Licensing Requirements for Microreactors and Other Reactors with Comparable Risk Profiles

The Samuel Lawrence Foundation opposes the proposed rule, arguing that it moves too quickly and lacks sufficient oversight for microreactors. They specifically criticize the reduction of quality assurance standards from Appendix B to ANSI/ANS-15.8, the lack of clear definitions for safety terms, and the arbitrary nature of the eligibility criteria.

A government agency (the LEAD Agency) opposes the proposed licensing requirements for microreactors. The agency expresses solidarity with Indigenous Peoples regarding the historical environmental and health damages caused by nuclear fuel processing and uranium extraction.

Antares Nuclear, a company focused on microreactors, supports the NRC's proposed Part 57 licensing pathway for low-consequence reactors. They argue that the rule should maintain strict, objective entry criteria to preserve its streamlined nature and should not be expanded to include reactors that require more comprehensive safety mitigations.

REPLOY Power, Inc. supports the proposed rulemaking for microreactors but advocates for a performance-based entry criterion rather than a rigid heavy-metal inventory limit. They also recommend streamlining licensing for factory-manufactured reactors, including general licenses for specific pre-operational activities and right-sized site permit processes.

Geenex, a developer of large-scale energy infrastructure projects, supports the NRC's proposed rule to modernize reactor licensing for low-consequence technologies. They argue for clearer guidance on allowing site development activities to proceed independently of reactor technology selection and advocate for a site-neutral framework to maximize deployment flexibility.

Deep Fission, Inc. supports the NRC's efforts to modernize regulatory review practices for advanced reactors but argues that the draft guidance still relies too heavily on conventional light-water reactor structures. They recommend shifting to a risk-informed and performance-based (RIPB) approach that prioritizes high-level safety objectives and applicability determinations over traditional topical review areas.

The Breakthrough Institute, an independent non-profit research organization, supports the development of Part 57 as a risk-informed, performance-based licensing framework for high-volume deployment of microreactors and other reactors. They recommend clarifying the rule's purpose as a high-volume licensing pathway, aligning its tools with Part 53, and establishing clear transferability mechanisms between the two frameworks.

Tam Fortis Solutions, a nuclear energy company, expresses strong support for the proposed 10 CFR Part 57 rulemaking, noting that their helicopter-portable microreactor aligns with the rule's risk profile and safety philosophy. They recommend that the final rule prioritize a physics-grounded assurance framework for autonomous operations, adopt a risk-informed approach to failures, and ensure technology-neutral guidance for passive, non-water-cooled designs.

HEAL Utah, an organization dedicated to public health and environmental protection, opposes the proposed rule because it prioritizes rapid nuclear deployment over rigorous safety reviews and public participation. They argue that streamlining the licensing process for microreactors risks replicating design flaws on a large scale and fails to account for the cumulative environmental and health impacts of the full nuclear fuel cycle.

HEAL Utah, an organization dedicated to public health and environmental protection, opposes the proposed rule because it prioritizes rapid nuclear deployment over rigorous safety reviews and public participation. They argue that streamlining the licensing process for microreactors risks replicating design flaws on a large scale and fails to account for the cumulative environmental and health impacts of the full nuclear fuel cycle.