NRC lack of planning will increase delays for new reactor licenses
Update: (September 1, 2011) I have changed the title to be more assertive. There is no longer any doubt in my mind that the lack of foresight WILL result in delayed reviews of new license applications though there will be strenuous efforts to foist the blame for poor performance onto the applicants. End Update.
Ever since the Fukushima events began, I have been worried about the effect of the unplanned resource expenditures on new reactor design licenses. I freely admit to having a vested interest; I work for a company that is spending a large quantity of money developing a new reactor design and preparing an application to get that design approved for use in the United States. (The thoughts expressed here are strictly my own and do not represent those of my employer.) I am also a shareholder in a number of companies that will benefit if new reactor licenses ever get issued.
I spent hundreds of hours making presentations to potential investors during more than a decade of unsuccessful effort to gather the capital that would have enabled Adams Atomic Engines, Inc. to build revolutionary new reactor based power systems. Based on the question and answer sessions following those presentations, I understand the importance of a predictable licensing process with a reasonable schedule to investors. It can make, or, in my case, break a deal.
It is with that background that I began asking representatives of the NRC when they planned to tell Congressional appropriators that they require additional resources to cover large Fukushima-related expenditures that could not have been anticipated at the time that their FY 2011 budget was submitted in 2009 or when their FY 2012 budget was submitted in 2010.
The first opportunity that I had to ask the question was in April 2011, during the American Nuclear Society Student Conference in Atlanta, GA. The response at that time was that the NRC had not yet been able to quantify the level of resources required.
Aside: In my role as a resource / requirements officer in the Navy, I had heard similar responses on a number of occasions. My answer back to the organization with the unplanned expenditure was always the same – “The very worst estimate you can provide is no estimate. That will get you zero dollars. You and I both know that your “unknown” need is a number that is greater than zero.” End Aside.
I have asked the question several more times and received the same response. The NRC has now been devoting resources to the Fukushima response for nearly 6 months; it should at least be able to tell appropriators what it has already spent and what planned work it did not do in order to provide the financial and human resources used to cover those unplanned expenditures.
A couple of weeks ago, a friend of mine was in attendance at the American Nuclear Society Utility Working Group meeting. She shared a statement that she heard during one of the panel discussions with me. That led me to engage in the following email exchange with the Director, Office of Public Affairs and one of his colleagues. I thought it would be worth sharing that correspondence widely in hopes of stimulating more foresight and planning at the Commission. Here is the thread.
From: Rod Adams
Sent: Friday, August 19, 2011 2:25 PM
To: Brenner, Eliot; Burnell, Scott
Subject: Delaying or canceling current activities?Eliot or Scott:
During the ANS Utility Working Group meeting held this week, Martin Virgilio announced during a panel discussion that the NRC will have to delay or cancel some current activities in order to support needed regulatory changes from the Fukushima event.
On at least one previous occasion, I have asked a senior NRC official (during the ANS Student Conference held in Atlanta) when the NRC was going to seek additional resources to ensure that events occurring 12,000 miles away were not going to impact the timely review of new applications, license extensions and other important NRC work.
The response that I got was that there was not yet a determination that any additional resources were required.
Does the NRC have any current plans to seek additional resources to support its assigned mission or is it planning to use a lengthening queue to manage its workload?
Rod Adams
On Aug 19, 2011, at 5:04 PM, Brenner, Eliot wrote:
Rod: I’m checking with higher authority about what our future finances may hold. I’m out for a couple of weeks but Scott or I will get back to you as quickly as we can. I will be monitoring things from a secret undisclosed location reported to be near my home. Remember that our core mission is the safety of existing plants. Anything past that is icing.
Eliot
From: Rod Adams
Sent: Monday, August 29, 2011 6:32 AM
To: Brenner, Eliot
Cc: Burnell, Scott
Subject: Re: Delaying or canceling current activities?Eliot:
I do not know if you have returned to work yet, but I wanted to follow up on the below conversation. Do you or Scott have any additional information about the effect that Fukushima response based decision to redirect resources away from new license applications might have on the time that it takes to obtain a COL or a design certification?
I am planning to publish something about this issue by Thursday.
Rod
From: Scott Burnell
Subject: RE: Delaying or canceling current activities?
Date: August 29, 2011 10:05:51 AM EDT
To: Rod Adams, Eliot BrennerHello Rod;
The Commission has yet to decide which Task Force recommendations will be acted on, so the question of potential costs, resource needs and resulting effects on new reactor activities cannot be answered at this time. The Commission has consistently noted that the safety of operating nuclear power plants will remain the NRC’s first priority. Thanks.
Scott
From: Rod Adams
Subject: Re: Delaying or canceling current activities?
Date: August 30, 2011 5:39:51 AM EDT
To: Scott Burnell
Cc: Eliot BrennerScott – thank you for confirming the fact that the NRC has not yet begun the process of helping congressional appropriators to understand that it is expending significant unplanned resources in response to the Fukushima events.
Though I and most of my colleagues in the nuclear industry agree that the FIRST priority of the NRC is the safety of the operating nuclear power plants, there is no other agency in the United States that has the responsibility to review license applications for new plants and no other agency that has the authority to allow those new projects to progress.
It is always important to establish priorities, but it is mismanagement to decide to ONLY accomplish the top priority and allow all other assignments to be put on hold. That approach is reasonable during an emergency, but once the emergency passes, day-to-day responsibilities must be put back into some kind of reasonable plan of timely execution.
By deciding to neglect its responsibility to identify and request resources in a timely fashion, the NRC is doing a grave disservice to the public. It is not adhering to its long established charter of enabling the safe use of special, source and byproduct nuclear materials. I understand the annual budgetary process, but I also understand the process of obtaining funds between budget cycles to pay for unanticipated expenditures.
I intend to continue pursuing the question of why the Commission is intentionally failing to request sufficient resources to perform its assigned duties. That question is especially pertinent, even in a time of overall budgetary constraints because the NRC is funded by licensee and applicant user fees, not by general revenue.
Best regards,
Rod Adams
So there you have it. Thoughts, comments, and letters to your favorite congressman would be most appreciated. There are hundreds of jobs at stake in my narrow little corner of the struggling nuclear renaissance, but I am fairly certain that the overall impact is far greater for the country as a whole. Of course, the man responsible for budgetary matters at the NRC would never even consider taking any responsibility for those jobs and the lives supported by the incomes of the hard working people who might be affected.
‘I will be monitoring things from a secret undisclosed location reported to be near my home. Remember that our core mission is the safety of existing plants. Anything past that is icing.
Eliot’
God help us. At first glance I thought this was a joke. I hope this is a VERY junior employee.
@Steve – there is a certain portion of the reply that is a joke, provided in a lighthearted manner.
However, the part about everything other than the operating plants being “icing” was provided in all seriousness. Eliot is most definitely NOT a junior employee.
Steve and Rod,
That “icing” comment was precisely what leapt from the page/screen for me.
Just wow.
Rod,
Thanks for poking at the NRC more directly. I was very concerned by Mr. Virgilio’s statements and while he didn’t not identify which programs would be affected, it was clear to me that he was target new plant licensing. Everything for the current operating fleet would have higher priority.
Every reactor design past AP1000 and ESBWR should consider themselves on notice for insufficient resources to do the job. Every COLA beyond Vogtle and Summer should do likewise.
@ Rod,
These budget issues at the NRC should come as no surprise to you. Our nation has been at war for ten years now and we’ve yet to have an honest budget process that applies national means to a realistic end. Every year, the funding for the wars has been emergency in nature even though we knew that we were in it for the long duration. I feel sorry for the rank and file at the NRC. They know what they need to do in order to meet agency objectives, but they are most likely receiving political pressure not to come up with new budget numbers except for the occassional cut drill.
@John – did you read the part of the post that points out that the NRC budget is supplied by fees, not by taxes?
Yes, but similar to the aviation trust fund, it all goes into the general fund and the NRC can only spend what they’re authorized to spend.
The first thing the NRC should have done was submitted an initial budget request to address Fukushima issues. This should not be an after-the-fact process.
“The first thing the NRC should have done was submitted an initial budget request to address Fukushima issues. This should not be an after-the-fact process.”
I believe that was exactly Rod’s point
Fees? The NRC works on a ‘cost plus’ invoicing system where its own inefficiencies are passed on to nuclear operators who simply act as captive customers.
No incentive to improve performance or be accountable. It is the most vicious of all budgeting/strategic framework where you do not have any desire to better yourself.
If the FAA can handle the triple obligations of design certification, oversight of existing fleets as well as accident investigations, there is no reason the NRC can’t do the same thing. If more money is needed then it is the obligation of the Chairman to put together the plan to request more funds from Congress despite the nation’s budgetary problems.
The FAA faces this issue of unplanned budgetary expenditures due to accident investigations on a regular basis. So if Chairman Jaczko wishes to have a history of being a true and competent manager versus that as a borderline anti-nuclear ideologue then he should have his people already working on this issue. He should have already had his people reviewing how similar organizations such as the FAA handle additional requests for money since he committed the NRC to following this current path the minute he took emergency control.
However based on the email exchange above and the news releases on the Yucca Mt budget issues , I’m not optimistic Dr. Jaczko will be proactive on this issue. He has consistently proven to me, as a very interested party in seeing the expansion of nuclear power for many reasons, as one who consistently puts the politics of nuclear power ahead of his responsibility of running the NRC in an orderly fashion. I suspect instead he is already working on the bureaucratic equivalent of “throwing-up-my-hands-what-could-I-do” defense if asked at a future date why the licensing of new reactors and new designs are stalling out.
From Eliot’s e-mail:
Remember that our core mission is the safety of existing plants. Anything past that is icing.
This says it all. It is any wonder that no nuclear power plant has yet been built under NRC rules during its whole existence of over three decades?
The core mission of the NRC needs to be the promotion of safe nuclear power plants by means of the licensing process. This may seem to be a subtle shift, but it is not. Since nuclear is the safest form of power generation (even including Fukushima), its use needs to be encouraged by a timely and predictable licensing process.
The tragedy of the situation is that the NRC still has to beg Congress to spend money on the licensing process, even though it is the licensees who fund the process, not the taxpayers.
@donb – I have resigned myself to to not seeing the NRC promote or encourage nuclear power in any way. I would be satisfied (for a year or two, anyway) if they took seriously the need to enable its future development.
@Joffan — I would take enable future development as well. As it is, the NRC seems to dream up as many ways possible to inhibit future development. Just try to license anything that isn’t a light water reactor if you want to experience this first hand.
Bill Rodgers has it spot on — look at the FAA as an example. Here you have an agency that is able to certify the design of a “plastic” airplane, certainly different from conventional aluminum designs. They have worked with aircraft manufacturers and airlines to make flying the safest way to travel without shutting out all new designs for the last 30+ years.
The NRC seems to be far more disabling than enabling in regards to new build nuclear power plants (NPPs), to the overall detriment both of the U.S. economy and of overall U.S. nuclear technology leadership.
Simply consider the fact that sitting here as of 9/1/2011 no U.S. new build NPP project has been both started and completed since the NRC was formed out of the breaking-up of the AEC.
From my perspective as a manufacturer, I am also concerned about the availability of critical components, such as pressure vessels.
If we granted a construction license today, we would not take delivery of a vessel for 8 years? 9 years? Or more. Even with additional production capacity in China, the backlog puts the U.S. at a huge disadvantage. I fear the ship sailed and we watched it leave port.
@John – smaller reactors are specifically designed to avoid the supply chain issues that you mention regarding pressure vessels. I hope you know that the United States never stopped producing nuclear energy production systems – we just stopped producing commercial power plants in the 1000 MWe range. We have produced a dozen or more nuclear propulsion power per per decade for nearly 5 decades in a row.