The electrical utility in South Africa (Eskom) plan to construct a first of a kind Pebble Bed Modular Reactor (PBMR). It has been recognized that there is a need to adapt the licensing process for the PBMR to ensure that credible and effective licensing process be developed and implemented for this technology. This paper will briefly outline the regulatory framework within South Africa, explain the licensing process adopted and present the challenges that the South African National Nuclear Regulator (NNR) was facing in developing and implementing the licensing process and how these are being addressed. The paper will discuss the update of the regulatory framework and the gaps identified in terms of regulatory requirements needed for such a project. The scope of the regulatory assessment for the licensing of the PBMR is based on the licensing requirements and criteria defined by the NNR in regulatory documents that expand on the current legislative requirements. In addition guidance is provided on selected issues in regulatory guidance documents and position papers. The requirements comprise, besides the general requirements to respect good engineering practice and the ALARA and defense-in-depth principle, specific risk criteria and radiation dose limits. These are categorized for normal operation and operational occurrences as well as for design basis events and beyond design basis events for workers and the public. Additional requirements and recommendations are stipulated by the NNR on safety important areas like quality and safety management, qualification of the nuclear fuel and the core structures, core design, verification and validation of computer codes, source term analysis and others. Selected NNR Position Papers have been developed to elaborate and provide further clarification on NNR requirements. For preparation of the PBMR safety case so-called Key Licensing Issues have been defined and agreed with the applicant. Discussions relating to these Key Licensing Issues allow important nuclear safety aspects identified for the PBMR demonstration plant to be clarified in advance of the safety case submittal.

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