This document summarizes the discussion between the nuclear power industry and NRC staff during meetings on December 11-12, 2025, pertaining to (1) the NRC review approach for power uprate license amendment requests (LARs) and (2) tabletop walkthroughs of the submittal strategies for two specific plants. This document highlights key discussion points from the meeting, states follow-up actions, and provides potential strategies for streamlining review of licensing submittals for power uprates.
In the context of the direction of Executive Order 14300 to reduce regulatory review time, and with understanding of the many planned upcoming submittals in support of power uprates, the NRC staff has developed a risk-informed strategy for applying appropriate resources to each submittal. This strategy has been shared as a draft Appendix A to Office Instruction LIC-112. Interactions during the meeting between the NRC staff and industry representatives provided clarification on how this risk-informed strategy is intended to be implemented. Specifically, the NRC proposes to use a graded approach where technical review areas within each submittal are “binned” based on characteristics corresponding to the expected level of NRC staff review.
Additionally, the industry prepared two “Tabletop” presentations to discuss the licensing approach for one PWR and one BWR. The Tabletop presentations described how the respective strategies included linked LARs (that are submitted in a sequence where review times will overlap) and bundled LARs (for which multiple related actions are included in a single LAR). These strategies are expected to significantly accelerate implementation (i.e., by years). The NRC staff affirmed that these strategies were aligned with their expectations.
Specific points of discussion during the meeting of particular importance include the following:
- Licensees do not need to obtain formal exceptions to NRC Office Instructions, including for bundled or linked LARs.
- BWRs with submittals for power uprates less than 122% Original Licensed Thermal Power with MELLLA+ that continue to use existing fuel/clad systems and maintain Peak Road Average Burnup of ≤ 62 GWD/MTU will not need to address Fuel Fragmentation, Relocation, and Dispersal (FFRD). The industry expects this conclusion to apply to other licensees planning to uprate in a similar fashion.
- The NRC staff expects that the Advisory Committee for Reactor Safeguards (ACRS) will not need to review most power uprate submittals. ACRS engagement may be needed for the initial industry submittal(s) as well as for any submittals with unique characteristics. If ACRS review is needed, it will be completed within the proposed NRC review timeline (e.g., 12-months for Extended Power Uprates).
The meeting also resulted in several follow-up actions, including an industry action to identify an appropriate specific licensee submittal for a workshop on how the NRC’s binning process will be implemented.
Finally, the meeting identified several potential strategies for licensees to support streamlining the NRC review process, such as developing a Regulatory Engagement Plan that provides an overarching description of the strategy for linked and/or bundled submittals.