ML25217A513
| ML25217A513 | |
| Person / Time | |
|---|---|
| Site: | 99902144 |
| Issue date: | 08/12/2025 |
| From: | Sayoc E NRC/NRR/DNRL/NLIB |
| To: | Jardaneh M NRC/NRR/DNRL/NRLB |
| Shared Package | |
| ML25217A506 | List: |
| References | |
| Download: ML25217A513 (3) | |
Text
Enclosure 3 U.S. NUCLEAR REGULATORY COMMISSION
SUMMARY
OF THE JULY 8, 2025, OBSERVATION PREAPPLICATION MEETING WITH HADRON ENERGY INC. TO DISCUSS TO DISCUSS THE HADRON MICROREACTOR DESIGN LICENSING STRATEGY AND REGULATORY ENGAGEMENT PLAN Meeting Summary The meeting held on July 8, 2025, focused on the Hadron Energy Inc., (Hadron) licensing strategy and regulatory engagement plan (REP). Various members from the U.S. Nuclear Regulatory Commission (NRC) and Hadron participated, including project managers, branch chiefs, senior inspectors, and technical reviewers. The meeting began with introductions, where participants highlighted their roles and expertise within their respective organizations.
Hadron's presentation was led by Samuel Gibson, Founder and Chief Executive Officer, and Ryan Mott, Director of Licensing and Operations. They introduced the Hadron microreactor, a 10 Megawatt (MW) electric, 30 MW thermal light-water-cooled reactor with a 10-year fuel cycle.
The presentation emphasized the use of mature, proven light-water technology for regulatory and safety advantages and discussed the challenges associated with the supply chain for HALEU (High-Assay Low-Enriched Uranium) fuel. They also outlined their REP, which was submitted on May 9, 2025,1 and revised on July 1, 20252. This plan is intended to provide transparency, and facilitate early engagement and resolution of technical and regulatory issues.
Hadron proposed a licensing strategy that includes a manufacturing license (ML), under Title 10 of the Code of Federal Regulations (10 CFR) Part 523, Subpart F, combined with a 10 CFR Part 704 license for possession of special nuclear material and fuel loading. They also considered a standard design approval (SDA), under 10CFR Part 52, Subpart E, and ML to streamline the regulatory process and discussed the potential for operational testing under a non-powered reactor license. In addition to the ML and special nuclear material handling license, Hadron will seek a 10 CFR Part 52 combined license in collaboration with future customers and may also consider a 10 CFR Part 535 pathway if it becomes available.
The presentation included several key sections. The Hadron microreactor is a light-water cooled, HALEU-fueled reactor using a proprietary design built on mature, proven technology, used in large nuclear power plants. The design avoids exotic fuels or materials, using thermal neutrons, a rectangular fuel lattice, uranium oxide fuel, and light-water coolant. Hadron's goal is to establish a manufacturing facility where Hadron Microreactors will be saleably produced, fueled, and shipped to their place of operation.
1 Letter from S. Gibson to NRC, Hadron Energy, Inc., Submittal of Microreactor Pre-Application Regulatory Engagement Plan for Standardized Microreactor Design, May 9, 2025, (ML25129A055) 2 Letter from S. Gibson to NRC, First Amended Hadron Energy Microreactor Pre-Application Regulatory Engagement Plan for Standardized Microreactor Design, July 1, 2025, (ML25182A304, part of ML25182A303) 3 Title 10 of the Code of Federal Regulations (CFR), 10 CFR 52 Licenses, Certifications, And Approvals for Nuclear Power Plants 4 10 CFR 70, Domestic Licensing of Special Nuclear Material 5 10 CFR 53, Risk Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors
2 The REP was drafted by Hadron's business, engineering, and regulatory teams using Nuclear Energy Institutes REP guidance6 available on the NRCs public website. The plan aims to provide a transparent view of Hadron's intended activities and facilitate early resolution of key technical and regulatory issues. The tentative schedule outlines key milestones, including the submission of topical reports, white papers, and various applications. Key dates include, September 2026 for the submission of the Standard Design Approval Application),
February 2027 for the submission of the Manufacturing License Application and Part 70 License Application (only possession and loading of pre-fabricated fresh fuel), and December 2028 for the submission of the Combined License Application (COLA) for the first site.
The NRC staff provided feedback and engaged in discussions about the proposed licensing pathways. They clarified the differences between SDA, ML, and design certification, noting that a ML provides more regulatory finality compared to an SDA and can be referenced in COLAs, construction permits, or operating licenses. The NRC staff suggested that the SDA may not be necessary, depending on Hadrons licensing goals.
Hadron also discussed the possibility of transporting fuel or a fueled reactor from either a domestic facility or a foreign country. The NRC staff explained the complexities of transporting the reactor and/or the fuel, including the need for Type AF (e.g., fresh fuel) or Type BF (e.g.,
spent fuel) packages depending on the type of material to be transported and the country of origin. For shipments originating in a foreign country, the staff emphasized the importance of early engagement with the NRC and the United States (U.S.) Department of Transportation (DOT) for transportation-related issues because DOT is the U.S. competent authority on transportation matters, including transporting a fueled reactor from a foreign country. The NRC staff mentioned that under this scenario, Hadron would also need a certificate from the Italian Competent Authority. Based on the information provided by Hadron at this meeting, the staff suggested for Hadron to have a separate meeting to discuss their transportation strategy and obtain feedback from the NRC staff. The staff also discussed additional regulatory alternatives like using an existing package for transporting fuel or a fueled reactor (depending the size), if the package design is adequate for transporting the contents, depending on whether the reactor is tested with fuel. Hadron acknowledged the feedback and noted its plan to refine their REP and licensing strategy, accordingly. Additionally, the NRC staff highlighted the need for a quality assurance (QA) program that meets the requirements of 10 CFR Parts 50, 71, and 727.
Hadron sought feedback from the NRC on potential gaps in their regulatory pathway, the advisability of seeking approval for a research reactor under 10 CFR 50.21(c), and the feasibility of shifting to a 10 CFR Part 53 pathway if it becomes available. They also requested feedback on the reasonableness of their proposed schedule. The NRC staff provided detailed feedback on these points, emphasizing the importance of incorporating the NRCs publicly available average review times for white papers and topical reports8, and applications9, into their schedule models. For most of the applications relevant to Hadrons licensing strategy, 18 months is the expected NRC review time. The NRC staff recommended that Hadron add preapplication licensing activities such as white papers, topical reports, and/or dedicated public meetings to 6 NEI, Draft Version OM NEI Guidance on Regulatory Engagement Plans and NRC Staff Feedback, March 13, 2018, (ML18122A293) 7 10 CFR 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste 8 U.S. NRC, https://www.nrc.gov/reactors/new-reactors/advanced/new-app/general-guidance/pre-app-process.html 9 U.S. NRC, https://www.nrc.gov/about-nrc/generic-schedules.html
3 their REP for topics that are complex in nature, new or novel technology, or involve unique licensing strategies. The NRC staff added that application review times are dependent on application completeness and quality, topic complexity, new technological features, novel licensing strategies, or the NRC staffs workload.
The NRC staff highlighted the importance of early engagement on storage issues, noting that these areas can be complex and require detailed planning. Hadron discussed the possibility of storing used fuel at the manufacturing facility, with suppliers, or at the operating sites. The staff clarified that in any of the proposed scenarios a 10 CFR Part 72 general or specific license for the storage of spent fuel is required. Hadron acknowledged the need to consider the entire lifecycle of the reactor and fuel.
The meeting concluded with Hadron agreeing to further engagements with the NRC staff to address specific topics such as transportation, storage, and QA. Both parties emphasized the importance of continued collaboration and transparent communication to ensure a successful licensing process for the Hadron microreactor. The NRC staff recommended references SRM-SECY-24-000810 and SECY-25-005211.
The NRC staff also mentioned upcoming public meetings on microreactors and encouraged Hadron to participate in these engagements, including those on July 14, 202512 and July 17-18, 202513, on the Licensing Requirements for Microreactors and Other Low Consequence Reactors Rulemaking.
The meeting adjourned at 4:05 pm.
10 U.S. NRC, SRM-SECY-24-0008: Micro-Reactor Licensing and Deployment Considerations: Fuel Loading and Operational Testing at a Factory, July 17,2025, (ML25168A133) 11 U.S. NRC, SECY-25-0052: Nth-of-a-Kind Microreactor Licensing and Deployment Considerations, July 3, 2025 (Package ML24309A266) 12 U.S. NRC, 07/14/2025 Licensing Requirements for Microreactors and Other Low Consequence Reactors Rulemaking, July 3, 2025, (ML25184A070) 13 U.S. NRC, 07/17/2025 Licensing Requirements for Microreactors and Other Low Consequence Reactors Rulemaking, July 3, 2025, (ML25184A368)