Licensing advanced reactors in the United States

On September 1-2 2015, the US DOE and US NRC jointly sponsored a workshop on advanced non-LWR [light water reactors]. Your intrepid reporter from Atomic Insights attended and managed to ask a few questions.

The presentations are available here.

One of the highlights of the first day of the workshop came during the question and answer session that included a venture capitalist and representatives of three advanced reactor vendors.

In the space of a few minutes, Eric Loewen, a past president of the ANS and an engineering leader at GE-Hitachi, was hypothetically elevated through a series of positions including Chairman of the NRC, Secretary of Energy, President of the United States and President of the World. In each position, questioners asked him how he would handle some of the complex challenges associated with developing and deploying advanced nuclear reactor systems.

Another crowd favorite was when Ray Tothrock, the venture capital representative from Venrock, admitted that he truly believed that the US Nuclear Regulatory Commission was the gold standard of nuclear regulators. He then reminded the audience that gold is heavy, inert, expensive, and hard to move.

The workshop attracted about 300 registered attendees, more than twice the number the organizers first envisioned. The welcoming talks by both Stephen Burns, NRC Chairman, and John Kotek, Acting Assistant Secretary of Energy for Nuclear Energy set a positive tone.

Kotek emphasized the importance of nuclear energy to the nation’s electrical power supply system, especially in light of the Clean Power Plan. He pointed out a number of ways that the DOE contributes to the development of advanced reactor concepts including providing laboratory support for testing, moderate assistance for licensing and development for SMRs, and supporting university education programs.

Chairman Burns reviewed some of the NRC’s accomplishments during his nearly 40 years on the agency staff and stated that he believes it can do almost anything it sets its collective energies to doing. He challenged the prevailing feeling that the NRC is unable to license non-light water reactor technology without a major preparatory effort. He told us “we can do this.”

There is little doubt that the NRC can eventually license non-light water reactors, but adapting the current framework is not the most efficient path forward. Since no advanced reactor developer has announced that they are preparing a design certification or licensing application, it is a good time to make a significant change.

Jim Kinsey’s brief of lessons learned from the Next Generation Reactor Program (NGNP) highlighted the need. His first slide started with the following bullet:

The existing NRC process for pre-licensing requirements development is workable and viable – it’s not “broken” based on NGNP experience

He then proceeded to describe four needed policy decisions that have been under consideration for 5-8 years without a final resolution. No one in the audience publically challenged the inconsistency between the bullet statement and the lack of closure.

However, I learned from several hallway conversations that many people wondered how such a situation could be considered “not broken.” If nothing else, it is in need of serious repair work. Though the NRC representatives at the meeting acknowledged the need, they also indicated that resource constraints were pushing them in the direction of using the current standard review plan and general design criteria with an expressed openness to justified exemptions.

Probing questions revealed that the resource constraint issue could not be solved by rearranging existing priorities.

The NRC’s financing model, established in the Omnibus Budget Reconcillation Act of 1990, is the root cause preventing many needed actions.

That model requires that the agency bill users of its services for 90% of its operating budget. When there is work needed on a generic issue that applies to numerous parties, the cost is spread among the existing base of operating licensees. If there are more tasks than available people, some tasks get moved below the action line and wait for resources.

Apparently, the 10% of the NRC budget that is not billed to licensees or applicants covers international coordination and some interagency activities.

The “user fee” model sets up an inevitable tension. For good reasons, many current licensees have no interest in funding genaric work to design a more efficient process for licensing advanced reactors. Not only do they want to minimize their fees, but they have a number of active issues they consider to be more pressing.

Fixing the NRC financing model requires Congress to act, but that is not the firm barrier that some imply that it is. It is a political challenge to complete an “act of Congress,” but a budget model can be altered with the insertion of a few carefully chosen words. Clear explanations describing the value provided by sufficient regulatory resources might be enough to stimulate action if made to the right representatives.

The investment of a few tens of man-years in creating policies for a technology neutral licensing path, for example, might enable hundreds of millions to billions of dollars worth of investment. It would retire a certain amount of investment risk by providing more clarity about the actions needed for an applicant to achieve approval to begin and complete physical system development. The result might be tens of thousands of good jobs.

It might be possible to provide the necessary dedicated resources without changing the budget model by directing a portion of the Department of Energy’s $30 billion annual budget to support an NRC effort to develop generic rules. Clear rules that are not specific to light water reactors could enable efficient licensing processes that ensure public health and safety and environmental protection without having to produce and review dozens of individual examption requests.

The disadvantage of this less direct path is that it puts another layer of decision makers in between the source of money and the agency that needs the resources. That situation almost inevitably leads to “taxes” applied on the budget line by the extra layer, leaving fewer resources than expected for completing the needed tasks.

It’s not within the purview of the NRC to push to make the financing model change. It is incumbent on those of us who believe that advanced reactor development is a beneficial activity. It is already a technical challenge; making it more difficult than necessary does not enhance safety or security.

Without action, the NRC will have to rely on existing rules and tell applicants they are willing to entertain justified exemptions. That process is not only difficult to execute for the applicant, but it also provides targets for later challenges. Nuclear energy opponents love attacking exemptions and questioning the reasons why the NRC agreed not to enforce its own rules.

During the next week or two, I will be culling my notes and recordings for additional workshop highlights, but I thought it was important to begin discussing the need for a long lead action. It’s never too early to start when streamlining a process requires “an act of Congress.”

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