I apologize for the acronym soup in the title. Here is what I really wanted to say, but couldn’t fit into the title field.
On February 27, 2015, nearly three years after it was submitted, the Nuclear Regulatory Commission (NRC) issued a letter reporting that the NRC staff had prepared a final Topical Report Safety Evaluation for document number WCAP-17573, Rev 1 titled Westinghouse Small Modular Reactor Small Break Loss of Coolant Accident (LOCA) Phenomena Identification and Ranking Table (PIRT).
The letter said that the staff determined that the Licensing Topical Report was acceptable for referencing in licensing applications for the W-SMR within the limitations specified in the Topical Report and in the final Safety Evaluation. As of March 22, 2015, the final Safety Evaluation of the small break loss of coolant accident phenomena identification and ranking table has not yet been loaded to the NRC ADAMS database.
Westinghouse issued a press release with the headline Westinghouse Advances SMR Design Certificate with USNRC Approval for Safety Testing Program to announce the issuance of the topical report safety evaluation.
Westinghouse Electric Co had a right to be happy that the document had finally been issued. The company had submitted WCAP-17573 to the NRC on April 25, 2012. On August 24, 2012, about 120 days later, the NRC sent a letter to Westinghouse saying that the staff had completed an acceptance review and determined that the Topical Report contained enough details to enable a full technical review. That letter said that the staff expected to issue requests for additional information (RAIs) around April 30, 2013 and a draft safety evaluation around December 15, 2013.
The letter said that the review would consume about 800 staff hours. That equates to a projected cost to WEC of approximately $225,000 for NRC time.
On May 3, 2013, a few days after NRC said Westinghouse should expect to receive its requests for additional information, the company received another letter from Anna H. Bradford of the Small Modular Reactor Licensing Branch. It included the following disappointing news.
“Due to NRC’s budget constraints and work prioritization, NRC has rescheduled the staff work on this project. Out latest estimates are that NRC will issue RAIs around October 30, 2013 and the DSER around March 1, 2013, provided that Westinghouse continues to give sufficient design data, satisfactorily responds to the RAIs, and addresses issues identified during the review process in a timely manner.”
It is worth noting that this review delay was announced well before February 2014, when Westinghouse announced that it was slowing its investment in its SMR development program. It is difficult to determine how many other documents Westinghouse had in the NRC review queue at the time.
It is also worth noting that, as proud as Westinghouse is that they achieved an important milestone by getting a final topical report safety evaluation issued, the scope of the document that was evaluated is fairly limited. It is not, as some industry news outlets have reported, an safety evaluation of Westinghouse’s SMR testing program.
It is an approval of the phenomena identification and ranking table (PIRT) that the company will use to identify the measured parameters that it will need to test and to prioritize the tests that will be developed to ensure that the design meets its safety goals.
For people not deeply immersed in the esoteric process of obtaining a design certification and then a construction and operating license with an identified customer, the terms “topical report” and “technical report” sound very similar.
The primary distinction between the terms inside of the licensing process is that a topical report requires a full NRC staff review and an eventual safety determination. A technical report is a significant step up in detail from the normal presentation-level discussions done during the pre-licensing review phase, but it does not require a complete staff review and does not require generation of a safety evaluation.
I’ve taken the detour to explain that distinction because vendors have a lot of leeway in the licensing process in the determination of whether they want to describe any given topic of discussion by submitting a topical report or by submitting a technical report. There are numerous considerations and one path is not necessarily better than another.
The technical report path is more flexible and can result in quicker entry into the actual process described. The topical report gains an early approval and can help shorten the time to review a design certification application assuming that no design changes invalidate the safety evaluation that was conducted.
One more consideration that often comes into play is that a technical report does not generate the kind of final decision that can be the subject for a press release. From the outside looking in, it can appear that one vendor is making more progress than another simply because they have achieved a milestone worth announcing in public. A competing vendor might have submitted a technical report on the same topic and might already be performing work described by that report.
Westinghouse’s March 17 press release also created some additional confusion among those who follow the new nuclear plant development industry closely. The announcement did not indicate that Westinghouse has altered its previously announced plan to put its W-SMR design on hold, carefully preserving the option of dusting it off for submission.
A source within the company confirmed that Westinghouse continues to keep close tabs on the potential market and has seen nothing that would cause it to change its current course of action. Its SMR design effort remains on hold in a condition that will allow it to complete a design certification application about a year after the company decides to restart the effort. That decision has not been made.
The issuance of the final topical report safety evaluation for the small break LOCA PIRT was good news, but it was actually overdue news about a document review process that the company had started in April of 2012.