Communication processes between the ASNR and project developers

New security challenges and security objectives that need to be adapted

While the location of a new nuclear power plant is one aspect of the project that can, to a certain extent, be chosen, this is not the case for many PRM projects.     
Indeed, in the case of a SMR dedicated to industrial heat production or district heating, the site is determined by the location of the customer to whom it will be delivering the energy. Numerous SMR projects are thus aiming for deployment on industrial sites located near to or even within urban areas. 
This type of siting near to densely populated or industrial areas is being envisaged by the project developers because these reactors are likely to be able to achieve safety levels significantly better than those of today’s large power generating reactors. The low power to be removed in the event of an accident should make it possible to combine passive and active safety systems, leading to increased diversification of the safety provisions, longer grace periods ^[1] and better protection of the containment barriers. In addition, some of the new technologies proposed have specific characteristics (such as the intrinsic containment performance of the particular fuels of high-temperature reactors), which also make it possible to envisage a significant reduction in radioactive releases in the event of an accident, even the most severe.

Even if these reactors can in principle achieve a higher safety level than those of the high-power electricity generating reactors, ASNR considers that it is necessary to adjust the required safety standards before envisaging such siting close to population centers.

ASNR thus set up a framework for defining enhanced safety objectives to be established when considering such facilities, all while meeting societal expectations regarding the safety level of the relevant PRM projects. The results of this analysis also contribute to the work on harmonizing safety objectives being carried out by the ASNR with its European counterparts within the framework of WENRA.

In order to optimise preparations for any creation authorisation applications for these various projects, and in order to mobilise resources proportionate to the level of development maturity of each project, a four-phase framework of incremental technical exchanges was set up.

Phase 1: Screening phase

During a meeting, the project developer is asked to present the following to ASNR :

• the main characteristics of its project (technology, power, form of energy output, upstream and downstream of the fuel cycle, … ),
• the state of progress of the reactor or its factory design and its safety demonstration,
• the project development schedule,
• the current technical and financial capacity of the company developing the project, along with its growth plan (calls for funds and staffing).

At the end of this prospective contact, the ASNR assesses the maturity of the project as a whole with regard to the following 3 elements:

1. Minimum maturity of the technical project:
   the project developer has an initial complete conceptual design and stabilized of its project;
2. Project developer’s capacity to conduct technical exchanges: the project developer has a sufficient in-house technical team  to be able to carry out technical exchanges with ASNR on all the technical issues involved in its safety demonstration;
3. Minimum financial security of the project developer: the company behind the project has sufficient financial guarantees to ensure its medium-term development.

If the overall maturity of the project does not appear sufficient to initiate a preparatory review, the project owner is invited to continue its development before contacting the ASNR again. 

Phase 2: Project preparatory review

Once the project maturity is considered to be sufficient with respect to the three above-mentioned criteria, a cycle of thematic technical meetings is scheduled.

The aim of this cycle of meetings is to enable the ASNR, through presentations and technical dialogue, to gain an overall view of the project, to understand its design choices, to take stock of the state of knowledge available or to be acquired, and to understand the main safety orientations on which the project leader intends to base his safety demonstration and justification.

A summary seminar may be organized to close this cycle of meetings.

This phase is merely an exchange of information in preparation for future instructions. No opinion or decision is expressed on the project at this stage by the ASNR. 

Phase 3: Pre-licensing of the fundamental safety options of the project

Pursuant to Article R. 593-14 of the Environment Code, before finalising the detailed design of its reactor, the project developer that intends to apply for a creation authorisation procedure can ask ASNR for its opinion on some or all of the fundamental aspects of its project.

With regard to these innovative reactor projects, ASNR recommends that the project developers take advantage of this pre-licensing step. This step enables initial technical assessments to be started and enables the positions of the regulator to be obtained on a jointly agreed list of identified high-stakes subjects highlighted during the preparatory review phase.

Phase 4: assessment of the Creation authorisation application

Finally, once the detailed design of the project is ready, a submission of a creation authorisation application can be envisaged.

This phase represents a new step in the increasing commitment of resources by ASNR. Following the complete technical evaluation of the project, there will also be an evaluation of the characteristics of the planned site and a programme of inspections of the applicant, who acquires the de facto status of licensee, notably with the aim of checking its management system and its ability to manage subcontracting.

Lightbox

Despite the already high level of harmonisation both internationally, with the safety standards from the International Atomic Energy Agency (IAEA), and at the European level, with the safety objectives and reference levels adopted by the Western European Nuclear Regulators’ Association (WENRA), each project to build a reactor model in a new country generally involves adapting the design to comply with to the national regulatory context and the requirements of the local licensee (including the proposed organizational structure for both day-to-day operations and emergency management, in coordination with local authorities). 

Lightbox

The business model for PRMs is based on mass production to reduce costs through economies of scale. Project developers therefore aim to have a single model approved in multiple countries.

To facilitate deployment of these new small reactors, ASNR is participating in several international initiatives (IAEA, NEA, WENRA, etc.).