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.

ClearPath, a nonprofit organization focused on clean energy policy, supports the proposed Part 57 rulemaking but argues that its scope should be expanded beyond microreactors to include all reactors meeting the safety criteria. They also recommend incorporating the rule's innovative licensing concepts into existing regulatory frameworks (Parts 50, 51, 52, and 53) to maximize their impact and efficiency.

The Nuclear Energy Institute (NEI) supports the proposed Part 57 rulemaking for microreactors and other reactors with comparable risk profiles, praising its risk-informed and performance-based approach. They offer specific recommendations to improve the rule's efficiency, including expanding the scope of eligible technologies, refining entry criteria, and incorporating their "Rapid High-Volume Deployable Reactor" (RHDRA) framework into other regulatory parts.

X Energy, LLC, a developer of pebble-bed, high-temperature gas-cooled reactors, supports the NRC's proposed Part 57 rule to establish a risk-informed regulatory framework for low-risk reactors. They advocate for specific refinements to the rule, including more flexible dose criteria, the use of existing guidance for change evaluations, and consistent definitions for quality assurance and reactor states.

The Nuclear Innovation Alliance (NIA) supports the proposed rule for licensing microreactors and other reactors with comparable risk profiles, commending the NRC's ambitious approach. They provide specific recommendations to improve the rule, including creating a standalone construction permit pathway for first-of-a-kind reactors and reconciling inconsistencies between the rule and its draft guidance.

Rocinante Fieldworks, an independent venture and advisory platform, supports the proposed action but recommends specific modifications to 10 CFR Part 57 to include "deployment support facilities." They argue that the current framework lacks a licensing pathway for the intermediate "deployment chain"—such as nuclear spaceports and maritime ports—which are necessary for the high-volume deployment of microreactors and transportable reactors.

Lockheed Martin Corporation supports the NRC's proposed risk-informed and performance-based licensing framework for microreactors, noting it addresses key economic barriers to scalability. However, the company requests more transparent, predictable, and formalized processes for determining eligibility and approving alternate testing and quality assurance standards to reduce uncertainty for investors and federal agencies.

Radiant Industries, Inc., a clean energy startup, supports the proposed rule for licensing microreactors because it provides a practical pathway for mass-manufacturing and deployment. The company offers specific technical suggestions to streamline the regulatory process, clarify definitions for irradiated fuel, and adjust transportation dose rate limits to reduce costs and logistical burdens.

The United States Nuclear Industry Council (USNIC), a bipartisan membership organization for nuclear energy companies and institutions, supports the proposed rule for licensing microreactors and other low-consequence reactors. They advocate for a risk-informed, performance-based framework that includes streamlined pathways for high-volume deployment, factory fabrication, and remote operations.

The IEEE Nuclear Power Engineering Committee (NPEC) Subcommittee 2 expresses significant concerns regarding the proposed rule's reduction of Quality Assurance (QA) standards from the rigorous Appendix B to the less stringent ANSI/ANS-15.8. They argue that this shift creates risks of inconsistent QA across applicants, places undue burdens on suppliers, and potentially compromises the reliability of safety-related components in microreactors.