What a last few days… honestly, what a last few years. Not just for us, but I’m sure for all of you as well.
We wanted to openly share with you what has happened with the NRC, and what we are doing now.
We woke up a few days ago to incredibly surprising decisions by the NRC. Although Oklo responded to every request for information, and the last thing we heard from the NRC was that the information we submitted was helpful, the NRC has denied our first application on the basis of not having submitted information. The NRC has now gone from having one combined license under review to none.
Since then, we’ve had conversations with our team, friends, investors, national lab teammates, partners, and so on. What might be surprising is that in the midst of this all, there are some great things emerging. A challenge really is an opportunity.
The first silver lining is this: the NRC actions are catalyzing a new wave of support, momentum, and introspection from those that support advanced fission. This might not have happened in the same way, had we proceeded on what we and everyone imagined would be a slow process of many smaller “paper cuts.”
An example of this would be the work that NuScale has done — dutifully moving forward after almost 14 years of pre-application and design certification work, with their license application still ahead. Oklo supported the “lessons learned” letter that NuScale put out regarding needed NRC process improvements, but it really was not given the attention it should have been. Too often people think issues won’t happen again or won’t affect them, and ignore opportunities to unite to drive improvement. This time we are seeing that support, which is crucial: the climate cannot wait.
Time can kill support and momentum. We knew that to start building and learning, on a timeline quick enough to make a difference for people and the planet, we had to start small and simple with both a completely new concept for a fission powerhouse, but built on decades of data. We also knew there are elements of a slow government project that guarantee a slow expensive outcome that had to be avoided. At the same time, we were fortunate to build critical partnerships with the Department of Energy and with the national labs. We have been working with customers, and our business model is set up to support them. Since we are both privately funded and intend to build, own, and operate, we care about the whole lifecycle of costs, we don’t push them off on either customers or taxpayers.
We also knew we had to work with the NRC to familiarize them with our design and regulatory model from early on, and to learn and iterate from our work with them as soon as we could. So we started pre-application with the NRC more than five years ago, as the first advanced fission company to engage in pre-application in recent history (and the only one in formal engagement, for a couple years). It really was an exciting time. We were motivated to do something new, as was our NRC core review team, and NRC leadership. Together with them, we piloted the core team review concept, iterated our new application format, piloted a draft application in 2018, took that feedback into our final application development, submitted the novel application, and reached the historic acceptance for review (“docketing”) of the first advanced fission combined license application in 2020. So in comparison to this history of working with the regulator, these recent decisions have felt blunt and sudden.
Despite this, conversations we have had with NRC management in the last few days have made it clear that the door is open to supplement the application and to resubmit. We are already discussing next steps with them and new ways to communicate. We submitted an application that addressed existing regulations, was complete and accepted for review, and we responded to all requests for information in a timely manner. And now, we are ready to keep moving forward by supplementing the application and resubmitting. It takes years to be budgeted for, but the NRC has budgeted for more than one Oklo application under review. Oklo has multiple projects under way with the NRC, the Aurora was just the first. Simultaneously, our partners at the labs remain dedicated, as they have been, related to fuel and site.
Here’s the second silver lining: all the learning we’ve had in this unprecedented review doesn’t go away. We certainly weren’t perfect on our first try; we get the chance now to resubmit based what we’ve learned. We may also get the chance to have in-person meetings and audits as originally planned for our first application. In March of 2020, we literally returned from application submittal meetings in DC to California that went into indefinite lockdown just days later. This completely changed our plans with the NRC for an open-door, in-depth, in-person review. Suddenly everything had to be curated for Zoom and Teams sharing, instead of engineers sitting down together at computers and walking through simulations.
So how are we taking this? Yes, it was surprising. And there are elements that were frustrating and even angering. But frankly, the Oklo team is energized. We’ve grown both in terms of team size and understanding, our mission has only strengthened, and we see how we can respond to the NRC better and iterate even faster. We’re ready to do that.
Oklo will respond to the NRC letter with a letter clarifying things that cannot be left the way they were characterized. So you will see that soon. But mostly, we want you to know that we are moving ahead. With your support, this will generate positive change. This is a distraction, but it may ultimately enable us to move ahead even faster. We look forward to continuing to share more about what is next for us as we move forward!
