Research by Tjerk Kuipers, nuclear safety specialist at the Ministry of Defense, shows that Dutch regulations seem to meet basic requirements of flexibility and efficiency.³² However, some risk factors for the licensing process itself should be addressed, the lack of capacity and practical experience in both public departments and the regulator, which can lead to delays and/or substantial cost increases. Plus needlessly slow processes are not conducive to public support.

Here are our recommendations that can contribute to an efficient and smooth licensing process, which meets the international safety requirements set for nuclear power generation  installations.

Streamline licensing. If a reactor system in the country of origin has successfully passed through all licensing-stages, it offers confidence to license the system in other countries as well. In practice it works well if the supervisor of the host country 'walks along' during the licensing procedure or is informed by the regulator of the country of origin.

Licensing based on Module Design Certification. Module Design Certification (MDC) would be a beneficial factor for the international acceptance of SMRs. It is a cost-effective approach in which reactor certification is separated from site approval. Have the ANVS offer international expertise to the IAEA to facilitate this and allow it to participate in reactor validation processes. This way, these methods and knowledge can be deployed in the Netherlands to have the licensing included in legislation, with the aim of implementing and accepting foreign or  internationally agreed (IAEA) codes and standards of reactor designs.

Further shape a 'risk-informed' and 'graded approach'. A gradual approach ('grading') involves applying certain preconditions proportionately, depending on the potential risk to the environment. In the authorization process of large research reactors (several tens of megawatts thermally), the gradual approach may show that the prerequisites set for the power reactors apply accordingly. It is also possible that several prerequisites do not apply to certain reactors. Our recommendation would be to add an annex to the VOBK (Safe Design and Safe Operation of Nuclear Reactors) guide on how to apply the gradual approach to SMRs, other low-power reactors, nuclear barges, etc. or a more general annex on this topic.

32 Tjerk P. Kuipers, Developing nuclear security related legislative guarantees in licensing mobile Small Modular Reactors (Master thesis, T.U. Braunschweig, Augustus 2020) - https://doi.org/10.25933/opus4-2662