April has seen significant milestones in licensing of advanced reactors. We take a closer look at these developments, in particular the first submission of an advanced reactor license application in Canada.
On March 20, 2019, Global First Power (GFP), partnered with Ontario Power Generation and Ultra Safe Nuclear Corporation (Ultra Safe), submitted a license application to the CNSC for a “License to Prepare Site” for a future SMR at Chalk River Laboratories in Ontario. GFP seeks eventually to build an Ultra Safe Micro Modular Reactor (MMR) at the site producing 15MW thermal / 5MW electric. GFP has been an early leader in response to the Canadian Nuclear Laboratories’ invitation to site an SMR at one of facilities. GFP was the first participant to progress through the second stage of the invitation process, and has been invited to participate in certain land and commercial discussions as well.
The Canadian Nuclear Safety Commission (CNSC) licensing process is staged, with separate licensing actions to prepare the site, construct, and then operate a reactor (although the latter two steps can potentially be combined into one licensing action). The License to Prepare Site is the first step in the process, and evaluates whether the proposed site is suitable for a nuclear reactor of a given general design. As summarized by the Canadian Nuclear Safety Commission:
An application for a license to prepare site (LTPS) does not require detailed design information or specifications of a facility. . . . The review of the application focuses on determining whether the site characteristics that have an impact on health, safety, security and the environment have been identified, and that these characteristics have been taken into consideration and will also be considered in the design, operation and decommissioning of the proposed facility.
In this sense U.S. and Canadian licensing processes share many similarities. For example, the License to Prepare Site mimics the “Early Site Permit” licensing process in the United States. Under the U.S. nuclear licensing regime laid out in 10 CFR Part 52, companies can first request an Early Site Permit from the U.S. Nuclear Regulatory Commission (NRC), and then a “Combined License” to both construct and then operate a reactor on the pre-approved site.
Like in the U.S., the Canadian nuclear regulator will first conduct a sufficiency review to ensure the application has all required elements, before processing it on the merits. Once the application has been assessed, the CNSC will issue a notice of commencement and the project description will be available to the public for comment as part of the environmental review. The timeline for completing the license review process for a License to Prepare Site is 24 months, similar to what the NRC advertises for completing many of its related licensing actions. Both countries have set forth long term visions to lead in siting of advanced reactors (as discussed in prior blog posts for the U.S. and Canada). Also like in the U.S., the CNSC has set forth guidance as to the licensing process for SMRs, and what an application should contain.
What will be interesting is to see how the Canadian licensing process compares with the U.S. process in implementation, and how both can benefit from lessons learned by each other. The U.S. arguably has a head start, already reviewing a Design Certification Application for a NuScale SMR, and recently having completed the environmental review for an Early Site Permit for a SMR system of up to 800 MWe next to the Clinch River in Oak Ridge, Tennessee (although a few further steps remain till the permit is granted).
However, the Canadian licensing strategy has received early accolades for offering a graded, and streamlined process, including with its Pre-Licensing Vendor Design Review. In the U.S., the Clinch River Early Site Permit process is expected to take over 3 years to complete (see timeline), and the environmental review document alone comes in at near 1400 pages, including appendices (keep in mind that the costs of NRC licensing reviews are charged back to the applicant). Although the U.S. Clinch River project is for a much larger reactor, a key metric to watch will be whether the CNSC meets or exceeds its licensing timelines, and whether it can truly adopt a graded licensing approach given the much smaller size of the GFP MMR project.
To learn more about SMR licensing, please contact the authors.