Terra Praxis is glad to have had the opportunity to review this document that the Nuclear Energy Institute just submitted to the Nuclear Regulatory Commission to lay out a predictable and efficient licensing pathway for manufactured reactors. As the document notes, it is critical that the regulation be capable of meeting the requirements of commercial customers.
With nuclear power on the advent of an unprecedented opportunity, the NRC, industry, and even Congress have identified the need for modernization of regulatory processes. Advanced reactors bring with them very different manufacturing, construction, and operational models, coupled with vastly different business models that will enable and require adaptation of the regulatory processes that have developed to date. Rapid high-volume deployable reactors in remote applications (RHDRA) have low potential radiological consequences that are on the order of research and test reactors, are capable of being fully assembled in the factory and delivered to site ready to operate, and blend simplicity with automatic features that allows a single on-site operator, or no on-site operators with the use of remote operations.
This paper proposes numerous changes to NRC regulations and implementing guidance that would achieve a modern regulatory framework that is more effective and efficient to address the unique considerations of RHDRA, and would also benefit larger advanced (light-water and non-light-water) reactors. These proposals align with and expand upon the NRC’s valuable efforts to establish a modern and efficient regulatory framework for new and advanced reactors consistent with the 2019 Nuclear Energy Innovation and Modernization Act (NEIMA). These proposals would also form the basis for risk informed and performance-based strategies and guidance to license and regulate micro-reactors that meet the requirements in Section 208 of the ADVANCE Act of 2024. Furthermore, these proposals could satisfy, in part, other requirements in the ADVANCE Act that are contained in Sections 206, 505, 506 and 507. Input specific to those and other sections of the ADVANCE Act will be provided separately.