NRC issues SER for Westinghouse Small Break LOCA PIRT
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.
So the NRC needs wagons of money and years of time to review a couple tables.
This organisation is the jailor of nuclear innovation in the USA. They keep claiming they have too few people and too little money. The opposite is true. They charge far too much money for very simple jobs, take far too long to do it (if they get around to it at all), lack priorities in real safety issues, and there are too many people interfering with everything in an overly bureaucratic and uncommunicative, unconstructive manner.
The NRC is held up as a “gold standard” for nuclear power regulation. Perhaps strangulation would be a more apt term. If Congress and both political parties were not captured by fossil fuel interests, it would be reformed to facilitate nuclear energy growth. Perhaps a structure more like that of the FAA would ensue, as ThorCon says it requires for its innovative design to be rapidly prototyped. We also seem to see a “strangulation” regime put in place in Japan in the wake of their prior regulatory regime engaging in criminal misconduct that led to Fukushima. But this situation can change rapidly. China and Russia both have big ambitions for nuclear reactor exports. Both are challenging US hegemony in other spheres. For example, the new BRICS bank (and Asian Infrastructure Investment Bank, or are they the same thing?) challenge the IMF and World Bank. The China International Payments System that is being set up tends to replace the SWIFT (Society for Worldwide Interbank Financial Telecommunications) system dominated by the U.S. These developments may eventually challenge the petrodollar as a world currency. This is a very important challenge to the USA. If Russia and China are unafraid to do these things, when other countries that challenged the petrodollar were summarily invaded and crushed; I don’t think they will be afraid to “overthrow” the “gold standard” of the NRC, and along with it the radiological bunk of the No Safe Dose/linear non-threshold theory as a world standard either. I don’t think the Chinese are anxious to waste their $4 trillion they have allocated for infrastructure development in the “third world”, perhaps one half being targeted to nuclear energy exports, on regulatory bullshit. International commerce is a cutthroat arena. And now, China is prepared to undersell US military exports, after reverse engineering planes tanks and so forth. Deference to the NRC will not continue for long, in my estimation. May it die a swift death. Safety will be enhanced if bureaucratic nonsense is shredded. And world health and ecological protection will be improved tremendously if regulatory bodies were required to consider the benefits of replacing coal with nuclear in their calculations.
This is an excellent post, Rod. What we are starting to see is reactor vendors using early NR review of key technical issues, before substantial investments are made in the detailed engineering needed to develop a complete license application. This is similar to the phased review process that is used to develop new drugs. It is interesting that the FDA is only required to recover about half of its budget from user fees, http://www.fda.gov/ForIndustry/UserFees/PrescriptionDrugUserFee/ucm119253.htm . The FDA also waives fees on about 1/4 of the applications it receives, where the applications meet specific criteria (e.g., orphan drugs, applications submitted by small businesses).
The difference is, in medicine, new medicines are developed and then tested.
In nuclear power, there is only pencil licking and paper pushing. And they’re not very good at that even, taking years to do simple paperwork.
As I understand it, the major impediment to NRC regulatory approvals is it’s “rule based” framework that essentially regulates the design itself. Regulatory bodies in other countries use a “performance-based” framework that establishes key requirements that must be met by any particular design. While a performance-based model could allow design flaws to slip through, the onus would be on the manufacturer, not the regulatory body. It wouldn’t be a case of “well they approved it so we’re not at fault”. More importantly though, a performance-based model would be much more adaptable to innovation. The current NRC model is so stifling that some innovative firms have publicly stated they will not even consider attempting NRC regulatory approval given the current rules-based framework..
We are in the age of transition from fossil to fissile. In the real world, old technologies resist new technologies that replace them. Wind and solar pretend to be part of the new, but are mere figleaves over the old fossil fuel genitalia. The anti-nuclear “Greens” are the designated liars, while Big Oil and Coal, can sit back, and buy Senators and Representatives. They fight dirty. They lie. In the real world, there is struggle and strife, drama and tears. Much resides on this battle. Modern societies will collapse without cheap, clean energy. Poor societies cannot grow wealthier. The NRC, though undoubtedly composed of many good scientists and engineers, is in the final analysis, run by Wall Street and armies of lobbyists who operate through our bought-off political representatives. To pretend that this giant cesspool of regulatory suppression is not a political football, is to be willfully blind or is a tactical concession necessary for working within the system. James Conca exposes another aspect of this situation today: http://www.forbes.com/sites/jamesconca/2015/03/23/the-nuclear-regulatory-commission-thinks-america-should-be-more-like-europe/
The NRC is also likely to be infiltrated with anti-nuclear activists, in the same way that you will find NRDC employees working for a time at the EPA. It’s a near certainty that when anti-nuclear minions are appointed to the NRC committee, they arrange to let these political hires in the door.
Most likely there are multiple camps inside NRC working against each other and making it vastly more difficult for good engineers to do and conclude proper work.
@Ike Bottema March 22, 2015 at 8:43 PM
A fairly good assessment, but not quite accurate. The US NRC does in fact have a “performance based framework that establishes key requirements…,etc”. It’s here:http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact=8&ved=0CCUQFjAA&url=http%3A%2F%2Fwww.nrc.gov%2Freading-rm%2Fdoc-collections%2Fcommission%2Fsecys%2F2000%2Fsecy2000-0077%2F2000-0077scy.pdf&ei=LyYQVcy1JNe5oQTAyYKQBw&usg=AFQjCNFBfmoS1uZJINlCUQZ67zyFD_OjyQ&bvm=bv.88528373,d.cGU
Read the two quantitative (measurable) objectives:
Prompt individual fatalities
Latent population cancer fatalities
These two objectives define “acceptable risk”, within a framework of pre-determined Design Basis Accidents.
So how does the system break down on implementation, resulting in a “rule based” framework?
Case study: Fukushima. Rule based regulations (FLEX) have already been passed, resulting in hardware money being spent on US nuke plants, with more still to come. Based on exactly what? Which of the above quantitative objectives justified it? It could hardly be the first “prompt fatalities”, and the second one will be argued about forever (official TMI2 latent fatalities are zero, antis claim a million), but in any event the latent fatalities are currently unknown. But yet FLEX is already regulation. The NRC abandoned the quantitative objective idea of regulation. If the NRC was capable of “backfit problem solving”, which they are not, they would go back and retract most of the post-TMI2 rule based requirements that drive the cost of new designs. Because there is no cost/benefit based justification based on the actual technical event. Almost all of that regulation can be traced to NRC response to the Media Event of TMI2.
To understand how and why that happens, and back it up with documented arguments, is beyond the scope of this simple comment. But the big picture is the NRC regulates to the scale of the Media Events, not the scale of the Technical Event. And the small picture is because the Commission is by nature a political organization, like it or not. The most recent discussion for why it has been kept a political organization is contained in the official NRC discussion document about the firing of Jaczko.
The pertinent discussion is in the section discussing why the Commission stayed 5 members vice one, when this was revisited after TMI2 by the Carter Administration. The 2 arguments are “provides better decision making discussion” and prevents a “rogue” commissioner from leading NRC astray. Both are wrong. Rickover and his staff had plenty of decision making discussions, the stories are legend. And Jaczko was a rogue. So what’s the real reason?
NRC is dysfunctional, can’t be fixed, needs to be replaced with a different structure. Someone else can work out the details, but my goals are follow Dale Kleins’s advice “No bozos allowed” and add “No nuclear agnostics allowed.”
mjd – while there is much to agree with in your comment, it should be recognized that FLEX is not “NRC regulation.” FLEX, in fact, was created by the plant owners and presented to the NRC via the NEI. This was an effort to get ahead of the NRC to avoid a repeat of the post-TMI NRC response (seemingly endless new requirements). FLEX was an attempt by the owners to say, “we will do this, this and this.” As opposed to waiting for the NRC to tell them what to do.
That the owners felt that it was necessary to take this approach tells us a lot about how they view the NRC. But any problems with FLEX shouldn’t be laid at the NRC’s feet. It’s not their baby.
OK, I stand corrected. I’m fairly well removed these days from some of the actual implementation details of the Fukushima “fixes.” And I “assumed” on FLEX. But anyone who read the 90-day Task Force Report and lived through the post-TMI2 era is responding to the hand writing on the wall, as you point out. I still feel correct laying it at the NRC’s feet, because it belongs there. So the utilities feel it is better to pre-pay a ransom than wait for NRC? It is still the same problem as I describe above. Is this just a chess game? What exactly is the applicability of Fukushima to US sites, based on the two quantitative objective safety goals described above, as Fukushima is now understood? I say none, yet NRC continues to expend resources on it.
As for the utilities, what exactly could drive a utility, that has already expended resources on a beyond DBA SBO Diesel to agree to FLEX? What exactly is not understood about the difference between “acceptable risk” and zero risk? I suggest utilities are not the folks driving that attitude. It comes straight out of NRC responding to the magnitude of the Media Event, not the magnitude of the Technical Event.
Again, I accept I was wrong about who actually “created” flex, but I am not wrong about what created a perceived need for FLEX.
The only advantage I can see to pre-paying the ransom and getting out in front of a pending issue is that it gives you a slight (note, slight) chance of framing the initial conditions to your viewpoint a bit better than a strictly reactive approach. I guess it comes down to a realization that you’re going to take a hit, try to deflect as much of the force as you can before it hits you, and channel it to your advantage if that’s possible.
I was in the research reactor business back in the ’80s when the “get-rid-of-any-and-all-HEU” virus was infesting the NRC commissioners. We knew the anti-nuclear organizations were targeting universities because they knew if they took out the upcoming generation of engineers they’d win the war in the long run. I did what I could to deflect that onrushing inertia so at least the operators could get DOE funding and also use some of that for facility upgrades (we did a power increase at the same time as the fuel switch). It didn’t save everybody, but a few came out a little ahead of the game, better than they would have if events had taken their trending course.
“I was in the research reactor business back in the ’80s when the “get-rid-of-any-and-all-HEU” virus was infesting the NRC commissioners.”
The roots of that viral infestation are actually the Rand Corporation. And they have infested a lot more than the NRC policy over the years; namely through both foreign and domestic policy at a Presidential Cabinet level.
Wasn’t Victor Gilinsky — one of the NRC commissioners during TMI — a RAND guy?
Rod – Not just a Rand guy, he was head of Rand’s Physical Sciences Department.
Gilinsky was the major force behind the ban-the-use-of-HEU back then. Asselstine picked up the flag after Gilinsky left. Ironic thing is it has come back to bite us in the a$$ on the 99Mo shortage issue. The absolute best way to make 99Mo is bombarding HEU targets in a research or test reactor. All other alternatives are paltry when it comes to efficiency of production. But because NRC has the HEU=bad mantra now a part of its regulatory culture, we’ve needlessly spent millions of dollars on “alternate” production methods that are nowhere near as efficient. Yet another example of a pathologically dysfunctional NRC.
My interpretation is different; I believe it is another example of the way that the hydrocarbon economy elites — which includes the leaders of the military industrial complex whose lifeblood is selling weapons systems that are, in large measure, used to protect access to oil — have used non-proliferation arguments to handicap the use of nuclear energy. (I hope that most people understand that RAND is an integral part of the MIC.)
Even most nuclear advocates that I’ve spoken to do not understand how useful HEU can be in enabling far smaller power generators, reduction in waste generation, improved purity of isotope production, more capable research reactors, and longer lived cores. Refined fuels are not necessarily associated with weapons systems. In fact, manufactured fuel assemblies, especially those using ceramics or alloys, are quite difficult to convert into weapons material. That statement is true when they are unused; it’s doubly or triply true after the assemblies have been substantially irradiated.
In a development that should really anger some of the people on this board, who share some of my background and training, there is a big push from the non-proliferation community for the US to once again shoot itself in the foot in order to provide a good example for the rest of the world. The idea this time is that we should stop using HEU in our naval reactors.
Imagine the non-value added, high cost evolution that would be required to redesign cores, manufacturing facilities, and possibly the ships themselves if it turns out that LEU cores will eliminate our ability to pack a lifetime of fuel into a submarine reactor core. This would put a huge kink into the kind of long range life-cycle planning that I used to do as a requirements officer.
Somehow, I’m not surprised that Alan Kuperman wrote the document claiming the effort is necessary.
What a disaster that would be, running ship-based systems on LEU cores. Your viewpoint may be equally valid. The Navy did away with nuclear-fueled cruisers using the rationale that gas turbine-powered vessels could be ready for sea on a much shorter notice than nuclear-fueled units. Maybe, but the need to re-fuel at sea on a long cruise certainly brings its own set of disadvantages, especially when the vulnerability of fuel tenders is considered.
Switching to LEU in our case didn’t make a big difference, but we’re talking about a megawatt-range pool reactor that has maybe a 30-40% duty cycle, and a few megawatt-days annually for power history. Not in the same league as a seaborne system.
There is one example I know of where HEU for naval reactors contributed to nuclear proliferation. That was the diversion of HEU for US naval reactors at the NUMEC facility in Apollo, PA to Israel for use in their nuclear weapons program.The loose controls at the NUMEC facility required for hiding the diversion has resulted in a contamination problem that is still being cleaned up today.
The answer is not to stop the use of HEU, but to make sure critical facilities and infrastructure are not under the ownership/control of those with loyalty to a foreign state. This was an “inside job”.
Please add the context of dates to your story. It’s not something that’s ongoing or likely to happen again. The “Apollo Affair” happened when I was in the third grade, nearly fifty years ago.
Rod, the date of the “Apollo Affair” is not as important as the fact that our government simultaneously frets about nuclear proliferation from commercial nuclear power while covering up it’s own contributions to proliferation. Not only did the government try to cover it up, it rewards the perpetrators with billions in direct foreign aid each year in addition to dispatching our military to pre-empt any potential threats to our little buddy.
I was just trying to point out the hypocrisy of the US government. Perhaps chutzpah is a more appropriate word.
JFK was the last president that tried to stop Israel’s nuclear weapons program.
JFK was the last president that tried to stop Israel’s nuclear weapons program.
He was also the last president that effectively supported and promoted the development of nuclear energy for the benefit of mankind. Many people remember the Apollo Program as one of his greatest legacies. I like to remember the Bandwagon Market for nuclear power plants that lasted for about as long but has had a much longer impact on the American economy as many of the plants built then are still producing a large amount of non-fossil fuel, ultra-low emission electricity today.
One more thought: Have you ever considered the enormous profits raked in by the hydrocarbon economy — and its closely affiliated MIC — that are enabled by a volatile situation in the Middle East?
Ever notice that when things really heat up, the price of oil skyrockets due to worries about supply security along with the increased consumption by ships, tanks, and airplanes?
I can think of several instances where “bear markets” in petroleum have ended because of increased tension in the Middle East. In fact, I think we are experiencing one more example now.
See how useful it is to keep a burr in the area that can be rubbed almost at will?
Here is a wonderful side note when it comes to the craziness that has developed post-Fukushima. I’m now required to be qualified to operate a front loader and excavator for debris removal…….and I’m an RP……who works at a Nuclear Power Plant in the desert of Eastern Washington……about 3.5 hours away from the coast!!!!
While I’m sure getting qualified is going to loads of fun, It’s hard for me to imagine the 70+ million dollars my plant has spent on Fukushima upgrades being worth it.
” … the craziness that has developed post-Fukushima …”
As in “accidental”, driven by paranoia? Has it ever dawned on you just how much this stuff is similar to what we all lived through during the propaganda campaigns of the cold war era? I think it started well before Fukushima. With the collapse of the USSR, the Military Industrial Complex lost its main tool for driving the fear and paranoia that it used to justify its obscene defense budgets. It needed a new tool! It really started at 9/11, but it just packaged Fukushima into the fear and paranoia campaign. It’ll take anything it can get!
The $70M+ you cite is a thought provoker. These nuke $ numbers have gotten so big nobody even blinks an eye seeing them anymore. But as a number comparison, that $70M, in 1971 dollars, built the W turn-key project HB Robinson plant. The plant I retired from went commercial in ’77 with well under 250 site employees. There are now nukes with 300 security force. Have fun in your training, but you might as well start on your CDL now, that’ll be next as soon as INPO gets it’s mitts on your training program!
And people really wonder why some of these smaller plants in some markets can’t make money any more? No mystery to me… they’ve been priced out of business.
I don’t know if it is the oil companies per se that benefit from middle east saber rattling or the (paper) commodity traders. The oil companies themselves would probably prefer to just quietly pay for the oil rather than use military force. Those that run corporations are very pragmatic and always willing to cut a deal. Note that in post-Saddam Iraq, US oil companies did not do so well.
Certainly the big defense contractors benefit. But they could just as easily benefit from imaginary boogieman scares as well.
We are in the middle east on the behalf of the Israeli’s and AIPAC. Israel cannot tolerate a competent, secular Arab nation. They would rather see an Islamic fundamentalist state that would be embroiled in religious divisions. That’s why they actually assist Islamic fundamentalist forces in Syria, for example. This has been Israel’s strategy since at least the early 1980’s.
To this end, the Israeli’s pull our strings today just as the British and US Anglophiles did to get us in WW1 and WW2.
Here’s a thought: Why not have Westinghouse get the AP1000 on track before worrying about SMRs?
Apparently you did not read the article. Westinghouse is not expending effort on their SMR development. They are focusing their efforts on the projects that are in progress and on expanding their ability in what they believe is a growing market for decommissioning. That strategic move was announced in February 2014.
As noted in this article, Westinghouse had not changed its mind and is still waiting for the SMR market to develop before it takes its project off of the shelf.
I apologize, as you are correct. I did not read the article. As soon as I saw Westinghouse, it drew a negative emotional response. WEC has some fine, hard working people but,….. Well, I’ll just leave it at that.
@Rod Adams March 25, 2015 at 5:06 PM
Wasn’t Victor Gilinsky — one of the NRC commissioners during TMI — a RAND guy?”
You mean ol one-trick-pony-Vic, yup, so was James Schlesinger, Carter’s Sec of Energy. Such a coincidence… they banned reprocessing (against the advice of the NRC Staff) and set us on the road to Yucca. Google Rand Alums… it’s the who’s who of (insert yer own word, and yes… some of them are hyphenated words).
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