New Reactor / Technology Portfolio

EXCEL has vast U.S. and international licensing experience working with regulatory bodies including the U.S. Nuclear Regulatory Commission, International Atomic Energy Agency, and Canadian Nuclear Safety Commission. EXCEL has worked with numerous nuclear plant designers and operators to develop and implement licensing and regulatory strategies for all phases of the nuclear plant life cycle, from design certification, initial licensing, license renewal, to decommissioning.

Since August 2005, EXCEL has been extensively involved in the preparation, review, and/or defense of most new build applications for Early Site Permits (ESPs), Design Certification Applications, and Combined Operating License (COL) applications. EXCEL’s Part 52 work has supported large light water reactors, small modular reactors, and advanced reactors. EXCEL works with the advanced reactor technology companies to develop integrated plans for design, construction, and deployment.

EXCEL personnel have extensive, current experience with Part 52 issues and other activities related to managing and resolving first-of-a-kind, complex issues. EXCEL leadership led to the first ever Part 52 ESP for Clinton Power Station and first ever COL for Vogtle Electric Generating Station (VEGP) Units 3 & 4. Few within the industry can provide this extensive Part 52 background, and understanding of the regulatory issues and resolutions associated with Part 52.

Service Offerings Include:

  • Combined License Application (COLA)
  • Design Certification support (DCD development and review)
  • Early Site Permitting (ESP development and review)
  • Siting
  • Technical Licensing Support
  • Emergency Planning Support (including EPZ revisions)

Application (COLA)

EXCEL has been extensively involved in the preparation, review, and/or defense of most new build applications for COLAs. EXCEL support includes project leadership, development of COLA text, and responses to NRC RAIs and licensing position papers. EXCEL has developed regulatory strategies to resolve complex licensing issues and interfaced with the NRC staff. EXCEL interfaced with the reactor vendors to resolve plant-specific issues and modify their DCDs. As part of this interface, EXCEL developed, reviewed and commented on draft DCD-related documents, topical reports, and ITAAC closure packages.

EXCEL senior level personnel are serving in leadership positions for TVA/NuScale in the planning and execution of deploying SMRs at Clinch River and INL.

EXCEL provided leadership or participated in the various DCWG for coordinating standardization of applications across the member utilities, including support of the DCD Amendment activities (topical report development and review, RAI response development and review, licensing strategy input, DCD revision drafting and review) and consideration of those activities on the COL applications.

Key Projects in this area include:
  • NuStart AP1000 Reference COLA (R-COLA) and Subsequent COLAs (S-COLAs);
  • NuStart ESBWR R-COLA;
  • UniStar COLAs (six COLAs);
  • Entergy, DTE Energy, and Dominion Power COLAs (GEH ESBWR);
  • NRG South Texas Project (STP) COLA;
  • Vogtle 3&4 COLAs; and
  • V.C. Summer 2&3 COLAs.

Design Certification
support (DC development and review)

EXCEL has been involved in the preparation and/or review the majority of applications for the various reactor designers applying for U.S. design certification (DC) or amending a previous DC under Part 52. We have experience working on the various DCD information types (Tier 1, Tier 2, Tier 2*, and Technical Specifications). EXCEL personnel were responsible leads for most DCD chapters and supplemental support for all other chapters, including significant roles in drafting and negotiating Tier 1 content including ITAAC.

Our expertise includes coordinating and developing revisions to DCD chapters, responses to NRC RAIs, developing position papers to address first-of-kind or evolving licensing issues, and preparing ACRS presentations. EXCEL also provided licensing leadership and participated in the various Design Centered Working Groups (DCWG), which maintain standardization of the applications across the member utilities.

Key Projects in this area include:
  • The AP1000 Design Certification Application Amendment;
  • The GEH ESBWR Design Certification Application;
  • The AREVA EPR Design Certification Application;
  • MHI US-APWR Design Certification Application;
  • The KHNP APR1400 Design Certification Application; and
  • The Toshiba ABWR Design Certification Rule Renewal Application.

Early Site Permitting (ESP development and review) / Siting

EXCEL provided overall licensing leadership for development and submittal of the first ever Part 52 Early Site Permit application including development of responses to NRC requests for additional information (RAIs). This role also included preparation and presentation to the Advisory Committee for Reactor Safeguards (ACRS) and expert testimony to the Atomic Safety and Licensing Board (ASLB), leading to the eventual issuance of the Clinton ESP, the first such ESP issued under Part 52. This ESP provides for eventual utilization of a wide range of reactor designs through a plant parameter envelope evaluation format. EXCEL is also currently providing management-level support for the Clinch River ESP EXCEL is developing and implementing the tools required for successful deployment of the NuScale SMR at Clinch River and INL.

Key Projects in this area include: The Exelon Clinton Power Station and TVA Clinch River SMR Project.

Technical Licensing Support

For advanced reactor designers and potential license applicants, EXCEL can develop and implement a licensing strategy for success that applies key elements including:
  • Utilizing the progress achieved from previous licensing efforts and NRC interactions associated with a particular technology or design center
  • Working collaboratively with vendors, applicants, NRC and industry on resolution of generic licensing issues
  • Engaging NRC early to identify and resolve technical, regulatory and policy issues
  • Determining the optimum license approach (e.g., Part 50, Part 52, etc.) by evaluating the available alternative approaches to plant licensing (e.g., Part 50, Part 52 COLA or COLA/DCD combination, prototype nuclear power plant (using 10 CFR 50.43(e)) and provide a recommended approach
  • Identifying pre-application activities associated with key licensing issues such as defining the project-specific activities that need to be performed in order to identify those areas where NRC light-water reactor (LWR) licensing requirements may need to be adapted or revised to address the licensing of a gas reactor technology
  • Estimating the scope of expected interactions with NRC staff
  • Identifying possible pre-application Topical and Technical Reports applicable to the technology; and
  • Developing a level 1 proposed schedule for licensing-related activities leading to a license.

EXCEL is reactor technology neutral and is very knowledgeable of global large, small, and advanced reactor technology designs. As such, EXCEL is uniquely qualified to provide Reactor Technology Assessment Reports for any country considering large, small, and/or advanced reactor builds. EXCEL has performed 11 such studies and reports over the last 10 years. These reports have been used to justify decisions for stakeholders such as Prime Ministers, Parliament, Government Ministries, Regulatory Authorities, Owners/Operators, Investors, and Citizenry. Key Projects in this area include: UAE, Switzerland, and Finland.

Emergency Planning Support (including EPZ revisions)

EXCEL supports the development, testing, and validation of emergency preparedness and response programs that ensure client sites are prepared to react to a wide spectrum of emergencies. EXCEL has had success assisting plants by reviewing the emergency preparedness and response program and making independent recommendations on changes that can be accomplished under 10 CFR 50.54(q), with additional reviews of changes possible under 10 CFR 50.90. EXCEL has also been successful in providing on-demand licensing and regulatory assistance to clients. This assistance includes inspection support, preparing for interactions with the regulator, developing and/or reviewing licensing or change packages, and assisting and mentoring staff.