Comment from Nano Nuclear Energy Inc.

NANO Nuclear Energy Inc. submits the attached public response to MARAD’s Request for Information, “Development of a Commercially Viable System Centric Small Modular Reactor Concept for Deployment in the Marine Transportation System,” Docket No. MARAD-2026-0729. NANO supports MARAD’s system-first approach. Commercial maritime nuclear propulsion will depend not only on reactor technology, but also on a coordinated operating system encompassing licensing, vessel safety, classification, ports, liability, insurance, financing, fuel service, shipyard capability, workforce, emergency preparedness, and international acceptance. NANO recommends establishing a seven-year Maritime Nuclear Pathfinder governed by evidence-based decision gates. The program should evaluate a maritime derivative of NANO’s KRONOS MMR Energy System for a new-build, U.S.-flagged nuclear-electric logistics vessel in regular domestic service. The reference concept uses two independently isolable 15 MWe-class KRONOS-derived modules, subject to naval-architecture, safety, regulatory, commercial, and economic validation. KRONOS is currently a stationary high-temperature gas-cooled microreactor under development; NANO does not represent it as a marine-qualified propulsion plant. A maritime derivative would require a separate safety case, marine-environment qualification program, regulatory engagement plan, propulsion-specific classification pathway, port-acceptance framework, and operating model. NANO requests coordinated federal action to: (1) establish an NRC–Coast Guard–MARAD project structure and responsibility matrix; (2) develop propulsion-specific classification rules and a repeatable interface-control model; (3) create model port-acceptance, emergency-response, and safe-haven protocols; (4) clarify nuclear and maritime liability treatment and provide a limited first-project risk backstop where commercial capacity is unavailable; (5) establish maritime-nuclear workforce and credentialing pathways; (6) confirm eligibility for Title XI and related financing tools; and (7) support domestic shipyard, fuel-service, logistics, and simulator capability. The attached response directly addresses MARAD’s eleven questions and provides a preliminary technical data sheet, interface model, risk register, lifecycle-economic methodology, partner-participation framework, and detailed decision-gate roadmap. This is a public submission. It contains preliminary concepts and forward-looking planning assumptions, not a safety determination, licensing conclusion, commercial offer, or representation that any identified third party has agreed to participate.