Terrestrial Energy has been engaged in the Canadian Nuclear Safety Commission’s (CNSC) Vendor Design Review (VDR) process since 2015 which is an optional service provided by the CNSC when requested by a vendor. The VDR is a mechanism that enables CNSC staff to provide feedback early in the design process based on a vendor's reactor technology. The word “pre-licensing” signifies that a design review is undertaken prior to the submission of a licence application to the CNSC by an applicant seeking to build and operate a new nuclear power plant. An application by a vendor for a review is not an application for a licence to prepare a site or to construct or operate a nuclear power facility and is not an indication of intent to proceed with a project.
William F. Smith
Senior Vice President, Operations and Engineering
The objective of a review is to verify, at a high level, the acceptability of a nuclear power plant design with respect to Canadian nuclear regulatory requirements and expectations, as well as Canadian codes and standards. These reviews also identify fundamental barriers to licensing for a new design in Canada and assures that a resolution path exists for any design issues identified in the review.
A vendor who has completed a Phase 2 Pre-Licensing VDR, has committed to increased regulatory efficiencies at the time of licensing. The results of Phase 2 will be taken into account mainly for the Construction Licence Application and is likely to result in increased efficiencies of technical reviews.
The primary regulatory document for the VDR is CNSC’s Physical Design of Reactor Facilities REGDOC-2.5.2 , which is developed for solid-fueled, water-cooled reactors and some specific areas do not apply to the IMSR. However, in general Terrestrial Energy has established that Canada’s regulatory framework is applicable to the IMSR, and that the REGDOC does apply with some notable exceptions where IMSR has proposed alternative approaches. Terrestrial Energy is introducing the technical and programmatic details to the Nuclear Regulatory Commission (NRC) in the United States (USNRC). The two regulators are collaborating under their mutual Memorandum of Cooperation to review selected IMSR technical submissions. The cooperation agreement is intended to supplement and strengthen the existing cooperation and share best practices and experiences between the CNSC and the USNRC.
Licensing is a fundamental requirement of the design, development, construction, operation and decommissioning of a nuclear power plant. As such the investment underpins the work necessary to ensure that safety requirements are met, and, hence, the ability to obtain a license is moving towards reasonable conclusion. In this respect the investment in the VDR, the USNRC activities, and the associated collaborative work, is considered essential and is a deliberate risk-mitigation strategy.
Primary lesson learned is to engage early with regulators and attempt to address more than a single jurisdiction.