;

JULY 2025 REFORM NUCLEAR SECURITY REGULATION UPDATE THE DESIGN BASIS THREAT Executive Summary Re-baseline the Design Basis Threat (DBT) and adversary characteristics to reflect credible threats Align with protection levels used across the nation's critical infrastructure Limit DBT scenarios to realistic tactics and durations and discontinue the assumption of an omniscient insider Account for technological advancements in post-9/11 counterterrorism and intelligence capabilities Outcomes Optimized defensive strategy that ensures reasonable assurance of adequate protection Licensees and NRC will focus on realistic and more probable threats Critical resources will not be diverted to low-impact security requirements and non-essential activities Why This Matters A DBT limited to realistic and credible threats ensures that security resources are used effectively and protect actual vulnerabilities. By this change and by crediting timely law enforcement response, facilities can implement practical and effective security programs, aligning nuclear energy with the rest of the critical infrastructure.

Proposed Timing and Method Immediate implementation:

o Rescind NRC DBT Order and revise Regulatory Guide 5.69 o

Use enforcement discretion and exemptions to effect immediate changes where appropriate.

o Issue Security Bounding Time (SBT) guidance within three months

76

ACCELERATING NRC REFORM INDUSTRY RECOMMC:NDAYIONS JULY 2025 Where changes to the regulations are needed, integrate rulemaking into the wholesale regulation review with a completion date of November 2026.

References and Background AEA1954,Sec.170E NRC DBT Order April 29,. 2003 (SECY 06-0219) 10 CFR 73.1 Regulatory Guide 5.69 DOE O 470.3C Change 2, February 23, 2024 Specific Recommendations Area Proposed Change Description Basis Benefit DBT Revise the Design Basis Threat 10 CFR 73.1 Regulatory Guide 5.69 Rescind the DBT Order NRC DBT Order April 29, 2003 Revise 10 CFR 73.1 and RG 5.69 to reflect credible threats and adversary tactics, credit timely law enforcement response, limit proposed attack duration and align with modern security practices used across critical infrastructure. Discontinue the assumption of an omniscient insider.

The current DBT does Unnecessary not reflect credible burden is threats which divert reduced, and attention and resources away from safety-and security-significant areas.

innovation is not inhibited.

77

ACCELERATING NRC REFORM IN D USTRY RECOMMENDATIONS J U LY 2025 REFORM NUCLEAR SECURITY REGULATIONS REDESIGN FORCE-ON-FORCE INSPECTION PROGRAM Executive Summary Eliminate current model for NRC-led force-on-force (FOF) exercises for operating plants Implement a licensee led force-on-force process Focus the force-on-force exercise on credible threats and tactics Outcomes Focus on reasonable assurance of adequate protection Efficient and performance-based security framework and oversight process Why This Matters The NRC-led FOF exercise inspection program exceeds what is required for reasonable assurance of adequate protection and demands extensive coordination, staffing, and resource expenditure from both NRC and licensees. By continuing to execute and inspect exercises separately, NRC imposes unnecessary burden when robust, regulator-observed licensee-led exercises would meet current statutory requirements.

Proposed Timing and Method Immediate implementation through expedited process improvements, and exemptions,_where needed, until the wholesale regulatory review rulemaking is completed by November 2026.

78

ACCELERATING NRG REFORM INDUSTRY RECOMMENDA,.IONS JULY 2025 References and Background SECY-99-024 (1999)- Recommends replacing NRC-led OSRE with licensee~led evaluations.

[ML003751815]

SECV-01-0023 (2001)- Describes how 9/11 paused near-final rulemakingto eliminate NRC-led FOF. [ML010310326]

SECY-14-0088 (2014)- Formal industry request for NRC to observe (not lead) FOF exercises.

[ML14139A231]

SECY-16-0073 & SRM - Commission orders legal analysis of industry's licensee-led proposal.

[ML16109A200] & [ML16279A345]

SECY-17-0100 (2017)- NRC proposes pilot for enhanced licensee-led inspection model.

[ML17223A279]

NRC OIG Audit OIG-09-A-12 (2009)- Endorses independent adversary teams as mitigation for bias. [ML092110644]

March 31, 2025, Industry Lette*r-Advocates for licensee-developed scenarios and full transition.

Specific Recommendations Proposed Change Area Basis Benefit FOF Description Eliminate NRG-led triennial FOF inspection (IP 71130.03). NRG will instead oversee licensee-led FOF exercises as the means to evaluate security.

readiness and satisfy the requirements of Section 170D of the AEA.

NRC's FOF program is duplicative and resource intensive. Licensees already perform regular FOF drills, which the NRG evaluates, satisfying the intent of AEA §170D without a separate NRG-led event.

Past Commission decisions and industry petitions have supported a licensee-driven model as maintaining security effectiveness.

Removing the NRG-led exercise eliminates overlapping evaluations and potential inconsistencies between NRG-led and licensee-led exercise results. NRG oversight, along with independent adversary teams, will ensure no loss of rigor or objectivity in testing security defenses.

Improves efficiency: Frees up NRG inspectors and advisors from planning and executing mock attacks, saving thousands of labor hours and allowing a focus on other high priorities.

Reduces industry burden while ensuring robust security programs: Licensees avoid the disruptive preparation for NRG-led exercises (which temporarily doubles security staff and strains resources) in addition to their own drills. The same vulnerabilities are identified and corrected through NRG-monitored licensee exercises, with real-time NRG feedback.

Modernizes Oversight: Aligns.

security exercise oversight with NRC's performance-based 79

ACCELERATING NRC REFORM I NDUSTRY RECOMMENDATIONS JULY 2025 Proposed Change Area Basis Benefit Description

regulatory philosophy and is consistent with how emergency preparedness exercises and DOE security tests are managed. Overall, the change maintains reasonable assurance of protection against credible threats 80

ACCELERATING NRC REFORM INDUSTRY ~ECOMMENDATIONS JULY 2025 REFORM NUCLEAR SECURITY REGULATION REMOVE PRESCRIPTIVE SECURITY REQUIREMENTS Executive Summary Eliminate prescriptive and outdated requirements to enable flexible, risk-informed protection programs consistent with other critical infrastructure.

Modernize security regulations and guidance and eliminate obsolete mandates Abide by the reasonable assurance standard for prevention of significant core damage, spent fuel sabotage Maximize use of and reliance on existing on and off-site resources in protective strategies Outcomes Provides reasonable assurance of adequate protection Eliminates outdated and obsolete requirements Eliminates low value requirements to free up resources Improves coordination with law enforcement Why This Matters Prescriptive requirements, often rooted in legacy assumptions, divert licensee and NRC resources toward compliance activities with limited security benefit. A risk-informed, performance-based framework will enable licensees to focus resources on areas that have a demonstrable impact on safety and security outcomes. Reducing unnecessary complexity and administrative burden also streamlines processes so resources can be directed toward higher-value efforts, such as implementing innovative technologies and enhancing coordination with external organizations.

Proposed Timing and Method Immediate implementation through expedited process improvements, and exemptions, where needed, until the wholesale regulation review rule making is completed by November 2026.

1l1

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS J ULY 2025 References and Background Staffing, credit for site capabilities, and external resources (e.g. LLEA), equipment/testing, and legacy/outdated regulations addressed in 10 CFR 73.55 Security Training addressed in 10 CFR Appendix B Proposed Rule: Alternative Physical Security Requirements for Advanced Reactors (APSRAR)

Specific Recommendations Area Proposed Change Basis Benefit Description Staffing Armed Responders Prescriptive Enables site Eliminate§ 73.55(k)(5)(ii) requirements should be specific, right-sized OCA Searches replaced with a defensive strategy.

Eliminate§ 73.55 (h)(2)(iii) performance-based approach.

Last Access Control Revise§ 73.55 (g)(1 )(i)(E}

Legacy/Outdated High Assurance Modernizes the security Removes obsolete Revise§ 73.55(b)(1) regulations and requirements.

Vital equipment and Vital Areas eliminates obsolete Eliminate§ 73.55 (e)(8)(i)(C),

mandates.

(e)(8)(v), (e)(9)(i), (e)(9)(ii),

(e)(9)(iii), (e)(9)(iv), (e)(9)(v)

(e)(9)(v)(A), (e)(9)(v)(B),

(e)(9)(v)(C), (e)(9)(v)(D),

(e)(9)(vi), (e)(9)(vi)(A),

(e)(9)(vi)(B), (g)(1 )(i)(D), (g)(4),

(g)(4)(i), (g)(4)(ii), (g)(6)(i),

(g)(7)(i), (g)(7)(i)(E), (g)(7)(ii),

(i)(5)(v)

Illumination Revise§ 73.55(i)(6)(i), (i)(6)(ii)

Isolation zone Revise§ 73.55(e)(7)(i)(B),

(e)(7)(ii)

Alarm Stations Eliminate§ 73.55(i)(4)(iii)

Credit for site Target Sets Would add credit for Clear rules enable capabilities, and Revise§ 73.55(f)(1 ), (k)(8), (k)(9)

LLEA to regulations.

defense-in-depth external resources via credit for

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ACCELERATING NRC REFORM

JNDUSTRY RECOMMENDATIONS J ULY 2025 Area Proposed Change Description (e.g. local law enforcements (LLEA)

Maintenance, testing, Testing Frequencies and calibration Revise§ 73.55(n)(2), (n)(4),

frequencies (n)(5), (n)(6)

Independent Spent ISFSI Security Requirements Fuel Storage Revise§ 73.51, § 72.212 Installation (ISFSI)

Appendix B Security Training Revise Part 73, Appendix B APSRAR Finalize the Proposed Rule:

Alternative Physical Security Requirements for Advanced Reactors while addressing NEI comments.

Basis Benefit

.operators and LLEA.

Testing Frequencies are Optimized testing overly prescriptive and and maintenance add additional activities frequencies that that are not aligned with ensure proper system or component equipment failure data.

performance.

Currently, ISFSI security Enhances the rules differ by license clarity and and should be consistency of the consistent. Replace regulations.

reference to 73.55 with 73.51 in 72.212 to align all lSFSI se_curity requirements.

Modernize training Training requirements.

requirements that ensure proficient responders with optimized capabilities.

Right-size security Enables site requirements for new specific, right-sized reactors.

defensive strategy.

83

ACCELERATING NRC REFORM INDUSTRY R!;COMMENDATICNS JULY 2025 REFORM NUCLEAR SECURITY REGULATIONS RIGHT-SIZE CYBERSECURITY STANDARDS Executive Summary Align cyber security standards to the reasonable assurance standard for prevention of significant core damage and spent fuel sabotage.

Modernize cyber security requirements:

o Remove low risk requirements o

Credit physical security programs and insider threat mitigation programs o

Focus protections on assets directly related to the prevention of significant core damage, spent fuel sabotage and prevention of significant reactivity changes (per FERC/NERC requirements with NRC as the sole regulator under FERC-NRC MOU)

Outcomes Refocuses requirements on providing reasonable assurance of adequate protection Eliminates low value work and streamlines processes, freeing up resources for innovation Enables a performance-based program crediting the site physical security program and defense-in-depth Why This Matters Current cybersecurity regulations are misaligned with core physical security objectives and based on an outdated characterization of cyber threats, creating a disconnect that has driven unnecessary burden since 2009. This misalignment, compounded by overly conservative guidance, has led to low-significance inspection findings and excessive unnecessary compliance obligations.

Proposed Timing and Method Immediate implementation via expedited process improvements, and where changes to the regulations are needed, via exemption until completion of the rulemaking. Integrate rulemaking into the wholesale regulation review with a completion date of November 2026.

84

ACCELERATING NRG REFORM INDUSTRY RECOMMENDATIONS JULY 2025 Refere*nces and Background 10 CFR 73.54, "Protection of Digital Computer and Communication Systems and Networks" Regulatory Guide 5.71, Revision 1, "Cybersecurity Programs for Nuclear Power Reactors" Regulatory Guide 5.69, "Guidance for the Application of the Radiological Sabotage Design-Basis Threat in the Design" NEI 08-09, Revision 6, "Cyber"Security Plan for Nuclear Power Plants" Specific Recommendations Area Proposed Change Description Basis Benefit Modernize cyber Implement realism into nuclear Current regulatory Focus NRG oversight security cyber security programs, focusing on requirements and and regulatory commitments to digital assets and controls necessary guidance are not requirements on eliminate low risk to prevent radiological sabotage performance-based protecting digital requirements against a credible threat. Including and exceed assets associated Align cyber leveraging defense-in-depth and reasonable with preventing security with DBT developing flexible performance-assurance of radiological objectives based program requirements.-

adequate protection sabotage.

Reduce overly conservative guidance standard.

and commitments in RG 5. 71, NEI NRG has not credited 08-09, to focus on reasonable defense-in-depth.

assurance of adequate protection.

Innovation has been hampered due to cyber security requirements (e.g.,

new security systems and technologies, monitoring tools, etc.).

Reduce low risk Credit Physical Security and Insider NRG inspections Ensures protections cyber security Mitigation Programs - Credit have only resulted in are right-sized to the controls comprehensive and mature physical very low safety-threat, and permits security programs to reduce low risk significant violations.

rea?onable credit for cyber security controls.

NRG guidance does existing programs, Implement a performance-based not credit defense-processes, and cyber security program.

in-depth controls procedures that and requires provide cyber Revise RG 5.71 and NEI guidance unrealistic protection.

documents (e.g., NEI 08-09) to requirements for Enables efficient reduce low value cyber security controls, credit defense-in-depth assets already cy_bersecurity and physical security controls.

protected.

85

ACCELERATING NRC REFORM INDUSTRY RECOMMEND ATIO N S JULY 2025 Area Proposed Change Description Basis Benefit Eliminate.requirements/controls that are required to be performed at unrealistic frequencies and credit defense-in-depth.

inspection and oversight activities.

Reduce low value requirements and focus on prevention of significant core damage and spent fuel sabotage.

BG

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS

.LILY 2025 REFORM NUCLEAR SECURITY REGULATIONS MODERNIZE AA/FFD PROGRAM REQUIREMENTS Executive Summary Modernize Access Authorization (AA)/Fitness-for-duty (FFD) program requirements to eliminate outdated, low value requirements that:

Provide no safety or security benefit Impose an administrative burden that distracts from the core mission and drives unnecessary cost.

Outcomes Expedite the access authorization of nuclear workers by eliminating low-value administrative requirements.

Eliminate testing and auditing requirements that do not have a measurable impact on the fitness for duty program.

Eliminate unnecessary work and documentation requirements Why This Matters Redirecting resources away from low-value compliance requirements allows industry to focus on more impactful safety, reliability and program enhancements.

Proposed Timing and Method Immediate implementation through expedited process improvements, and exemptions, where needed, until the wholesale regulation review rulemaking is completed by November 2026.

References and Background The NRC introduced 1 O CFR 73.56 on May 29, 1991, establishing foundational requirements for personnel access authorization at nuclear power plants to ensure that individuals granted unescorted access are trustworthy and reliable. Since thattime, the industry has strived to reduce unnecessary burden while meeting high standards of trustworthiness and reliability. The

87

ACCELERATING NRC REFORM IN DUSTRY RECO M MENDATIONS JU L Y 2025 recommendation described below continue to those standards while enabling innovation and efficiency Specific Recommendations A

Proposed Change B

B t*t rea O

as1s ene 1 escnpt1on Access Eliminate or revise the Authorization following requirements and inspection procedures (iP):

1)

IP71130.01

2) 73.56 (i) (iv)

3) 73.56 (j)

4) 73.56 (n) (1) (2)

Access authorization requirements should be modernized to eliminate low-value legacy administrative burdens that do not demonstrably enhance safety or security Access Authorization Inspection: Access authorization program is inspected during security, cyber and access inspections.

Annual Supervisor Review: 31 Day Review encompasses a behavioral review.

31 Day Review Frequency: Recommend a bi-annual frequency.

Extend Audits from 1 to 2 years for contract vendors. From 2 to 3 years for licensees.

5)

NEI 03-01 6.2 (c.)

FFD Potentially Disqualifying Information (POI) Background Expansion Shorten from 5 to 3 years, eliminating expanded background.

6) 73.56 (i) (v) (A,B) (1-5)

Reinvestigations Align the 3-year re-assessment with the 5-year psychological re-assessment. RAP-Back could replace reinvestigations

7) 73.56 (4)

8)

NEI 6.2, 6.3

Eliminate Best Effort: Align with Part 26 requirements; 3 attempts to solicit information from employers within a 24-hour period.

Initial/Updated Unescorted Access Authorization, Unescorted Access (UA/UAA) Eliminate verifying longest claimed employment in each calendar month for years 2 & 3.

Eliminates redundancy and enhances efficiency 88

ACCELERATING NRC REFORM INDUSTRY RECOMMENDA-~'ONS J ULY 2025 Area Proposed Change Description

9)

NEI 6.2, 6.3,6.4

10) NEI 6.4, 6.5

11) NEI 7.4.3

12) NEI 7.4.4 Fitness for Eliminate or revise the Duty following regulations:

13) 26.168

14) 26.41

15) 26.41

16) 26.189 (5)(c)

17) 26.97

18) 26.109

Basis Benefit Unemployment Verifications: Remove the requirement to verify periods of unemployment Reinstate 31-365: Change requirement for drug results from 5 business days to 10.

Military: Change hand carried DD214 to veteran obtaining DD 214 on-line in presence of AA/FFD staff. Change last duty station to pertinent contact for today's military environment OR remove the requirement in its entirety and rely solely on the DD214.

Education: Change education period from 5 years to 3 years to match employment.

Fitness for duty requirements should be Removes modernized to eliminate low-value legacy duplicative administrative burdens that do not requirements, demonstrably enhance safety or security reduces unnecessary Blind Specimen Testing. Eliminate blind burden and specimen testing comparable with DOT.

enhances efficiency and Audit Frequency: Change audit frequency flexibility to 2 yrs tor vendor, and 3 for programs.

Program performance to determine more frequent audit need.

Laboratory Audits: Eliminate lab audits.

Use HHS audits instead. Licensee reserves the right to audit if there is evidence of program deficiency in the HHS lab program.

Face-to-Face Evaluations: Allow web-based electronic evaluations, use face-to-face determinations only if ordered by the licensed professional.

Oral Fluid: Include oral fluid testing for all conditions oftest. Allow multiple collections at once. (One collector with several donors)

Urine Specimen Quantity: Eliminate split specimen verbiage. Require only one specimen at 30 ml.

89

ACCELERATING NRC REFORM

!NDUSTRY RECOIV!MENDATIONS JULY 2025 Area Proposed Change Description

19) 26.187(b)1-4

20) 26.31 (d) (D)

21) 26.119 Fatigue Eliminate or revise the following regulations:

22) 26.203(4)

23) 26. 717 (b) (9)

24) 26.203(e)(1 )(i)(ii)(iii) 26.203(e)(2)

25) 26.205

Basis Benefit Substance Abuse Expert: Regulation fails to include master's level education for professionals that have specifically trained in addiction science.

Panel Expansion: Allow for fast and immediate rule changes that provide additions to the drug panel providing immediate flexibility to combat societal drugs of abuse.

Shy Bladder: Eliminate the requirement for an immediate medical exam and revert to oral fluid testing when the donor cannot produce the required volume of urine. A medical exam may be ordered by the Medical Review Officer (MRO) scheduling of the exam, if ordered by MRO, should be within 10 days, thus providing enough time for the donor to make arrangements with medical personnel.

NRC's fatigue rules often impose Removes unnecessary administrative burdens and duplicative restrict workforce scheduling without clear requirements, safety benefits reduces unnecessary Disciplinary Actions burden and Eliminate disciplinary actions.

enhances efficiency and Performance Data flexibility Eliminate FFD program performance data reporting.

Performance Data Information These sections describe what is evaluated and included in the NRC Form 892, no tonger needed per (table item 2)

Work Hours Revise such that the prescriptive requirements are eliminated, and administrative requirements are simplified, easily understood, and flexible. Current regulation is overly complex, and changes will help enhance the transparency of the requirements while ensuring safety.

90

ACCELERATING NRC REFORM INDUSTRY KECOMMENDATIONS

.ULY 2025 REFORM & MODERNIZE THE REACTOR OVERSIGHT PROCESS OVERHAUL THE ROP FRAMEWORK Executive Summary Further evolve the operating fleet Reactor Oversight Process (ROP) to be risk-informed and performance-based Shift regulatory focus to actual safety significance and plant performance Risk-inform and streamline ~xisting NRC Performance Indicators (Pl)

Streamline the Significance Determination Process (SDP)

Develop risk-informed and performance-based model for advanced reactor oversight Outcomes Maintains the ROP purpose of assessing performance and responding appropriately to declines Resets oversight to a level that provides reasonable assurance of adequate protection Improves the efficiency of NRC decisions, outcomes, and timelines Refocuses oversight effort on any lower performing plants Focuses the ROP on activities and systems that are most safety-significant Why this Matters Over time, the ROP inspection hours and scope have grown beyond what is needed to provide reasonable assurance of adequate protection and included areas of low safety significance.

Documentation requirements have increased, and decision-making has become inefficient.

Overhauling the ROP can be accomplished in a manner that maintains the NRC's ability to inspect and assess the safety and security performance of the industry and respond to any decline in performance.

Proposed Timing and Method Immediate implementation of recommendations not needing Commission approval.

Implementation of additional recommendations upon Commission approval.

91

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATIONS J ULY 2025 References and Background SECY-25-0045, "Recommendations for Revising the Reactor Oversight Program."

SECY-23-0048, "Vision for the Nuclear Regulatory Commission's Advanced Reactor Construction Oversight Program" SECY-24-009, "Proposed Revisions to tt1e U.S. NRC Enforcement Policy."

Specific Recommendations Area Proposed Change Basis Benefit Description ROP/Oversight Immediately approve SECY ROP should reflect Improves the 0045, "Recommendations for improved plant effectiveness and Revising the Reactor Oversight performance and focus efficiency of NRC Program."

on what is safety oversight.

(In the interim, recommendations significant.

that do not require Commission approval should be implemented immediately)

ROP/Oversight Immediately approve SECY Establishes a more Applies a graded 009, "Proposed Revisions to the appropriate enforcement performance U.S. NRC Enforcement Policy."

policy and realistic approach to description of NRC traditional findings.

enforcement violations ROP/Oversight Simplify and risk-inform Pis to Some Pis are Improves NRC focus on safety-significant unnecessarily complex oversight efficiency.

performance gaps.

and should be simplified.

Reduces licensee Pis should focus on resources responding parameters that reflect to low to moderate safety-significant issues that are in the attributes.

corrective action program.

Aligns with ROP's fundamental purpose to assess performance.

ROP/Oversight Streamline the SDP to eliminate Licensee PRAs more Enhances technical the use of NRC's SPAR models accurately model the accuracy, as SPAR and utilize the utility PRAs.

plant design and models are Eliminate greater-than-green operation and are of high intentionally findings for deterministic or quality.

simplified, are not updated as frequently

92

ACCELERATING NRG REFORM INDUSTRY RECOMIV'.ENDATIONS JULY 2025 Area Proposed Change Description qualitative thresholds (EP, Security, RP).

Risk-inform the SOP screening guidance:

Revise the screening guidance in IMC 0609, Appendix A to provide credit for plants that have adopted TSTF-505 and implemented risk-informed completion times (RICTs).

Reduceresourcesfor completing detailed risk assessments when an AOT is extended utilizing an improved NRG process and risk management actions are implemented.

Revise Appendix A, C, I and M to institute off-ramps and remove the requirement to use deterministic criteria.

ROP/Oversight Credit licensee actions for responding to Licensee-Identified and Self-Revealing findings for oversight.

Deterministic criteria should be risk-informed and consider defense-in-depth for findings/violations.

Require the staff to use the Very Low Safety Significance Issue Resolution (VLSSIR) process, when applicable.

Limit the time spent on low safety-significant issues and streamline documentation of the issues.

Overhaul and risk-inform the Traditional Enforcement guidance and implement a VLSSIR-like process for Traditional Enforcement.

Basis Benefit Using the licensees' as licensees' models, PRAs streamlines and may not reflect decision-making.

design changes.

A graded approach Reinforces NRC's based on the risk commitment to risk-significance of the informed oversight.

application allows the NRG to allocate Modernize and streamline SDP resources more screening with a efficiently without reducing safety.

focus on safety significance.

Focus regulatory Improve NRG oversight on safety-oversight significant issues.

effectiveness and The 95001 process is too efficiency and focus burdensome considering attention on safety-white findings are of low significant matters.

safety significance. Any follow up should be performed by the Resident Inspector.

The 95002/3 processes should be simplified and focused on only safety-significant issues.

93

ACCELERATING NRC REFORM

NDU STRY RECO M MENDATIONS JULY 2 0 25 Area Proposed Change Description Revise more than minor guidance in IMC 0612 to remove the "potential result or outcome" subjective criteria when determining if a violation is minor or more than minor.

Eliminate White Findings and the 95001 process and simplify the 95002 and 95003 program.

Eliminate the subjective deterministic criteria for reactive inspections and utilize a risk-informed approach.

ROP/Oversight Sunset the current inspection report model and replace it with a more modern, efficient and transparent system that incorporates:

Real-time digital tracking of inspection findings Quarterly summary reports for public stakeholders Graded approach to documentation based on safety significance Simplified documentation approach with standard templates for low safety significance issues Eliminate or streamline reporting for issues of green or minor significance and rely on the licensee's corrective action program ROP/Oversight Eliminate inspection finding cross-cutting attributes (CCA) from the ROP.

Basis Benefit Inspection reports are an Modernizing and outdated process from a simplifying the paper-based system and documentation should be replaced by process enhances simplified methods of public transparency, documentation.

and saves inspector and licensee Lengthy inspection resources.

reports obfuscate information of interest to stakeholders.

Green findings are by definition of very low safety significance, and minimal resources should be spent on them.

CCAs are subjective, Eliminates a low-inconsistently applied, value regulatory and add little regulatory oversight process.

value. CCAs were Streamlines originally intended to inspection findings, promote safety culture awareness, but over 20+

reduces ambiguity, years of experience have and focuses attention proved to be neither 94

ACCELERATING NRC REFORM INDUSTRY RECOMMENDATI ONS

" JULY 2025 Area Proposed Change Description Risk-Informed Develop a risk-informed approach and for grading the level of oversight for Performc;1nce-advanced reactors with based demonstrated lower risk profiles Advanced to: (1) prioritize continuous self-Reactor reporting performance indicator Oversight evaluation and threshold analysis and periodic inspection, and (2) replace resident inspector mode with periodic inspectors conducting reduced baseline inspections.

Ensure the SOP is realistic.

Finalize Advanced Reactor Construction Oversight Program (ARCOP) guidance.

Basis Benefit predictive nor on actual informative.

performance issues.

CCAs are redundant to existing safety culture monitoring programs (e.g., CAP, INPO) required by 10 CFR 50, Appendix B.

Advanced reactors have Provides predictable, significantly lower risk effective and efficient profiles that should be oversight that credited in operational provides reasonable oversight.

assurance of public health and safety.

95

ACCELERATING NRC REFORM I NDUSTRY RECOMMENDATIONS JULY 2025 REFORM & MODERNIZE THE REACTOR OVERSIGHT PROCESS ALIGN INSPECTIONS BASED ON SAFETY SIGNIFICANCE Executive Summary Implement a reduction in inspection procedures, commensurate with safety significance Eliminate and streamline baseline inspection procedures Risk-inform the inspection program and incorporate performance-based approaches Eliminate duplicative inspections Develop a risk-informed approach for grading the level of oversight needed that allows advanced reactors with demonstrated lower risk profiles to reduce or eliminate the number of resident inspectors.

Outcomes Resets inspection to a level that provides reasonable assurance of adequate protection Reduces NRC inspection workload and frees up resources for work in other areas Provides a more risk-informed and performance-based program so effort is focused on safety significant areas Reduces unnecessary burden Why This Matters NRC resident inspectors perform full-time on site inspections and oversight bolstering public confidence and transparency of the regulatory process. Additional inspection programs have not resulted in safety improvements. Implementing a risk-informed and performance-based inspection program allows the industry to focus on more impactful safety and reliability improvements and allows the NRC to redeploy resources to support energy dominance.

Proposed Timing and Method Immediate implementation of recommendations not needing Commission approval.

Implementation of additional recommendations upon Commission approval.

96

ACCELERATING NRG REFORM INDUSTRY RECOMMENDATIONS JULY 2025 References and Background IMC 2515, "Light Water Reactor Inspection Program Operations Phase" IMC 2525 Appendix D, "Plant Status" Specific Recornmendations Area Proposed Change Description Basis Benefit Revamp Inspector Baseline Inspections Streamline the inspection program using risk insights and incorporate performance-based principles. Eliminate low value inspection proced4res and credit inspections and discontinue duplicative inspection. Problem Identification & Resolution Inspection (IP 71152)

Outage based inspections - lnservice Inspection and Radiation Protection Inspections.

Security program inspections -five of the existing security inspection procedures (e.g., Access Authorization, Access Controls, Security Plan Changes, Security Equipment, etc.).

Reduce low value inspections performed by resident inspector and eliminate minimum sampling process, which will enable the elimination of regional inspectors.

Revise IMC 2515, "Light Water Reactor Inspection Program Operations Phase,"

(including Appendix D), to eliminate low value inspections and minimum sampling process using risk and performance-based insights.

Eliminate inspections with historical performance of no or limited violations of very low safety significance - 70% of the 49 baseline inspection procedures have seen historical good performance with limited violations.

Consolidate eight physical security inspections into a single inspection program and transition the majority of inspections to resident inspectors.

The majority of inspections result in outcomes of very low safety significance.

The inspection program is not adequately risk-informed or performance-based, resulting in low value inspections and unnecessary requirements.

80% of inspection violations are driven from approximately 11 inspection procedures; the remaining 38 inspection procedures account for 20% of violations.

Eliminates low-value inspection programs allowing licensees to prioritize staffing for safety and reliability improvements.

97

ACCELERATING NRC REFORM INDUSTRY RECO M MENDATI ON S JULY 2025 Area Proposed Change Description Consolidate team and program inspections to focus on risk-informed aspects and use performance-based criteria to extend inspection cycles.

Extend Program Inspection cycle to 4 years - Cyber Security, Radiation Protection, Emergency Planning and Security Force-on-Force

Combine Security and Emergency Planning evaluated exercise and program inspection procedures Eliminate low risk and low safety inspections, documentation and administrative process to allow resident inspectors to perform risk-informed and performance-based inspections.

Eliminate NRC preparation and documentation process for very low safety significance items.

Eliminate Eliminate and streamline inspection Regional programs:

Inspections Revamp inspection program to be risk-informed and performance-based, focused on items of safety significance

Consolidate and eliminate 49 baseline inspection procedures by 70%.

Eliminate team engineering and program inspections (e.g., CETI, FEI and Pl&R)

Consolidate and reduce security-related inspections and transition inspections to resident inspectors Develop a Risk-NRC should adopt a graded and risk-Informed and informed approach in establishing an Performance-advanced reactor oversight program so that based Advanced inspection hours and the need for a resident Reactor inspector is a function of the safety profile Oversight and performance of a plant.

Program

Basis Benefit NRC resident Focuses NRC inspectors maintain and licensee full awareness of resources on plant activities and risk significant review licensee inspections.

programs.

Eliminates Resident inspector duplicative performs similar efforts by region and overlapping inspectors and inspections as resident those performed by inspectors.

the region.

Advanced reactors Reduced have a lower risk operating costs profile and a graded for advanced approach to the reactors while presence of ensuring safety.

resident inspectors is appropriate.

98

ACCELERATING NRG REFORM INDUSTRY RECOMMENDATIONS IULY 2025 REFORM & MODERNIZE THE REACTOR OVERSIGHT PROCESS ELIMINATE LOW VALUE WORK.IN OTHER NRC PROCESSES Executive Summary Streamline and eliminate NRC processes Reduce scope and process in the Office of Investigations Streamline the allegation process Eliminate regulation of Safety Conscious Work Environment Outcomes Resets NRC effort to a level that provides reasonable assurance of adequate protection Immediately reduces NRC workload and frees up resources for work in other areas Avoids duplication of licensees' investigations, and licensees' actions can be done more effectively and efficiently Eliminates unnecessary work and documentation of NRC processes that are outside of the ROP framework Why This Matters Resets NRC effort to a level that provides reasonable assurance of adequate protection, reduces unnecessary regulatory burden and frees up resources for work in other areas.

Proposed Timing and Method Immediate implementation via a change to NRC programs and processes with a completion date of December 2025.

99

AC ELERATING NRC REFORM I NDUSTRY RECOMMEN DATIONS JULY 2025 References and Background NRC's SCWE Policy, "Freedom of Employees in the Nuclear Industry to Raise Safety Concerns Without Fear of Retaliation," 61 Fed. Reg. 24,336 (5.14.96) or Regulatory Issue Summary 2005-18.

A Proposed Change 8

8 t*t rea D

as1s ene 1 Office of Investigations (01) escnpt1on Streamline 01 (as established by 10 CFR 1.36) and focus NRC oversight on cases of serious deliberate misconduct Revise Investigation Procedures Manual to:

Allow NRC to assess licensee materials (licensee-identified issues, findings and corrective actions) to satisfy need for investigation; allow non-interview, truncated process for licensee-identified issues Set clear thresholds and off-ramps during investigations (e.g., for retaliation claims, first assess whether a non-prohibited reason for adverse action exists)

Set timeliness criteria considering severity and seriousness of claims Risk-inform investigation resources based on materiality and importance Risk-inform investigative functions. Some can be consolidated and

01 duplicates investigations already performed by licensees, even where the licensee substantiated the claim.

01 process is lengthy and delayed and requires NRC and licensee resources, even where the licensee does not dispute the facts.

In retaliation cases, the alleger and the licensee may wish to settle claims after an investigation has commenced. But such settlement is hampered by the inability of 01 to turn off an ongoing investigation.

NRC conducts investigations of alleged willful misconduct/wrongdoing, which NRC defines as either deliberate misconduct or careless disregard for requirements. This proposed change is intended to conform guidance documents with the thrust of NEl's overall concern, which is to focus and tailor NRC investigations on truly serious deliberate misconduct.

Focuses NRC and licensee resources on serious deliberate misconduct.

Eliminates duplicative efforts between NRC and licensees.

Reduces NRC resources by consolidating job functions and utilizing investigation agents only for claims of serious deliberate misconduct.

100

ACCELERATING NRG REFORM INDUSTRY RECOMMENDAT!ONS J ULY 2025 Area Proposed Change Description handled by resident inspector staff.

Modify the process to allow an investigation to be terminated before completion under appropriate circumstances (e.g.,

alleger and licensee reach settlement in a retaliation case; 01 uncovers exculpatory evidence)

Revise applicable NRG guidance documents to delete references to "willful misconduct" and replace them with "deliberate misconduct."

Allegation Streamline Allegation Process Process to focus on nuclear safety concerns.

Revise Allegation Manual and M.D. 8.8 to screen allegations for credibility and materiality, eliminate unnecessary documentation associated with responses.

For technical allegations, refer the issue to the licensee and allow licensee and NRG to use existing corrective action processes and inspection process to resolve the issue.

Safety-Eliminate NRG oversight of Conscious SCWE through Work inspections, referral of

Basis Benefit The allegation process is Focuses NRG and unnecessarily burdensome.

licensee Other processes exist that can assess resources on and address concerns more efficient, established processes for addressing concerns.

Focus investigations on credible concerns and issues related to public health and safety.

Licensees may maintain SCWE Reduces NRG and policies to ensure compliance with 10 licensee CFR50.7.

resources on assessments for 101

ACCELERATING NRG REFORM I NDUSTRY RECOMMENDATIONS JULY 2025 Area Proposed Change Description Environment allegations to licensees (SCWE) and investigations.

Revise Allegation Manual and M.D. 8.8, Management of Allegations, to remove requirements and process for responding to SCWE claims.

Eliminate NRC Inspection Manual, Inspection Procedure 93100, "Safety-Conscious Work Environment Issue of Concern Follow-up."

Substantially limit the Request for Information (RFI) process and limit the requirement to perform nuclear safety culture assessments within the ROP framework.

Office of Require NRC staff to Enforcement engage in meaningful (OE) mediation of disputes under its Alternative Dispute Resolution (ADR)

Program, including but not limited to considering facts presented by the licensee.

Basis Benefit There is no regulatory basis to which there is no regulate or inspect against NRC's regulatory basis.

SCWE Policy.

In ADR, OE refuses to consider facts More meaningful other than those developed in the 01 dispute resolution Investigation and is solely interested that considers all in negotiating an outcome (i.e.,

of the facts and numerous and burdensome results in corrective actions) based on NRC's corrective actions often flawed and incomplete that address the understanding of the facts.

actual problem.

102

Chairman Resource From:

Sent:

TRUE, Doug <det@nei.org>

Thursday, July 31, 2025 3:11 PM To:

CMRMarzano Resource; CMRCaputo Resource; CMRCrowell Resource; Chairman Resource Cc:

mike.king2@nrc.gov

Subject:

Attachments:

[External_Sender] Industry Recommendations on Accelerating NRC Reform 07-31-25_NRC_Accelerating NRC Reform.pdf; Accelerating NRC Reform.pdf July 31, 2025 The Honorable David Wright, Chairman The Honorable Annie Caputo, Commissioner The Honorable Bradley Crowell, Commissioner The Honorable Matthew Marzano, Commissioner U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Industry Recommendations on Accelerating NRC Reform

Dear Commissioners:

The Nuclear Energy Institute (NEI), on behalf of its members, appreciates the opportunity to provide the enclosed report outlining specific recommendations to implement the May 23, 2025, Executive Order 14300, "Ordering the Reform of the Nuclear Regulatory Commission." This Executive Order (EO) marks a critical opportunity to transition the NRC to a more deployment-oriented, risk-informed, and performance-based framework that fully enables the next era of U.S. nuclear innovation, essential for American energy independence, resilience, and security.

We are encouraged by the progress the NRC has made under the ADVANCE Act and other modernization initiatives. However, to effectively respond to EO 14300 and meet the nation's surging demand for reliable electricity, the agency must pursue more substantial reforms and accelerate its efforts. The enclosed report is provided to assist the Commission as it directs, reviews and approves the staff's efforts to implement the EO.

We believe our recommendations will maintain safety while significantly increasing the effectiveness and efficiency of the agency. NEI and the industry stand ready to work with the NRC to ensure the success of these transformational efforts.

Sincerely, Doug True I. Senior Vice President & Chief Nuclear Officer Nuclear Energy Institute 1201 F Street NW, Suite 1100 I Washington, DC 20004 P: 202.739.8093 M: 925.998.8810 nei.org 1

~

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ML25212A217

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