Oklo’s Director of Communications and Media, Bonita Chester, interviews Ross Moore, the Director of Regulatory Affairs at Oklo, to discuss Oklo’s licensing updates, including the submitted licensing project plan. Watch the full conversation here and read the abbreviated highlights below.
What is a Licensing Project Plan, and why is it important for our future license applications?
Oklo’s Licensing Project Plan (LPP), or the Regulatory Engagement Plan, describes the important interactions that Oklo intends to have with the U.S. Nuclear Regulatory Commission (NRC) to ensure alignment on key licensing and policy-related matters. Specifically in pre-application. The LPP is intended to be an iterative plan informed by Oklo’s identified engagement topics, which are important to have focused conversations on pre-application as well as experiences and lessons learned through these pre-application engagements.
Only 11 of our 201 application sections require more information to support the NRC’s review. Our goal from a company perspective is to have an intentional pre-application process tailored to the feedback necessary to ensure that we are incorporating feedback from the NRC review staff as we finalize submitting our next application.
Importantly, this includes accounting for key feedback we’ve received during the review of our previously submitted license application for our Aurora powerhouse, which the LPP will be updated to be more explicit on how each item raised by the NRC is being resolved through the licensing project plan.
We want to ensure we’re very explicit in communicating the lessons learned. The staff has communicated to us that there they are ready to pick up on the review where they left off, but it is critical that we address and resolve staff feedback that was provided to us through the review of the previous application.
Oklo is licensing fast fission, which isn’t a technology that the NRC is used to licensing. Having worked at NRC, can you share some background on the existing regulatory framework developed based on Light Water Reactors?
The existing regulatory framework for licensing nuclear technologies has largely been founded on decades of experience of a relatively static industry centered around large light water reactors. What that means is the requirements for the regulations were placed in effect, and the applications that the NRC had received up until now have primarily been focused on large light water reactor technologies or light water reactor technologies. Through the decades of that experience, numerous guidance documents have been developed to support how one licenses technologies, addressing technical considerations for light water reactors.
That said, a lot of effort has been underway over the last couple of years to bring forward key policy and technical issues that may be new or different for non-light water reactors, including evaluating the utility of the existing requirements and how those apply to non-light water reactor technology.
While several topics are still under development, a lot of progress has been made by NRC staff to help facilitate the licensing of advanced reactors, advanced fission technology, and specifically, in our case, fast fission technologies. There are still a lot of pre-existing requirements that have their bases founded in light water reactor technology, so the onus is on us to understand the existing framework and the existing requirements and evaluate what the staff needs to assess advanced reactor technologies from a safety perspective using those requirements, and make sure that we’re demonstrating that we were still meeting the intent in either a compliance space or another mechanism through intentional design safety features.
For a unique reactor design like ours, there are about 200 key topics we had to do differently. The NRC is asking for more information in only 11 of the 201 application sections. Can you elaborate on how the NRC responded to our novel licensing items?
Oklo’s reactor designs use fast fission technology, and it is phenomenal to see a reactor that doesn’t require human action to ensure safety. Instead, relying on inherent safety characteristics and unique passive safety features. As a previously licensed senior reactor operator for light water reactors, inherent characteristics and passive safety features always astonish me that transients can be entirely mitigated without the action of licensed personnel to ensure safety.
Oklo’s reactor design is unique. There is a lot of great operating experience associated with major portions of our technology, having been demonstrated previously, that we can build on to help inform how we approach and validate the safety basis for our future designs.
The NRC staff has really been receptive to our novel licensing items. They want to understand the motivation behind some of these topics we’ve identified that look different from how previous rector facilities have been licensed and why we’re taking new approaches.
NRC’s concerns aren’t with the fact that this is different than what they have seen before. Their concern was intended to be rooted in safety. They want to understand how we are meeting the safety construct in the foundation that they have leaned on before. We can help by translating the specific safety basis of our technology and how the NRC staff is used to seeing it from previous reviews of light water reactor technology. Given the differences in technology, it may require more effort on our part because we have to share how we are developing our safety basis in in ways that support how the staff has consistently seen before, what that means for our technologies, and how that can afford the ability for us to do things differently. The NRC has been receptive to our approaches, and while the staff is still looking for some of those safety basis items, we are happy to provide them so they can make the right decisions they need to make.
The NRC is also evaluating novel licensing items on a more general basis or a generic basis. Beyond the review of our application, we’ve seen certain items that we have raised as unique licensing topics in our application transcended into generic licensing efforts to help support, facilitate, and streamline reviews of advanced reactor technologies or the establishment of guidance that helps reflect the inherent safety features of these new technologies.
We submitted our combined license during the onset of the pandemic, which challenged the ability to transmit information to the staff. How have we changed our approach to sharing information now that we are engaging in person again while also recognizing the interactions are still a combination of virtual and in-person interactions?
A lot of the structure that we developed in pre-application for the Aurora combined license application was intended to leverage more in-person interactions and in-person auditing, which we were unable to implement in the face of the global pandemic. It did challenge some of the communication pathways we’d initially relied upon, which were key in reviewing that application.
As we moved through the last several years, we’ve taken a lot of those lessons learned and incorporated them for how we support the review of our applications with the NRC. We’ve established a more robust communication pathway for key technical information, so we can share with the agency and the NRC staff non-audit-based material to support information sharing. The process allows NRC staff to get a better basis for the technical information we are providing.
Leaning into those in-person interactions again now, we’re able to have this hybrid environment, which allows us to do a little bit of both. We can have quick iterative conversations in a virtual space and get direct feedback. Especially top to bottom, management to staff level, allow us to iterate quickly on the feedback we receive. We can also present information in a technical way in person so we can have that engineer-to-engineer conversation that we found beneficial early in the pre-application phase. Having the team in the same room and having targeted conversations to understand the questions that the NRC staff are raising so that we can provide the feedback we need to help prepare our next application and support their necessary reviews.
Can our LPP prepare us for an effective and efficient application review?
We’re excited about taking the feedback from the NRC staff and incorporating that into an updated application. The licensing project plan allows us to communicate key topics that we are interested in engaging on in advance of submitting an applicationThe NRC has recognized them as key topic areas on which they have open questions. . We can also incorporate topics the NRC staff have identified as being useful pre-application topics. The LPP allows us to align on those items and identify the right mechanism for providing early information to the NRC so that we can ensure when we submit our application, there are no critical open questions about how we’re approaching certain topics and that the staff is on the same page as we are in terms of details we are providing in an actual application.
By aligning on how we handle key technical items that the staff is interested in reviewing, we should enable a streamlined review. Our interactions would be well-documented in pre-application, so when we get to the review space, the staff and Oklo will have an understanding of what the path forward is on those topics.