AI-Powered Test Plan Generation for Small Modular Reactors

1. Executive Summary

Small modular reactors (SMRs) represent a transformational shift in nuclear energy — factory-fabricated, scalable, and designed to serve markets that traditional large reactors cannot reach. With over 80 SMR designs in development globally and first deployments expected in the late 2020s, the nuclear industry is entering its most dynamic period in decades.

However, every SMR design must navigate one of the most demanding regulatory environments in any industry. Thousands of verification and validation (V&V) test cases must be developed, each traceable to specific regulatory clauses across multiple jurisdictions. The test planning process today is overwhelmingly manual: teams of nuclear engineers and licensing specialists spend months cross-referencing regulatory text, writing procedures in documents, and maintaining traceability through spreadsheets. When designs iterate or regulations evolve, the cascade of required updates is enormous and error-prone.

This document presents a multi-agent AI platform purpose-built for the nuclear domain that automatically generates comprehensive, traceable, and audit-ready test plans by synthesizing regulatory documents, internal historical data, and system APIs. The platform reduces test plan development timelines from months to days, ensures complete regulatory coverage across jurisdictions, and produces the traceability matrices that nuclear regulators expect — while preserving the rigor and defensibility the industry demands.

2. Industry Context: The SMR Compliance Challenge

2.1 The SMR Landscape

The global SMR market encompasses over 80 reactor designs across multiple technology families, each with distinct safety profiles and regulatory considerations:

• Light-water SMRs: Evolutionary designs based on proven PWR/BWR technology (e.g., NuScale VOYGR, GE Hitachi BWRX-300). Benefit from existing regulatory precedent but must demonstrate safety at smaller scale with passive systems.

• High-temperature gas reactors (HTGRs): Use TRISO fuel and helium coolant for inherent safety (e.g., X-energy Xe-100). Require new fuel qualification frameworks and graphite performance testing.

• Molten salt reactors (MSRs): Liquid fuel or coolant designs (e.g., Terrestrial Energy IMSR, Kairos FHR). Present novel challenges for fuel integrity testing, materials qualification, and tritium management.

• Sodium-cooled fast reactors (SFRs): Fast-spectrum designs using liquid sodium coolant (e.g., TerraPower Natrium). Require sodium fire testing, intermediate heat exchanger qualification, and fast neutron materials data.

• Microreactors: Very small (<20 MWe) transportable designs (e.g., Westinghouse eVinci, BWXT BANR). Introduce unique testing requirements for transportability, autonomous operation, and remote site safety.

2.2 The Regulatory Complexity Problem

Unlike conventional large light-water reactors that benefit from decades of established regulatory precedent, SMR vendors face a compounding matrix of complexity:

• Novel designs × evolving regulations: The NRC is simultaneously developing Part 53 (technology-inclusive licensing) while vendors submit applications under existing Part 50/52 frameworks. Test plans must address current rules while anticipating new ones.

• Multi-jurisdictional licensing: Vendors pursuing deployment in the US, Canada, UK, and export markets must develop parallel compliance programs mapped to NRC, CNSC, ONR, and IAEA frameworks — each with distinct requirements and review processes.

• First-of-a-kind (FOAK) risk: Without operating precedent, every requirement must be explicitly tested and verified. A single missed requirement can trigger Requests for Additional Information (RAIs) that delay licensing by months or years.

• Digital I&C complexity: SMRs rely heavily on digital instrumentation and control, which faces some of the most rigorous qualification requirements in any industry — software V&V, hardware qualification, cybersecurity, common cause failure analysis, and environmental qualification.

2.3 The Cost of Manual Test Planning

Current approaches to V&V test plan development are fundamentally manual and do not scale to the demands of the SMR industry:

• A typical design certification V&V program requires 5,000–15,000 individual test cases traceable to regulatory requirements

• Test plan development for a single major system (e.g., reactor protection system) can take 6–12 months with a team of 5–10 engineers

• Regulatory changes or design iterations can invalidate 20–40% of existing test cases, requiring months of rework

• Knowledge loss from workforce attrition is acute: the average nuclear engineer is over 50, and institutional V&V expertise is concentrated in a small number of experienced practitioners

• The cost of a licensing delay due to incomplete test coverage is measured in hundreds of millions of dollars and years of schedule impact

3. Solution Overview

The platform deploys a multi-agent AI architecture purpose-built for the nuclear domain. It automatically generates comprehensive, traceable, and audit-ready test plans by synthesizing three categories of input:

Input Category 1: Regulatory & Standards Documents

The system ingests and continuously monitors the full spectrum of nuclear regulatory and standards documents, including NRC 10 CFR Parts 50, 52, and 53; NUREG guidance documents and Standard Review Plans (NUREG-0800); NRC Regulatory Guides; IEEE nuclear-grade standards (603, 7-4.3.2, 338, 344, 384); ASME Boiler & Pressure Vessel Code Section III; NRC Branch Technical Positions and Interim Staff Guidance; 10 CFR 73.54 cybersecurity requirements; IAEA Safety Standards (SSR-2/1, SSG series); Canadian CNSC REGDOC series; UK ONR Safety Assessment Principles and Technical Assessment Guides; and vendor-specific topical reports and exemption requests.

Input Category 2: Internal Historical Data

The platform learns from the organization’s accumulated V&V experience, including previous V&V test plans and procedures, safety analysis reports (preliminary and final SARs), probabilistic risk assessments (PRAs) and importance measures, NRC inspection findings and corrective action records, operating experience (OpE) reports and lessons learned databases, design basis documents and system design descriptions, and RAI responses and licensing correspondence.

Input Category 3: System & Tool APIs

Direct integration with the engineering and quality management toolchain provides real-time awareness of requirements management systems (IBM DOORS, Jama Connect), configuration management and change control systems, digital I&C development and simulation environments, nuclear QA/QMS platforms (NQA-1 compliant), test data acquisition and management systems, and CAD/CAE systems for system architecture context.

The platform combines these inputs through a pipeline of specialized AI agents, each responsible for a distinct phase of test plan generation. The agents collaborate through a shared knowledge graph that maintains the relationships between regulatory requirements, design elements, safety functions, and test cases.

4. Multi-Agent Architecture

The platform is composed of six specialized agents that operate in a coordinated pipeline. Each agent has a defined scope, input/output contract, and quality gate before passing work to the next stage.

4.1 Shared Knowledge Graph

All agents operate on a shared knowledge graph that maintains the semantic relationships between regulatory requirements, design elements, safety functions, structures/systems/components (SSCs), test cases, and evidence artifacts. The graph enables impact analysis (what tests are affected when a regulation changes), gap detection (which requirements lack test coverage), and cross-referencing (how a single test case satisfies multiple regulatory requirements across jurisdictions).

4.2 Human-in-the-Loop Controls

Given the safety-critical nature of nuclear V&V, the platform is designed with mandatory human review gates. No test plan is finalized without explicit engineering approval. The system presents generated test plans as recommendations with full traceability justification, allowing engineers to accept, modify, or reject each test case. All human decisions are captured in the audit trail, maintaining full compliance with NQA-1 quality assurance requirements.

4.3 Continuous Learning

Each time an engineer modifies a generated test case, the feedback is captured and used to improve future generation. The system learns organization-specific conventions, preferred test methodologies, and regulatory interpretation patterns. Over time, the acceptance rate of generated test plans increases as the platform adapts to the organization’s engineering culture and regulatory approach.

5. Detailed Use Cases

5.1 Design Certification & Licensing Test Plans

The primary use case is generating the V&V test plans required for NRC Design Certification (DC) and Combined License (COL) applications. The system parses the Standard Review Plan (NUREG-0800) chapter by chapter, extracting acceptance criteria from each section and mapping them to testable requirements.

For a typical SMR design certification, this covers reactor core and fuel design (SRP Chapter 4), reactor coolant system and connected systems (Chapter 5), engineered safety features (Chapter 6), instrumentation and controls (Chapter 7), electrical power (Chapter 8), auxiliary systems (Chapter 9), containment (Chapters 3 and 6), and radiation protection (Chapter 12). The system generates test procedures for each acceptance criterion, including test objectives, prerequisites, test configurations, step-by-step procedures, acceptance criteria with quantitative limits, required instrumentation and data acquisition, and links to supporting analysis.

5.2 Digital I&C Qualification Testing

Digital instrumentation and control systems are among the most complex and scrutinized elements of any SMR design. The platform generates qualification test plans covering:

• Software V&V (IEEE 7-4.3.2, RG 1.152): Unit testing, integration testing, system testing, and acceptance testing for safety-related software. Includes test plans for software hazard analysis verification, timing and sizing analysis, and software configuration management.

• Hardware qualification (IEEE 344, 323): Seismic qualification, environmental qualification (temperature, humidity, radiation, EMI/RFI), and aging analysis test plans. Generates test specifications for type testing, analysis, and combined approaches.

• Cybersecurity (10 CFR 73.54, RG 5.71): Test plans for critical digital asset identification, security architecture verification, access control testing, attack surface analysis, and ongoing monitoring validation.

• Common cause failure (CCF) analysis: Test plans to verify diversity and defense-in-depth measures, including functional diversity between redundant safety divisions, equipment diversity, and software diversity.

• Human factors engineering: Test plans for human-system interface (HSI) validation, including task analysis verification, staffing validation, and control room design testing under normal, abnormal, and emergency conditions.

5.3 Passive Safety System Validation

Most SMR designs incorporate passive safety features that rely on natural phenomena rather than active components. These systems must be validated through a rigorous combination of analysis and testing:

• Separate effects tests (SETs): The platform generates test specifications for individual thermal-hydraulic phenomena — natural circulation flow rates, condensation heat transfer coefficients, critical heat flux under passive cooling conditions.

• Integral effects tests (IETs): Test plans for scaled facility tests that demonstrate the integrated performance of passive safety systems under design basis accident scenarios (LOCA, main steam line break, loss of feedwater, station blackout).

• Code validation matrices: Generates the assessment matrices required to validate thermal-hydraulic safety analysis codes (RELAP, TRACE) against experimental data, ensuring the analytical methods used in the FSAR are adequately validated.

• Beyond-design-basis scenarios: Test plans covering severe accident management, passive containment cooling performance, and long-term decay heat removal without operator action.

5.4 Factory Acceptance & Site Integration Testing

The modular, factory-built nature of SMRs introduces a testing paradigm fundamentally different from traditional stick-built nuclear plants:

• Factory acceptance testing (FAT): Module-level functional tests, leak tests, dimensional verification, instrumentation calibration, and wiring verification performed at the factory before shipment.

• Transport qualification: Test plans for shock, vibration, and environmental exposure during transport from factory to site. Includes post-transport inspection and retest requirements.

• Site integration testing (SIT): Module interconnection verification, system-level functional testing, and integrated system testing after all modules are assembled on site.

• Pre-operational and startup testing: The full scope of pre-op testing required before fuel load, through initial criticality, power ascension, and warranty/guarantee testing programs with hold points and acceptance criteria.

5.5 Fuel Qualification & Materials Testing

Advanced SMR designs using novel fuel forms (TRISO, metallic fuel, molten salt fuel) require extensive fuel qualification programs. The platform generates test plans for fuel fabrication QA, irradiation testing, post-irradiation examination, fuel performance code validation, and transport/storage cask qualification. For materials, it covers high-temperature materials qualification, corrosion testing (particularly for molten salt and sodium environments), irradiation effects testing, and long-term creep and fatigue programs.

5.6 Emergency Preparedness & Operator Training Validation

SMR designs with smaller source terms may qualify for reduced emergency planning zones under new NRC frameworks. The platform generates test plans to validate emergency preparedness programs, including dose projection model verification, protective action decision-making drills, emergency notification system testing, and simulator-based operator qualification examinations covering normal, abnormal, and emergency operating procedures.

6. Regulatory Coverage Matrix

The platform maintains a continuously updated regulatory knowledge base spanning the following frameworks. When any regulation is updated, the system automatically identifies every affected test case and generates the required updates.

7. Integration Architecture

The platform is designed to integrate with the existing nuclear engineering and quality management toolchain through standard APIs and data exchange formats. No rip-and-replace is required; the system augments existing workflows.

7.1 Requirements Management Integration

Bidirectional synchronization with IBM DOORS and Jama Connect allows the platform to import the current requirements baseline, generate test cases linked to specific requirements, and export completed traceability matrices back to the requirements management system. The integration supports DOORS modules, formal module baselines, and change-controlled updates.

7.2 Configuration Management

Integration with configuration management systems ensures that test plans are always aligned with the current design baseline. When a design change notice (DCN) is processed, the platform automatically identifies affected test cases and generates change impact assessments.

7.3 Quality Management System

The platform operates within the organization’s NQA-1 quality management framework. All generated artifacts include revision control, approval workflows, and audit trails. Test procedures are generated in formats compatible with the organization’s QA document control system. Nonconformance and corrective action tracking is integrated to feed lessons learned back into the Historical & OpE Agent.

7.4 Simulation & Analysis Tools

The platform interfaces with thermal-hydraulic analysis codes (RELAP5, TRACE), neutronics codes (MCNP, Serpent), and severe accident codes (MELCOR, MAAP) to validate that test acceptance criteria are consistent with safety analysis results. It can also connect to digital twin environments and hardware-in-the-loop simulation platforms for I&C system testing.

7.5 Data Exchange Formats

The platform supports industry-standard data exchange formats including ReqIF (Requirements Interchange Format) for requirements data, IEEE 829 and IEEE 29119 compliant test documentation formats, NRC electronic submission formats (ADAMS-compatible), and standard report templates aligned with FSAR chapter structure.

8. Implementation & Deployment

8.1 Deployment Models

Given the sensitive nature of nuclear design and licensing data, the platform supports multiple deployment configurations:

• On-premises deployment: Full platform installed within the organization’s secure network perimeter. All data remains on-site. Required for organizations handling Safeguards Information or Export Controlled Information.

• Private cloud: Deployed in a dedicated, isolated cloud environment (AWS GovCloud, Azure Government) with FedRAMP-equivalent security controls.

• Air-gapped deployment: For highly sensitive defense or classified programs, the platform can operate in fully air-gapped environments with no external network connectivity.

8.2 Implementation Phases

1. Phase 1 — Foundation (4–6 weeks): Platform installation, regulatory knowledge base initialization with applicable standards, integration with requirements management system, and baseline configuration.

2. Phase 2 — Historical Data Loading (4–8 weeks): Ingestion of prior V&V test plans, SAR documents, PRA data, audit findings, and OpE records. Training of the Historical & OpE Agent on organization-specific patterns.

3. Phase 3 — Pilot Program (6–8 weeks): Generation of test plans for a selected system (typically I&C or a specific safety system). Side-by-side comparison with manually developed test plans. Refinement of agent parameters based on engineering review feedback.

4. Phase 4 — Full Deployment (ongoing): Expansion to all systems and regulatory scopes. Integration with full toolchain. Continuous learning from engineering feedback and regulatory updates.

8.3 Security & Compliance

The platform is designed to meet the security requirements of the nuclear industry, including 10 CFR 73 physical and cyber security requirements, NIST SP 800-53 security controls, SOC 2 Type II compliance, role-based access control with multi-factor authentication, complete audit logging of all user actions and system decisions, and encryption at rest and in transit for all data.

9. Benefits & ROI

10. Target Users & Market

10.1 Primary Users

SMR Vendors & Reactor Designers

Companies developing SMR designs and pursuing design certification or construction permits. This includes NuScale Power, X-energy, Kairos Power, TerraPower, GE Hitachi Nuclear Energy, Terrestrial Energy, Rolls-Royce SMR, Holtec International, Westinghouse (eVinci), BWXT (BANR), and dozens of other developers worldwide. These organizations face the most acute test planning challenge as they build V&V programs from scratch for first-of-a-kind designs.

Nuclear Engineering & AE Firms

Engineering firms performing V&V, safety analysis, and licensing support for SMR vendors and utilities. Firms such as Sargent & Lundy, Black & Veatch, Bechtel, Enercon, and Jensen Hughes manage large V&V programs and would benefit from accelerated test plan generation while maintaining engineering quality.

Digital I&C Suppliers

Companies developing and qualifying safety-grade digital instrumentation and control platforms for SMR applications, including Framatome, Westinghouse, Rolls-Royce, Ultra Electronics, and others. Digital I&C qualification testing is one of the most documentation-intensive areas in nuclear licensing.

10.2 Secondary Users

Nuclear Regulators

Regulatory bodies (NRC, CNSC, ONR, IAEA) developing inspection and examination frameworks for novel reactor types. The platform can help regulators develop standardized review checklists and inspection procedures aligned with new licensing frameworks like Part 53.

Utilities & Project Developers

Organizations planning SMR deployment programs, including Ontario Power Generation (Darlington SMR), Tennessee Valley Authority, Utah Associated Municipal Power Systems (UAMPS), and international utilities. These organizations need to develop owner’s acceptance testing programs and operational test procedures.

National Laboratories

DOE national laboratories (Idaho National Laboratory, Oak Ridge, Argonne, Sandia) supporting advanced reactor testing, fuel qualification, and materials qualification campaigns. Laboratories manage complex test programs spanning multiple facilities and funding sources.

10.3 Market Sizing

The global SMR market is projected to grow from approximately $6 billion in 2025 to over $60 billion by 2035. Licensing and V&V costs typically represent 8–15% of total project development costs. With over 80 SMR designs in development across 18 countries, the addressable market for automated test plan generation is substantial and growing rapidly.

The platform addresses a critical bottleneck in every SMR deployment pathway: the ability to generate comprehensive, regulation-compliant V&V programs faster than traditional manual methods allow. As the industry moves from design phase into construction and deployment in the late 2020s and 2030s, the demand for scalable V&V solutions will intensify.