ML25233A298
| ML25233A298 | |
| Person / Time | |
|---|---|
| Site: | 99902049 |
| Issue date: | 08/21/2025 |
| From: | Lashley P, Shurtleff C Holtec, SMR |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML25233A296 | List: |
| References | |
| 300-USNRC-113 | |
| Download: ML25233A298 (1) | |
Text
www.holtec.com www.smrllc.com SMR-300 LWA Planning Updates August 27, 2025 Presented by: Phil Lashley & Clark Shurtleff SMR, LLC, A Holtec International Company Krishna P. Singh Technology Campus One Holtec Boulevard Camden, NJ 08104, USA
[Not Export Controlled]
holtec.com l smrllc.com l Page 2 Meeting Agenda
Introductions
Purpose Regulatory Basis Planned LWA Activities
holtec.com l smrllc.com l Page 3 Purpose Communicate SMRs plans for the Palisades SMR LWA Part 50 licensing pathway Construction Permit Application (CPA)
Operating License Application (OLA)
Limited Work Authorization (LWA) as part one of a two-part CPA Comprehensive Environmental Report submitted with LWA Reminder - Palisades SMR Existing Palisades SMR-300s Property Line
holtec.com l smrllc.com l Page 4 Application Timeline Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 CPA Part I CPA Part II OLA 2025 2026 2027 2028 2029 2030 Submittal NRC Review Submittal NRC Review Approval Approval Submittal NRC Review Approval Preapplication
~14-month LWA construction window
holtec.com l smrllc.com l Page 5 holtec.com l smrllc.com l Page 5 Mar 1972: 50.10(c) defines commencement of construction Feb 1974: proposed rule creates 50.10(e), LWA concept Apr 1974: NRC responds to public comments on proposed rule Apr 1974: NRC issues final rule Oct 2007: 50.10 revised to current text, established current LWA process
SECY-R-74-167
72 FR 57416 Regulatory History/Basis
holtec.com l smrllc.com l Page 6 SECY-R-74-167 discusses the basis for the LWA rule Encl 2, Page 8: There is a strong incentive to ensure that the rule establishing LWAs incorporates sufficient critical path work to effectively utilize the time saving that an LWA offers.
Encl 2, Page 12: Thus, provision has been made to ensure maximum effective use of the potential time saving offered by the LWA concept.
Encl 2, Page 15: The optimum course of action is one that results in the issuance of LWAs that include a well-defined scope of work large enough to take advantage of the potential time saving
holtec.com l smrllc.com l Page 7 1974 Regulations Allowable LWA activities:
LWA 50.10(e)(1):
Site preparation Construction support facilities SSCs not subject to 10 CFR 50 Appendix B (i.e., non-safety-related SSCs)
LWA 50.10(e)(3):
(for safety-related SSCs)
Subsurface preparation Installation of foundations
- (SSCs: structures, systems, and components)
holtec.com l smrllc.com l Page 8 Current Regulations (2007 Rule)
Allowable LWA activities under current 50.10(d)(1):
Driving of piles Subsurface preparation Placement of backfill, concrete, or permanent retaining walls within an excavation Installation of foundations
holtec.com l smrllc.com l Page 9 holtec.com l smrllc.com l Page 9 Development of 10 CFR 50.10 Regulation Onsite Activities Allowed Without NRC Approval Onsite Activities Allowed With an LWA 1972 rule Site exploration N/A - LWA did not exist Exemptions could be considered 1974 rule Same as 1972 All non-safety-related work*
(LWA-1 activities)
Installation of safety-related foundations (LWA-2 activities) 2007 rule All non-construction activities defined in 50.10(a)(2)
Installation of safety-related foundations
- 50.10(e)(1)(v) allowed the construction of structures, systems, and components which are not subject to the provisions of Appendix B.