NUCLEAR 

REGULATORY 

COMMISSION

Efforts Intended to 

Improve Procedures 

for Requesting 

Additional Information 

for Licensing Actions 

Are Under Way

Accessible Version

Report to Congressional Requesters

April 2017

GAO-17-344

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-344, a report to 

congressional requesters

April 2017

NUCLEAR REGULATORY COMMISSION

Efforts Intended to Improve Procedures for 

Requesting Additional Information for Licensing 

Actions Are Under Way

What GAO Found

At the Nuclear Regulatory Commission (NRC), individual offices that issue 

requests for additional information (RAI) each have their own guidance that is 

generally the same across the offices. NRC offices have some efforts underway 

to update their guidance. These efforts are intended to improve oversight of RAIs 

and include an increased focus on oversight of RAIs and on staff compliance 

through managerial review. For example, one of the offices that issues RAIs calls 

for management to discuss the need to send a licensee additional questions on 

the same topic before doing so. 

Summary of Process Used by Nuclear Regulatory Commission Offices to Develop and Issue 

Requests for Additional Information 

NRC offices that issue RAIs do not specifically track the number of RAIs that 

they have issued and do not have a comprehensive accounting for the last 5 

years, although one office has a system capable of tracking the number of RAIs. 

Information from NRC officials and licensees GAO interviewed suggests that 

certain activities and circumstances often elicit RAIs. There is no legal 

requirement for the agency to track the number of RAIs; however, offices are 

updating their internal tracking systems in order to improve information on their 

licensing activities. Receiving RAIs is not unusual, particularly for certain 

activities such as complex licensing actions and activities for which regulations 

are unclear, according to officials. In such cases, increased coordination 

between NRC and the licensee may be required to resolve certain issues. 

Licensees GAO interviewed were generally satisfied with the RAI process, 

identifying strengths and two common weaknesses, and NRC has made recent 

efforts intended to address these weaknesses. Some licensees noted that they 

see RAIs as a natural part of interacting with a regulator and identified NRC’s

openness to communication and engagement as a strength of the RAI process. 

Two common weaknesses that licensees cited are a gap between NRC’s 

expectations and licensees’ understanding of what to include in their 

applications, and staff departure from guidance. NRC offices have made recent 

efforts to address these issues. For example, to address inconsistencies 

between NRC’s expectations and licensees’ understanding, NRC offices are 

emphasizing greater communication between review staff and licensees.

View GAO-17-344. For more information, 

contact Frank Rusco at (202) 512-3841 or 

ruscof@gao.gov.

Why GAO Did This Study

NRC issues RAIs to obtain information

in licensing requests to ensure that 

officials can make a fully informed, 

technically correct, and legally 

defensible regulatory decision. RAIs 

are necessary when the information 

was not included in an applicant’s 

initial submission, is not contained in 

any other docketed correspondence, or 

cannot reasonably be inferred from the 

information available to agency staff. 

NRC’s use of RAIs has come under 

scrutiny in the past. For example, 

NRC's Inspector General, in a 2015 

report, cited concerns about RAIs, 

including the amount of time it took to 

complete the RAI process and the 

resources required to do so.

GAO was asked to review how NRC 

uses RAIs. This report examines (1) 

NRC’s guidance for developing and 

issuing RAIs and how it differs across 

offices; (2) how many RAIs NRC has 

issued over the past 5 years and the 

kinds of activities that elicit RAIs; and 

(3) strengths and weaknesses of 

NRC’s processes to develop RAIs 

identified by NRC and licensees and 

the actions NRC is taking to address 

concerns. GAO examined agency 

guidance documents and selected 

licensing actions containing RAIs. GAO 

interviewed NRC officials and selected 

licensees. GAO randomly selected 

licensing actions and licensees from a 

sample of recent licensing actions that 

included cases from each of NRC’s 

RAI-issuing offices.

What GAO Recommends

GAO is not making any 

recommendations. NRC generally 

agreed with GAO’s findings. 
Page i GAO-17-344 Requests for Additional Information in Nuclear Licensing

Contents

Letter 1

Background 5

Individual NRC Offices Have Their Own Guidance to Issue RAIs 

and Are Updating It in an Effort to Improve the RAI Process 7

NRC Offices Do Not Track the Number of RAIs They Issue, and 

Certain Activities Often Elicit RAIs 12

Licensees Were Generally Satisfied with the RAI Process but Also 

Identified Weaknesses, Which NRC Has Made Recent Efforts 

to Address 16

Agency Comments and Our Evaluation 21

Appendix I: Comments from the Nuclear Regulatory Commission 23

Appendix II: GAO Contact and Staff Acknowledgments 24

Appendix III: Accessible Data 25

Agency Comment Letter 25

Figure

Figure 1: Summary of Process Used By Nuclear Regulatory 

Commission Offices to Develop and Issue Requests for 

Additional Information 6

Abbreviations

NRC Nuclear Regulatory Commission

RAI request for additional information

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-17-344 Requests for Additional Information in Nuclear Licensing

441 G St. N.W.

Washington, DC 20548

Letter

April 25, 2017

The Honorable John Barrasso

Chairman

Committee on Environment and Public Works

United States Senate

The Honorable Shelley Moore Capito

Chairman

Subcommittee on Clean Air and Nuclear Safety

Committee on Environment and Public Works

United States Senate

The Honorable James M. Inhofe

United States Senate

The Nuclear Regulatory Commission (NRC), the independent nuclear 

regulatory agency of the United States, reviews about 2,500 licensing 

actions per year in its regulation of commercial nuclear power plants and 

other uses of nuclear materials, such as in nuclear medicine, through 

licensing, inspection, and enforcement of NRC’s requirements. Through 

the licensing process, NRC may authorize an applicant to conduct the 

following activities: (1) construct, operate, and decommission commercial 

reactors and fuel cycle facilities; (2) possess, use, process, export and 

import nuclear materials and waste, and handle certain aspects of their 

transportation; and (3) site, design, construct, operate, and close waste 

disposal facilities. To become licensed for the aforementioned activities 

(or to amend, renew, or transfer an existing license), an entity must 

submit an application to NRC and, if applicable, respond to any requests 

for additional information (RAI) from NRC staff. According to NRC 

documents, RAIs are intended to help agency staff obtain information 

needed to make a regulatory decision that is fully informed, technically 

correct, and legally defensible.1 NRC documents also state that RAIs are 

necessary when information is not included in an applicant’s initial 

submission, is not contained in any other docketed correspondence, or 

cannot reasonably be inferred from the information available to agency 

 

1Nuclear Regulatory Commission, “Office of New Reactors NRO Office Instruction: 

Processing Requests for Additional Information,” NRO-REG-101 (July 10, 2014) and U.S. 

Nuclear Regulatory Commission, “Office of Nuclear Reactor Regulation Office Instruction: 

License Amendment Review Procedures,” LIC-101, Revision 4 (May 25, 2012).
Letter

staff. For example, agency staff may use RAIs during an environmental 

review to look for new or updated information on the issues they are 

reviewing as part of a license renewal. In other cases, agency staff may 

use RAIs to obtain information missing from an initial application, such as 

qualifications of applicants using nuclear materials for medical purposes.

Three NRC offices are responsible for reviewing and approving licensing 

actions and associated RAIs:

· the Office of New Reactors, which is responsible for licensing and 

processing license amendment requests for new reactors;

· the Office of Nuclear Reactor Regulation, which is responsible for 

licensing for operating nuclear power reactors;

· and the Office of Nuclear Material Safety and Safeguards, which is 

responsible for the safe and secure production of nuclear fuel; the 

safe storage, transportation, and disposal of high level radioactive 

waste and spent nuclear fuel; and the transportation of certain 

radioactive material.

Page 2 GAO-17-344 Requests for Additional Information in Nuclear Licensing

2

These offices operate under the Executive Director for Operations, the 

arm of NRC that carries out the policies and decisions of the five-member 

Nuclear Regulatory Commission.

NRC’s use of RAIs has come under scrutiny in the past. During the late 

1990s, the Senate Environment and Public Works Committee identified 

concerns regarding excessive use of RAIs that resulted in unnecessary 

increased costs and schedule delays. More recently, in 2015, NRC’s 

Inspector General cited concerns about RAIs in a report on oversight of 

spent fuel pools, including the amount of time it took to complete the RAI 

process and the resources required to conduct and review complex 

research and analyses requested through RAIs.3

You asked us to review NRC’s use of RAIs in the licensing process. This 

report examines: (1) NRC’s guidance for developing and issuing RAIs 

 

2The Office of Nuclear Material Safety and Safeguards has four RAI-issuing divisions: 

Material Safety, State, Tribal, and Rulemaking Programs; Spent Fuel Management; Fuel 

Cycle Safety, Safeguards and Environmental Review; and Decommissioning, Uranium 

Recovery, and Waste Programs. 

3Office of the Inspector General, U.S. Nuclear Regulatory Commission Defense Nuclear 

Facilities Safety Board, “Audit of NRC’s Oversight of Spent Fuel Pools,” OIG-15-A-06 

(Feb. 10, 2015). 
Letter

and how it differs across offices; (2) how many RAIs NRC has issued 

over the past 5 years and the kinds of activities that elicit RAIs; and (3) 

strengths and weaknesses of NRC’s processes to develop RAIs identified 

by NRC and licensees, and the actions NRC is taking to address 

concerns.

For all three objectives, we interviewed a nongeneralizable sample of 12 

industry licensees.

Page 3 GAO-17-344 Requests for Additional Information in Nuclear Licensing

4 We selected interviewees from a set of licensing 

actions submitted within the randomly selected month of March 2015.5

From the set of licensing actions submitted to NRC in March 2015, we 

randomly selected two licensees that submitted a licensing action to the 

Office of New Reactors, four licensees that submitted to the Office of 

Nuclear Reactor Regulation, and six licensees that submitted to the Office 

of Nuclear Material Safety and Safeguards, in keeping with the general 

proportion of licensing actions processed annually by each office. Our 

approach ensured that selected licensees had recent experience working 

with NRC and that we obtained at least two licensees’ perspectives for 

each of the three RAI-issuing offices. We interviewed licensees by using 

a standard set of questions that included questions about: (1) the 

licensees’ experience with RAIs, (2) the effect of RAIs on site operations, 

(3) NRC guidance pertaining to RAIs, (4) past and current challenges with 

RAIs, and (5) strengths and weaknesses of the RAI process. We 

analyzed the licensees’ responses and grouped them into categories 

developed through team consensus. When referring to the findings from 

this analysis, we use “some” to refer to responses from 2 or 3 licensees, 

“several” to refer to responses from 4 or 5 licensees, “half” to refer to 

responses from 6 licensees, “many” to refer to responses from 7 to 9 

licensees, and “most” to refer to responses from 10 licensees.6

To examine NRC’s guidance for the development and issuance of RAIs, 

we reviewed applicable sections of title 10 of the Code of Federal 

 

4Because this was a nongeneralizable sample, our results are not generalizable to all 

licensees and applications but provide examples of licensee perspectives on RAIs.

5We use the term “licensing action” to describe licensing activities that feature the 

submission of an application to NRC, a review by NRC staff, and a determination by NRC 

whether or not the applicant’s assumptions are technically correct and the proposed 

activity will not threaten the environment. 

6We did not find agreement among more than 10 licensees on any of the categories we 

identified. 
Letter

Regulations.

Page 4 GAO-17-344 Requests for Additional Information in Nuclear Licensing

7 We also reviewed guidance documents specific to each of 

NRC’s RAI-issuing offices. These documents included, among others, 

office instruction for the Office of New Reactors,8the Office of Nuclear 

Reactor Regulation’s License Amendment Review Procedures,9 and 

guidance documents for the four RAI-issuing divisions of the Office of 

Nuclear Material Safety and Safeguards.10 To ensure the completeness 

and relevancy of the information, we interviewed knowledgeable NRC 

officials from the offices that issue RAIs and use these documents. We 

asked NRC officials about efforts underway to maintain the focus on 

improving the RAI process and staff compliance with guidance. We also 

asked the nongeneralizable sample of 12 industry licensees about their 

experiences using NRC guidance documents when addressing RAIs.

In an effort to determine the number of RAIs issued by NRC in the past 5 

years, we asked NRC officials to estimate how many RAIs they issued, to 

describe internal and external tracking systems they use, and to describe 

the ability of these systems to provide information on the number of 

additional, follow-up questions issued to licensees. We also reviewed 

NRC’s guidance for tracking RAIs, issuing follow-up questions, and 

managing the licensee response to RAIs. To identify the type of 

information contained in RAIs, we asked NRC officials to describe 

common reasons for RAI issuance and reviewed a nongeneralizable 

sample of three licensing actions with RAIs.11 The sample contained one 

 

7See 10 C.F.R. § 2.102(a). NRC’s regulations state that during the review of an 

application by NRC staff, an applicant may be required to supply additional information. 

The regulations also call for NRC staff to establish a schedule for the agency’s review of 

the application and to specify the intermediate steps between the time of docketing until 

the completion of the review.

8Nuclear Regulatory Commission, “Office of New Reactors NRO Office Instruction: 

Processing Requests for Additional Information,” NRO-REG-101 (July 10, 2014).

9Nuclear Regulatory Commission, “Office of Nuclear Reactor Regulation Office

Instruction: License Amendment Review Procedures,” LIC-101, Revision 4 (May 25, 

2012).

10Guidance documents we reviewed include: Nuclear Regulatory Commission, “Fuel 

Cycle Licensing Review Handbook,” Revision 5, (July 2015); Nuclear Regulatory 

Commission, “Consolidated Guidance About Materials Licenses,” NUREG-1556, Vol. 20 

(December 2000); Nuclear Regulatory Commission, “Decommissioning and Uranium 

Recovery Licensing Instructions/Procedures,” Revision 2, (Mar. 27, 2009); and Nuclear 

Regulatory Commission, “SFM Division Instruction: Operational Strategies and 

Management Expectations,” SFM-26, Rev. 0 (Aug. 8, 2016). 

11Because this was a nongeneralizable sample, our results are not generalizable to all 

licensing actions but provide illustrative examples of the types of information included in 

RAIs and processes followed by different NRC offices.
Letter

randomly selected licensing action from each of the three RAI-issuing 

offices submitted within the randomly selected month of March 2015. The 

examples also reflected different types of licensing actions, as one was 

for a license renewal, another was for a license amendment request, and 

the third was for a relief request.

Page 5 GAO-17-344 Requests for Additional Information in Nuclear Licensing

12 We also asked the nongeneralizable 

sample of 12 industry licensees about the type of information requested in

RAIs they received.

To assess the strengths and weaknesses of NRC’s processes for 

developing and issuing RAIs, we asked for the perspective of NRC 

officials and conducted interviews with the 12 industry licensees or 

applicants, as noted above. To obtain additional perspective, we also 

interviewed an industry interest group representative who interacts with 

both industry and NRC on regulatory issues. To identify NRC efforts to 

address concerns raised, we reviewed updates made to guidance 

documents and asked NRC officials and licensees about actions taken to 

mitigate challenges.

We conducted this performance audit from June 2016 to April 2017 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Background

The process for developing and issuing RAIs begins with either preapplication activities or the submission of an application (see fig. 1), and 

is generally consistent across the NRC offices that use RAIs.

 

12A relief request allows a licensee to deviate from a regulatory requirement. 
Letter

Figure 1: Summary of Process Used By Nuclear Regulatory Commission Offices to Develop and Issue Requests for 

Page 6 GAO-17-344 Requests for Additional Information in Nuclear Licensing

Additional Information

Pre-application activities occur before NRC receives an application; these 

activities may include a meeting between the licensee and NRC staff, or 

communication between parties via phone or e-mail. NRC offices assign 

each licensee a project manager or license reviewer who is responsible 

for overseeing the licensing process and coordinating with review staff. 

Pre-application activities provide an opportunity for licensees to ask 

clarifying questions of NRC staff and for NRC staff to prepare for the 

review of an incoming application. Not all license applications or NRC 

offices include this step, as pre-application activities vary based on the 

complexity of the application. All licensing actions across NRC offices, 

however, include the submission of an application. After NRC receives an 

application, officials may conduct an acceptance review to ensure there is 

enough information contained in the application to perform a technical 

review. NRC considers submitted applications “tendered” until the 

acceptance review is complete. If it is found during acceptance review 

that the application does not contain sufficient information, the application 

may remain tendered while the applicant submits supplemental 

information, or may be denied.

The process of developing and issuing RAIs begins after either the 

submission of the application or acceptance review and culminates in a 

licensing decision. NRC reviewers have to make a conclusion that what 

the licensee is proposing provides a reasonable assurance of safety; this 

allows reviewers to complete a safety evaluation report and conduct both 

a technical review and a regulatory review. If NRC’s reviewers are able to 

arrive at a conclusion with the information that the licensee provided in 
Letter

the application, then there is no need for NRC to issue an RAI. However, 

if there are areas where the information the licensee has submitted 

appears incomplete, then NRC staff will address these areas by 

developing and preparing RAIs for management review.

Page 7 GAO-17-344 Requests for Additional Information in Nuclear Licensing

13 After 

management review, NRC issues RAIs to licensees. Prior to issuance, 

NRC staff may also send draft RAIs to the licensee and reach out to the 

licensee via telephone to ensure that the information that NRC needs is 

understood and that the RAI language is clear. In such cases, NRC would 

issue the formal RAIs after this outreach. The licensee is then expected to 

submit responses to the RAIs within a specified period of time, typically 

within 30 or up to 60 days. The NRC review team may develop and issue 

additional, follow-up questions to the original RAIs—also known as 

“additional rounds”—if the review staff requires more information than the 

licensee’s initial response contained. When the NRC review team has the 

information needed to ensure a fully informed, technically correct, and 

legally defensible decision, it will either approve or deny the license 

application.

Individual NRC Offices Have Their Own 

Guidance to Issue RAIs and Are Updating It in 

an Effort to Improve the RAI Process

Each NRC office that issues RAIs has its own guidance, and the Office of 

Nuclear Reactor Regulation, the Office of New Reactors, and some 

divisions in the Office of Nuclear Material Safety and Safeguards have 

efforts underway to update guidance intended to improve oversight of 

RAIs. Guidance for developing and issuing RAIs is generally the same 

across individual offices that issue them but also reflects each office’s 

own specific responsibilities and procedures.

NRC Offices Have Their Own Guidance to Issue RAIs, 

and Offices Have Efforts Under Way to Update Guidance 

Intended to Improve RAI Oversight

NRC offices that issue RAIs each have their own guidance, and some 

offices have been updating their guidance over the past year in an effort 

 

13NRC uses contractors when the agency does not have staff with the specific expertise 

required to support the review of a particular license application.
Letter

to improve the RAI process. This updated guidance includes an increased 

focus on ensuring staff compliance with the process through managerial 

review. The Office of Nuclear Reactor Regulation’s guidance on RAIs is 

contained in an office instruction document for license amendment-review 

procedures called LIC-101. In April 2016, the Office of Nuclear Reactor 

Regulation issued an expectations memorandum to staff intended to 

provide additional guidance and clarity to expectations addressed in 

existing office guidance and practice. For example, the expectations 

memorandum elevates the issuance of additional questions on the same 

topic to divisional management to discuss the need for an additional 

round of RAIs before submitting them to a licensee. The memorandum 

also calls for the branch chief to review the draft safety evaluation report 

and confirm that the holes in the draft report align with RAIs. This is a 

change from the version of LIC-101 that officials had been using.

Page 8 GAO-17-344 Requests for Additional Information in Nuclear Licensing

14 NRC 

incorporated changes contained in the April 2016 expectations 

memorandum into a new edition—version five—of LIC-101 in January 

2017.15 The Office of Nuclear Reactor Regulation’s management also 

issued a memorandum in August 2016 to all operating reactor licensees 

that stated, among other things, that staff will actively seek opportunities 

to conduct an on-site audit or a public meeting in order to reduce the 

number of rounds of RAIs.

In the Office of New Reactors, office instruction document NRO-REG-101 

provides information to guide staff in the processing of RAIs. In 2008, the 

office also produced a detailed pamphlet on the RAI process—called a 

job aid—intended to help standardize office practices, ensure proper 

focus in the reviews, and enhance efficiency. In October 2016, 

management in the Office of New Reactors issued a memorandum to 

staff on the effective use of RAIs in new reactor licensing reviews. 

According to the memorandum, all RAIs in the Office of New Reactors will 

be reviewed up through division management, and the office director will 

review samples of RAIs in an effort to keep informed of issues deemed 

high priority identified in reviews. This memorandum accompanied an 

updated RAI job aid to replace the earlier version, as well as two other job 

aids focused on carrying out audits and confirmatory analysis, in which 

NRC staff conduct an independent assessment of a licensee’s 

 

14Nuclear Regulatory Commission, “Office of Nuclear Reactor Regulation Office

Instruction: License Amendment Review Procedures,” LIC-101 Revision 4, (May 25, 

2012).

15Nuclear Regulatory Commission, “Office of Nuclear Reactor Regulation Office 

Instruction: License Amendment Review Procedures,” LIC-101 Revision 5, (Jan. 9, 2017). 
Letter

calculation. The updated RAI job aid contains some modifications to the 

text from the 2008 version that include, for example, instruction to division 

management to audit draft RAIs to assure conformance with office 

expectations for quality.

RAI guidance for the Office of Nuclear Material Safety and Safeguards’

Division of Spent Fuel Management is contained in an instruction 

document referred to as SFM-3.

Page 9 GAO-17-344 Requests for Additional Information in Nuclear Licensing

16 The division issued a new instruction 

document in August 2016—referred to as Office Instruction 26—that is 

intended to provide management expectations and guidance to 

employees.17 The document calls for staff to follow the existing division 

guidance for RAIs and outlines new guidance that staff are required to 

follow as well. This new guidance includes preparing, for supervisory 

review, a draft safety evaluation report showing the regulatory holes that 

call for RAIs. The new guidance also calls for notifying management of 

additional rounds of RAIs and receiving management concurrence before 

issuance. The office’s Division of Material Safety, State, Tribal and 

Rulemaking Programs relies on guidance contained in Volume 20 of a 

multi-volume series of guidance documents on materials licenses called 

NUREG-1556.18 Volume 20 provides guidance on administrative licensing 

procedures and, according to officials, is currently being updated along 

with the other volumes in the series. Officials told us that Volume 20 is 

expected to be published as a draft report for comment in spring 2017 

and published as a final report sometime that year.

According to officials, procedures to process RAIs in the Division of 

Decommissioning, Uranium Recovery, and Waste Programs were first 

issued in 2000. These procedures include the requirement that a draft 

safety evaluation report be used to support RAIs, calls for RAIs to refer to 

specific portions of regulation, guidance, or both when issued to 

licensees, and encourages staff to conduct telephone conferences to 

discuss technical issues and possible resolution. The instruction 

document covers licensing as it applies to all project managers, technical 

reviewers, and staff within the Division of Decommissioning, Uranium 

 

16Nuclear Regulatory Commission, “DSFM Division Instruction Change Notice: Requests 

for Additional Information,” SFM-3, Rev. 5. 

17Nuclear Regulatory Commission, “SFM Division Instruction: Operational Strategies and 

Management Expectations,” SFM-26, Rev. 0 (Aug. 8, 2016). 

18Nuclear Regulatory Commission, “Consolidated Guidance About Materials Licenses,”

NUREG-1556, Vol. 20 (December 2000).
Letter

Recovery, and Waste Programs. According to officials, the most recent 

revision to the procedures in 2009 did not include changes to specific 

procedures guiding the development of RAIs.

In addition to guidance, NRC’s offices have practices in place intended to 

ensure management and staff continue to focus on improving RAIs. 

Officials from each of the NRC offices that issue RAIs said that their 

management is continually focused on improving RAIs. For example, 

officials from the Office of New Reactors told us there are plans to assess

the revised process for developing and issuing RAIs throughout upcoming 

license reviews to look for additional opportunities for improvement. In the 

Office of Nuclear Material Safety and Safeguards, officials told us that 

RAIs receive attention from the management of all divisions and that 

office leadership is working with licensee representatives to identify ways 

to improve the RAI process. Officials also told us that because most of 

the staff are involved in the process to develop and issue RAIs, it is an 

essential component of their work. As a result, their work on RAIs will 

factor into their performance review. According to officials, NRC’s 

standards for employee assessments are written at a general level for 

almost all staff at NRC. Technical staff are evaluated against four 

standards: planning and implementation, problem solving and analysis, 

communication, and professional development and organizational 

effectiveness.

NRC Offices’ Guidance Reflects Their Specific 

Page 10 GAO-17-344 Requests for Additional Information in Nuclear Licensing

Responsibilities and Procedures, but Processes Are 

Similar across Offices

According to NRC officials, the individual guidance developed by each 

office reflects the office’s own responsibilities and procedures. Guidance 

may differ across offices when a license application requires review by 

multiple technical branches; one office may issue RAIs to the licensee as 

they are completed by a technical branch, while another may wait to issue 

RAIs until all relevant technical branches have completed the initial 

review. For example, the Fuel Cycle Licensing Review Handbook used by 

the Division of Fuel Cycle Safety, Safeguards and Environmental Review 

in the Office of Nuclear Material Safety and Safeguards notes that if the 

same regulatory issue occurs in more than one technical section, the 

issue should be addressed in a general section rather than multiple times 

in each section. The handbook also encourages reviewers to issue one 

set of RAIs, as opposed to multiple sets.
Letter

Guidance on the response times given to licensees also differs among 

NRC offices. Consequently, the Office of Nuclear Reactor Regulation’s 

guidance document, LIC-101, calls for licensees to respond to RAIs in 30 

days or within a timeframe specified by the review team. Updates 

intended to align LIC-101 with the office’s expectations memorandum 

include guidance for a default response period of 30 days, an extended 

response period of 60 days, and approval for a longer response period if 

the review schedule allows. However, the Office of Nuclear Material 

Safety and Safeguards’ Fuel Cycle Licensing Review Handbook calls for 

the project manager to set a response date of 30 to 60 days. The Office 

of New Reactors’ guidance for RAIs references NRC regulations calling

for responses within 30 days of the date of the request, and states that 

applicants will be encouraged to respond to questions once they have 

prepared their responses, rather than respond to packages of multiple 

questions on a set date. The Office of New Reactors’ guidance also 

requires that officials use email to transmit RAIs.

In addition, guidance on the level of management’s review given to RAIs 

varies by NRC office. RAIs issued for combined license applications and 

early site permits in the Office of New Reactors are automatically sent to 

branch managers and are reviewed by both division management and the 

Office of General Counsel.

Page 11 GAO-17-344 Requests for Additional Information in Nuclear Licensing

19 Guidance for the Office of Nuclear Reactor 

Regulation states that RAIs should be reviewed by branch managers. It 

also calls for branch managers and staff to discuss the need for a second 

round of RAIs and whether alternative methods to obtain information—

such as a public meeting or an audit—may be more effective and 

efficient. In the Office of Nuclear Material Safety and Safeguards, the 

level of management review is determined by the guidance of each 

division. For example, in the Division of Spent Fuel Management, RAIs 

must be submitted to branch management for review, and divisional 

management must be notified of additional rounds of RAIs.

Nevertheless, based on our review of the guidance, the guidance is 

generally the same across the offices. Specifically, guidance for the 

different offices describes similar processes for issuing RAIs, including 

 

19A combined license application requires the applicant’s qualifications, design safety, 

environmental impact, operational programs, site safety, and verification of construction, 

and authorizes the licensee to construct and operate a nuclear power plant at a specific 

site. An early site permit authorizes a specific site for a nuclear power facility, requiring 

that the applicant address site safety issues, environmental protection issues, and 

emergency preparedness in the application.
Letter

the reason for issuing an RAI, the procedures undertaken to develop 

RAIs, and time frames during the process. Guidance for all offices states 

that RAIs should be used to gain the information needed for making a 

licensing decision, and due to recent updates, most office guidance also 

states that RAIs be used to fill gaps in a safety evaluation report. The 

process for developing and issuing an RAI is also similar across all 

offices, and includes: (1) the development of RAIs by technical reviewers 

based on information contained in an application, (2) the review of 

proposed RAIs by management, (3) the issuance of RAIs to licensees for 

response, and (4) the incorporation of information received through RAIs 

into the safety evaluation report and final licensing decision. Additionally, 

guidance across all offices includes direction on setting time frames for 

issuing RAIs and receiving responses from licensees.

NRC Offices Do Not Track the Number of RAIs 

Page 12 GAO-17-344 Requests for Additional Information in Nuclear Licensing

They Issue, and Certain Activities Often Elicit 

RAIs

NRC offices do not track the number of RAIs and do not know how many 

they have issued over the past 5 years, and there is no legal requirement 

for NRC to track the number of RAIs it issues. According to NRC officials 

and some licensees we interviewed, certain activities and circumstances 

often elicit RAIs, such as complex licensing actions and activities for 

which regulations are unclear.

Offices Do Not Track the Number of RAIs That NRC 

Issues, and There Is No Legal Requirement to Do So

NRC offices that issue RAIs do not specifically track the number of RAIs 

that they issue, and there is no legal requirement for the agency to track 

the number of RAIs. An official from the Office of New Reactors estimated 

that a combined license application could have 1,000 RAIs, while a 

license amendment request could have few, if any, RAIs. Officials added 

that the number of RAIs issued in a given review varies depending on the 

complexity and size of the requested licensing action. Officials also said 

the number of RAIs per year depends on how many license applications 

the office receives; it can take 5 years or more to review and make a 

decision on a combined license application. In contrast, for plants that are 

licensed, officials said that NRC typically reviews 20 to 25 license 
Letter

amendments per year. According to officials, the Office of Nuclear 

Reactor Regulation reviews about 700 licensing actions per year, and 

officials also estimated that on average, each licensing action has 5 to 10 

RAIs. Officials added that the Office of Nuclear Material Safety and 

Safeguards reviews about 1,800 license applications or amendments per 

year, with varying numbers of RAIs per action.

NRC officials cannot say with certainty how many RAIs they have issued 

over the past 5 years, in part because the current internal tracking 

systems used by the Office of Nuclear Reactor Regulation and the Office 

of Nuclear Material Safety and Safeguards do not track the number of 

RAIs. Officials in the Office of Nuclear Reactor Regulation told us that 

they do not track the number of RAIs because RAIs are only one 

component in the broader licensing process. Instead, officials said, they 

focus more on whether the office is carrying out licensing activities in an 

efficient, effective manner. The Office of New Reactors has an internal 

tracking system, called eRAI, which is specifically configured to manage 

RAIs and is capable of tracking the number of RAIs per year. However, 

according to an official, the office does not use eRAI to track the number 

of RAIs. Instead, the Office of New Reactors uses eRAI to monitor RAIs 

associated with applications that can be up to 12,000 pages long, identify 

related questions, and track RAIs by regulatory issue area.

Some NRC offices have been working to update their internal tracking 

systems for licensing actions. These updates are intended to, among 

other things, allow officials to better track milestone dates in the licensing 

action process, such as the date that an RAI response is due. For 

example, the Office of Nuclear Reactor Regulation is changing to a new 

system called the Replacement Reactor Program System, which tracks 

major milestones within each of the licensing reviews. Unlike the previous 

system, the new system can track multiple rounds of RAIs. In addition, 

according to NRC officials, the Division of Spent Fuel Management in the 

Office of Nuclear Material Safety and Safeguards is moving to a webbased tracking system from a system that only tracked milestone dates. 

The new system is intended to track RAIs and to help identify issues early 

in the process that may influence the timeliness of the review. Elsewhere 

in the Office of Nuclear Material Safety and Safeguards, officials in the 

Division of Fuel Cycle Safety, Safeguards and Environmental Review told 

us that they are upgrading their tracking system and will use the same 

one as the Division of Spent Fuel Management. Further, the office’s 

Division of Material Safety, State, Tribal, and Rulemaking Programs is 

also in the process of enhancing its tracking system by streamlining the 

Page 13 GAO-17-344 Requests for Additional Information in Nuclear Licensing
Letter

process to allow the staff to issue licensing actions directly from the 

system.

NRC officials told us that tracking the number of RAIs is challenging and 

may not reflect the role that RAIs play in the licensing process. According 

to officials, counting the number of RAIs may be challenging because 

different reviewers can refer to an RAI as a single question, or as a letter 

to a licensee containing several questions. Officials also told us that the 

number of RAIs does not capture the variance in size and complexity of 

RAIs; for example, NRC may request simple editorial changes that 

require little effort and time on the part of the licensee, or RAIs may 

request additional technical analyses that require more effort and time to 

address.

RAIs Are Not Unusual, and Certain Activities Often Elicit 

Page 14 GAO-17-344 Requests for Additional Information in Nuclear Licensing

RAIs

NRC officials told us that receiving RAIs as part of a licensing action is 

not unusual, and officials and licensees we interviewed said that RAIs are 

often issued for the following activities and circumstances: complex 

licensing actions, activities for which regulations are unclear, new 

activities, and when the initial application does not contain adequate 

information or detail.

Complex licensing actions: NRC officials told us that licensing actions 

and the associated RAIs vary greatly in complexity, and the number of 

RAIs issued may vary depending on the complexity of the review. Some 

actions are simple and may take 40 to 80 hours to review, while others 

are more complex and may take more than 5,000 hours for review. Many 

licensees we interviewed stated that they would expect to receive more 

RAIs for more complex licensing actions. For example, a licensee we 

interviewed told us that most of the RAIs the company receives are 

related to technical specifications, which are NRC’s standardized 

requirements for its approved reactor types. Officials from this licensee 

said they may receive additional questions for technical specifications and 

issues that are plant-specific, such as differences in equipment when 

compared to other plants with the same reactor type, and more detailed 

drawings and information about the plant’s equipment. Conversely, 

another licensee told us that a simple license amendment request for a 

name change on a license did not elicit any RAIs.
Letter

Unclear regulatory guidance: Some licensees we interviewed also said 

that they would expect to receive more RAIs for activities for which 

regulations are unclear and may require increased coordination between 

NRC and the licensee. One licensee described an instance where 

guidelines pertaining to the licensing action were not clear, and it took

several years and additional RAIs to try to reach agreement with NRC. 

NRC officials told us that licensees are most likely to receive RAIs in 

cases where they request an exception to regulatory guidance. NRC 

officials and licensees said that a request for an exception can occur, for 

example, when a licensee asks NRC for a license to use a construction 

material that is not referenced in regulatory guidance. Further, NRC 

officials said that applications for new reactors typically elicit RAIs, 

particularly when technology proposed by licensees does not align with 

regulations, such as the shift from analog instrumentation and controls 

used in most operating reactors to digital instrumentation and controls 

proposed for new reactors.

First-of-its-kind activities: NRC officials told us that a new type of 

licensing action may require more RAIs. Half of the licensees we 

interviewed told us that they received RAIs when requesting a license for 

an activity that is the first of its kind or is setting a precedent. For 

example, a licensee stated that the company received RAIs for a license 

amendment that was one of the first submitted to NRC for a particular 

activity.

Quality of the application: Officials told us that the number of RAIs 

associated with each license application often depends on the quality of 

the application. For example, a license application or response to an RAI 

that does not contain adequate information can result in more than one 

round of RAIs. Conversely, an application that is comprehensive and 

addresses all of the requirements outlined in NRC guidance is less likely 

to receive RAIs, and if RAIs are issued, they are less likely to receive 

more than one round of RAIs. Some licensees told us that they may 

receive RAIs for issues that may have been addressed in another 

application or, as one licensee stated, were otherwise obvious; licensees 

noted that this was likely because NRC wanted that information included 

as part of the docket.

The nongeneralizable sample of licensing actions that we reviewed 

reflected several different types of licensing actions and contained RAIs 

that varied in format. We reviewed three licensing actions that contained 

RAIs—each one representing one of the three offices that issue RAIs. 

One action was for a license renewal, another was for a license 

Page 15 GAO-17-344 Requests for Additional Information in Nuclear Licensing
Letter

amendment request, and the third was for a relief request. One of the 

licensing actions received four RAIs sent in two separate e-mails several 

weeks apart. NRC officials described these as “official” RAIs, which they 

followed with an email identifying apparent editorial errors in the 

application. In another example, NRC sent a licensee two draft RAIs in 

advance of the formal RAI submission. With regard to the types of 

information that NRC asked in its RAIs, one RAI asked for clarification on 

technical specifications the licensee used to support its request. Another 

asked for specific information about the equipment used, including name 

and model number, as well as details concerning maintenance. In the 

third example, NRC asked for clarification about testing completed for a 

particular piece of equipment in order to approve a license renewal. 

Because this was a nongeneralizable sample, our results are not 

generalizable to all licensing actions but provide illustrative examples of 

the types of information included in RAIs.

Licensees Were Generally Satisfied with the 

Page 16 GAO-17-344 Requests for Additional Information in Nuclear Licensing

RAI Process but Also Identified Weaknesses, 

Which NRC Has Made Recent Efforts to 

Address

Many of the licensees we interviewed were generally satisfied with the 

current process to develop and issue RAIs and identified certain 

strengths. NRC officials and licensees also identified two common 

weaknesses in the process to develop and issue RAIs, weaknesses that 

NRC has made recent efforts to address.

Licensees We Interviewed Were Generally Satisfied with 

the RAI Process and Identified Certain Strengths

Many of the licensees we interviewed expressed satisfaction with NRC’s 

current process to develop and issue RAIs and acknowledged the role of 

RAIs in the licensing process. Some said that they viewed them as a 

natural part of interacting with a regulator. For example, one licensee said 

that RAIs are needed to allow for formal communication between NRC 

and licensees on issues that may arise again in future licensing actions. 

Some licensees said that the experience with NRC had been positive, 

and another stated that the RAI process worked well for completing 

licensing actions.
Letter

Licensees identified NRC guidance as a strength of the RAI process. 

Most licensees we interviewed told us that they found NRC guidance to 

be helpful; such guidance includes regulatory documents, procedural 

documents, and memorandums. For example, the majority of the 

licensees we interviewed that worked with the Office of Nuclear Reactor 

Regulation said that the office’s April 2016 expectations memorandum 

was a positive step by the agency and an improvement in the RAI 

process. Specifically, one licensee told us that the policy of ensuring that 

RAIs ask for information needed to fill a gap in the safety evaluation 

report—as outlined in the memorandum—was an appropriate procedure. 

Some licensees also said that they found it particularly useful when NRC 

reviewers identified for them specific passages of a guidance document 

relevant to the licensing action or RAI.

Licensees we interviewed also identified NRC’s openness to 

communication and engagement as a strength of the RAI process. Most 

licensees we interviewed said that communication with NRC staff during 

the process to develop and issue RAIs was helpful, including preapplication meetings, informal interactions via phone or e-mail, and 

coordination with project managers. As mentioned above, pre-application 

meetings provide an opportunity for the licensee and NRC to clarify 

potential issues or questions before the initial license application is 

submitted and RAIs are issued. Of those licensees we interviewed who 

participated in a pre-application meeting, the majority said that the 

meeting helped to either resolve or clarify issues before the acceptance 

review. Some licensees said that pre-application meetings were 

particularly helpful when NRC staff assigned to the review participated, 

with one licensee stating that it was critical for the staff member who 

develops RAIs to be present. A licensee also stated that participating in a 

pre-application meeting significantly reduced the number of RAIs issued 

later in the process. Additionally, some licensees told us that informal 

interactions via phone or e-mail with NRC staff also helped to resolve 

issues quickly, as opposed to clarifying or resolving issues through formal 

correspondence. Similarly, several licensees noted that the active 

engagement of project managers in the review process improved the 

efficiency of the review and the quality of RAI questions. For example, 

officials from one licensee said that in recent years NRC’s project 

manager e-mailed draft RAIs to them, which allows the licensee to review 

them in advance, ask clarifying questions, and propose response times. 

In another case, a licensee told us that a project manager included 

divisional management in a conference call to discuss RAIs, which 

resulted in NRC withdrawing some RAIs.

Page 17 GAO-17-344 Requests for Additional Information in Nuclear Licensing
Letter

In addition, several licensees we interviewed noted NRC’s 

responsiveness to industry operational issues and time constraints in the 

review process as a strength. Several licensees described instances in 

which operational issues or time constraints required flexibility from NRC, 

and they told us that NRC worked with them to ensure uninterrupted 

operation or service. Some licensees told us that NRC extended the 

response time required for RAIs when licensees asked for additional time. 

In another instance, a licensee described a case where NRC expedited 

the review process to prevent a disruption in patient medical care that 

relies on radiological material. An industry interest group representative 

we interviewed told us that both industry and NRC should take steps to 

ensure that the recent improvements to the process to develop and issue 

RAIs are maintained going forward.

Licensees Identified Two Common Weaknesses in the 

Page 18 GAO-17-344 Requests for Additional Information in Nuclear Licensing

RAI Process, Which NRC Has Made Recent Efforts to 

Address

Licensees and NRC officials that we interviewed identified weaknesses in 

the RAI process, including two commonly mentioned ones: (1) a gap 

between NRC’s expectations and licensees’ understanding of what 

should be included in a license application and (2) staff departure from 

guidance that leads to RAI questions that appear to be redundant or 

beyond the scope of the review.

Gap in expectations and understanding: NRC officials and licensees 

whom we interviewed told us that a gap between NRC’s expectations and 

licensees’ understanding of license application content can be a 

weakness of the RAI process. Both NRC officials and licensees stated 

that inconsistencies may exist between NRC’s expectations and 

licensees’ understanding of what should be included in a licensing 

application, especially in cases of complex or new activities. According to 

NRC officials, such inconsistencies can lead to reviewers’ using RAIs to 

gather the information needed to make a licensing decision. NRC officials 

said that varying levels of understanding regarding expectations may 

result in confusion for licensees and may incentivize them to exert fewer 

resources when developing an initial application. According to one NRC 

official, licensees may submit an application containing enough technical 

information to pass the acceptance review with the understanding that 

NRC will develop RAIs to address unresolved issues in the application. 

Officials added that the standard and level of detail required for issuing a 

licensing action is more stringent than that for an acceptance review. For 
Letter

half of the licensees, expectations have become clearer in the last several 

years as a result of increased communication with NRC. However, 

several licensees we interviewed identified unclear or inconsistent 

expectations as a current concern. For example, one licensee described 

a case where a license amendment received RAIs on a new activity for 

which NRC did not have permanent guidance in place. The licensee 

rescinded the license amendment request rather than expend the 

resources needed to answer RAIs according to NRC’s interim guidance.

The Office of New Reactors, the Office of Nuclear Reactor Regulation, 

and the Division of Spent Fuel Management in the Office of Nuclear 

Material Safety and Safeguards have made recent efforts to address 

inconsistencies between NRC’s expectations and licensees’

understanding by emphasizing greater communication between review 

staff and licensees. The Office of New Reactors placed more emphasis 

on the pre-application period in which the NRC review team works with 

licensees to resolve questions and potential issues that otherwise may 

necessitate formal RAIs. In addition, through its April 2016 expectations 

memorandum, the Office of Nuclear Reactor Regulation’s management is 

encouraging project managers and review staff to engage in increased 

communication with licensees to resolve questions, in addition to placing 

increasing emphasis on acceptance review. Division of Spent Fuel 

Management leadership has also made recent efforts to encourage more 

frequent conversations through updated guidance. Some licensees we 

interviewed recognized NRC’s efforts, and one licensee told us that NRC 

officials have recently been more receptive to discussing RAIs over email, a practice which has helped to make the process more efficient. It is 

too soon to tell whether these initiatives will address the gap in 

expectations between NRC and licensees in the long term.

Staff departure from guidance: NRC officials and licensees both told us 

that some staff may depart from guidance by issuing redundant or 

unrelated RAIs, which may require additional time and resources for the 

licensee to address. According to officials and licensees, an RAI is 

redundant if the information requested is contained in or could be inferred 

from information contained in the original license application, other 

correspondence, or a response to a previous RAI. Likewise, an RAI is 

unrelated to the application if the information requested is not necessary 

for making a regulatory decision or filling a gap in the safety evaluation 

report. NRC officials said that ensuring staff adherence to internal 

guidance regarding appropriate RAIs can be challenging, and many of the 

licensees we interviewed identified the influence of individual staff 

reviewers as a weakness of the process to develop and issue RAIs. Half 

Page 19 GAO-17-344 Requests for Additional Information in Nuclear Licensing
Letter

of the licensees we interviewed said that they noticed questions that were 

either redundant or seemed to appear unrelated to a regulatory 

requirement, but which may have been intended to satisfy the individual 

reviewer’s curiosity. Some licensees also said that inexperienced 

reviewers may ask redundant questions or revisit issues that have 

already been resolved and codified in the licensing document through 

prior communication with NRC. According to licensees, redundant or outof-scope RAIs create additional work for them, and most of the licensees 

interviewed identified the impact of RAIs on resources as a related 

weakness of the RAI process. For example, one licensee reported 

receiving questions outside of the scope of the license application that 

required additional analyses and work—nearly doubling the length of the 

review and costing the licensee almost double the amount in fees 

budgeted for the review.

In an effort to mitigate concern over the influence of individual staff 

reviewers, the Office of New Reactors, Office of Nuclear Reactor 

Regulation, and the Division of Spent Fuel Management in the Office of 

Nuclear Material Safety and Safeguards recently updated guidance and 

introduced more management review of RAIs. As mentioned above, 

updated NRC guidance includes an increased focus on ensuring staff 

compliance with the RAI process. For example, the offices and division 

cited above have recently updated internal guidance to clarify the 

expectation that staff reviewers use RAIs to fill holes in a draft safety 

evaluation report. Guidance updated by all three offices also includes 

calls for elevating questions at least to divisional management: in the 

Office of Nuclear Reactor Regulation and the Division of Spent Fuel 

Management, all second-round RAIs require division management 

approval; and in the Office of New Reactors, all RAIs require divisional 

management approval and the office director reviews samples of RAIs on 

high priority issues. Half of the licensees we interviewed expressed that 

these efforts represent an improvement in the RAI process. Several 

licensees specifically described the expectations memorandum issued by 

the Office of Nuclear Reactor Regulation as an improvement, and officials 

from one licensee noted that they have seen progress with NRC’s 

management intervening when potential unnecessary questions are 

identified. Because these efforts were made recently, it is too early to 

assess the effectiveness of such approaches to mitigating the influence of 

individual staff reviewers.

Page 20 GAO-17-344 Requests for Additional Information in Nuclear Licensing
Letter

Agency Comments and Our Evaluation

Page 21 GAO-17-344 Requests for Additional Information in Nuclear Licensing

We provided a draft of this product to NRC for comment. NRC generally 

agreed with our findings and provided technical comments, which we 

incorporated as appropriate. NRC’s comments are reprinted in Appendix 

I.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to appropriate congressional 

committees and the Chairman of the Nuclear Regulatory Commission. In 

addition, the report will be available at no charge on the GAO website at 

http://www.gao.gov.
Letter

If you or your staff have any questions about this report, please contact 

me at (202) 512-3841 or ruscof@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made key contributions to this report 

are listed in appendix II.

Frank Rusco

Director, Natural Resources and Environment

Page 22 GAO-17-344 Requests for Additional Information in Nuclear Licensing
Appendix I: Comments from the Nuclear 

Regulatory Commission

Page 23 GAO-17-344 Requests for Additional Information in Nuclear Licensing

Appendix I: Comments from the Nuclear 

Regulatory Commission
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 24 GAO-17-344 Requests for Additional Information in Nuclear Licensing

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Frank Rusco, (202) 512-3841 or ruscof@gao.gov

Staff Acknowledgments

In addition to the individual named above, Hilary Benedict (Assistant 

Director), Bridget Grimes, and Rachel Rhodes made key contributions to 

this report. Tim Bober, Kevin Bray, Antoinette Capaccio, Cindy Gilbert, 

Timothy M. Persons, and Dan Royer also made important contributions.
Appendix III: Accessible Data

Page 25 GAO-17-344 Requests for Additional Information in Nuclear Licensing

Appendix III: Accessible Data

Agency Comment Letter

Text of Appendix I: Comments from the Nuclear 

Regulatory Commission

March 17, 2017

Mr. Frank Rusco, Director

Natural Resources and Environment

U.S. Government Accountability Office 441 G Street, NW

Washington, DC 20226 Dear Mr. Rusco:

On behalf of the U.S. Nuclear Regulatory Commission (NRC), Iam 

responding to your e-mail dated February 14, 2017, which provided the 

NRC an opportunity to review and comment on the U.S. Government 

Accountability Office (GAO) draft report GA0-17-344, "Nuclear Regulatory 

Commission: Efforts Intended to Improve Procedures for Requesting 

Additional Information for Licensing Actions are Underway."

The NRC staff appreciates the opportunity to review the draft report, and 

we appreciate the GAO staff's professionalism and many constructive 

interactions during this GAO engagement. Overall, the NRC agrees with 

the draft report and its findings. The draft report accurately describes the 

request for additional information process and the efforts the NRC has 

taken to make this process more efficient and effective. In the enclosure 

to this letter, we have provided some minor comments and clarifications 

for your consideration.

Thank you again for the opportunity to provide comments on the GAO 

report. Please feel free to contact Mr. John Jolicoeur at (301) 415-1642 

or John.Jolicoeur@nrc.gov if you have questions or need additional 

information.

Victor M. Mccree
Appendix III: Accessible Data

Executive Director for Operations

Enclosure:

NRC Comments on Draft Report GA0-17-344

Page 26 GAO-17-344 Requests for Additional Information in Nuclear Licensing (100910)
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