NRC Issues Guidance on New Reactor Construction

The Nuclear Regulatory Commission has published updated descriptions of the types of new reactor construction activity that require prior agency approval.

The NRC’s interim staff guidance covers the activities that companies can request in applications for Limited Work Authorizations and Combined Licenses under the agency’s new reactor licensing process. The guidance, including specific examples of plant systems covered by the definitions, is available at

The guidance outlines the staff’s conclusion that construction requiring NRC approval includes work on a structure, system or component that

a. has a safety, security or accident mitigation function, or
b. whose failure could prevent a safety system from functioning or cause a reactor shutdown.

Examples of these structures include any part of a reactor building, including foundations, and fire protection systems. Construction also covers actions to prepare an excavated site (e.g., compacting soil or placing engineered backfill material) for eventual erection of the kinds of structures described in the guidance. Under the guidance, companies are free to perform “pre-construction” activities that would not have any impact on safety-related systems in the final plant. These activities would include:

• Clearing and grading a site and installing erosion control and other environmental mitigation measures.
• Erecting fences, construction support buildings and service facilities such as railroad spurs.
• Simple excavation.
• Erecting plant structures (e.g., cooling towers) that can be shown to be unrelated to reactor safety and whose failure would not cause a reactor shutdown.

Companies must accurately describe “pre-construction” excavation activities in any subsequent application to the NRC.

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