Comment from Kyle Arestivo

I respectfully submit the attached white paper, "Availability-Centered Design Considerations for Maritime SMR Deployment," in response to MARAD's Request for Information on developing a commercially viable, system-centric Small Modular Reactor (SMR) concept for deployment within the United States Marine Transportation System. My comments are informed by professional experience in nuclear engineering, maritime operations, fleet maintenance and modernization, lifecycle asset management, and operational readiness. The attached paper focuses on an area that I believe is critical to the long-term success of maritime nuclear propulsion but receives less attention than reactor technology itself: the development of a sustainable operational and maintenance ecosystem capable of supporting fleet-scale deployment. Specifically, the paper discusses the importance of operational availability, maintainability, integrated logistics support, workforce development, industrial base readiness, shipyard capability, and lifecycle sustainment planning as key factors influencing commercial viability. It also recommends an availability-centered evaluation framework and a formal Design for Maintainability and Availability criterion for future concept development and demonstration efforts. While the successful development of maritime SMR technology is essential, in my opinion, history suggests that long-term commercial adoption will ultimately depend upon the strength of the broader ecosystem supporting operation, maintenance, modernization, regulatory compliance, workforce development, and lifecycle sustainment. The attached paper is intended to provide recommendations in those areas for MARAD's consideration. Thank you for the opportunity to provide these comments and supporting material. Respectfully submitted, Kyle J. Arestivo Port Engineer Supporting U.S. Navy Maintenance and Modernization Programs United States Merchant Marine Academy, Class of 2015 Former Qualified Nuclear Shift Test Engineer and Supervisor, NAVSEA Norfolk Naval Shipyard Former Nuclear Engineering Professional, U.S. Department of Energy