What We Heard Report – DIS-16-04

DIS-16-04, Small Modular Reactors: Regulatory Strategy, Approaches and Challenges

Preamble

Discussion papers play an important role in the selection and development of the regulatory framework and regulatory program of the Canadian Nuclear Safety Commission (CNSC). They are used to solicit early public feedback on CNSC policies or approaches.

The use of discussion papers early in the regulatory process underlines the CNSC’s commitment to a transparent consultation process. The CNSC analyzes and considers preliminary feedback when determining the type and nature of requirements and guidance to issue.

Introduction

In recent years, novel reactor technologies have emerged to supply power to smaller electrical grids or remote, off-grid areas. These technologies are commonly referred to as small modular reactors (SMRs). The electrical output of existing or proposed SMR facilities varies from less than a megawatt from non-grid-connected sites to several hundred megawatts from grid-connected sites.

The CNSC published discussion paper DIS-16-04, Small Modular Reactors: Regulatory Strategy, Approaches and Challenges, in May 2016. The document examines key areas with potential licensing challenges. In some cases, the CNSC confirmed that existing requirements remain valid and useful. In other areas, it concluded that the implications of the proposed innovative approaches need to be examined further to confirm the level of applicability of existing requirements and guidance – and the extent to which different requirements or guidance are needed.

The following summarizes the results of the CNSC’s consultation on DIS-16-04 and outlines some of the next steps the CNSC plans to undertake regarding the regulatory framework for SMRs.

Consultation process

Discussion paper DIS-16-04 was published on the CNSC website on May 31, 2016. Visitors to the CNSC website were alerted via the Latest News and What’s New pages that the document had been posted. An email was sent to the CNSC’s subscribers’ list alerting recipients that DIS-16-04 had been posted. A consultation notice was also posted on the Government of Canada’s Consulting with Canadians website. On September 12, 2016, the CNSC held a question-and-answer session for those who had previously contacted the CNSC about the regulatory framework for SMRs. The purpose of the session was to provide additional clarity to interested stakeholders prior to their submitting comments on DIS 16-04 and to answer their questions. At this session, it was stressed that all comments on the paper had to be submitted through the CNSC’s official consultation channels.

The consultation period lasted 120 days and ended on September 28, 2016. On November 14, 2016, the CNSC posted the comments it had received on its website, and issued an invitation to provide feedback on those comments until December 5, 2016. The CNSC received more than 430 comments from 15 sources. Of those, 13 were from industry representatives and 2 from other stakeholders.

Summary of comments

General comments and observations

The majority of respondents stated that SMRs do not pose an insurmountable challenge to existing regulatory requirements in Canada. They also confirmed that the CNSC is currently in a position to consider an application to license an SMR under the existing Canadian regulatory framework. While they indicated that new regulations are not needed, they commented that amendments to some regulations, notably the Nuclear Security Regulations, should be considered.

Commenters indicated that the existing regulatory framework could be clarified in some areas, so that vendors and future licence applicants better understand how the CNSC’s licence application requirements might be applied to SMRs.

In particular, the industry would appreciate more information on how the "risk-informed" and "graded approach" concepts would be applied to SMR designs, and also commented that the regulatory requirements should be applied commensurate with risk. Industry respondents also said it is important to articulate how the graded approach would be applied to all SMRs, taking new safety features into account for smaller SMRs in particular (e.g., those with less than approximately 10 megawatts electric [Mwe] in output per reactor module).

Technical information, including research and development activities used to support a safety case

Feedback received indicated that, in general, requirements regarding the scope and adequacy of supporting information required for a licence application are sufficiently clear.

Commenters stated that an important aspect of licensing projects involving SMRs in Canada is the CNSC’s graded approach, under which regulatory requirements are commensurate with risk. It is therefore important for the CNSC to articulate how its graded approach may be applied to SMRs. Respondents also encouraged industry and the CNSC to hold further discussions on the implementation of the graded approach, to achieve common understanding.

Commenters noted that most SMRs employ novel technology that will not have the same historical operating data as existing nuclear power plants. As a result, commenters were of the opinion that this should be recognized during the licensing review process and that emphasis should be placed on the proponent’s research and development (R&D) program and on commissioning the first plant.

The CNSC also heard that the principle of reproducibility is vital for SMR business models, since these units are produced, installed and operated in a standardized, repeatable manner. The same notion was put forth as to how SMRs are sited, licensed and regulated. Stakeholders suggested that it should be possible to license a fleet of SMRs should an applicant demonstrate that it could operate multiple reactors on different sites under the same conditions, barring any unique local environmental conditions.

CNSC comment

CNSC staff recognize that additional discussions are necessary to further reinforce how the graded approach may be applied in the development of safety cases for SMR projects. To facilitate this discussion, staff are planning workshops on the application of the graded approach. Potential topics include:

• an overview of the CNSC’s approach to risk-informed decision-making processes and an applicant’s role in informing those processes with suitable information to support safety claims
• reinforcement of the principles of defence in depth (DiD), including a discussion on the appropriateness of the number of barriers or DiD levels
• the role of regulatory guidance in articulating criteria that could be considered when applying the graded approach in particular areas without compromising safety
• the role of supporting information in demonstrating that proposed safety and control measures meet requirements
• the application of conservative approaches, where significant uncertainties exist in safety analysis

Alternative approaches to interpreting requirements, such as those being employed in the vendor design review process, may also be used in the licensing process for SMRs.

Regardless of the application, the CNSC’s decision making around the acceptability of a proposed alternative requires a well-articulated rationale supported by a clear demonstration of the adequacy of the proposed features to meet the requirements. Safety margins are expected to take into account the uncertainties presented by the features, particularly where operating experience is minimal.

The CNSC remains open to discussing proposals to increase efficiencies through the implementation of alternative approaches to fulfilling licensing requirements. What is paramount is that the applicant can demonstrate that the activity or the operation of a given facility can be carried out safely and that the environment will be protected.

Licensing process for non-permanent facilities / relocatable SMRs

Commenters indicated that some SMRs may be small, non-permanent structures that are easily relocated. Therefore, the CNSC may receive licence proposals to install relocatable SMRs in a defined area with flexibility to relocate within that area when power needs change (e.g., to provide steam for the oil sands).

A number of respondents indicated that it would be desirable to establish a licensing basis that allows the SMR module to be more readily accepted by regulatory jurisdictions in Canada and internationally.

CNSC comment

The CNSC recognizes that it may be asked to review proposals for relocatable reactors and for locating SMRs on multiple sites and/or across multiple jurisdictions within Canada. It also recognizes the value of a consistent regulatory approach across multiple international jurisdictions. The CNSC will take both of these considerations into account when developing its regulatory approach to licensing SMRs.

The CNSC also encourages potential proponents to come forward and outline their proposals to improve understanding of how regulatory requirements would apply in their specific cases.

Licensing approach for a new demonstration reactor

Feedback indicated that a new reactor facility may be used to gather operating experience needed for future commercial facilities. In that event, additional requirements or guidance would be needed to address operational restrictions, because licensing information is not sufficiently clear.

Respondents indicated that the scope and adequacy of supporting information called for in licence application guides^{Footnote 1} depend on the quality of the deterministic and probabilistic safety analyses. The designs for these reactors should be used to address the uncertainties introduced by the application of integrated multiple novel features in a demonstration facility.

Commenters stated that regulatory/guidance document RD/GD-369, Licence Application Guide: Licence to Construct a Nuclear Power Plant, allows the use of licensing basis documents and guidance not normally used in Canada, with an appropriate assessment such as a gap analysis. Respondents indicated, however, that performing gap analyses between, for example, foreign codes/standards and Canadian standards could be a significant challenge.

Some respondents indicated that no special licensing approach needs to be put in place for a demonstration reactor and that many of these will become commercial plants in any case, after an initial period of operation. The licensing case for any reactor, they noted, has to demonstrate that the plant is safe to operate.

CNSC comment

CNSC licence application guides take into account lessons learned from numerous global first-of-a kind (FOAK) new-build nuclear projects.

The CNSC expects applicants to present a safety case that sets out appropriate operational limits and conditions (OLC) taking into account uncertainties, and to adjust those OLCs over time as sufficient operating experience is gained. The CNSC also expects that applicants will demonstrate which safety and control measures will be implemented to adequately address uncertainties in the design features and their construction and commissioning programs.

Where an applicant intends to conduct activities in a phased manner, depending on levels of uncertainties or design completeness, the application should provide sufficient information to show how each phase will be conducted safely. This approach enables the licence to be structured to permit such activities to gather the necessary operating data and experience to support progression to the next phase.

Licensing process and environmental assessments for fleets of SMRs

Respondents indicated that many characteristics of SMR designs, some of which are mentioned in the introduction to DIS-16-04, make SMRs suited to a graded approach in the application of regulatory requirements. However, respondents emphasized that it is not known how CNSC staff would concretely apply the graded approach concept during their review.

In addition, although noting the CNSC’s willingness to apply risk-informed application of regulatory requirements, respondents emphasized that there is no clear acknowledgement that the licensing timeline for Class IA nuclear facilities could be reduced below the nine-year duration as described in regulatory document REGDOC-3.5.1, Licensing Process for Class I Nuclear Facilities and Uranium Mines and Mills. There is thus no indication of the duration of the review process for SMRs (and other facilities, including prototypes and demonstration facilities) that would make significant use of risk-informed decision making.

Commenters also sought a way for the environmental assessment process to be streamlined. Some suggested this could be achieved by allowing a single licence on multiple sites, especially for the same or similar SMR designs and for the same licensee.

CNSC comment

CNSC staff have committed to hosting a workshop on the graded approach in late 2017 to further explain how this approach (which is effectively a framework for risk-informed decision making) is applied in various processes relevant to new builds, such as performing technical assessments, ensuring compliance and managing the regulatory framework.

The licensing timelines provided in REGDOC-3.5.1 are for a FOAK large nuclear power plant. Global experience from new-build nuclear projects has shown that the following factors cause significant uncertainties and can delay licensing timelines:

• degree of completeness of licence application
• degree of stakeholder support (i.e., from nearby communities, Aboriginal groups and other consultations, including those with provincial or territorial agencies)
• state of completeness of design (i.e., whether there is sufficient information to make a decision for the proposed activity)
• outstanding safety issues
• novel features or approaches
• state of completion of supporting R&D (i.e., whether there is sufficient information to make a decision for the proposed activity)
• quality and timeliness of construction and commissioning

The licensing timelines for SMR projects will depend on how the above factors are addressed. FOAK nuclear power projects are expected to take longer to review than subsequent projects, as experience needs to be gained in the licensing and conduct of activities for those specific reactor concepts.

The required considerations of environmental effects are described in regulatory document REGDOC 2.9.1, Environmental Protection: Environmental Principles, Assessments and Protection Measures, and in the Canadian Environmental Assessment Act, 2012.

Management system considerations: licensees of activities involving SMRs

Commenters stated that sealed cores or modules (i.e., factory-fuelled and non-refuellable reactor modules) pose a number of licensing and operational issues. A licensee would be responsible for the condition of a module received and for ensuring that the module is not damaged during transportation.

Respondents also stated that there may be long lead times for procurement of items such as sealed-core SMR modules (including integral vessel designs), which may be designed and manufactured outside Canada under different nuclear jurisdiction requirements, codes and standards. Extensive and retroactive standard-to-standard comparisons may not be feasible or useful to demonstrate equivalency to Canadian codes and standards and regulations. Industry encouraged the CNSC to develop some efficiency for the process.

CNSC comment

The licensee is responsible for safety. As such, it is responsible for demonstrating that the safety and control measures proposed for a project ensure adequate provision for the protection of the environment, the health and safety of persons and the maintenance of national security and measures required to implement international obligations to which Canada has agreed.

Proponents may propose to use codes and standards from other countries in their activities as long as they demonstrate that these referenced codes and standards are appropriate.

Management system: minimum complement in SMR facilities

Comments suggested that CNSC staff consider innovative approaches to defining minimum shift complements, which take into account new designs and technology, as they review guidance document G-323, Ensuring the Presence of Sufficient Qualified Staff at Class I Nuclear Facilities – Minimum Staff Complement.

CNSC comment

Currently all guidance in G-323 can be applied in a risk-informed manner to different types of reactor facilities. However, the need for an adequate number of qualified staff is an integral part of a facility’s DiD approach. This would need to be reflected in the licensee’s safety and control measures, which would include adequately proven design features.

CNSC staff understand that further elaboration on guidance may be helpful to clarify expectations in this area.

Safeguards implementation and verification

Feedback indicated that in general, the safeguards arrangements – as defined by the International Atomic Energy Agency (IAEA) and supplemented by the CNSC’s additional requirements described in regulatory document RD-336, Accounting and Reporting of Nuclear Material – should be acceptable. However, commenters indicated that some designs may require special techniques to verify the accounting of fuel being added and removed from the core offsite (and possibly outside Canada). The correct time and method to engage with the CNSC and IAEA during safeguards design is not clear.

Commenters also noted that there may be some technical challenges with safeguards for SMRs, as outlined in the regulations and in licences. These include factors such as SMRs sited at remote locations with limited IAEA inspector access, and SMRs with long-life sealed cores as well as those with high initial excess reactivity. Responders also indicated that some of these challenges are also potential benefits. For example, a remote location makes diversion more difficult and the same is true of a sealed long-life core.

CNSC comment

CNSC staff note that clarity is needed on when and how parties developing reactor technologies should engage with safeguards specialists from the CNSC and IAEA.

Safeguards requirements for SMRs will depend on the reactors’ design and operation. These requirements or measures typically involve the controlling, tracking and reporting of nuclear materials to ensure that the material remains in peaceful activities and that nuclear facilities are used only for peaceful purposes. This means that safeguards measures will vary with design and operation, such as open or sealed-core structures, and fuel types. Specific measures may therefore be needed to cover construction and operational activities to ensure safeguards effectiveness for the SMRs.

Deterministic and probabilistic safety analyses

Feedback stated that the regulatory framework for SMRs needs to take into account designs that include extensive use of passive features. It is claimed by some respondents that these features will prevent some or most of the traditional accident events and scenarios from causing any core damage or from releasing radioactive materials to the environment. Traditional probabilistic safety analyses may be difficult to employ, and alternate techniques should be recognized as applicable to or acceptable for safety cases.

CNSC comment

The decision to accept safety claims of new SMR safety features is highly dependent on the quality of the information to support such claims. This quality influences the credibility of claims to exclude specific events and the safety analysis results. Early feedback on integrated safety analysis methodologies (such as deterministic and probabilistic safety analyses and hazard analyses) is provided to vendors that participate in the vendor design review process. Existing safety analysis requirements and guidance permit alternative approaches if suitably justified.

Per regulatory document REGDOC-2.4.2, Probabilistic Safety Assessment (PSA) for Nuclear Power Plants, applicants and licensees are required to seek the CNSC’s acceptance of the PSA methodology to confirm that the proposed methodology can support the PSA’s objectives. It is therefore expected that applicants and licensees will submit PSA methodologies that factor in their specific design features.

Defence in depth and accident mitigation

The CNSC also heard that the innovative safety features of SMRs (i.e., the passive and inherent safety characteristics that may account for the safety benefits) can constitute the basis for a change in traditional safety design practices and may lead to a change in the relative importance of the five DiD levels.

Some feedback noted that the five levels of DiD have obvious relevance to traditional water-cooled reactors, and that it must be recognized that this is at least partly because the entire notion of DiD itself has evolved with experience from operating light-water reactors and heavy-water reactors.

Commenters noted that new designs are placing an increased emphasis on the first three levels of DiD (i.e., prevention, control and protection) with an increased emphasis on inherent and passive safety features. An SMR that places more emphasis on the front end of DiD would not need to place as much emphasis on the back end (i.e., accident management and offsite measures).

CNSC comment

The CNSC addresses the principles of DiD in requirements and guidance for all activities regulated under the Nuclear Safety and Control Act, and a certain amount of flexibility already exists for reactor facilities. However, a key tenet underpinning requirements for DiD is that "DiD shall be achieved at the design phase through the application of design provisions specific to the five levels of defence". DiD applies to all organizational, behavioural, and design-related safety and security activities to ensure that they are subject to overlapping provisions. The proponent’s demonstration of its understanding and application of the concept to the design and associated activities will be the focus of the technical assessment during the licensing process. Pre-licensing engagement via the vendor design review process may also provide early feedback to reactor vendors. Design requirements and guidance pertaining to reactor facilities can be found in regulatory document RD-367, Design of Small Reactor Facilities, and regulatory document REGDOC-2.5.2, Design of Reactor Facilities: Nuclear Power Plants.

Emergency planning zones

Feedback indicated that the discussion paper covers this topic well. There is already sufficient flexibility in the requirements for emergency planning zones. No further regulatory guidance is needed.

Commenters stated that remote regions represent a special case. In these regions, short-term offsite emergency measures are difficult to implement – making it even more imperative that such measures not be prescribed as requirements (unless they could be implemented in a timely, reliable fashion by local personnel such as police).

CNSC comment

Emergency planning zone sizes are determined by looking at the full suite of potential accidents and their associated probabilities, which are identified in the safety analysis. The accidents that must be considered for emergency planning go beyond the large-release frequency design criteria.

The degree of passive and inherent safety of the plant is considered within the safety analysis.Site-specific and technology-specific detailed emergency response plans must take remote regions into consideration and demonstrate how the requirements of regulatory document REGDOC-2.10.1, Nuclear Emergency Preparedness and Response, version 2, will be satisfied.

Transportable reactor concepts

Commenters noted that, although Canada has certified packages for used nuclear fuel, the packages for new and used reactor cores could be developed and approved in a foreign country and then certified in Canada. Since both the used and new cores would contain fissile material, prevention of tampering and diversion during transit and criticality would be areas of detailed review.

CNSC comment

Section 2.11 of the discussion paper stated that the transport of packages for new and spent reactor cores (whether containing fuel or defuelled) can be addressed under the existing regulations for the packaging and transport of nuclear substances. The requirements for import or export licences will need to be considered for each country of transit, consistent with that country’s regulatory framework.

Increased use of automation for plant operation and maintenance

Respondents indicated that one area that may require attention is the increased automation of maintenance through computerized aids (e.g., virtualization). This should increase the reliability, efficiency, safety and effectiveness of maintenance.

CNSC comment

The CNSC recognizes that modern technologies are likely to enable the use of extensive automation, but this strategy needs to be considered carefully in the overall safety and security objectives of the facility. The CNSC has noted that, around the world, instrumentation and control challenges have arisen in both regulatory reviews of new technologies and licensing of projects referencing new reactors. Automation in nuclear applications is expected to be qualified to a level commensurate with its potential impact on safety. The use of such automation should also be reviewed within the licensee’s human factors program to ensure that “error-likely” situations are prevented, or mitigated should such a situation occur.

Industry stakeholders should examine the existing suite of standards to confirm that quality requirements for such tools are clearly articulated. However, any standards development should avoid duplication of existing regulatory requirements. Lessons learned can also be applied to the CNSC’s existing regulatory framework pertaining to reactors.

Human–machine interfaces in facility operation

Commenters noted that the existing requirements cover most of the design aspects required to design human–machine interfaces (HMIs) that are capable of supporting oversight and control of SMRs.

They indicated that one prospective area that could benefit from additional clarity would be guidance for HMI technology selection. Human performance and operational safety and effectiveness should be major deciding factors in choosing technologies.

Respondents also noted that new HMI technologies – such as tablets, handheld devices, large and high-resolution displays, wearable devices and augmented reality systems ‐ have been introduced in other industries. These can be expected to become options for the nuclear industry, particularly for new builds. Most new reactor designs would employ FOAK technology in this industry.

CNSC comment

It is not the CNSC’s role to guide design choices such as level of automation, computational intelligence, operator support systems and other means to optimize HMI. The proponent must demonstrate that its choices support the achievement of the safety objectives.

By following verification and validation activities in the existing CNSC regulatory framework (e.g., guidance document G-278, Human Factors Verification and Validation Plans), these new designs should meet the existing requirements and guidance for HMIs used for facility operation and maintenance. Furthermore, the CSA Group standard CSA N290.12-14, Human factors in design for nuclear power plants, addresses the challenge of integration.

The impact of new technologies on human performance

Respondents indicated that existing human performance requirements and guidance are sufficiently clear with respect to new technologies; however, they noted that greater emphasis could be placed on system knowledge because of the potential increase in complexity that may accompany the introduction of new technologies.

CNSC comment

These comments will be considered in developing expectations in this area.

Financial guarantees

Stakeholders requested clarity as to which financial guarantee regime would apply to SMRs and how the regime would account for the range of nuclear liabilities associated with increasing the number of SMR modules deployed at a site.

CNSC comment

The CNSC is currently reviewing its regulatory information and will clarify (where required) which financial guarantee regime applies to SMRs and how the regime will account for the potential increase in nuclear liability coinciding with the increased number of modules onsite.

Site security provisions

Feedback stated that SMRs would require new approaches to site security because the credible threats to these units may be completely different from those faced by existing facilities. Should nuclear material not be stored onsite, other than in the reactor, vulnerability would be significantly reduced. The use of passive systems may eliminate most of the systems that are traditionally vulnerable to sabotage.

Commenters also stated that, in view of potential enhanced inherent and passive safety characteristics, a smaller security force than for a conventional NPP could be justified. Regulatory guidance on this would be useful.

CNSC comment

This information is being considered as part of the review of the Nuclear Security Regulations, and a workshop was held with SMR stakeholders early in 2017 to collect additional information. It is important to note that the use of "security by design" is possible under the existing regulations and that a graded approach to security can be applied to meet requirements based on security risk-informed considerations.

Waste management and decommissioning

Commenters stated that SMRs with factory-fuelled cores and operating lives of 5 to 10 years need to address used-core storage. The size and layout of the sites may not allow temporary onsite storage of many cores.

Commenters noted that REGDOC-3.5.1 states that applicants must be aware of, and comply with, the Nuclear Fuel Waste Act (NFWA). Respondents also pointed out that the NFWA would need to be revised if the operator of an SMR did not meet this act’s definition of a nuclear energy corporation. Furthermore, subsections 10(1) and 10(2) would need to be revised to include a funding formula that accounts for increasing the amount of nuclear fuel waste as a function of the number of SMR modules that would be deployed at a site.

CNSC comment

An applicant is expected to demonstrate that it can meet the safety and control measures associated with the proposed waste-related activities. The applicant is also expected to demonstrate that programs and activities are of sufficient quality commensurate with the risk. Available codes and standards can be used to accomplish this with the support of R&D activities that address gaps in knowledge and technologies. For example, sections 6.1 and 6.2 of CSA N292.2-13, Interim dry storage of irradiated fuel, describe the requirements for site selection for dry storage.

If choosing another site for used-fuel storage, SMR operators would have to provide CNSC staff with the handling, packaging and transportation procedures for the chosen site. These comments were shared with Natural Resources Canada, which administers the NFWA.

Subsurface civil structures important to safety

Respondents noted that existing plants have significant numbers of embedded safety-related structures and are often located in areas with relatively high groundwater tables. In many cases, areas of these structures are difficult or impossible to monitor for degradation. The embedded designs of SMRs should not be considered unique.

CNSC comment

The embedment of civil structures is not unique, but the contemplated depths of some of these designs are significantly greater than what is found in the existing fleet and different siting scenarios may pose specific challenges to long-term inspection and maintenance of such structures.

A large body of operating experience, on assessing degradation and aging management of steel and concrete structures, has been gathered over the past decades. CNSC staff expect that this operating experience will be considered in design activities, in addition to the application of codes and standards.

Fusion technologies

Some respondents told the CNSC that fusion and fission technologies are not necessarily discrete, as most practicable fusion interactions release free neutrons. A novel reactor concept could incorporate both fusion and fission as a source of energy. A single regulatory framework could be applicable to both fusion and fission reactors and any combination of them. If the risk of operating a fusion reactor is quantifiable, then it should be regulated similarly to a fission reactor with the same quantifiable risk.

Others indicated that the risks associated with fusion technologies can be significantly different from fission technologies. However, both sides appear to agree that although the hazards are different, the mechanisms for quantifying and managing those risks are the same.

Respondents also indicated that a waste stream would still exist, as components become activated over the course of operations. Fusion facilities (both those at the R&D stage and future commercial power producing systems) would have radiation hazards driven by three factors:

• inventory of volatile radioactive substances, primarily tritium
• prompt exposure to neutron or high-energy photon flux from a fusion reaction
• radioactivity from decay of materials activated by fusion neutron flux

Feedback indicated that the magnitudes of these radiation hazards would depend on the specific fusion technology and the nature of the system. Large-volume magnetic fusion systems, for example, may have higher tritium inventories than pulsed approaches. Similarly, neutron and photon energy flux would depend on the design of blanket and shielding systems that may be technology-specific.

Respondents said that the radiation hazards in fusion (i.e., tritium and activation) would be considered secondary hazards in fission systems, because the severity of any accident would be much lower than the primary fission risks stated above and unlikely to cause any risk to the public. Fusion reactions are driven reactions, where heating and control systems (both in the case of pulsed and continuous operation) are required for fusion reactions to occur. Therefore, any form of system failure severe enough to compromise fusion system operation would also immediately stop any fusion reaction.

CNSC comment

The regulatory framework is intended to take into consideration the level of risk posed by a proposal. Application of this framework would be adapted to the specific options considered by a proponent.

CNSC staff continue to monitor fusion developments and efforts around the world and remain open to engaging with potential proponents seeking to conduct activities in Canada.

Next steps

The next steps in providing further clarity to the regulatory framework for SMRs will be as follows:

• consider amendments to the Nuclear Security Regulations
• provide greater clarity on application of the graded approach
• provide greater clarity on licensing for SMRs
• review identified CNSC regulatory documents

Consider amendments to the Nuclear Security Regulations

On January 31, 2017 a workshop was held with those who commented on DIS-16-04, as well as other interested stakeholders, on potential amendments to the Nuclear Security Regulations. The CNSC will publish a synopsis of this workshop, with an invitation for stakeholders to comment, in fall 2017. The workshop, as well as comments received on the published synopsis, will inform the direction that the CNSC will take before making any amendments to the Nuclear Security Regulations.

Greater clarity on application of the graded approach

The CNSC is committed to providing greater clarity, where possible, on the application of the graded approach for SMRs. It will host a workshop on the subject in November 2017. A synopsis of this workshop will be published, and the comments received, as well as the input from the proposed workshop, will inform the CNSC’s expectations for SMRs.

Greater clarity on licensing of SMRs

The CNSC is committed to engaging with stakeholders who plan to submit applications for SMRs. Pre-licensing engagement can be used to understand the specific objectives of a FOAK or demonstration reactor and how the application process could proceed in light of these objectives. As well, CNSC staff are developing a proposal on a regulatory document that will address licensing of SMRs.

Review of CNSC regulatory documents

As a matter of good regulatory practice, the CNSC regularly reviews its suite of regulatory documents. Several regulatory documents were cited by respondents in their feedback on DIS-16-04; this feedback will also be considered when these regulatory documents come up for their scheduled reviews. Regulatory documents cited in the feedback on DIS-16-04 include:

• G-323, Ensuring Presence of Sufficient Qualified Staff at Class I Nuclear Facilities – Minimum Staff Complement
• RD-336, Accounting and Reporting of Nuclear Material
• RD-346, Site Evaluation for New Nuclear Power Plants
• RD-367, Design of Small Reactor Facilities
• RD/GD-369, Licence Application Guide: Licence to Construct a Nuclear Power Plant
• REGDOC-2.4.2, Probabilistic Safety Assessment (PSA) for Nuclear Power Plants
• REGDOC-2.5.2, Design of Reactor Facilities: Nuclear Power Plants
• REGDOC-3.5.1, Licensing Process for Class I Nuclear Power Plants and Uranium Mines and Mills

Revised and new regulatory documents are subject to the CNSC’s consultation process. This provides interested stakeholders with an opportunity to comment on any proposed/new requirements or guidance prior to implementation.

Finally, the CNSC is participating in a Nuclear Energy Agency initiative with the United States and the United Kingdom to develop a joint technical assessment document for SMR technology.