NEI Small Reactor Forum Report – Part 2

The Nuclear Energy Institute (NEI) hosted its biannual Small Reactor Forum on February 25, 2014. The agenda for the one day event included six well-organized sessions with presentations from three small reactor vendors, the industry trade group, the regulatory agency, and several outside observers with a significant interest in the technology from a variety of perspectives. The slide show presentations are available from the conference archive page.

The first part of this report focused on the plenary session and an overview of the event. This focuses on the remaining sessions and provides some perspective on the current state of small reactor supporting activities in the US.

Mike McGough, the Chief Commercial Officer for NuScale Power, led of the session about the small reactor regulatory framework with a comment about the importance of establishing a solid design and regulatory framework as an foundation for success that may never been seen by most observers. He used an analogy about watching a large commercial building construction process for many months without seeing visible progress, yet understanding that the work going on behind the fence is vital to the durability of the structure that will be built.

Mike emphasized the importance of standardization for each reactor design and the effort that NuScale has made to improve safety by design instead of by engineered safety systems.

Though the small reactor designs that appear capable of being licensed and deployed in the US within the next decade are mostly integral light water reactors that share many of the same technical capabilities as existing large light water reactors, there are several important differences. For example, the substantially smaller size reduces the “source term” in the case of an accident. In another example, passive safety has been vastly improved by avoiding the use of large pipes that might catastrophically fail and require electrically driven pumps to provide coolant to the core. Those features change some of the basic assumptions in current regulations; they offer a different approach to protecting the public from radioactive materials or radiation exposure.

Small reactor designers benefit from early interactions with the Nuclear Regulatory Commission so they can develop rule interpretations that take maximum advantage of those differences. Those early interactions provide the opportunity for system designers to explain their concepts, methods and assumptions to regulators to reduce the potential for later misunderstandings.

NuScale began their pre-application discussions with the NRC in 2008. They will be incorporating as many lessons learned as possible from previous part 52 (the current “one step” licensing process) applications, particularly with regard to avoiding the kind of time delay associated with the AP1000 application and also gaining a more complete understanding of the expected contents of a “quality application.”

NuScale licensing specialists have worked with the NRC to create a design specific standard review plan that acknowledges both the similarities between NuScale and existing reactors and takes advantage of the unique features of the design. NuScale leaders have engaged in discussions about ways to properly staff control rooms for their unique plant layout of 12 independent modules controlled from a single room. They’ve talked about security staffing and reducing the emergency planning zone diameter to a distance that is more closely related to the risk associated with their design.

Aside: It’s probably worth noting here that NuScale’s Chief Technology Officer and primary system inventor, Dr. Jose Reyes, was an NRC regulator for about a decade early in his career. He has a deep understanding of the system and the value of an independent regulatory body. End Aside.

The US nuclear licensing and communications process is extraordinarily detailed; NuScale has already provided the NRC with 35 technical reports describing various parts of their design and plans to submit another 35 more before finally submitted their design application. These technical reports provide an opportunity for identifying and addressing questions or concerns as early as possible in the process. They have been conducting an extensive component and system testing program that includes validation of various computer codes for more than a decade.

McGough bragged a little about the fact that NuScale’s design efforts have resulted in a system whose expected response to a station blackout event is to shut itself down and keep itself cool indefinitely with no required operator action, no additional water and no source of AC or DC power.

Doug Walters, NEI’s VP of regulatory affairs provided an update on NEI’s involvement in preparing the NRC for licensing smaller reactors and the numerous documents that the organization has submitted to lay the groundwork for a licensing process that recognizes the differences that make some believe that smaller reactors can be simpler and safer to build and operate. He talked about how the technology fits with the US energy policy and how it provides an opportunity to develop technology that can meet needs in growing international markets.

Doug spent a little time talking about one of the primary conceptual challenges associated with a one step licensing process where the operating license is issued at the time that construction begins. Once that license is issued, making any change to something that is described in the design certification requires getting permission from the NRC. That can be difficult at a construction site, where the need may occasionally arise to make a change in response to unanticipated conditions. Part of the key is ensuring that the design certification contains all of the right information and little in extra details.

One of the potential approaches to accounting for specific differences between the sensible rules for SMRs and the existing regulations that were created under the assumption that all reactors are large and somewhat similar is to take advantage of the existing process for requesting — with adequate justification — an exemption from the existing rule. That approach concerns me because it seems fraught with risk of non-standard practices and responses to the request that might be different depending on the judgement of the specific reviewer.

Though Walters acknowledged that current market conditions are not favorable for near term deployment of any significant new capacity, he reminded everyone that no one has any idea what natural gas prices will be in five to ten years and also reminded people that there are numerous pressures on existing generating plants that might require them to be retired. The implication is that those plants will need to be replaced once the economy begins growing rapidly and population continues to increase. NEI believes that SMRs will be a welcome option that can provide grid stability in many of the places where the power source that is there today has been retired.

Anna Bradford provided a brief update that essentially said that the NRC has participated in the engagements that the vendors have been describing and she showed a proposed application submittal schedule that included several entries that are “reevaluating” their expected dates. As noted below, that slide may already be out of date and need some dates that are currently identified to be changed to “reevaluating.” There was one very brief mention and entry on a slide that was intriguing – Anna stated that the NRC had heard from a company identifying itself as X-Energy. They have notified the NRC of their intention to submit a design certification during the first quarter of 2017 for a gas cooled pebble bed reactor. The X-Energy web page has a very old-fashioned “currently under construction” statement.

Peter Hastings, the Licensing Director at Generation mPower, provided a quick history of the B&W mPower^TMbeen unable to find a buyer on acceptable terms, partially due to the lack of near term product sales. The company is working diligently on a plan to respond to that market reality. The plan might involve a substantial reduction in current project spending.

The forum then included sessions about the role of federal and state government to support and enable development of new nuclear technology. This is a topic that often causes controversy among typically conservative nuclear professionals. “Free market” purists often state a belief that the government should never get involved in providing financial or implied subsidies to any technology; they imply that any product that is good enough will attract sufficient financing from capitalists seeking profits.

That assumption cannot work in a field where the government is so deeply involved already as a result of laws enacted 60 years ago and as a result of the substantial history that has accumulated since that time. No one would accept a situation without a strong federal regulator, no one wants to spent general tax dollars to fund the regulator, and no one wants to put fixed boundaries or deadlines on that regulator. That essentially gives the government veto power and makes government approval a huge part of the initial cost of developing a new product.

With all that said, there are many economic and strategic reasons why government leaders at the local, state, and federal level may want to enable and encourage the development of energy generating technology that does not consume precious fossil fuel, that does not produce any air or water pollution, and that provides the kind of family wage jobs associated with building, operating, securing and maintaining nuclear power plants.

One of the surprising features of the forum was a session on closing the nuclear fuel cycle with the development and deployment of advanced reactors that can consume materials that are currently discarded as waste from conventional reactors. Jessica Lovering, a policy analyst from The Breakthrough Institute, described how much more traction she gets when discussing nuclear energy among environmentalists when they realize that there are technical solutions to problems they thought were intractable, like “the waste issue.” Dr. Leslie Dewan, Chief Science Officer of Transatomic Power described her company’s reactor concept and the way she and her partners have designed the system to run on the used nuclear fuel from conventional reactors. Dr. Eric Loewen described GE-Hitachi’s PRISM reactor and its potential to address the UK’s inventory of separated plutonium along with its ability to create substantially more electricity from the same mined amount of uranium when compared to light water reactors.

There was also a session about the possible export opportunities for nuclear energy equipment developed and approved for use in the United States. This was probably one of the best panel discussion sessions I’ve seen at a recent nuclear related conference, partially because Rita Bowser, Vice President for Enhanced Reactors at Westinghouse, ran it like a panel should be run. There were no prepared slide shows; it was all conversation, questions and answers.

The panelists brought a wide range of viewpoints including the perspective of a high level executive from an internationally known engineering and construction firm, the perspective of a man who runs the clean energy program at a major political think tank, and the perspective of a woman who is deeply involved in the process of developing US companies into nuclear energy suppliers.

Ms. Bowser, who worked on new nuclear energy projects in South Africa for a number of years, has a broad perspective on international development needs and opportunities. She reminded the audience that electricity delivered into individual homes changes lives in many important ways. It is perhaps the most life-changing technology development of the industrial age.

Josh Freed, Vice President for the clean energy program at Third Way, emphasized the importance of nuclear technology as it relates to achieving carbon emissions reductions, which many political leaders in the US and around the globe have stated is one of their key issues. He included President Obama in the category of world leaders whose political statements have made it clear that they cannot avoid the inclusion of nuclear energy into their future plans.

Greg Ashley, President of Bechtel Nuclear Power, talked about doing things differently with exporting SMRs than was done with nuclear plants during the first wave of nuclear plant builds. He emphasized the need to build a sustainable supporting infrastructure, training programs, and local maintenance and manufacturing bases.

There was a good question from the audience about international partnership versus a nationalistic “Team USA” approach. It stimulated a conversation about the importance of recognizing that many of the competitors in the global nuclear market are state-backed enterprises like Rosatom, Areva, and Kepco but that one of the strengths of companies with a strong US presence is the fact that they are global companies with access to several pools of capital. Carol Berrigan, Senior Director, Supplier Policy and Programs for NEI, described “Atoms for Prosperity” as a program brand that describes how US government agencies are seeking to coordinate policies to enable nuclear energy trade that is roughly analogous to an Atoms for Peace program brought into modern times. Ashley pointed out that it is important for US policy makers to understand the potential for large negative effects if laws or policies are enacted that prevent US participation in international partnerships through excessive restrictions on technology exports, restrictions on scientific exchanges, or restrictions on students gaining access to study in the US.

Throughout the discussion, all of the speakers recommended that the US approach the international market with humility, recognizing that we want to participate, but that we do not dominate and we should not wish to dominate and dictate to others who have already developed their own expertise.

I had the opportunity during that session to ask a question that I hoped would provide a motivating push for those who wonder why we should be working so hard to get new designs ready for construction now. After all, “everyone” thinks that shale gas is a revolution that will dominate our energy markets for many years to come. I pointed out that Argentina has already started building a small, integral pressurized water reactor and that Russia is also building small modular reactors on barges for delivery to some of the same customers that the US vendors are hoping to attract.

Ashley described the highly competitive international marketplace and the advantage of being a first mover, but also pointed out that NRC approval is still the “gold standard” in the west. Freed observed that policy makers are often stimulated to make investment decisions if they believe that they are in a race, so it may be a good thing for US efforts if there is more recognition that we are not alone in thinking that small reactors have a bright future.

The Small Reactor Forum was a worthwhile event. In two years, when the NEI again hosts a similar event, I hope there will be significantly more progress to report and significantly more interest from prospective customers. There might even be more visible progress on reactors that do not use light water as the coolant.