Will the NRC issue a Request for Additional Information (RAI) or supplemental information request on FRMI's COLA application by December 31, 2026?

NRC RAIs are a standard, expected part of the COLA review process — virtually every nuclear application receives multiple rounds of RAIs. The question is not whether an RAI will be issued but when. With the application accepted and a 9-month window (March to December 2026), the NRC's typical review timeline strongly suggests at least initial RAIs would be issued. The only scenario for NO is if the NRC review proceeds extremely slowly (processing backlog) or the application is so deficient that it requires a fundamentally different type of response. Historical NRC review patterns show RAIs within 6-12 months of acceptance.

The question asks about RAI or supplemental information requests — a very broad category that encompasses most forms of NRC engagement beyond simple acknowledgment. Given that FRMI's application is the first large reactor COLA in 15+ years, the NRC will likely apply heightened scrutiny. The fact that FRMI has not publicly disclosed its reactor design compounds the likelihood of RAIs — the NRC will need detailed technical information that may not be in the initial application. The 9-month window is generous for initial RAIs.

NRC review of COLA applications historically involves extensive RAI exchanges. The committee identified NRC as the existential variable with REGULATORY_EXPOSURE at EXISTENTIAL. For the question to resolve NO, the NRC would need to either (a) not begin substantive review within 9 months, or (b) find the application so complete that no additional information is needed. Neither scenario is likely given the unprecedented nature of the application, the undisclosed reactor design, and NRC's thorough review standards. I estimate 80% probability that some form of formal information request will be issued.

This is nearly certain. RAIs are the default NRC engagement mechanism — it would be extraordinary for a COLA application, especially one this novel, to NOT receive RAIs. The 9-month window is more than sufficient. The NRC staff will begin technical review within months of acceptance and will inevitably identify areas requiring clarification. The only uncertainty is whether the NRC review timeline is so slow that formal RAIs haven't been issued by year-end 2026.

While RAIs are standard, I slightly discount for the possibility that the NRC is resource-constrained and this novel application may sit in queue longer than expected. The NRC has not reviewed a large reactor COLA in 15+ years, which could mean either (a) heightened priority (more attention, faster RAIs) or (b) institutional atrophy (slower processing, rebuilding review capability). I lean toward the former but acknowledge uncertainty about NRC processing capacity.

The question is broadly framed — any RAI, supplemental request, or deficiency notice counts. The NRC's formal review process almost always generates information requests within the first year. Given that FRMI filed a COLA for a novel application type and the NRC accepted it, substantive technical review should produce formal requests well within 9 months. The committee's EXISTENTIAL classification reinforces that the NRC process will be thorough and demanding.

RAIs are standard NRC procedure. Novel application type ensures scrutiny. 9-month window is sufficient for initial requests. High probability YES.

Standard NRC process strongly favors RAI issuance. Slight discount for possible NRC processing delays given this is the first large reactor COLA in 15+ years. The NRC may need to rebuild review capacity, potentially delaying formal requests. Still well above 50%.

Broad resolution criteria combined with standard NRC review process makes this highly likely. The undisclosed reactor design means information gaps are guaranteed. RAIs within 9 months of acceptance is consistent with historical NRC patterns.