The following statement may be attributed to Judi Greenwald, President and CEO of the Nuclear Innovation Alliance:
“On June 15th, NIA submitted public comments on NRC’s proposed Part 57 rule, Licensing Requirements for Microreactors and other Reactors with Comparable Risk Profiles. NIA believes that Part 57 will provide a valuable and efficient licensing pathway if NRC incorporates several improvements into the proposed rule.
“The Part 57 rulemaking is the most significant and complex action NRC has taken thus far under Executive Order 14300. It is essential that this rule have a strong foundation to allow for efficient, effective and durable implementation. NIA commends NRC for publishing an ambitious and innovative proposed rule on a short timeline.
“NIA recommends improvements to the proposed Part 57 rule on several topics first-of-a-kind licensing, consistency between the proposed rule and guidance, categorical exclusions, entry criteria, and early site permits. NIA recommends:
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That NRC simplify the entry criteria for applicants to use the rule.
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Specifically, NIA recommends the six proposed core safety and security attributes in tandem with the proposed accident dose-based entry criterion be the only entry gates to use the rule.
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That the final rule include an explicit standalone construction permit pathway to allow first-of-a-kind applications to efficiently use Part 57. Our comment outlines a detailed recommended pathway.
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That NRC reconcile inconsistences between the proposed rule and the draft guidance. In particular, the proposed §57.350 categorical exclusion criteria reference Part 51 Appendix C, which is more stringent than the draft Part 57 guidance in NUREG-2271.
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That NRC align the draft guidance with the rule language, which does not require Appendix B for quality assurance. Part 57 explicitly states that the traditional Appendix B is not required. However, the draft guidance frames Appendix B as the primary option, with the alternative requiring a gap analysis.
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That NRC implement changes to Part 57.350 for categorical exclusions, to make them more performance based. Our comment outlines specific recommendations.
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That NRC develop a Part 57-compatible Limited Work Authorization process.
“Review NIA’s public comment here for our answers to NRC staff questions and our comments on the following topics: first-of-a-kind licensing, inconsistencies between the proposed rule and guidance, categorical exclusions, entry criteria, relationship between Part 57 and Part 53, early site permits, alternate dose rates, hearings, remote and autonomous operations, and single failure criterion.”
The Nuclear Innovation Alliance (NIA) is a non-profit think-and-do-tank working to enable nuclear power as an energy security and climate solution. Through policy analysis, research, and education, we are catalyzing the next era of nuclear energy. Our organization is funded primarily through charitable grants and philanthropic donations.