The Nuclear Regulatory Commission's Office of Advanced Reactors recently launched a series of workshops aimed at those who want to learn more about or will need to navigate the NRC's licensing process. Dubbed "License to Launch," the series began with primers on 10 CFR Parts 50, 52, the finalized 53, and the proposed 57.

Last week, "License to Launch" dove into the topic of reactor and facility designs authorized by the Department of Energy with the workshop, "Building the Bridge: From DOE Authorization to NRC Licensing." This topic became more relevant as the NRC finalized a rule in October allowing applicants with Department of Defense- or DOE-authorized reactor designs to pursue a streamlined pathway through the NRC's commercial licensing process. The rule will become effective on November 25.

How to leverage information: Much of the discussion during the October 28 workshop revolved around a white paper by NRC staff titled "Leveraging Information from Previously Authorized Facilities." While the white paper is not intended for prospective applicants to rely on during application preparations, it can support public interactions on the topic.

NRC staff referenced the 158-page document several times during the workshop, most notably when addressing how much an applicant should leverage information and data gathered from DOE authorization during NRC licensing. The white paper considered that information in three categories: maximum, moderate, and limited. As the category names suggest, maximum leveraging will depend on data gathered during DOE authorization to a much greater extent than in the moderate or limited instances, where information may be only partially useful or used for background or supplemental purposes.

Matt Hiser, senior materials engineer at the NRC, reminded attendees that there are key differences between DOE-authorized facilities and NRC-licensed facilities. To date, DOE-authorized test facilities in the Reactor Pilot Program or the Nuclear Energy Launch Pad generally have been for limited-duration, limited-scope operations, and their preliminary and final documented safety analyses may not contain the explicit design criteria and requirements that are necessary in the NRC's commercial licensing process.

"That just creates some different considerations. If you look at an operating reactor for 40 years, you're maybe looking at different things in terms of fuel cycle, in terms of the level of fission products that are produced versus operating for maybe a period of weeks or months or hours," he said. "When you're thinking in decades, you have to have some different considerations."

According to the white paper, factors that will determine the extent to which an applicant could leverage information may ultimately come down to these:

• The similarity of DOE and NRC requirements and guidance.
• The quality of the application and the justification of the relevance of the DOE authorization to the NRC review.
• The safety significance of information leveraged.
• The similarity of the scope and depth of the reviews conducted by the two agencies.
• The documentation that serves as the basis for the DOE authorization in the NRC review.

If there was one piece of advice NRC staff hoped the public would take from the workshop, it was this: Don't be afraid to participate in early engagement activities with the NRC.

"I cannot stress enough how important preapplication engagement is . . . . Preapplication will help build a mutual understanding of the information in the authorization, the information intended to be leveraged, potentially the information that will be needed to fill gaps if there are gaps identified," said Jackie Harvey, senior project manager with the NRC.

Additional information: According to the NRC, the next "License to Launch" workshop is scheduled for December 2. Additional information on the first two workshops, including a link to the white paper, can be found on the License to Launch webpage.