# What an NRC Pre-Application Project Number Actually Means

> An NRC pre-application project number is a tracking identifier, not an approval. What it changes is the fee basis, and that provision expires in 2030.

[Resources](https://rankshieldenergy.com/resources) / Licensing & pre-application Licensing & pre-application

# The NRC has given RankShield Energy a project number. Here is what that does and does not mean.
Published September 15, 2026 · By [Jamie Kloncz](https://rankshieldenergy.com/authors/jamie-kloncz), Founder, RankShield Energy

HELIX microreactor, concept render. RankShield Energy is at the pre-application stage; this depicts a design under development, not an operating facility. Technical paper · document control
Published September 15, 2026 Subject NRC pre-application project number 99902183 Regulatory status RankShield Energy is a pre-applicant. It holds no NRC license, permit, or design approval, and no application has been filed. Nature of document Public communication. Not a submittal to the NRC, and not legal or regulatory advice.
The U.S. Nuclear Regulatory Commission has assigned RankShield Energy, Inc. project number 99902183, under the docket name RankShield Energy Pre-application Activities, with an assigned NRC project manager. The number was issued on August 31, 2026, and on September 15, 2026 the company completed the credentialing required to submit documents through the NRC's external partner submission gateway. A project number is an administrative tracking identifier. It is not a license, a permit, a certification, a design approval, or an endorsement of any kind, and no application has been filed.
The honest description of what changed is narrow. RankShield Energy's interactions with the NRC staff now have a place on the record, a named staff contact, and a defined billing basis. That last item is the part most often reported incorrectly, and it is the part worth explaining at length.
Under a statutory change Congress made in 2024, the staff review work associated with a pre-applicant's licensing project plan is billed at a reduced hourly rate [[1]](#src-1). For fiscal year 2026 that is the difference between $337 and $154 per staff-hour [[2]](#src-2), and the provision expires on September 30, 2030 [[2]](#src-2). This article sets out the sequence to date, the mechanism behind that fee treatment, the licensing framework choice the company has made and why, the quality assurance gate that governs everything else, and the specific things RankShield Energy has not yet done.
Key takeaways

- A project number confers nothing. It creates a docket name, assigns a project manager, and establishes a billing basis. It is not a finding on any technical matter.
- The substantive consequence is fee treatment. Section 201 of the ADVANCE Act of 2024 directs a reduced hourly rate for advanced reactor applicants and pre-applicants [[1]](#src-1).
- The reduced rate is conditional. It attaches to work described in a licensing project plan [[3]](#src-3), not to pre-applicant status generally.
- The provision sunsets on September 30, 2030 [[2]](#src-2), which is less time than a first-of-a-kind licensing effort typically takes.
- RankShield Energy has not filed an application, has not submitted its licensing project plan, and does not yet have an accepted quality assurance program.

## 1. What a project number is, and what it is not
A project number is how the NRC tracks a prospective applicant's interactions with the staff before any application exists. It creates a docket name under which correspondence and meeting summaries can be filed, it assigns a project manager as the point of contact, and it establishes the basis on which staff time is billed to the company.
It confers nothing. It is not a finding, not a determination, and not a statement by the NRC that any aspect of a design is acceptable. The NRC has not reviewed the HELIX design. No RankShield Energy document has been accepted, approved, or endorsed. A reader who takes a project number as a signal of technical merit has misread it, and any company that encourages that reading is misrepresenting its position.
The reason to announce it anyway is that pre-application is where most of the durable work happens, and it is almost entirely invisible from outside. We have written separately on [how the NRC advanced reactor pre-application process works](https://rankshieldenergy.com/resources/nrc-pre-application-process-explained). Publishing the milestones, including the unflattering ones, is a way for a company at this stage to be judged on something other than its own adjectives.

## 2. The sequence to date
**August 4, 2026.** RankShield Energy submitted a letter of intent to the NRC Document Control Desk stating its intent to begin pre-application engagement and requesting a project number. This article cites that letter by date rather than by accession number, because the accession has not been verified as publicly retrievable.
**August 25, 2026.** An introductory meeting was held with the NRC staff. The meeting was introductory and non-technical. Nothing was submitted for review, and the staff took no position on any technical matter.
**August 31, 2026.** The project number was assigned, with a docket name and an assigned project manager.
**September 15, 2026.** The company completed identity proofing and multifactor credentialing for the NRC's external partner submission gateway. This is purely administrative. It is the difference between having something to file and being able to file it. Roughly six weeks separate the letter of intent from a working submission channel, which is a reasonable expectation for anyone measuring their own path.

## 3. What the project number actually changes: the fee mechanism
This is the substantive consequence, and it rests on a specific and recent change in federal law. On July 9, 2024, the Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy Act of 2024, the ADVANCE Act, was signed into law. Section 201 of that Act, titled "Fees for Advanced Nuclear Reactor Application Review," directs the NRC to apply a reduced hourly rate to advanced nuclear reactor applicants and pre-applicants [[1]](#src-1). The NRC implemented the provision in the fiscal year 2025 final fee rule [[4]](#src-4) and carried it forward in the fiscal year 2026 final fee rule [[2]](#src-2).
The operative regulation is 10 CFR 170.20, "Average cost per professional staff-hour," which establishes two rates [[3]](#src-3). For fiscal year 2026 the professional hourly rate is $337 per hour and the Reduced Hourly Rate is $154 per hour, which the NRC describes as "an over 50 percent reduction from the professional hourly rate" [[2]](#src-2). The fees themselves are assessed under the schedule at 10 CFR 170.21 [[5]](#src-5).
The condition attached to the reduced rate for pre-applicants is the part most easily missed. The rule provides that for advanced nuclear reactor pre-applicants, fees relating to "the review of submitted materials as described in the licensing project plan" are calculated using the reduced hourly rate [[2]](#src-2). The reduced rate is not a general discount on being a pre-applicant. It attaches to work that a licensing project plan has described in advance.
Two consequences follow, and we state them plainly because they govern our own sequencing. First, the plan is the instrument: technical material submitted before a licensing project plan describes it does not obviously fall within the reduced-rate provision, and at small company scale the gap between $337 and $154 per staff-hour is a direct constraint on how much regulatory interaction is affordable. Second, the provision sunsets. The rule states that the pre-applicant paragraph "shall cease to be effective on September 30, 2030" [[2]](#src-2). Companies entering pre-application after that date, or still in pre-application when it passes, should not assume the treatment persists.
RankShield Energy has not yet submitted its licensing project plan. It is written and staged. Until it is filed and the staff has acted on it, the company should be understood as not yet having secured the treatment described above.

## 4. The licensing project plan
RankShield Energy's next submittal is its Regulatory Engagement Plan, submitted as a licensing project plan. The document identifies the application the company intends to build toward, the technical topics it expects to bring to the staff, the topical reports it intends to submit, and a preliminary schedule.
A licensing project plan is not a technical submission and asks for no approval. It is a statement of intent detailed enough that the staff can plan resources against it. Its value to the company is sequencing: it establishes what will be submitted and in what order, which is the precondition for the fee treatment described above and, more importantly, the precondition for the staff being able to schedule anything at all.
The plan is complete and staged for submission. It has not been submitted as of publication.

## 5. Which licensing framework, and why
There are three candidate frameworks, and the choice among them is a live question across the advanced reactor industry rather than a settled one. We have set out the full analysis in [which regulations apply to a microreactor today](https://rankshieldenergy.com/resources/which-regulations-apply-to-a-microreactor).
**10 CFR Part 52, Subpart E, Standard Design Approvals** [[6]](#src-6) is the pathway RankShield Energy names in its plan. The reason is unglamorous: it exists in final regulation today. A standard design approval is a staff determination on a design, separable from any particular site, and the rules governing it are in force and have been for years.
**10 CFR Part 53** [[7]](#src-7), the risk-informed, technology-inclusive framework for commercial nuclear plants, is final and available. It was written with advanced reactors in view.
**proposed 10 CFR Part 57 (a proposed rule published in the Federal Register on May 1, 2026, with the comment period closed on June 15, 2026; not final, and no developer is licensed under it)** is the framework written specifically for microreactors and other reactors with comparable risk profiles [[8]](#src-8). The NRC maintains a public index of its microreactor regulatory activities, including the staff papers behind that rulemaking [[12]](#src-12). Proposed Part 57 remains RankShield Energy's preferred destination if it is finalized substantially as proposed, and the company has said so in its plan. But a pre-applicant that builds its schedule on a proposed rule has taken on a risk it does not control, and the honest position is that a rule which has not been finalized cannot be relied upon. Our reading of what that framework would and would not carry forward is set out in [our analysis of off-site fabrication oversight](https://rankshieldenergy.com/resources/who-inspects-a-reactor-built-in-a-factory).
Choosing the instrument that exists over the instrument that would be more convenient is not a statement that Part 52 is the better framework for a microreactor. It is a statement about what can be planned against today.

## 6. The gate in front of everything else: quality assurance
The constraint that governs the technical program is not a technical one. It is quality assurance. Under the NRC's framework, analysis that supports a licensing submittal must be produced under an accepted quality assurance program. Regulatory Guide 1.28, Revision 6 [[9]](#src-9) endorses specified editions of the ASME NQA-1 standard, including NQA-1-2022. RankShield Energy's first topical report will be a Quality Assurance Program Description committing to NQA-1-2022 as endorsed by that guide.
The practical effect is severe and worth stating without softening. Work performed before an accepted quality assurance program is in place does not become qualified retroactively. It is screening work. It is useful for deciding what to build and where the sensitivities are, and it is not usable as the basis for a regulatory finding.
RankShield Energy's physics results to date are unqualified pre-program screening results. The company labels them that way in its own filings rather than presenting them as qualified analysis, and it labels them that way here. Any figure the company has published about reactor behavior should be read in that light. This is the same standard we apply when we write about [how to evaluate a microreactor vendor](https://rankshieldenergy.com/resources/how-to-evaluate-a-microreactor-vendor), and it applies to us.

## 7. Where the design stands, and what we do not publish
HELIX is a factory-fabricated heat-pipe microreactor in the 11.0 MWth and 4.40 MWe class, using HALEU TRISO fuel, with sealed heat pipes and no primary coolant pumps or loops. It is a design under development. It is not operating, not licensed, and not approved. Everything said about how the design is intended to behave is design intent, and none of it has been demonstrated to or accepted by the NRC.
This article does not publish enrichment levels, core geometry, fuel loading, reactivity coefficients, or lifetime figures for the design. That is a deliberate restriction the company applies to all of its public material, on export-control grounds under 10 CFR Part 810 [[10]](#src-10). Readers accustomed to vendor material that leads with such figures should read their absence as a policy rather than an omission. Class-level context on the fuel is covered in [where HALEU comes from](https://rankshieldenergy.com/resources/where-haleu-comes-from-advanced-reactor-fuel).

## 8. What RankShield Energy has not done
A status article that lists only progress is marketing. The following are accurate as of publication. No application of any kind has been filed: not a standard design approval application, not a construction permit application, not a combined license application. The licensing project plan has not been submitted; it is written and staged. No topical report has been submitted, and the Quality Assurance Program Description is the earliest one queued. No accepted quality assurance program is in place, so the company's analysis is screening work rather than qualified analysis.
No site has been identified and no host institution agreement is in place. No NRC staff position has been obtained on any technical question, because the August meeting was introductory and non-technical. The fee treatment described above is not yet secured, because it depends on a plan that has not been filed.
The immediate next step is submission of the licensing project plan, followed by the Quality Assurance Program Description as the first topical report. Beyond that, the sequence the company expects to follow is the one set out in the NRC's content-of-application roadmap for risk-informed, technology-inclusive advanced reactor applications, DANU-ISG-2022-01 (interim staff guidance, which is guidance and not a requirement) [[11]](#src-11), which identifies the pre-application topics a developer can usefully close before an application exists. That guidance ties a meaningful review-schedule benefit to completing pre-application work, and conditions it on the design not changing significantly in between [[11]](#src-11). That is a real engineering constraint rather than a formality: the design of record has to be closed before the engagement is worth much, which is a harder problem than it sounds for a company still doing screening analysis. Pre-application engagement is measured in years. We will publish each milestone as it is reached, including the ones that do not go the company's way.

## Frequently asked questions

### Does an NRC project number mean the reactor is approved?
No. A project number is an administrative tracking identifier. It creates a docket name, assigns a project manager, and establishes a billing basis. It is not a license, a permit, a certification, a design approval, or an endorsement, and it reflects no NRC finding on any technical matter. RankShield Energy has filed no application.

### What does a project number actually change?
Principally the fee basis. Section 201 of the ADVANCE Act of 2024 directs a reduced hourly rate for advanced reactor applicants and pre-applicants, implemented at 10 CFR 170.20. For fiscal year 2026 the professional rate is $337 per hour and the reduced rate is $154 per hour. For pre-applicants the reduced rate attaches to work described in a licensing project plan.

### Is the reduced fee rate permanent?
No. The fiscal year 2026 final fee rule states that the pre-applicant paragraph shall cease to be effective on September 30, 2030. That is less time than a first-of-a-kind licensing effort typically takes, so companies entering pre-application should not assume the treatment persists through their program.

### Which licensing framework is RankShield Energy pursuing?
Its plan names a standard design approval under 10 CFR Part 52, Subpart E, because that instrument exists in final regulation today. 10 CFR Part 53 is also final and available. The microreactor-specific framework at proposed 10 CFR Part 57 is a proposed rule that is not final, and no developer is licensed under it, so it cannot be relied upon for schedule.

### Why does this article not give enrichment or core dimensions?
Because specific reactor design data can be export-controlled under 10 CFR Part 810. RankShield Energy speaks publicly at the architecture, concept, and regulatory level and does not publish enrichment levels, core geometry, fuel loading, reactivity coefficients, or lifetime figures for its design.

## Sources

- [U.S. Nuclear Regulatory Commission. Description of the Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy Act of 2024 (ADVANCE Act), section 201, Fees for Advanced Nuclear Reactor Application Review, as set out in the fiscal year 2026 final fee rule](https://www.federalregister.gov/documents/2026/06/16/2026-12067/fee-schedules-fee-recovery-for-fiscal-year-2026)
- [U.S. Nuclear Regulatory Commission. Fee Schedules; Fee Recovery for Fiscal Year 2026. Final rule, 91 FR 36470, June 16, 2026](https://www.federalregister.gov/documents/2026/06/16/2026-12067/fee-schedules-fee-recovery-for-fiscal-year-2026)
- [10 CFR 170.20, Average cost per professional staff-hour. Office of the Federal Register, current CFR](https://www.ecfr.gov/current/title-10/chapter-I/part-170/section-170.20)
- [U.S. Nuclear Regulatory Commission. Fee Schedules; Fee Recovery for Fiscal Year 2025. Final rule, 90 FR 26730, June 24, 2025](https://www.federalregister.gov/documents/2025/06/24/2025-11544/fee-schedules-fee-recovery-for-fiscal-year-2025)
- [10 CFR 170.21, Schedule of fees for production and utilization facilities, review of standard referenced design approvals, special projects, inspections, and import and export licenses](https://www.ecfr.gov/current/title-10/chapter-I/part-170/section-170.21)
- [10 CFR Part 52, Subpart E, Standard Design Approvals. Office of the Federal Register, current CFR](https://www.ecfr.gov/current/title-10/chapter-I/part-52/subpart-E)
- [10 CFR Part 53, Risk-Informed, Technology-Inclusive Regulatory Framework for Commercial Nuclear Plants. Office of the Federal Register, current CFR](https://www.ecfr.gov/current/title-10/chapter-I/part-53)
- [U.S. Nuclear Regulatory Commission. Licensing Requirements for Microreactors and Other Reactors With Comparable Risk Profiles. Proposed rule, 91 FR 23628, May 1, 2026; comment period closed June 15, 2026; not final](https://www.federalregister.gov/documents/2026/05/01/2026-08550/licensing-requirements-for-microreactors-and-other-reactors-with-comparable-risk-profiles)
- [U.S. Nuclear Regulatory Commission. Regulatory Guide 1.28, Revision 6, Quality Assurance Program Criteria (Design and Construction), September 2023. Endorses specified editions of ASME NQA-1, including NQA-1-2022](https://www.nrc.gov/reading-rm/doc-collections/reg-guides/power-reactors/rg/)
- [10 CFR Part 810, Assistance to Foreign Atomic Energy Activities. Office of the Federal Register, current CFR](https://www.ecfr.gov/current/title-10/chapter-III/part-810)
- [U.S. Nuclear Regulatory Commission. DANU-ISG-2022-01, Review of Risk-Informed, Technology-Inclusive Advanced Reactor Applications, Roadmap. Interim staff guidance, March 2024](https://www.nrc.gov/reactors/new-reactors/advanced/modernizing/rulemaking-and-guidance.html)
- [U.S. Nuclear Regulatory Commission. Microreactors: Regulatory Activities](https://www.nrc.gov/reactors/new-reactors/advanced/modernizing/microreactors/reg-activities)

This article reflects the state of the cited record as of its publication date. Fee schedules are set annually and regulatory proposals are subject to change. Section references should be re-checked against the current docket before use.

## Related

- [How the NRC Advanced Reactor Pre-Application Works →](https://rankshieldenergy.com/resources/nrc-pre-application-process-explained)
- [Which NRC Regulations Apply to a Microreactor Today? →](https://rankshieldenergy.com/resources/which-regulations-apply-to-a-microreactor)
- [Who Inspects a Nuclear Reactor Built in a Factory? →](https://rankshieldenergy.com/resources/who-inspects-a-reactor-built-in-a-factory)

Written by
Jamie Kloncz
Founder, RankShield Energy
Jamie leads the HELIX microreactor pre-application program and RankShield Energy's verification-first approach to advanced-reactor operations. [More about the author](https://rankshieldenergy.com/authors/jamie-kloncz)

**About this article.** RankShield Energy is a pre-applicant engaged in early regulatory interaction with the U.S. Nuclear Regulatory Commission (NRC). Nothing here should be read as a representation that any RankShield Energy design, product, or facility is NRC-approved, licensed, or certified, or that any safety, performance, or operational characteristic has been demonstrated or accepted by the NRC. Descriptions of reactor and system behavior reflect design intent and are subject to analysis, testing, and regulatory review. This article is for general educational purposes and is not engineering, legal, regulatory, or investment advice.
Where this article describes a proposed rule, that rule is not final and may change. Readers responsible for regulatory decisions should rely on the primary sources cited rather than on this summary of them.

A note on how we write about our own reactor
HELIX is in pre-application development. Where this article touches our design, every figure is a design target and every physics result is unqualified screening, labeled as such. We cite authoritative sources (NRC, DOE, IAEA, national laboratories) and never invent statistics.
RankShield Energy · HELIX · pre-application