ML25083A143

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T6: S. Klein - Industrys Vision for Efficient Licensing: Policy, Regulation, and Innovation
ML25083A143
Person / Time
Site: Nuclear Energy Institute
Issue date: 03/11/2025
From: Klein S
Nuclear Energy Institute
To:
NRC/NRR/DANU
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Download: ML25083A143 (12)


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©2025 Nuclear Energy Institute Industry's Vision for Efficient Licensing:

Policy, Regulation, and Innovation March 11th, 2025 Spencer Klein Senior Project Manager, New Nuclear

©2025 Nuclear Energy Institute Goals for NEIs Generic Regulatory Work Enable new business models, specifically focusing on applications with technological characteristics, and concepts of deployment and operation to support high-volume deployment of nuclear reactors, and Maximize the applicability of proposed approaches to other advanced reactors and business models.

Regulations of Rapid High-Volume Deployable Reactors in Remote Applications and Other Advanced Reactors Interest in Business Model for Oil & Gas Upstream Less than 180 days from specific site identification to operations Regulatory costs are less than 1% of capital and O&M Enabling High-Volume Reactor Deployment

©2025 Nuclear Energy Institute Prioritization of Resolving Issue Topics

©2025 Nuclear Energy Institute Design Features

  • Physically small and simple
  • Low risks and consequences
  • Small footprint - land and environmental
  • Safety relatively insensitive to site conditions
  • Factory construction
  • Site assembly
  • May load fuel at factory and ship fueled
  • Fully replaceable modules Applications and Use Cases
  • Remote locations and micro-grids
  • Industrial applications (heat and power)
  • Large volume of deployments
  • Deployment in months not years
  • No disproportionate regulatory costs
  • Limited or no on-site fuel movements
  • Limited time of used fuel on-site Alternative Regulatory Approaches
  • Incentivize safety enhancements
  • Avoid undue regulatory burden
  • Leverage use of manufacturing license or design certification
  • Technology-inclusive, performance-based and risk-informed
  • Oversight scaled to the safety profile
  • More similar to research and test reactors Rationale for An Alternative Regulatory Approach

©2025 Nuclear Energy Institute Rapid Efficient Repeatable Licensing Process

©2025 Nuclear Energy Institute NRC Processes that Could Enable Rapid Efficient Licensing of Sites

©2025 Nuclear Energy Institute Aircraft Impact Assessments (Methodology Under Development)

Schedule:

Q2 2025: Submittal to NRC

Background:

The 10 CFR Part 50.150 Aircraft Impact Assessment (AIA) Rule requires applicants to perform a design-specific assessment of the effects on the facility of the impact of a large, commercial aircraft.

NEI Lead: Jon Facemire Issue Statement:

NRC-endorsed guidance for meeting 50.150 assumes a large light water reactor and credits primarily concrete and steel containment structures that ensure the reactor and its cooling systems are protected. NEI is proposing additional acceptance criteria for smaller reactors including:

Hitability - Microreactors may be underground or too small to target.

Source term - Microreactors may have small enough radionuclide inventories that there is no credible large release.

Microreactors may rely on robust fuel like TRISO which may withstand the aircraft impact.

©2025 Nuclear Energy Institute Meteorology and Weather Data (Methodology Under Development)

Schedule:

Q2 2025: Submittal to NRC

Background:

NRC last updated guidance (RG 1.23) for Meteorological Monitoring programs in 2007. Data sources have improved with high quality data available from NOAA and state met stations which are used by EPA.

NEI Lead: Jon Facemire Issue Statement:

RG 1.23 is the sole NRC-endorsed methodology for site-specific meteorological data collection and requires installation of a 60m onsite tower. Potential cost and schedule impacts:

Potential critical path data collection

Eng/proc/install - up to 1 year (long-lead time on equipment)

Data collection - 1 to 2 years pre-application

Data processing and impact modelling - 6 months

Costs: +/- $1m

NEI is proposing use of existing data sources shortening timeline to <6 months and eliminating costs of constructing a site-specific tower

©2025 Nuclear Energy Institute Geologic and Geotechnical (Methodology Under Development)

Schedule:

Q4 2025: Submittal to NRC

Background:

RG 1.208 has guidance for the steps of performing site geo-characterization investigations specific to seismic-related hazards, identifying seismic sources (e.g., faults), developing a probabilistic seismic hazard analysis (PSHA), and accounting for local site effects (e.g., soil amplification).

NEI Lead: Jon Facemire Issue Statement:

Seismic aspects of site characterization for NPPs is resource-intensive in time and cost, and current regulatory guidance was based on gigawatt-scale LWRs.

New NPPs may come in all shapes and sizes. Industry desires confidence in using alternative approaches that require less resources

Building on an NRC White Paper, NEI is proposing a methodology for graded seismic site characterization

©2025 Nuclear Energy Institute Schedule:

Q1 2025: Submittal to NRC Population Siting Criteria (Basis Under Development)

Background:

10 CFR Part 100 and RG 4.7 provide population siting criteria (e.g.,

low population zone (LPZ), population center distance (PCD)) and guidance for siting away from densely populated areas NEI Lead: Marty ONeill / Kati Austgen Issue Statement:

The current population siting requirements in 10 CFR Part 100 were established more than 60 years ago during the nascent stages of the commercial nuclear power industry, and about 20 years before the NRC issued its first emergency preparedness (EP) regulations in 1980.

As a result, those requirements were focused on early large light-water reactor (LWR) technologies and developed using deterministic methods.

The safety features of those advanced reactors that enable them to establish that no plume exposure pathway (PEP) emergency planning zone (EPZ) is required, or that the PEP EPZ does not extend beyond the site boundary, should also enable LPZ and PCD at the site boundary.

©2025 Nuclear Energy Institute Process for Implementing the Proposed Approaches

Thank You for Your Time!