The Corrective Action Program Advantage New Nuclear Projects Will Only Have Once

The NRC issued the first US construction permit for a small modular reactor on September 29, 2026: TVA’s BWRX-300 at Clinch River, Tennessee. The permit came four months ahead of schedule and six months after TerraPower’s Natrium plant in Kemmerer, Wyoming became the first commercial advanced reactor to receive one in more than 40 years.

Most of the coverage will focus on the reactor. What deserves equal attention is everything that has to be built alongside it.

TVA runs a mature nuclear fleet, with corrective action programs, quality programs, security and emergency plans, and operations and performance improvement functions developed over decades. Not all of that fits the BWRX-300, a design that has never operated in the US.

The harder part is that much of it will try to come along anyway. The people standing up new reactors are often the best the operating fleet has, and they bring what they know, including processes that grew heavy over decades of fixes and workarounds. A plant designed to run leaner, with more technology and fewer people, can quietly inherit the old machine’s problems.

That is a challenge. It is also an opportunity almost nobody names: the chance to build programs for the machine in front of you.

What Program-Building Requires

A new reactor needs two sets of programs, on two clocks. The first has to be in place for the construction permit: a quality assurance program under 10 CFR 50 Appendix B, usually built on NQA-1, and the corrective action program inside it. The second gets built during construction and has to be ready before the plant operates: the emergency plan, security, radiation protection, fire protection, the maintenance rule, training and operator licensing, and the procedures that run the plant day to day. Alongside both sit the programs no regulation requires but every well-run plant has: operating experience, self-assessment, benchmarking and trending.

Those last ones are usually the first to go when a lean plant looks for weight to cut. That gets it backwards. They are how a small staff finds its own problems before an inspector does, and under the NRC’s new construction oversight program, problems a plant finds and fixes itself are normally treated as minor, with no formal enforcement.

An operating plant has to fit AI around all of these programs as they already exist. A new plant gets to write them with AI in mind.

What the Retrofit Looks Like

At South Texas Project, the AI-assisted condition report screening system I built runs as six agents working together. They extract the facts from a condition report, classify it against the CAP taxonomy, apply the grading logic, route it to the right reviewer, and draft a recommendation for a person to decide on.

That design exists because the STPNOC program was already running. Its grading criteria, routing rules and reviewer assignments lived in licensed procedures, so the agents had to work inside them. The system advises, and a person still decides. That is the right design for a plant with a licensed program. It is not the only option for a project that does not have one yet.

The Clean-Slate Window

If you are building a corrective action program for an SMR or other new reactor, you get a choice operating plants never had: design AI into the program from the beginning, or retrofit it after the procedures are approved.

Retrofitting works, but every step is constrained by procedures that came first. Writing them with AI in mind means grading logic that is machine-readable from the start, routing rules built for how an AI layer will use them, and a human review step designed around AI output.

That window closes the moment someone writes the first procedure the old way, out of habit, because it was faster.

What to Do Before It Closes

If your project is standing up a corrective action program now, or will in the next year or so, settle three questions before the first procedure is drafted.

1. Who decides what roles AI will play in your programs and processes? Screening and grading are the obvious place to start, but the same decision applies to trending, operating experience, work management and the rest. If nobody owns it, the default is whoever writes the first procedure fastest, and you inherit the same retrofit problem operating plants are working through.

2. Is your quality program ready for how language models behave? Appendix B and NQA-1 were written for software that gives the same output every time. Verifying a system whose outputs vary is a different question, and it needs an answer before the first procedure reaches your QA team.

3. Who will confirm your operating corrective action program is ready before fuel load? Under the NRC’s new construction oversight program, no inspection specifically tests that. Demonstrating it is up to the plant.

If You Are Building a Program Right Now

I spent fifteen years in commercial nuclear power, running corrective action programs and performance improvement functions at an operating plant. The work at South Texas Project is the production example of what AI inside a licensed CAP actually looks like.

If you are designing a corrective action, quality or performance improvement program for a new reactor and want to compare building the AI layer in from the start against retrofitting it, I am glad to talk. Reach me through the contact page, or see how I work with commercial nuclear power programs on the services page.