The U.S. Nuclear Regulatory Commission (NRC) recently re-issued its request for information from potential NRC reactor applicants, entitled: “Process for Scheduling and Allocating Resources for Fiscal Years 2020 Through 2022 for the Review of New Licensing Applications for Light-Water Reactors and Non-Light-Water Reactors.” It is designated as Regulatory Issue Summary (RIS) 2017-18. For small modular and advanced reactor ventures, responding to the RIS is a low-cost means by which to engage with the NRC about your technology, and help the agency improve its resource allocation for new reactor licensing.
This periodic RIS, last issued in the middle of 2016, is used to help the NRC schedule and allocate its limited resources for new reactor development. It was created following the Vogtle and Summer AP1000 reactor licensing process, in order to facilitate pre-licensing interaction. In particular, the agency must budget years in advanced for expected application activity—for example, although we are just at the start of 2018, this RIS will be used to determine budget allocations as far out as FY2022. The document itself contains a further background as to its development and purpose.
The questions are relatively straightforward, and responders can request that certain information be withheld as proprietary. Questions include:
- What types of NRC interactions do you plan to seek?
- When do you plan to file an application?
- What is the fuel type/basic design information?
- Will you be part of a working group?
- Who is assisting in the design?
- Have you developed quality assurance plans and/or models that may need approvals or analyses?
There is no deadline for a response, but we encourage potentially interested parties to submit a response to the NRC if they feel their design has matured to a certain threshold. RIS responses provide the NRC with a mechanism to gain basic familiarity with new technologies under development (do not assume that they are already aware). A healthy number of responses also allows the NRC to advocate for increased staffing for advanced reactor development in coming years. Last but not least, the RIS itself provides some insight into what the NRC staff is looking for early on from reactor developers, and thus serves as a sanity check to make sure new ventures are doing all they can to ensure that a new technology will run into fewer licensing problems later (such as development quality assurance programs early on).
Nonetheless, despite its low risk, any response should be thought through as it likely represents one of the first significant written interactions with the agency. We have helped multiple parties fashion responses to such information requests, and would be happy to talk further about any questions, as well as other ways to informally interact with agency staff.