Rumina Velshi – A Debate with Ludwik Pieńkowski on the Activities of OSGE and the SMR BWRX-300 Project

Due to false information disseminated in the media by Ludwik Pieńkowski regarding the OSGE’s project and the BWRX-300 SMR design, we are publishing the following statement by Rumina Velshi – former President and CEO of the Canadian Nuclear Safety Commission (CNSC) and advisor to the Management Board of OSGE.

Statement by Rumina Velshi

A recent article by Professor Ludwik Pieńkowski raises questions about the maturity of the BWRX-300 reactor design and the prudence of OSGE’s decision to begin adapting it to Polish regulatory requirements. Several of these questions reflect legitimate public interest in a major infrastructure programme. However, the article contains material mischaracterisations of how nuclear regulatory processes work internationally, and draws conclusions that are not supported by the evidence cited.

I address the principal claims below, drawing on my direct experience in international nuclear regulation and reactor licensing.

Pre-licensing engagement is not a design deficiency

Professor Pieńkowski cites the ongoing NRC review of topical reports on reactor stability (NEDC-34270P), safety strategy (NEDC-33934P), and composite panel construction technology (NEDC-33926P) as evidence that the BWRX-300 design is insufficiently mature. This reflects a misunderstanding of the pre-licensing process. Topical report review is an iterative technical dialogue between a vendor and a regulator, conducted in advance of a formal certification application. Requests for additional analysis, supplementary validation data, and revised submissions are the normal functioning of this process, not evidence of regulatory concern about the viability of a design. Every advanced reactor design that has ultimately been certified—including the AP1000—went through comparable iterative exchanges. The NRC has not identified any proposed BWRX-300 technical solution as unsafe; it has requested further substantiation, which is precisely what pre-licensing engagement is designed to produce.

Furthermore, the specific technical areas cited by Professor Pieńkowski—such as the validation of TRACG modelling codes for a smaller core, natural circulation dynamics, and the use of Diaphragm Plate Steel Composite (DPSC)—represent the optimisation of known engineering principles, not fundamental safety risks. Natural circulation, for instance, is a proven methodology that enhances passive safety by eliminating the need for mechanical pumps; the Dodewaard reactor in the Netherlands operated successfully on natural circulation for decades. The NRC’s requirement for further validation of TRACG for the BWRX-300 core geometry is simply the regulator ensuring that analytical models match the physical realities of a scaled-down, highly optimised core—a matter of establishing precise modelling margins, not discovering fundamental physical flaws. Similarly, DPSC is an evolution in modular civil construction methodology, not experimental technology.

The CNSC’s phased licensing approach is standard practice, not a concession

The article characterises the Canadian Nuclear Safety Commission’s April 2025 construction licence, with its defined hold points, as evidence of the design’s immaturity. As the former President and CEO of the CNSC, I can state directly that phased licensing with hold points is the CNSC’s established regulatory approach for first-of-a-kind reactor projects. Hold points are proactive regulatory controls that ensure specific safety demonstrations are completed before defined construction milestones. They are a feature of the regulatory framework, not a reflection of doubt about the underlying technology. The suggestion that the first hold point’s timeline indicates regulatory distress is unsupported.

The relationship between the Preliminary Safety Report and the Polonization agreement

Professor Pieńkowski identifies an apparent inconsistency between OSGE’s November 2024 announcement of work on the Preliminary Safety Report and the February 2026 agreement with GVH to adapt the design to Polish conditions. In fact, these are complementary, not contradictory. The Preliminary Safety Report is prepared by the applicant and addresses site-specific and country-specific safety analysis. Adapting the underlying design documentation to the host country’s legal and regulatory framework is a precondition for a complete and approvable PSR, not a sign that the base design is unstable. Beginning this work in parallel with PSR preparation is standard sequencing in international nuclear project development.

On costs and commercial viability

The article references a December 2025 MIT study on comparative labour hours per unit of power. Academic cost modelling of this nature necessarily relies on assumptions about construction methodology, learning rates, and supply chain maturity that may not reflect the specific conditions of a fleet deployment programme. OSGE’s business case is predicated on the construction of over twenty units, which generates substantial learning-curve and supply-chain efficiencies that single-unit academic comparisons do not capture.

On regulatory consultation and governance

The article attempts to create a false dichotomy between the decision to adapt the design to Polish standards and ongoing engagement with the National Atomic Energy Agency (PAA). In major nuclear infrastructure programmes, these are not sequential steps; they are concurrent necessities.

A vendor cannot present a fully realised, country-specific design to a national regulator for final approval without first investing the capital to adapt the base design to that country’s legal, environmental, and engineering codes. OSGE’s February 2026 agreement with GVH provides the precise technical and financial vehicle required to translate the base BWRX-300 design into a format that the PAA can ultimately review and approve. To wait for a fully certified, globally standardised design before beginning localised adaptation would delay deployment by years, ignoring the realities of international nuclear supply chains and regulatory frameworks.

Conclusion

Public scrutiny of major nuclear investment decisions is appropriate and welcome. However, that scrutiny must be grounded in an accurate understanding of how nuclear regulatory processes function internationally. The BWRX-300 is progressing through structured, rigorous regulatory engagement in both the United States and Canada. OSGE’s decision to concurrently adapt the design to Polish requirements is not a premature gamble; it is the standard, necessary sequencing for first-of-a-kind nuclear deployments. The project’s timeline and investment structure reflect the complex realities of building a modern nuclear fleet, and the programme is advancing under the oversight of established regulatory authorities in every relevant jurisdiction.

Rumina Velshi
Advisor to the CEO and Management Board, OSGE
Former President & CEO, Canadian Nuclear Safety Commission