POLICY ISSUE 

(Information) 

August 28, 2014 SECY-14-0095

FOR: The Commissioners 

FROM: Glenn M. Tracy, Director 

Office of New Reactors 

SUBJECT: STATUS OF THE OFFICE OF NEW REACTORS READINESS TO 

REVIEW SMALL MODULAR REACTOR APPLICATIONS 

PURPOSE: 

The purpose of this paper is to inform the Commission of the readiness of the Office of New 

Reactors (NRO) to conduct safety and environmental reviews of new small modular reactor 

(SMR) applications under Title 10 of the Code of Federal Regulations (10 CFR) Part 52, 

“Licenses, Certifications, and Approvals for Nuclear Power Plants,” and under 10 CFR Part 50, 

“Domestic Licensing of Production and Utilization Facilities.” The scope of the paper includes 

both light-water and non-light-water SMR designs. This paper does not address any new 

commitments or resource implications. 

SUMMARY: 

NRO is ready to conduct safety and environmental reviews of all types of light-water SMR 

applications. The office has gained significant experience in the use of the 10 CFR Part 52 

licensing process during the reviews of recent large light-water reactor (LLWR) applications, and 

continues to refine internal and external guidance consistent with current regulations and with 

lessons learned from the LLWR, 10 CFR Part 52 application reviews. NRO is systematically 

updating existing guidance such as NUREG-0800, “Standard Review Plan for the Review of 

Safety Analysis Reports for Nuclear Power Plants: LWR Edition” (SRP). 

CONTACT: Michael S. Jones, NRO/DARR 

301-415-0189 
The Commissioners - 2 - 

Staff activities conducted since NRO’s last SMR program update to the Commission in March 

2011 align closely with the key activities necessary to prepare the agency for reviews of 

applications related to the design, construction, and operation of advanced reactors described in 

the U.S. Nuclear Regulatory Commission’s (NRC’s) “Report to Congress, Advanced Reactor 

Licensing,” August 2012 (“Report to Congress”) (Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML12153A014). Examples include the issuance 

of new review guidance, such as the development and deployment of design-specific review 

standards (DSRSs) and the implementation of a risk-informed, integrated review framework for 

SMRs. 

In SECY-10-0034, “Potential Policy, Licensing, and Key Technical Issues for Small Modular 

Nuclear Reactor Designs” (ADAMS Accession No. ML093290268), NRO identified a range of 

potential issues to be reviewed and resolved for both light-water and non-light-water SMR 

designs. NRO also developed and implemented a systematic methodology to identify and rank 

possible SMR issues, known as the Issues Identification and Ranking Program (IIRP). The staff 

has reviewed the issues identified in SECY-10-0034 and by the IIRP reviews, and is working to 

resolve these issues or to develop recommendations for the Commission where appropriate. 

This paper summarizes and provides the current status of these issues, and provides the bases 

for those determinations. 

Opportunities for enhancing NRO’s readiness are identified in the areas of design-specific 

training for SMR technical reviewers; staff familiarization with 10 CFR Part 50 construction 

permit (CP) and operating license (OL) application reviews; long-term planning for attrition of 

subject matter experts (SMEs); and coordination between primary, secondary, and interface 

technical reviewers. 

Separately, NRO faces a significant readiness challenge to review a non-light-water SMR 

application if one is submitted in the near term (within 5 years). This paper describes current 

efforts to remain engaged with the non-light-water reactor (non-LWR) community, and areas 

where NRO and the agency need to make additional preparations for non-LWR applications. 

The “Report to Congress” remains relevant and accurate as a reference in this regard. 

BACKGROUND: 

NRO last presented formal SMR program updates to the Commission in a meeting on 

March 29, 2011 (ADAMS Accession No. ML110880157) and published further updates in the 

“2013 New Reactor Program,” NUREG/BR-0476, Volume 3, March 2014 (ADAMS Accession 

No. ML14055A176). 

DISCUSSION: 

NRO has prepared this paper to inform the Commission of its readiness to review new SMR 

applications, and to describe some associated challenges and opportunities for enhancing 

NRO’s readiness. Both light-water and non-light-water SMR designs are considered. The 

scope of the paper comprises staff SMR activities including infrastructure development, preapplication interactions with potential SMR applicants and stakeholders, possible issuance of 

safety and environmental licensing decisions, rulemaking, and inter-office coordination as 

appropriate. The scope excludes post-licensing activities within the NRC’s regulatory purview 
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such as construction oversight, the Reactor Oversight Program, and end-of-lifecycle 

decommissioning activities. The paper focuses on the core functions required to perform safety 

and environmental reviews of SMR application submittals. However, related NRC secondary 

support functions and infrastructure are also reviewed to the extent that they directly impact the 

NRC’s ability to execute the core functions successfully. 

Infrastructure Development, Pre-Application Activities, Accomplishments, and SMR Stakeholder 

Interactions 

NRO has worked continuously since the office was established to create the necessary 

organizational infrastructure to support new reactor licensing reviews, including SMRs. The 

“Report to Congress” lists the key activities necessary to prepare the agency for reviews of 

applications related to the design, construction, and operation of advanced reactors.1

 These 

activities are as follows: 

• Identify and resolve significant policy, technical, and licensing issues. 

• Develop the regulatory framework to support efficient and timely licensing reviews. 

• Engage in research focused on key areas to support licensing reviews. 

• Engage reactor designers, potential applicants, industry, and the U.S. Department of 

Energy (DOE) in meaningful pre-application interactions and coordinate with internal 

and external stakeholders. 

• Establish an advanced reactors training curriculum for the NRC staff. 

• Remain cognizant of international developments and programs. 

This list correlates closely with staff activities (completed or in-progress) in preparation for 

conducting light-water SMR application reviews. Examples of related staff activities and 

accomplishments since 2011 include: 

• Identification of overarching policy and technical issues for SMRs that will need to be 

addressed to support licensing reviews through the use of IIRP reviews. The IIRP 

topics reviewed or in-progress include SMR security, emergency preparedness, 

source term, environmental issues, control room staffing, SMR cross-organizational 

issues, and multi-module licensing. 

• Development of SMR review infrastructure including internal and external guidance. 

Examples include revisions to the NRO Office Instruction for acceptance reviews for 

design certification (DC) and combined license (COL) applications, DSRS 

development, and preparation of guidance for conducting SMR readiness reviews. 

 

1

 As used in the 2012 report, “advanced reactors” refers to those designs of commercial reactors, employing either 

light-water or non-light-water technology which incorporate the Commission’s expectations set forth in the Policy 

Statement on the Regulation of Advanced Reactors, 73 Federal Register, 60612 (October 14, 2008). 
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• Revision of the SRP Introduction to add a second part specific to light-water SMRs 

for the implementation of a risk-informed and integrated review framework. 

• Development of an optimum baseline schedule for light-water SMR DC reviews with 

assumptions and bases. 

• Updates to reviewer guidance for environmental reviews to include lessons learned. 

ISGs are being developed for use while the primary review guidance (NUREG-1555) 

undergoes more extensive revisions. 

A more detailed listing of SMR activities and accomplishments since 2011 is provided in 

Enclosure 1. 

NRO is conducting robust, technically substantive pre-application interactions with potential 

SMR applicants and SMR stakeholders. In response to documents and presentations provided 

by these potential applicants, the staff has provided informal feedback that the vendors have 

considered while developing their designs, maximizing the benefits of pre-application 

engagement. 

Other SMR stakeholders that have engaged with the NRC for SMR matters include the Nuclear 

Energy Institute (NEI) and the industry, the International Atomic Energy Agency (IAEA), DOE, 

the Environmental Protection Agency (EPA), the Department of Homeland Security (DHS), and 

the Federal Emergency Management Agency (FEMA). These interactions have considered a 

wide range of subject matters related to the development and deployment of SMRs. Specific 

examples of these stakeholder interactions are provided in Enclosure 2. 

Potential SMR Applicants 

NRO is currently conducting pre-application interactions with four light-water SMR vendors—

Generation mPower (mPower), NuScale, Westinghouse, and Holtec. The levels of 

pre-application activities vary, depending on the requests of the vendors. These vendors may 

submit a 10 CFR Part 52 DC application to the NRC for review within the next 2 to 5 years. 

The Tennessee Valley Authority (TVA) had originally planned to submit a 10 CFR Part 50 CP 

application for up to four mPower SMRs at the Clinch River site near Oak Ridge, Tennessee, in 

the second quarter of 2015. It was expected that the NRC review of this application would 

proceed in parallel with review of the mPower 10 CFR Part 52 DC application. However, this 

plan is likely to change as a result of a decision by the reactor designer, Babcock and Wilcox 

(B&W), to significantly reduce resources devoted to design development. More information 

regarding TVA’s plans is expected later in 2014. 

SMR Application Review Efficiency and Effectiveness 

The NRC’s mission is to ensure adequate protection of public health and safety, to promote the 

common defense and security, and to protect the environment. Safety will not be compromised 

in order to expedite SMR application reviews. Within that framework, NRO plans to complete 

SMR licensing reviews in an efficient and effective manner. 
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The staff developed a 39-month optimum baseline schedule for light-water SMR DC application 

reviews and held a public meeting on February 24, 2014, with all interested stakeholders to 

discuss the schedule and the underlying bases and assumptions. The actual duration of SMR 

application reviews will be contingent upon a number of factors, such as the degree of 

productive pre-application engagement with the NRC by the applicant, and the completeness 

and adequacy of the SMR application. 

NRO is currently working to identify and manage the review factors that are within the agency’s 

control, such as open policy issues, guidance development, and SMR-related technical 

questions. NRO is also interacting with potential applicants and other stakeholders to identify 

external factors that could cause extended review schedules, such as the need for early design 

finality and the need for timely, complete responses to requests for additional information (RAIs) 

during the application review. The goal of these interactions is to develop a common 

understanding of the information exchange necessary to conduct efficient and effective SMR 

application reviews. 

SMR Application Review Challenges 

SECY-10-0034 and NRO’s IIRP efforts identified a range of potential issues to be reviewed and 

resolved for both light water and non-light-water SMR designs. As NRO’s infrastructure for 

SMR application reviews has been developed, these policy issues have been examined and 

either resolved or identified as candidates for further study and potential escalation for 

Commission consideration. The list of open issues identified by the IIRP reviews or cited in 

SECY-10-0034 that may require Commission consideration and direction, along with the 

documents providing the bases for those conclusions, are provided in Enclosure 3. Issues cited 

in SECY-10-0034 that have been considered resolved or are awaiting design-specific 

applications to conduct further detailed analysis are provided in Enclosure 4. 

The “Report to Congress” included an examination of the NRC’s readiness to license advanced 

non-LWR designs. The report described potential license applications in the longer term 

(10 years or more) and various ongoing agency efforts to coordinate with DOE and international 

organizations to keep informed of the non-LWR state-of-the-art. Agency efforts and the status 

of its readiness to license non-LWR designs have not changed materially since issuance of the 

2012 report, and the NRC would be challenged to efficiently review a new non-LWR application 

if one is submitted in the near term (within 5 years). During the preparation of this paper, the 

agency received a letter from a potential non-light-water SMR vendor notifying the NRC of the 

company’s intent to engage in pre-application interactions and to submit a DC application for a 

non-light-water, high-temperature pebble bed SMR design in 2017. The staff expects that the 

company will engage with the NRC further as this effort progresses. Once the company has 

demonstrated that they have sufficient design maturity to support this schedule, the staff will reexamine NRO’s priorities and needs with respect to conducting a non-LWR application review in 

the near term. 

Opportunities for Enhancing NRO’s Readiness 

Several staff-related topics were reviewed to determine whether NRO is ready to review SMR 

applications. These topics included whether the organization had sufficient full-time equivalent 

(FTE) employee levels, appropriate technical skills, and sufficient training opportunities available 
The Commissioners - 6 - 

to prepare for and conduct the reviews. Planning processes for the attrition of SMEs were also 

examined. Finally, the current work process for technical review coordination between primary, 

secondary, and interface reviewers was examined for potential improvement opportunities. 

Based on the findings of the FTE and technical skills reviews described above, NRO staff is 

prepared to perform light-water SMR reviews. For highly specialized technical questions or 

areas of expertise that are outside of the NRC’s experience base, NRO will use contracted 

technical support in accordance with the agency’s established processes. 

During the preparation of this Commission paper, four specific training needs related to 

performance of SMR application reviews were identified. 

• First, new review processes for SMRs may require staff training development and 

deployment. Examples of new processes include the development and use of DSRSs, 

and the implementation of a risk-informed and integrated review framework in 

accordance with SECY-11-0024, “Use of Risk Insights to Enhance the Safety Focus of 

Small Modular Reactor Reviews,” May 11, 2011 (ADAMS Accession No. 

ML111320551). 

• Second, a need for design-specific training to aid reviewer familiarity with new or 

innovative SMR features was identified. NRO has commissioned design-specific 

training for the mPower design in preparation for the mPower DC application. Similar 

needs for other vendor designs are anticipated. 

• Third, a need for in-depth, design-specific integrated system operations training was 

identified for reviewers responsible for reviewing plant operating and emergency 

operating procedures. 

• Fourth, NRC staff have not received a new reactor CP or OL application for review under 

10 CFR Part 50 since the late 1970s. Most staff reviewers need training on the conduct 

of those reviews if new 10 CFR Part 50 CP/OL applications are anticipated. 

NRO will work with training experts in the Office of the Chief Human Capital Officer (OCHCO), 

and others as needed, to develop the needed training in a timely manner to support SMR 

application reviews. 

Regarding planning for SME attrition, NRO branch chiefs use internal budget formulation and 

staffing plan development processes, or other methods, to consider future staff needs and to 

provide recruiting needs to OCHCO. NRO is currently surveying critical skills in order to identify 

gaps and prepare for a possible larger percentage of the staff SME population leaving the NRO 

organization. NRO will work with OCHCO, as appropriate. 

Regarding technical review coordination, the NRC has traditionally been organized along 

discipline-specific technical branch lines. NRO continues this organizational approach, which 

has been effective during NRO’s review of LLWR applications. Lessons learned during those 

reviews with regard to the coordination and management of technical reviews between primary, 

secondary, and interface reviewers indicate that there is an opportunity for improvement in this 
The Commissioners - 7 - 

area. NRO has commissioned a working group to identify specific areas for improvement and to 

recommend changes to review guidance that will reflect the process improvements. 

COMMITMENTS: 

This paper contains no new staff commitments. 

CONCLUSIONS: 

NRO is ready to conduct safety and environmental reviews of light-water SMR applications. 

The duration of SMR application reviews will be contingent upon a number of factors, such as 

the degree of productive pre-application engagement with the NRC by the applicant, and the 

completeness and adequacy of the SMR application. 

NRO has previously identified several overarching policy and technical issues that will require 

review and resolution to support efficient and effective SMR licensing reviews. Commission 

guidance may be required for resolution of some of these issues, and NRO will develop 

recommendations for the Commission, when necessary. 

NRO faces significant challenges to be ready to review non-light-water SMR applications in the 

near term (within 5 years). The agency needs to continue development of the requisite review 

policies and guidance, and to develop a sufficient depth of technology-specific staff skills 

(including training) to be ready to review a non-LWR application. The agency also needs to 

continue working with international nuclear regulators that have non-LWR facility experience to 

leverage that experience for potential domestic designs. Additional research may be required to 

develop independent analytical tools and methods for designs that differ significantly from lightwater-reactor technology, so that the analysis methods and supporting experimental data can 

support an independent safety finding by the NRC. 

RESOURCES: 

Current NRO resources are adequate to support SMR-related activities for FY 2014 through FY 

2015. Resources needed beyond FY 2015 will be requested through the planning, budgeting, 

and performance management process. The staff will further clarify resource needs as the 

schedules for application submittals become more certain and as pre-application activities 

proceed. 

 
The Commissioners - 8 - 

COORDINATION: 

The Office of the General Counsel has reviewed this paper and has no legal objection. 

The Office of the Chief Financial Officer has reviewed this paper for resource implications and 

has no objections. 

/RA/ 

 Glenn M. Tracy, Director 

 Office of New Reactors 

Enclosures: 

1. Listing of Activities and Accomplishments 

Since 2011 Related to Preparation for 

SMR Application Reviews 

2. Examples of Interactions with SMR 

Stakeholders 

3. SECY-10-0034 SMR Technical and 

Policy Issues Which May Require 

Commission Consideration and Direction 

4. SECY-10-0034 SMR Technical and 

Policy Issues Which Are Considered 

Resolved or Are Awaiting DesignSpecific Applications to Conduct Further 

Detailed Analysis 
The Commissioners - 8 - 

COORDINATION: 

The Office of the General Counsel has reviewed this paper and has no legal objection. 

The Office of the Chief Financial Officer has reviewed this paper for resource implications and 

has no objections. 

 /RA/ 

 Glenn M. Tracy, Director 

 Office of New Reactors 

Enclosures: 

1. Listing of Activities and Accomplishments 

Since 2011 Related to Preparation for 

SMR Application Reviews 

2. Examples of Interactions with SMR 

Stakeholders 

3. SECY-10-0034 SMR Technical and 

Policy Issues Which May Require 

Commission Consideration and Direction 

4. SECY-10-0034 SMR Technical and 

Policy Issues Which Are Considered 

Resolved or Are Awaiting DesignSpecific Applications to Conduct Further 

Detailed Analysis 

ADAMS ML14073A710 NRO-2014-0001 *via e-mail SECY-012 

OFFICE PM:NRO/DARR/SMRLB2 LA:NRO/DARR/SMRLB2* BC:NRO/DARR/SMRLB2 Tech Editor* D:NRO/DARR 

NAME MJones BAbeywickrama ABradford CHsu MMayfield 

DATE 4/2/2014 3/20/2014 4/2/2014 3/20/2014* 4/11/2014 

OFFICE D:NRO/DCIP* D:NRO/DE* D:NRO/DNRL* D:NRO/DSEA* D:NRO/DSRA* 

NAME MCheok SCoffin (AValentin for)* FAkstulewicz SFlanders CAder 

(KHawkins for) 

DATE 4/30/2014 4/28/2014 5/02/2014 4/30/2014 5/29/2014 

OFFICE D:NRO/PRMS* OCFO* NMSS* NRR/DE* OGC* 

NAME CSchum JDyer (FMiller for) CHaney PHiland MCarpentier 

DATE 4/28/2014 4/22/2014 4/30/2014 6/10/2014 6/20/2014 

OFFICE NSIR* RES* D:NRO 

NAME JWiggins 

(BMcDermott for) 

BSheron GTracy 

DATE 4/29/2014 3/31/2014 8/28/2014 

OFFICIAL RECORD COPY 
The Commissioners - 9 - 

DISTRIBUTION: 

Commissioners 

SECY 

OGC 

OCAA 

ASLBP 
ENCLOSURE 1 

LISTING OF THE OFFICE OF NEW REACTORS ACTIVITIES AND ACCOMPLISHMENTS 

SINCE 2011 RELATED TO PREPARATION FOR SMALL MODULAR REACTOR 

APPLICATION REVIEWS 

Examples of small modular reactor (SMR)-related staff activities and accomplishments since 

2011 include: 

• Development of SMR review infrastructure including internal and external guidance. 

Examples include revisions to the Office of New Reactors (NRO) Office Instruction 

for acceptance reviews for design certification (DC) and combined license 

applications, design-specific review standard (DSRS) development, and preparation 

of guidance for conducting SMR readiness reviews. The NRO application 

acceptance review process for applications is being revised to incorporate lessons 

learned from the previous large light-water reactor (LLWR) application reviews (“New 

Reactor Licensing Process Lessons Learned Review: 10 CFR Part 52,” April 2013, 

Agencywide Documents Access and Management System (ADAMS) Accession No. 

ML13059A239). The revised process was piloted during the acceptance review of 

the Korea Hydro and Nuclear Power DC application for the APR1400. Additional 

experience gained during that pilot test will be incorporated in the NRO Office 

Instruction as appropriate and will be made publically available. 

• Issuance of over 40 Standard Review Plan (SRP) section updates in draft-forcomment or final revision as part of the regular guidance update cycle. The staff has 

also issued eight Interim Staff Guidance documents (draft or final) since the last 

Commission briefing. These updates benefit all light-water reactor (LWR) application 

reviews, including SMRs, and will ultimately be incorporated as final NRC guidance. 

• Identification of overarching policy and technical issues for SMRs that will need to be 

addressed to support licensing reviews through the use of Issues Identification and 

Ranking Program (IIRP) reviews. The IIRP topics reviewed or in-progress include 

SMR security, emergency preparedness, source term, environmental issues, control 

room staffing, SMR cross-organizational issues, and multi-module licensing. 

• Revision of the SRP Introduction to add a second part specific to light-water SMRs 

for the implementation of a risk-informed and integrated review framework. 

Implementation of this framework is described in NUREG-0800, SRP Introduction, 

Part 2, “Standard Review Plan for the Review of Safety Analysis Reports for Nuclear 

Power Plants: Light-Water Small Modular Reactor Edition,” January 2014 (ADAMS 

Accession No. ML13207A315). The framework provides technical reviewers with a 

methodology to apply a graded review approach to SMR structures, systems, and 

components (SSCs) in consideration of the safety and risk significance of the SSCs. 

The review approach is developed for a particular SMR design during development 

of the associated DSRS. Once the application has been received, reviewers have 

the flexibility to adjust the graded review approaches based on application specifics. 

• Conduct of extensive and ongoing interactions with internal and external SMR 

stakeholders, both domestic and international. Examples of these international 

interactions include NRO’s work with the International Agency for Atomic Energy 
2 

(IAEA) and with the Multinational Design Evaluation Program. NRO coordinates 

international SMR outreach efforts with the Office of International Programs as 

appropriate. 

• Development of an optimum baseline schedule for SMR DC reviews with 

assumptions and bases. 

• Preparation of the first draft DSRS for the Generation mPower (mPower) design for 

public comments. 

• Development of a design-specific training curriculum for staff assigned to review the 

mPower DC application. 

• Development of confirmatory tools and analyses for SMR deeply-embedded 

structures. Development of reviewer guidance for flow-induced vibration and 

acoustic resonance phenomena. 

• Completion of a formal lessons learned review associated with first use of the Title 

10 of the Code of Federal Regulations (10 CFR) Part 52 licensing process for 

LLWRs, and implementation of an action plan that will be applied to SMR reviews. 

• A comparison and evaluation of the licensing requirements for new reactors under 

10 CFR Parts 50 and 52 is ongoing. The staff is preparing recommendations for the 

Commission to incorporate 10 CFR Part 52 lessons learned and to ensure clear 

alignment between the outcomes of new reactor licensing reviews, regardless of 

which review licensing framework is selected by an applicant. 

• While not specific to SMRs, several work process improvements have been made 

that will contribute directly to SMR licensing effectiveness and efficiency. These 

include significant improvements in project management support systems including 

the scheduling, change management, risk management, and the electronic request 

for additional information process workflow system (eRAI) platforms. The purpose of 

these processes is to more effectively manage new reactor licensing reviews through 

enhanced work management controls, management reports, and schedule impact 

analysis. 

• NRO, working closely with the Office of Nuclear Materials Safety and Safeguards, 

will pay particular attention to the integrated fuel cycle management strategies for 

SMR designs. The staff will review fuel fabrication, spent fuel pool storage, and 

interim spent fuel management features such as on-site cask storage (the “back-end” 

of the fuel cycle) proposed by applicants. The SMR strategies are expected to be 

similar to those used by the LLWRs. 
ENCLOSURE 2 

EXAMPLES OF INTERACTIONS WITH SMR STAKEHOLDERS 

SMR Stakeholder Interactions – Nuclear Energy Institute (NEI)/Industry 

As part of the pre-application meetings and workshops NRO has conducted to discuss general 

technical and policy issues related to SMRs, NRO has received several industry position papers 

from the NEI. These papers have addressed a range of topics, including reactor source terms, 

emergency planning zone (EPZ) methodology and criteria, control room staffing requirements, 

insurance and liability requirements, pre-application engagement, multi-module facility license 

structures, decommissioning funding, annual fee assessments, and physical security. As the 

staff determines the best way to address the SMR technical and policy issues, the industry 

perspective is reviewed and considered, and meetings are held with NEI as needed to obtain 

clarifications or additional information. 

SMR Stakeholder Interactions – IAEA/International SMR Regulators’ Forum 

Several countries that are licensing or preparing to license SMRs have expressed an interest in 

piloting a forum for regulators. The purpose of the forum is to identify, understand, and address 

key regulatory challenges that may emerge in future SMR regulatory discussions. 

This will help improve efficiency in licensing and reviews and enable regulators to inform 

changes, if necessary, to their requirements and regulatory practices. During the 2-year pilot, 

Argentina, Canada, China, Finland, France, Germany, India, Japan, the Republic of Korea, the 

Russian Federation, South Africa, United Kingdom, and the United States may be invited to be 

members of the new forum. 

The IAEA will act as the forum (Steering Committee) secretariat and will, subject to the 

availability of extra-budgetary resources, promote and facilitate the forum. The United States 

has provided funds for the creation of a Cost-Free Expert position to support the IAEA for this 

effort for a period of 3 years. The structure of the forum will be a steering committee and issuespecific working groups. 

A draft “Terms of Reference” (ToR) for the forum was developed and sent to each country in 

March 2014 for review and approval. A consultancy meeting to establish the forum for SMRs 

was held at the IAEA on July 22-24, 2014. At the July 2014 meeting, the ToR was approved, a 

program plan was developed, and issues to move forward with in the forum were identified. 

SMR Stakeholder Interactions – U.S. Department of Energy (DOE) 

Since NRO’s last Commission briefing on SMR licensing preparations in 2011, both DOE and 

domestic industry support for near-term non-light-water (non-LWR) technologies have been deemphasized. With the domestic SMR community’s commercial focus on LWR designs, 

readiness for reviewing these applications has become a higher NRO priority than for the review 

of non-LWR applications. NRO activities since the previous Commission meeting include 

maintaining liaison efforts with the DOE, the review of various related non-LWR technical 

reports and white papers, participation in international non-LWR conferences, interactions with 

the Generation IV International Forum, and observing DOE’s development of proposed General 

Design Criteria for non-light-water designs, which will ultimately be sent to the NRC for review. 
2 

SMR Stakeholder Interactions – Emergency Planning 

In SECY-11-0152, “Development of an Emergency Planning and Preparedness Framework for 

Small Modular Reactors,” October 28, 2011 (ADAMS Accession No. ML112570439), the NRC 

staff stated its intent to develop a technology-neutral, dose-based, consequence-oriented 

emergency preparedness (EP) framework for SMR sites that considers the various designs, 

modularity and collocation with other industrial facilities. In that Commission paper, the staff 

also discussed developing a concept that EP requirements could be scaled to be 

commensurate with the accident source term, fission product release, and associated dose 

characteristics for the designs. The staff continues to review this concept and prepared an 

update of the review in a memorandum to the Commissioners dated May 30, 2013 (ADAMS 

Accession No. ML13107A052). In that memo, the staff clarified that it will continue to work with 

external stakeholders to address this issue further, as resources allow, but it will not go further 

in proposing new policy or revising guidance for specific changes to EP requirements absent 

specific proposals from an applicant or nuclear industry group. On December 23, 2013, NEI 

submitted a white paper to the staff entitled “A Proposed Methodology and Criteria for 

Establishing the Technical Basis for Small Modular Reactor Emergency Planning Zone” 

(ADAMS Accession No. ML13364A345). The staff conducted a public meeting to discuss the 

white paper on April 8, 2014, and sent a letter to NEI with follow-up questions on the proposed 

methodology on June 11, 2014 (ADAMS Accession No. ML14142A406). 

The Office of Nuclear Security and Incident Response (NSIR), with NRO participation, began to 

engage in late 2011 with stakeholders on the proposed framework laid out in SECY-11-0152. 

The staff made several presentations on proposed SMR EP to other Federal agencies at the 

Federal Radiological Protection Coordinating Committee (FRPCC) and to the Environmental 

Protection Agency (EPA)-led Protective Actions Guidelines (PAGs) subcommittee of the 

FRPCC. The FRPCC is an interagency body chaired by the Department of Homeland Security 

and the Federal Emergency Management Agency. The staff is working with the EPA PAGs 

subcommittee to establish an SMR EP subcommittee. 

Additionally, the staff made presentations on SMR EP at the 2012 annual and 2013 winter 

meetings of the American Nuclear Society, the National Radiological Emergency Preparedness 

annual meeting, the Conference of Radiation Control Program Directors, and the Health Physics 

Society annual meetings. 

Communication and coordination with internal and external stakeholders will continue as the 

staff further develops the SMR EP framework and associated recommendations. NRO is 

currently preparing a notation vote paper for the Commission with SMR EP policy 

recommendations. The paper is scheduled for completion in 2015. 
ENCLOSURE 3 

SECY-10-0034 SMR TECHNICAL AND POLICY ISSUES WHICH MAY REQUIRE 

COMMISSION CONSIDERATION AND DIRECTION 

SECY-10-0034 

Line Item No. Issue Title Status References 

3.2 Use of Probabilistic 

Risk Assessment in 

the Licensing 

Process for SMRs 

An inter-office staff working group 

has developed preliminary 

guidance for multi-module risk for 

SMRs and engaged stakeholders 

in a public meeting in June 2014. 

This guidance expands upon that 

which is currently in SRP Section 

19.0, “Probabilistic Risk 

Assessment and Severe Accident 

Evaluation for New Reactors,” 

Revision 3 (Draft) by providing 

criteria to ensure appropriate 

treatment of important insights 

related to multi-module design and 

operation. It is consistent with 

current Commission policy and 

objectives for the use of 

probabilistic risk assessment in the 

design, certification, and licensing 

of advanced light-water reactors. 

SECY-11-0079, 

ML110620459 
2 

SECY-10-0034 

Line Item No. Issue Title Status References 

3.3 Appropriate Source 

Term, Dose 

Calculations, and 

Siting for SMRs 

In the Commission Memo dated 

December 29, 2011, the staff 

stated it would remain engaged 

with SMR stakeholders regarding 

the applications of a mechanistic 

source term (MST), review preapplication white papers and 

topical reports concerning source 

term issues that it receives from 

potential SMR applicants, discuss 

design-specific proposals to 

address this matter, and consider 

research and development in this 

area. If necessary, the staff would 

propose revised review guidance 

or regulations, or propose new 

guidance to support reviews of 

SMRs. 

In Commission Memos dated May 

30, 2013 and June 20, 2014, the 

staff provided updates with regard 

to MST activities and interactions 

with DOE and nuclear-industry 

organizations. 

NRO continues to engage potential 

SMR applicants such as mPower 

and NuScale to review their 

design-specific approaches for 

source term. For example, a 

closed meeting was held by the 

staff and NuScale on March 9, 

2014, to discuss NuScale’s 

accident source term methodology 

for a single reactor module. 

NRO is actively working to better 

characterize the source term issue 

for SMRs through internal reviews 

and through interactions with 

stakeholders in order to determine 

whether a policy recommendation 

to the Commission is needed. 

Commission 

Memo, 

12/29/2011, 

ML113410366 

Commission 

Memo, 

05/30/2013, 

ML13107A052 

Commission 

Memo, 

06/20/2014, 

ML14135A482 
3 

SECY-10-0034 

Line Item No. Issue Title Status References 

4.7 Offsite Emergency 

Planning (EP) 

Requirements for 

SMRs 

In SECY-11-0152, staff identified 

three potential policy issues for 

future development and discussion 

in a future Commission paper: 

• Scalable EPZ 

• Modularity and Collocation 

• Considerations for Establishing 

SMR EPZ Size 

The referenced SECY stated that 

NRO is working with NSIR and the 

Office of Nuclear Reactor 

Regulation on an internal working 

group to review these issues 

further, liaise with other Federal 

agency stakeholders, consider 

industry position papers on this 

topic, and develop 

recommendations. 

In the referenced Commission 

Memo, the staff provided updates 

on staff activities for this issue with 

DOE and industry representatives. 

The staff stated that it would not go 

further in proposing new policy or 

revising guidance for specific 

changes to EP requirements 

absent specific proposals from an 

applicant or nuclear-industry 

group. 

On December 23, 2013, NEI 

submitted a white paper to the staff 

entitled “A Proposed Methodology 

and Criteria for Establishing the 

Technical Basis for a Small 

Modular Reactor Emergency 

Planning Zone.” The staff 

conducted a public meeting to 

discuss the white paper on April 8, 

2014, and issued follow-up 

questions to NEI on June 11, 2014. 

SECY-11-0152, 

ML112570439 

Commission 

Memo, 

05/30/2013, 

ML13107A052 

NEI white paper, 

12/23/2013, 

ML13364A345 

NRC Letter to NEI 

(R. Bell), 

06/11/2014, 

ML14142A406 
4 

SECY-10-0034 

Line Item No. Issue Title Status References 

5.1 Annual Fee for 

Multi-Module 

Facilities 

In accordance with the memo to 

the Commissioners from the Chief 

Financial Officer (CFO) on 

February 7, 2011, the staff intends 

to proceed with rulemaking for 

Alternative 4, Calculate the Annual 

Fee for Each Licensed Power 

Reactor as a Function of its 

Licensed Thermal Power Rating 

(MWt). The memo stated that 

Commission approval for the 

approach will be requested during 

development of the proposed rule. 

In July 2014, the Office of the Chief 

Financial Officer established a 

follow-up working group to draft a 

SECY paper, proposed rule, and 

final rule for the variable annual fee 

structure. 

Memo to 

Commission from 

CFO, 2/7/2011 

ML110380251 

5.2 Insurance and 

Liability for SMRs 

In accordance with SECY-11-0178, 

staff will prepare a comparative 

analysis of different designs to 

determine if an inequity exists 

between the treatment of reactors 

producing electrical power greater 

than 100 MW (MWe) and those 

with individual modules producing 

less than 100 MWe. Stakeholders 

will be engaged during the 

analysis. Rulemaking or a change 

to the current interpretation of the 

definition of “nuclear reactor” as 

given in the Price-Anderson Act 

may be required. Staff is 

beginning substantive work on this 

issue. 

SECY-11-0178, 

ML113340133 
ENCLOSURE 4 

SECY-10-0034 SMR TECHNICAL AND POLICY ISSUES WHICH ARE CONSIDERED 

RESOLVED OR ARE AWAITING DESIGN-SPECIFIC APPLICATIONS TO CONDUCT 

FURTHER DETAILED ANALYSIS 

SECY-10-0034 

Line Item No. Issue Title Status References 

2.1 License for 

Prototype 

Reactors 

No policy issues or rulemaking 

needs identified by staff in SECY11-0112. No further staff action 

planned unless an application for a 

prototype reactor is received. 

SECY-11-0112, 

ML110460434 

2.2 License Structure 

for Multi-Module 

Facilities 

Staff concluded that Alternative 3 

(license each module individually) 

with additional analysis to be 

performed for addressing common 

SSCs is preferable. In SECY-11-

0079, staff committed to submit a 

specific proposal to the Commission 

for its consideration and approval. 

The staff is awaiting an SMR 

application to finalize the 

recommended licensing approach 

for shared SSCs, using a specific 

multi-module facility design for 

practical insights. 

SECY-11-0079, 

ML110620459 

2.3 Manufacturing 

License 

Requirements for 

Future Reactors 

Staff has studied the issue and 

discussed it with the SMR 

community in public meetings. No 

current technical issue or policy 

issue was identified for resolution 

and no interest in obtaining a 

manufacturing license from nearterm SMR applicants was 

expressed. Therefore, no further 

staff action is planned at this time. 

Commission 

Memo, 3/27/13, 

ML13018A168 
2 

SECY-10-0034 

Line Item No. Issue Title Status References 

3.1 Implementation 

of Defense-InDepth (DID) 

Philosophy for 

Advanced 

Reactors 

As described in SECY-10-0034, 

DID as an issue was focused on 

non-light-water SMRs. In SECY09-0056, the staff proposed to defer 

development of a DID policy 

statement pending gaining 

additional experience and related 

insights from Next-Generation 

Nuclear Plant or other non-LWR 

reviews. 

More broadly, the concepts and 

goals of DID as applied generally to 

a technology-neutral regulatory 

framework was discussed in 

Enclosure 3 of the staff’s 

recommendations for disposition of 

NRC Fukushima Near-Term 

Task Force Recommendation 1 

(SECY-13-0132). 

In SRM-SECY-13-0132, the 

Commission disapproved SECY-13-

0132 Improvement Activity 2, 

“Establish Commission 

Expectations for Defense-in-Depth” 

and directed the staff to re-evaluate 

the topic as appropriate in the 

context of the Commission direction 

on a long-term Risk Management 

Regulatory Framework. 

The Commission also directed the 

staff to enshrine SECY-13-0132, 

Enclosure 3, “Defense-in-Depth 

Observations and Detailed History,” 

as an agency knowledge 

management tool and to republish 

the enclosure in other formats to 

make it more widely available. 

NRO will keep apprised of this issue 

as it is re-evaluated for potential 

SMR impacts. 

SECY-09-0056, 

ML090360197 

SECY-13-0132, 

ML13277A413 

SECY-13-0132, 

Enclosure 3: 

Defense-InDepth 

Observations 

and Detailed 

History, 

ML13277A425 

SRM-SECY-13-

0132, 

ML14139A104 
3 

SECY-10-0034 

Line Item No. Issue Title Status References 

3.4 Key Component 

and System 

Design Issues for 

SMRs 

Policy impacts on key components 

and system designs are designspecific and will be evaluated for 

individual applications. 

No further 

general 

references have 

been developed 

by the staff for 

this item. Item 

3.4 technical 

issue titled 

“Core 

Composition 

and Source 

Term Issues for 

SMRs” is 

discussed 

separately in 

Enclosure 3, 

Line Item No. 

3.3. 

4.1 Appropriate 

Requirements for 

Operator Staffing 

for Small or MultiModule Facilities 

In SECY-11-0098, staff concluded 

that evaluating applicant operator 

staffing exemption requests is the 

best short-term response for this 

issue. The SECY discussed 

performing updates of NUREG 

0800, NUREG 0711, and NUREG 

1791 for guidance of the short-term 

evaluations. Staff now concludes 

that the existing version of SRP 

Chapter 18 and Revision 3 to 

NUREG 0711 (published November 

2012) comprise adequate guidance 

for performing the exemption 

request evaluations. As experience 

is gained in performing the operator 

staffing exemption requests, the 

need for a long-term approach will 

be further evaluated. 

SECY-11-0098, 

ML111870574 

NUREG 0711, 

Revision 3, 

November 2012 

4.2 Operational 

Programs for 

Small or MultiModule Facilities 

As discussed in SECY-11-0112, 

this issue can be addressed with 

current guidance, no rulemaking or 

policy changes needed. 

SECY-11-0112, 

ML110460434 
4 

SECY-10-0034 

Line Item No. Issue Title Status References 

4.3 Installation of 

Reactor Modules 

During Operation 

of Multi-Module 

Facilities 

As discussed in SECY-11-0112, 

this issue can be addressed with 

current guidance, no rulemaking or 

policy changes needed. 

SECY-11-0112, 

ML110460434 

4.4 Industrial Facilities 

Using NuclearGenerated 

Process Heat 

As discussed in SECY-11-0112, 

this issue can be addressed with 

current guidance, no rulemaking or 

policy changes needed. This may 

be re-assessed if an applicant 

applies for this plant usage, 

depending on the specifics of the 

application. 

SECY-11-0112, 

ML110460434 

4.5 Security and 

Safeguards 

Requirements for 

SMRs 

Staff determined in SECY-11-0184 

that the current regulatory 

framework is adequate to certify, 

approve, and license light-water 

SMRs, the manufacturing of SMR 

fuel, transportation of special 

nuclear material and irradiated fuel, 

and the interim storage of irradiated 

fuel proposed for light-water SMRs 

under 10 CFR Parts 50, 52, 70, 71, 

and 72, respectively. Also, security 

and material control and accounting 

(MC&A) requirements in 10 CFR 

Parts 72, 73, and 74, respectively, 

are comprehensive and sufficiently 

robust, and therefore are adequate 

for light-water SMRs. 

SECY-11-0184, 

ML112991113 

4.6 Aircraft Impact 

Assessments for 

SMRs 

As discussed in SECY-11-0112, 

this issue can be addressed with 

current guidance, no rulemaking or 

policy changes needed. 

SECY-11-0112, 

ML110460434 
5 

SECY-10-0034 

Line Item No. Issue Title Status References 

5.3 Decommissioning 

Funding for SMRs 

Design-specific features will 

influence decommissioning costs. 

The near-term approach will be to 

consider allowing SMR applicants 

to deviate from existing regulations 

through exemption requests with 

supporting analysis. The long-term 

approach is to propose rulemaking 

based on the near-term exemption 

experience. 

No additional review of this issue 

has been performed since the 

SECY-11-0181 was issued. The 

issue may need to be revisited if 

there are changes to the regulatory 

and industry environments in the 

future. 

SECY-11-0181, 

ML112620358