The Exchanges

Q our company. And that is, you know, Indicative of progress. But, but I have no idea whether that's indicative of progress, right? Like, does that happen every single time? Is it always positive? Do people get rejected somewhere in this process? Like, what is it like in that murky, that murky early ground where there's all this iteration and, and work being done before you submit your formal construction permit?

A Yeah, absolutely. Um, I would say that while it is an indicator that things are happening in the company and an indicator that the NRC is not in the dark about what's happening in that company, at no point, sort of, in that process is NRC really issuing official decisions of any kind. In the pre-application activities, you do have to submit kind of a letter of intent. You have to submit, you know, billing information so that the NRC can start billing you for their time. Uh, and you, You do things like a regulatory engagement plan gets put together, and you tell the regulator how you want to, like, go about the process of engaging with them, and then there's usually public kickoff meetings and readiness assessments as a part of that, including public outreach meetings, and all of that is before you submit your application. Once you submit your application, NRC then decides whether or not to accept That application and start actually doing the review. People do get rejected at the acceptance of application stage, for example, if it just doesn't reflect the level of technical depth that NRC is going to need to do the review. That is certainly a thing that happens, and sometimes it's, you know, years after you've started your pre-application activities.

AI assessment note: “People do get rejected at the acceptance of application stage, for example”

Q I'm very excited for you to help me understand what's actually happening out there in the world of new nuclear reactors. Let's start with actually just walking through the process. If I'm a company who wants to go commercialize a new nuclear reactor in the United States, just high level, like, what are the key milestones in my process?

A Yeah, well, fundamentally, you're gonna have to start with a design and a site and some pre-application engagement with the Nuclear Regulatory Commission, and then you're gonna do a lot of safety analysis and put together a site report and a safety analysis report for your reactor design. You're gonna have to put together plans for how to operate that reactor, how to train operators, For that reactor, how to ensure its safety in certain design basis accidents, etc. All of those documents go into the NRC in different forms, and, um, the NRC takes those documents and gives you, first, a construction permit, ideally, and then an operating license, though there is a pathway that does those two things in parallel. Um, in the meantime, there's public meetings and hearings and You know, a lot of back and forth with the Nuclear Regulatory Commission in the form of technical white papers, technical reports, you know, uh, reports that then get reviews by NRC and responses from NRC, and then responses to the responses will come out of your company and into the NRC, and all of that is just in the context of licensing, because in addition to all that, you also have to have a financial plan, which the NRC also reviews, uh, but Generally speaking, there's a couple of different pathways for licensing. One's called part 50 of 10 CFR, the Federal Register Code. Um, one's called part 52 recently.…

AI assessment note: “fundamentally, you're gonna have to start with a design and a site”

Q So I, as an example, I remember, I know new scale is the first SMR company to receive design license approval. Um, I think also there have been companies like Oklo was rejected at some point. Was that for its design license application? Is that distinct from a construction permit?

A Yeah, so it's technically called a design certification, but yeah, it's, it's, it's a certification independent of the site, and so it is really hyper-focused on the reactor. It's hyper-focused on making sure that everything within the boundary of the site is going to go well, sort of, regardless of what site you put it on, and then separate, sort of, site-specific questions will be asked as part of The rest of the construction permit. But what you can then take that design certification and not have to sort of re-review the reactor every time you have a new place you want to put it. So the idea there is you're sort of certifying the reactor as safe, assuming the rest of the questions about particular sites are safe, right? And that allows you then for your subsequent license applications to be focused on site-specific questions about how safely that reactor behaves. In the context of your, like, site. So, new sites, etc. So, um, the thing that NRC denied is the combined license application. So, they submitted an application. Yeah, so Oklo. So, the thing that NRC denied for Oklo was that they, um, They submitted a combined license application, so this is for that parallel step where you don't do a separate design certification, you sort of submit a combined operating license and construction permit application, and it was rejected, um, largely because it contained information g…

AI assessment note: “the thing that NRC denied for Oklo was that they... submitted a combined license application”

Q program. They picked 11 companies who have new reactor designs, and they set a goal. They're working with all of them, and they set a goal for at least three of them. To achieve criticality on test reactors by July fourth of this year, not a coincidence that it's July fourth. What does it mean for a test reactor to achieve criticality and like how important a milestone is that?

A So I think it depends on what kind of criticality we're talking about. For example, there's something called a zero power criticality test, which means that you are multiplying neutrons, even if it's three or four neutrons, right? This is happening. This happens easily without making real necessarily engineering progress on either the fuels or the reactor design. And so I would be careful to sort of keep an eye out for some of the caveats about how those were really accomplished. Um, For example, Valor Atomics announced that they had reached criticality at Los Alamos, but, you know, it's an experiment that Los Alamos already had running. It is with a fuel similar to Valor Atomics fuel, but it was a zero power criticality test, so it's basically sort of at what we call cold zero power, which is to say they're not taking this, like, fuel up to the kinds of power densities that we would actually see in the reactor. They're simply checking whether or not you can multiply neutrons inside that fuel, which, generally speaking, we know from Lots of experience in simulation for most reactor fuels. So I would be careful not to sort of buy into the hype of any kind of criticality tests that sort of are caveated by things like zero power or cold zero power. I want to see myself criticality at what, what's called hot, full power. Um, and that kind of thing takes time. In fact, in the histor…

AI assessment note: “zero power criticality test, which means that you are multiplying neutrons”

Q How much does a plan for the spent nuclear fuel for the waste matter? I mean, we, we, we never built Yucca mountain, so we're still doing lots of onsite storage for all the spent nuclear waste from all the existing reactors. Like how much do all these new companies with new reactors have to contend with what are we going to do with the waste?

A Yeah, part of the NRC's licensing process is something called waste confidence. They have to, in the licensing that says you can turn this reactor on and start operating it, there has to be some level of confidence that there will eventually be a plan for the waste. Historically, there's been some Litigation back and forth about whether this waste confidence can simply rely on the federal process if we aren't successfully pursuing a Yucca Mountain type activity. Um, all of that is to say that at the moment, companies do need to include some plan for how they're going to manage in the interim their spent nuclear fuel on site until the federal government takes ownership of it, and so that has to be a part of their application to the regulator, and For a lot of companies, that means, you know, spent nuclear fuel is cooled either in pools or in, you know, small containers in the sort of circulated air and ideally eventually put into dry cask storage while it waits. For some companies, this may mean an active recycling facility right there on site with the reactor or at the reactor factory. Um, all of that kind of needs to be considered if that's in fact I think a lot of companies maybe are leaving that to that second phase of the operating license application, but I would love to see them being a little clearer about, you know, precisely what their plan is for interim storage in th…

AI assessment note: “companies do need to include some plan for how they're going to manage”

Q is maybe the hardest and longest, and then the construction permit is second to that. So you could imagine it being like a three years, two year, one year for the three Different steps or something like that. Just in terms of the order of time and complexity and difficulty, do I have it right? Or is it actually like harder to get a construction permit than a design certification?

A Well, the statistics are small here, right? And there's great variation per reactor, and so it's very challenging to say specifically, like, oh yeah, it's always going to be more time spent on the reactor. Actually, what we have seen, and there is some interesting statistics on, is the amount of environmental review time that also happens in parallel, because in terms of that site application, you are sort of really highly Focused on NEPA, and so the environmental impact assessment process can be a long pole in that tent, and it sort of has very little to do with the reactor design itself, and so actually you might see places where the site permit and construction permit, you know, are subject to environmental impact assessments and whatnot that aren't safety assessments, and that those can rival both in length of the report and, you In time that it takes to review it, um, the kind of reactor review.

AI assessment note: “it's very challenging to say specifically, like, oh yeah, it's always going to be”

Q just in terms of other milestones that I see startups announcing, um, as an example, radiant, which is doing micro reactors, which by the way, I want to ask you about micro reactors in the context of the NRC pathway. Is there any difference in terms of the NRC licensing process for a new light water reactor versus an SMR versus a micro reactor? Are they all exactly the same?

A So right now, there, the options before them are pretty much the same. There is a new licensing pathway called 10 CFR part 53 that was intended to be more supportive of advanced reactors, including micro-reactors, but right now it's not obvious that it would be that much faster for most companies, so a lot of them are still choosing 10 CFR part 50 or 52, and what you do instead is just have certain waivers for, uh, changed guidance that is specific to your reactor type, right? You just have a different way to evaluate that same requirement that's in the regulation, and so it may go faster, and in fact, NRC has done a really good job of looking into certain things that are very unique to micro-reactors, like whether or not the emergency planning zone needs to be any larger than the fence line is a question that NRC, you know, Uh, wrangled with for a little while and came out with a really, I think, reasonable sort of idea about how to approach that, and it will be totally reasonable if NRC decides that some of those micro-reactors have, you know, emergency planning zones that don't go any further than the reactor site itself, which is great.

AI assessment note: “So right now, there, the options before them are pretty much the same.”

Q I find that Because this is so complex, and because there's so many steps in the process, you get a lot of announcements, and because all these companies are raising a lot of money and need to raise a lot of money, they make a lot of announcements about various things, and it's like hard to separate signal from noise. So like, what would, what would be signal to you?

A Yeah, I think the lightest signal is we've submitted a letter of intent to the NRC. That's a company that actually intends to engage the NRC and nothing more. We've submitted a construction permit application to the NRC. Now, that's a company that has engaged with the NRC, gotten sort of good feedback on their regulatory engagement plan, and have a plan for, like, a construction permit. They They might submit a safety analysis report to the NRC that is sort of associated with the safety of the reactor. Um, that's serious, and submitting those things to the NRC is the bulk of the work that you're looking at. When the NRC accepts those applications, that's also a good sign, but it is not quite as good as when the NRC actually approves the construction permit, or approves the design certification, or approves the operating license. The operating license is last, or In the process that's parallel, it is together with the last step. That operating license requires that folks put together their, like, operating license plan and training plan and everything else. Once that's submitted, that's, again, a real step where, like, real documents have been submitted and they're about to be reviewed. And so I would say there's certain documents, the construction permit application, the safety analysis report, the operating license application, those things, once they're submitted, Those are r…

AI assessment note: “I think the lightest signal is we've submitted a letter of intent to the NRC.”

Q What, if anything, has changed at the NRC in this new administration, which is, uh, you know, pro-nuclear, pretty openly, at least rhetorically, um, but then also we've had doge during that period. So, like, is the NRC moving faster, moving slower, more equipped, less equipped? Like, is there any difference right now?

A Yeah, I think the NRC is under a great deal of pressure to move faster, but they also have a number of deadlines that they're facing that are likely taking up a great deal of staff time. Furthermore, they have fewer staff than they did, um, before this administration began, and so the staffing issue certainly is one to keep in mind. They have had the support through the last You know, in the Biden administration as well, with things like the Advance Act, which, you know, is sort of bipartisan. That bipartisan support has indicated ways in which the NRC can accelerate licensing, engage in international memoranda of understanding, for example, to, you know, share Information about reactor designs that one country is licensing and use that information in our own licenses. For example, um, it's given some authorization to the NRC to consider, you know, what it looks like to site a reactor on a former fossil site, like a coal plant site. Many of those sites are already quite contaminated, even radioactively contaminated, because the heavy metals in Cole. And so, you know, the way to approach those reviews in an accelerated way is sort of, there's a nice open door for that. The Advance Act was passed in the Biden administration, and the NRC now is sort of taking some of those instructions and going forth with some of the recommended activities from the Advance Act to accelerate licen…

AI assessment note: “NRC is under a great deal of pressure to move faster, but they also have”

Q You mentioned good announcements recently on progress from X-Energy and Kairos. What are the potential forthcoming big decisions? Are there, could X-Energy and Kairos get construction permits shortly? What it should be looking like? TerraPower, all the names that have sort of further along in this process, like what could be coming soon?

A Yeah, absolutely. It's going to be construction permits that you want to look out for. Kairos has test reactors ahead of their final commercial design. Those have already received some construction permits from the NRC in the 23, 24 time frame, and they're continuing to see kind of rapid progress with NRC on, you know, um, continued, you know, final safety evaluations for those reactors. Um, so that's great, and we'll see, you know, Construction permit applications, like, either being submitted or approved for a lot of the other reactors, and that's where you really start to get excited. Some such reactors have received construction permit, uh, early, early construction permission, even before they have technically a construction permit, they can start working on digging out those sites without building anything nuclear. That's a nice feature that the NRC allows folks to sort of start laying the land at their own risk. Without promising that the construction permit will be approved, they can say, ah, yeah, well, we know enough to say you can probably start doing the non-nuclear construction. That's happened. Um, yeah, so those are really great signs.

AI assessment note: “It's going to be construction permits that you want to look out for.”

Q Got it. Okay, so then back to the milestones. So Radian, as an example, has, uh, I think on their website that they say, in twenty-twenty-six Kaleidos, which is the name of their reactor, Will be the first new commercial reactor design to achieve a fueled test in over 50 years. What does it mean to achieve a fueled test, and how does that relate to criticality, for example?

A Yeah, so that would be that kind of hot, full power test that I was describing earlier. It's in a long set of tests that we call ITAC, but the, there's a whole bunch of things you need to do before you start up a reactor to make Make sure that everything's working, all the pressures are right, all the temperatures are right, and the fuel is working, and things of this nature. It means you put fuel in that reactor core vessel, you close it up, and you turn it on. You at least get up through some of these, like, multiplication levels that we are talking about that are sort of at real power. Um, fueled tests are critical before you can start, uh, well, they're critical in the You have to start working on figuring out, you know, whether or not all of your simulations and modeling match precisely the kind of approach to criticality with fuel inside the reactor that you were expecting.

AI assessment note: “It means you put fuel in that reactor core vessel, you close it up”