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Streamlining and Efficiencies

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Environmental Center of Expertise (ECOE) Streamlining and Efficiencies:

  1. Time and Page Limits: Amendments to the National Environmental Policy Act (NEPA) from the Fiscal Responsibility Act of 2023 (FRA) set mandatory deadlines for publication of Environmental Assessments (EAs) and Environmental Impact Statements (EISs), 12 and 24 months, respectively. In addition, it set page limits for EAs (75 pages) and EIS (150-300 pages), and requirements regarding the roles and responsibilities of lead, participating, and cooperating agencies.
     
  2. Resource Planning Models for License Renewals (LRs): Staff expects to be able to establish its environmental review schedule goal to support 18-month reviews for both initial LR and subsequent license renewal (SLR) applications. The staff will continue to refine and leverage its extensive experience and identify opportunities for efficiencies, including exploring the appropriateness of the EIS requirements for license renewals and whether EAs could more effectively meet agency objectives.
     
  3. Requests for Confirmatory Information (RCIs): The staff will continue its increased use of RCIs when applicable, rather than requests for additional information (RAIs), to facilitate reduced applicant turnaround time. The RAI process is a formal process to request additional information from an applicant. RCIs follow a simpler process in situations where the NRC staff is asking the applicant to confirm non-public information of which the staff is aware. RCIs are applicable to low complexity, high confidence, and factual information; and should typically result in a short yes-or-no response from the applicant.  The use of RCIs has reduced the number of hours required to develop information requests while also reducing applicant time and resources in responding to requests.
     
  4. Using Technology Tools to Improve Audits: The staff will continue to refine its use of hybrid audits by leveraging virtual meetings and the use of information technology tools to allow for more focused onsite reviews of structures, systems, and components to support the environmental review. The staff began to fully leverage these tools during the Coronavirus Disease 2019 pandemic, and continued use of virtual audits has reduced the number of staff hours and travel costs needed to successfully complete environmental audits for initial nuclear power plant LR and SLR reviews.
     
  5. Improvements in Comment Processing: The staff has worked to streamline and reduce comment processing time for comments submitted through regulations.gov for comments on scoping and draft EISs by allowing for batch processing of multiple comments. The staff will continue to work with internal counterparts to explore additional opportunities to expedite the administrative processing of public comments. Streamlining the administrative steps for processing public comments has resulted in a time savings of up to one week, depending on comment volume, and has reduced the overall staff hours required to perform these tasks. In 2022, the staff streamlined scoping summary reports to more closely align with the requirements in 10 CFR 51.29(b) and focus on identifying the significant issues of concern that are in the scope of the environmental review.
     
  6. Streamlining Administrative Prepublication Reviews: As part of the expanded use of contractor support, the staff has integrated technical editing as part of document preparation, which has allowed for the NRC’s Office of Administration to streamline its review in support of draft EIS publication by eliminating duplicative technical editing. This change has reduced turnaround times and expedited publication of draft EISs. The staff will continue to work with the Office of Administration to ensure its reviews are appropriately scoped while effectively complying with agency publishing standards. By reducing duplicative editing, the staff has reduced the timeframe for EIS reviews by at least one week.
     
  7. Assessment of Nonrequired Public Meetings: Recent efficiency gains achieved by reducing the scoping period have been offset slightly by the additional resources needed to hold two separate public meetings to accommodate both virtual and in-person attendees. Currently, a webinar and an in-person meeting are held at separate times during the comment period. Because scoping meetings are not required by NRC regulations, the staff will continue to assess whether holding these meetings, or multiple public meetings, is an effective use of staff resources based on recent public meeting data and feedback. If the staff determines that it can effectively engage the public through virtual meetings, it will reduce staff hours, travel, and other costs associated with an in-person meeting.
     
  8. AGILE Project Management for Workload Planning: In December 2022, the staff began applying an agile methodology for workload planning to balance review schedules. Under the agile schedule, the staff identifies periods of overlapping priorities and ensures schedule flexibility around fixed milestones (e.g., 60-day acceptance reviews, 30-day scoping periods, 45-day comment periods). This allows early identification of necessary contract support, shifts in work priorities (e.g., hearings, extension of scoping or draft EIS comment periods), and schedule risks. Due to the success of the agile methodology in balancing initial nuclear power plant LR and SLR priorities, the staff will expand its use across the ECOE to manage technical review work and effectively prioritize resources across business lines, which will support greater efficiency in workload management.
     
  9. Realignment of the ECOE: In November 2023, the ECOE reorganized to better share resources and manage workloads. This change helped staff get qualified faster, allowed them to work across different areas, and improved how the center oversees work. As a result, the ECOE manages tasks more effectively and is better equipped to meet review schedules.
     
  10. Increased Use of Contractor Support for Reviews: In 2023, the staff significantly increased the capacity for contractor support of environmental reviews. The staff will continue to leverage contractor support to meet the demands of the high concurrent workload and expects to realize efficiency gains as the contractor gains experience specific to environmental reviews. While contractor reviews have required additional NRC effort up front to ensure consistency of reviews and quality of written products, the staff expects the cost to level out in the near term. This additional technical review resource capacity has been, and will remain, critical to ensuring published schedule milestones are met for current environmental reviews.
     
  11. Hiring: Based on budgeted workload following the realignment of the ECOE, the staff are expanding the number of ECOE employees. In 2023, the staff recruited more than ten environmental project managers and environmental scientists, representing almost 25 percent of the total number of ECOE employees. As of October 2024, the ECOE is fully staffed to full-time equivalent (FTE) levels. In addition, the staff placed contracts with national laboratories to leverage expertise to support the staff’s environmental review responsibilities.
     
  12. Artificial Intelligence Research and Applicability: The overwhelming capability of artificial intelligence (AI) caught the eye of the public, industry, and the ECOE. The ECOE intends to conform with the NRC’s Strategic Artificial Intelligence Plan, which establishes the vision and goals for the NRC to cultivate an AI-proficient workforce, keep pace with AI technological innovation, and ensure the safe and secure use of AI in NRC regulated activities. In 2023, several staff analyzed the benefits and applicability of AI throughout the ECOE’s work. Several AI use-case proposals were created and submitted to the NRC Office of Nuclear Material Safety and Safeguards for the purpose of research. Follow along with the NRC’s Artificial Intelligence page for updates on the application of AI at the NRC.
     

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Additional Efficiency Considerations Directed by the ADVANCE Act:

  1. [Already Implementing] Using Other NRC NEPA Documents: The ADVANCE Act directs the NRC to consider using EISs, EAs, and categorical exclusions (CEs) previously prepared by the staff to streamline environmental reviews of licensing applications. The NRC accomplishes this through use of programmatic environmental documents and incorporation by reference. NRC programmatic environmental documents include the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (NUREG‑1437), Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (NUREG-2157), and Generic Environmental Impact Statement for Licensing of New Nuclear Reactors, Draft Report for Comment (NUREG-2249). Examples of incorporation by reference include the license renewal site-specific EISs for the Turkey Point Nuclear Generating Unit and the North Anna Power Station, and the EA for the Hermes 2 test reactors.
     
  2. [Under Consideration] Using the Applicant’s EIS as the Commission’s Draft EIS: In line with the FRA amendments to NEPA section 107(f), the ADVANCE Act directs the NRC to consider authorizing the use of an applicant’s EIS as the Commission’s draft EIS. In SECY-24-0046, the staff recommended rulemaking to develop new 10 CFR Part 51 regulations to explicitly allow for applicant preparation of a draft environmental document (EA/EIS) that will serve, under appropriate NRC supervision, as the draft EIS required for NEPA analysis.
     
  3. [Already Implementing] Using Other Federal Agencies’ NEPA Documents: The ADVANCE Act directs the NRC to consider using, through adoption, incorporation by reference, or other appropriate means, CEs, EAs, and EISs prepared by other Federal agencies to streamline environmental reviews of licensing applications. NRC regulations currently allow for incorporation by reference and the recent Hermes 2 EA made use of environmental documents produced by the U.S. Department of Energy. The NRC staff will continue to leverage other Federal agencies’ NEPA documents as appropriate and is considering recent revisions to NEPA made by the Council on Environmental Quality that facilitate the adoption of other agency’s EISs, EAs, or CEs.
     
  4. [Under Consideration] Using Mitigated Findings of No Significant Impact: The ADVANCE Act directs the NRC to consider using mitigated findings of no significant impact (mitigated FONSIs) in environmental reviews of reactor licensing applications to reduce the impact of a proposed action to a level that is not significant. The NRC already considers reasonably foreseeable mitigation when determining environmental significance in EISs and is assessing how this approach could be applied to EAs.
     
  5. [Under Consideration] Amending 10 CFR Part 51 to Allow Environmental Assessments: In line with FRA amendments to NEPA Section 106, the ADVANCE Act directs the NRC to consider amending 10 CR 51.20(b) to allow the Commission to determine, on a case-specific basis, whether an EA (rather than an EIS or supplemental EIS) is appropriate for a particular licensing application, including in proceedings in which the Commission relies on a GEIS for advanced nuclear reactors. In SECY-24-0046, the staff recommended rulemaking to remove the list of actions in 10 CFR 51.20(b) that automatically require an EIS (except those actions where an EIS is required by statute).
     
  6. [Under Consideration] Establishing New Categorical Exclusions: The ADVANCE Act directs the NRC to consider establishing new CEs that could be applied to actions relating to licensing applications. The NRC is currently pursuing a rulemaking that would amend the NRC's current list of actions that are eligible for categorical exclusion (see NRC-2018-0300). However, in SECY-24-0046, the staff recommends exploring whether any additional actions should be eligible for CE under the new definition in NEPA Section 111(1), or if other Federal agency’s categorical exclusions that may be established could help establish the basis for the determination of no significant effects. These CEs would be in addition to those being pursued in the current rulemaking.
     
  7. [Already Implementing] Increasing Opportunities to Coordinate with Other Federal Agencies: The ADVANCE Act directs the NRC to consider opportunities to coordinate the development of EAs and EISs with other Federal agencies to avoid duplicative environmental reviews and to streamline environmental reviews of licensing applications. The NRC has proactively sought cooperation with other Federal and State agencies and Tribal governments since the early 2000s and will continue to do so. A recent example of NRC cooperation with another Federal agency is the NRC’s memorandum of understanding with the U.S. Department of Energy, which establishes functional coordination between the agencies regarding NEPA and the National Historic Preservation Act requirements associated with the demonstration and deployment of advanced reactors receiving U.S. Department of Energy support.
     
  8. [Already Implementing] Streamlining Consultation and Coordination with Other Permitting Agencies: The ADVANCE Act directs the NRC to consider opportunities to streamline formal and informal consultations and coordination with other Federal, State, and local governmental permitting agencies during environmental reviews of licensing applications. The NRC has optimized internal processes to prioritize activities that reduce regulatory and schedule risks during consultations and to understand and address Tribal concerns.
     
  9. [Under Consideration] Streamlining Alternatives Analyses: The ADVANCE Act directs the NRC to consider opportunities to streamline the Commission’s analyses of alternatives, including the Commission’s analysis of alternative sites, in environmental reviews of licensing applications. In SECY‑24‑0046, the staff recommends streamlining the NRC’s analyses of alternatives, including the analysis of alternative sites, including modifying the purpose and need to focus on the agency action.
     
  10. [Under Consideration] Leveraging Online and Digital Technologies: The ADVANCE Act directs the NRC to consider opportunities to adopt online and digital technologies, including technologies that would allow applicants and cooperating agencies to upload documents and coordinate with the Commission to edit documents in real time, that would streamline communications between the Commission and applicants; and the Commission and other relevant cooperating agencies. The staff is currently evaluating the creation of a new online portal for a digital environmental application for certain types of license applications.
     

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Page Last Reviewed/Updated Friday, November 8, 2024