Making DOE's Nuclear Reactor Pilot Program Work

The Department of Energy’s (DOE) new Reactor Pilot Program (RPP) could be one of the most consequential steps for advanced nuclear in decades. These reactors are not gigawatt-scale commercial plants, but they are essential first-of-a-kind demonstrations. Done well, the program can generate the data, operating experience, and regulatory lessons that help clear the path for commercial advanced reactor deployment. This pilot program fills the gap in the prototyping stage of the innovation cycle, which is crucial for the U.S. to succeed.

Why Prototypes Matter

One of the core promises of advanced nuclear power is the potential for the nuclear industry to move away from one-off megaprojects and toward something closer to mass production. Small modular reactors, for example, are designed around the principle of iteration: build one, learn from it, and then iterate to create lower cost and higher quality. But, this industry shift only works if there is a robust prototyping phase in between.

No industry that depends on factory production skips the step of building a testing prototype before moving to full-scale manufacturing. When Ford designed the F-150, it did not send the very first prototype straight to the conveyor belt to mass manufacture. It built test models, put them through punishing conditions, and fixed problems before moving to mass production. Earlier in the process, the engine and transmission went through similar prototyping. Space Shuttle Enterprise was used as a test platform to fill gaps in prototyping and enable the rest of the Space Shuttle program. That innovation cycle is essential when you’re building multiple units of the same thing. The nuclear industry should be no different if it has its sights set on building tens, if not hundreds, of new nuclear reactors; adopting that same mindset is necessary.

Today, “prototyping” in the nuclear sector is fragmented across small-scale electrically heated mock-ups, sample irradiation campaigns in DOE test reactors, or the long and expensive process of licensing a large demonstration under Nuclear Regulatory Commission (NRC) oversight. There is no middle ground that provides a pathway for first-of-a-kind reactors that are not yet commercial products but are more than lab-scale models to be tested and iterated upon.

The pilot was created by Executive Order 14301, Reforming Nuclear Reactor Testing at the Department of Energy, which directed DOE to stand up an expedited authorization process for advanced reactors. DOE will authorize at least three projects to achieve criticality by July 4th next year under the auspices of the program.

The purpose of this pilot is straightforward: to enable the prototyping stage of the innovation cycle that will demonstrate that advanced reactors can be authorized and operated quickly on DOE sites and to clear away regulatory barriers before companies attempt full commercial deployment. Success here won’t deliver to the grid, but it can provide what the industry needs most: technical validation, regulatory insight, and investor confidence.

But success means more than meeting an arbitrary date on the calendar. The deadline is already shaping the process, with approvals being penciled in before applications are even complete. Going fast is not the problem; high-quality reviews can be done quickly. The problem is when speed becomes haphazard and rushed, creating uncertainty for developers, investors, and the public.

For this pilot to achieve its purpose, DOE must both move quickly and do the fundamentals right: protect public health, the environment, and common defense and security; execute a pathway that withstands legal and political scrutiny; and ensure that safety determinations are grounded in evidence, not negotiation or deadlines. That is the only way these demonstrations will contribute to scaling up the deployment of advanced nuclear technology.

Challenges that Could Derail the Pilot

The central concern is not simply whether DOE can move fast enough. It’s whether the pilot is being framed, resourced, and executed in a way that delivers on its real purpose. Some industry players and policymakers alike are treating this pilot as a shortcut to commercialization. That misses the point. These reactors are not meant to be commercial-ready products. They are meant to be prototypes: heavily instrumented, overbuilt with large margins, and designed to generate the data, lessons, and credibility needed for the next stage of deployment. These prototypes should be deliberately overbuilt for safety so that developers can push designs hard, collect detailed data, and then optimize the next iteration, ultimately yielding reactors that are both lower cost and higher quality. If DOE implements the pilot as a fast-track to market, it risks becoming a hype program rather than a useful innovation cycle.

The pilot’s purpose as an innovative demonstration project has not been consistently conveyed as the core purpose. This is evident from the timeline in and of itself, which was decided prior to guidance for the program, prior to applications being submitted, and even prior to choosing those admitted to the pilot. Companies that are already well along in design and pre-application work may be able to meet the schedule, but others won’t. Realistically, developers already need to be far along in design or breaking ground to come close to meeting that deadline. This means that review and construction will need to happen in parallel, which is not intrinsically a bad thing. But that puts extraordinary pressure on DOE’s licensing office to say “yes” even when technical or regulatory readiness might necessitate more work.

These issues point to the same challenge: the pilot program is trying to move reactors forward on a political schedule. The program should enable developers to innovate and test on whatever timeline they need to be successful. Unless DOE addresses these concerns head-on, it risks undermining the credibility and usefulness of the program before any pilot reactor even breaks ground. The goal should be innovation, data, and learning, not commercialization. If safety, credibility, and regulatory durability are sacrificed in the name of speed, the program risks doing more harm than good.

Compounding this uncertainty, DOE’s guidance for the pilot is still in flux. Legal interpretation is ongoing, and key requirements have not been finalized. This leaves developers unclear about what exactly must be included in their applications, adding another layer of risk to an already compressed schedule. This is where the July 4th deadline creates an unnecessary hurdle. While deadlines can motivate action, they can also distort priorities.

Whether or not RPP is successful will also hinge on the capacity of DOE to review, license, and operationalize the prototypes. DOE has committed to reviewing major safety documents in just 45 days. But, in the past nine months, a large portion of experienced DOE staff have either left the agency or retired early. The ongoing federal hiring freeze has prevented the staff from being replaced. In practice, that will mean fewer staff with less time to interrogate complex technical issues. Some developers can deliver strong applications that will require less effort to review, but others will be presenting first-of-a-kind designs that will require many hours of necessary licensing work.

The approach to environmental review is another weak point. DOE’s draft guidance suggests that if the public and workers are protected, then the environment is “almost always” protected too. That shortcut could be legally risky. If DOE is the lead agency for environmental review and fails to produce a defensible record, projects could face litigation that threatens delay or even cancellations. It is also unclear how cooperating agencies could fulfill their own statutory obligations without a DOE finding to adopt.

That ties into a larger statutory ambiguity: what does it mean for a reactor to be “under the control” of DOE? NRC’s authority to license reactors stems from its origins in the Atomic Energy Commission and its mandate to license industrial and commercial power plants. DOE’s authority is narrower and less tested. Developers need to understand how far DOE oversight extends and how it will compare to the NRC’s established licensing process.

Naturally, with the integrity of the review being a concern, liability becomes another question. The Price-Anderson Act, which governs nuclear liability insurance and indemnification, was written with NRC-licensed facilities and DOE contractors in mind. Qualified Test Reactors authorized directly under this pilot may fall into a gray zone. Reactors accepted into this program must be sufficiently “under contract with and for the account of” the DOE. Are they covered like DOE contractor-operated facilities that are typically DOE-owned? DOE asserts that they are “considered a DOE reactor, and still covered under Price-Anderson indemnification.” However, the private developers are responsible for ownership, all costs, operations, and decommissioning. DOE indicated that any “particular requirement will be addressed in the agreement negotiated under an Other Transaction Agreement,” which may be legally sufficient but does not address uncertainty about what this may entail. Until DOE clarifies how Price-Anderson applies, developers and investors face real uncertainty about financial liability in the event of an incident.

Unfortunately, DOE may not ultimately care if lawsuits follow or if these projects neatly transition to NRC licensing, as long as the program meets the deadline and leadership can declare success. But litigation after the fact could stall projects for years, undermining the very goal of accelerating deployment. If the environmental review record is weak, or if liability questions remain unresolved, the result could be projects that are technically approved but stuck in legal limbo.

For RPP to be successful, DOE must provide clear and stable guidance so developers know what belongs in their applications, rather than leaving rules in flux as deadlines loom. It must resource its review teams adequately; a 45-day turnaround is only credible if staff have the capacity and expertise to interrogate complex safety cases. It must build defensible environmental records so projects are insulated from litigation risk and cooperating agencies can meet their own statutory obligations. DOE must also clarify how liability will be handled under the Price-Anderson Act so that developers and investors are not left uncertain about their financial exposure.

DOE needs to show that speed and rigor can coexist, that the regulatory record it builds can withstand scrutiny, and that the lessons learned will actually smooth the way for future deployments.

Enabling the Transition to Commercial Licensing at the NRC

Even if the RPP’s statutory position can be clarified, it remains unclear how DOE’s new pathway will translate into NRC licensing. The pilot risks undercutting its own value if the NRC does not treat DOE’s reviews as credible input or if it treats them as too complete. The program should not be a crosswalk where the NRC simply adopts DOE’s determinations. The NRC must re-review DOE artifacts, question them, and use them to inform commercial licensing. If the NRC never gives DOE’s work weight, the pilot produces no regulatory insight. That does not mean the NRC should accept DOE’s determinations without question, but neither should DOE’s reviews end up ignored.

If the NRC is able to accept DOE’s work wholesale to license a commercial plant, it is an indicator that the pilot was not used properly to prototype and test non-commercial systems. For example, commercial plants are unlikely to need as much monitoring equipment to collect test data. The commercial plant may also be 10 times the size of the prototype. It might use a different fuel burnup rate after prototyping enabled optimization. A prototype might use a sealed containment building for added safety margin, or utilize existing infrastructure like INL’s DOME for cost efficiency, but the commercial plant might use a functional containment approach. If the prototype matches the final product exactly, then the developer didn’t use the prototyping process effectively. Instead, the developer built a first-of-a-kind proof of concept that cannot sell electricity to recoup investment.

The right balance is for DOE to build safety cases that are rigorous enough to serve as credible starting points for the NRC to re-examine and challenge those cases in the context of commercial licensing. In practice, that means DOE should map its analyses to NRC expectations, while the NRC should remain open to incorporating DOE’s findings where appropriate. A structured second look by NRC staff is what will make the pilot both safe and regulatorily relevant.

To get there, DOE can create direct bridges into the NRC's process, leveraging existing MOUs. One approach is for the DOE to use comparison matrices that show how each DOE safety determination maps onto NRC’s regulatory criteria, making it easier for NRC to understand what has been addressed and what remains outstanding. DOE could also convene joint review workshops, where NRC staff are invited to observe key stages of the DOE review and provide early feedback, without giving up their independent authority. If the NRC can coordinate and achieve constructive engagement with the Canadian Nuclear Safety Commission through an MOU, it should be able to do so with the Department of Energy.

Finally, DOE can build in structured hold points in its readiness reviews to stop and evaluate submissions. That way, DOE staff aren’t forced into an all-or-nothing “say yes or no by July 4th” decision. They can manage risk in stages, and the NRC can get clearer insight into how DOE’s work aligns with its own process.

The point is transparency: NRC doesn’t have to guess whether DOE’s work is relevant, and developers can see clearly what will still need to be redone for commercial licensing. Too often, developers encounter the “bring me a rock” problem: submitting information only to be told it isn’t the “right thing,” without clear guidance on what is the “right thing.” It’s not about “negotiating” safety, but about avoiding that cycle by showing where DOE and NRC requirements line up, and where they don’t.

Not One Size Fits All

Not every company will benefit equally. The developers best positioned to take advantage of the pilot are those who need an early proving ground to generate data, validate designs, and demonstrate safety cases before moving into NRC licensing. Companies facing bottlenecks around fuel supply, access to national labs, a viable site to build on, or other federal support services, stand to gain the most. But without a proving ground like this pilot, these bottlenecks or the NRC licensing process for an early test reactor may have been too high of a barrier for these developers.

The most established players—Kairos Power, X-energy, and TerraPower—have opted out. They are already pursuing NRC licensing for commercial plants, and the pilot would have been a step backward. Although TerraPower and Southern Company’s Molten Chloride Reactor Experiment (MCRE) at INL would have fit right into this program if it were available at the time.

For developers still in early stages, the demonstration pilot should function exactly as intended: a proving ground to collect operational data, identify technical gaps, and refine designs. That information will determine whether they can ultimately engage with the NRC on a viable commercial reactor design.

Building the Innovation Cycle

If these demonstrations are the start of an innovation cycle rather than the end of one (i.e., commercial products), the pilot can leave behind a framework that enables innovation that strengthens both safety and deployment moving forward.

Test reactors are prototypes, not products. Their value lies in being heavily instrumented, overbuilt, and designed to generate the data and operating experience that can inform safer, cheaper, and more efficient commercial plants. Treating them as shortcuts to commercialization would miss the point entirely. The pilot should give developers room to experiment, to make mistakes, and to learn from them, while ensuring that safety, security, and environmental protection remain uncompromised.

If DOE succeeds in implementing swift yet rigorous reviews that bring a new set of prototypes of advanced reactors into the world, this program can leave behind something far more valuable than three demonstration reactors. It can establish a model for how the U.S. develops, tests, and validates new nuclear technologies, setting the stage for commercial deployment at scale. In that sense, the pilot is not just about the projects that break ground now, but about proving that America can once again build nuclear reactors the way Ford builds trucks: by learning and iterating.