1. Very, very good post, Rod.
    I’m shocked and disappointed that the NRC would claim that “the staff believes that resolution of this issue need not occur until after a licensing application is submitted because it concerns activities that will need to be addressed during an operating license review.” How convenient for the NRC — and naive.
    No commercial entity is going to apply for the license with such a huge cost adder – it really destroys the business case. The only way they’ll enter (Hyperion and Toshiba at this point, B

  2. I understand that entrepreneurs would like to see some predictability here, but I also emphasize with the NRC in this situation.
    There are a number of different things that are emerging in the small reactor space: (i) small LWRs (Nuscale, MPower), (ii) small LMRs (Toshiba 4S, Hyperion), and (iii) HTGR-type reactors (PBMR, Adam’s Atomic Engines) are all relatively mature — then there are are concepts like LFTR, and Hyperion’s old hydride fuel design that are fascinating but a little further off.
    The regulatory scheme for a reactor is going to be highly dependent on what the reactor type is and what sort of safety issues it has. Small LWRs have the advantage that we know a lot about fuel performance and can ride on what we know about large LWR safety, with the caveat that the situation is a bit different (most think better) for smaller reactors. The first modular LWRs will be probably be installed in clusters at central power plants, will have operators, and generally can be regulated more-or-less the way large LWRs are regulated.
    For instance, it might feasible to charge one regulatory fee for a site that has up to so many GW of modular reactors installed at it.
    In the case of the other concepts, much less is known. There’s some experience w/ fuel performance, but not like with the LWR. The safety concepts are entirely different. Some of these are intended to be operatorless, like Toshiba 4S. In that case, the regulatory approach needs to be entirely different.

    1. @Paul – I agree that the NRC has a big challenge in front of it, but how does the challenge of learning about new reactor technology equate to a need to charge excessively large fees – fees that will never be collected because the projects will never be started – for small, relatively simple nuclear generators?
      The United States is shooting itself in both feet with its insistence that the cost of regulating nuclear power plants should be paid directly by the regulated entities. That might work okay for a mature industry whose technology has little room for further development. But what our legally mandated regulatory cost reimbursement structure does in an industry with big players who are already regulated is to force stagnation due to their natural desire to keep down the cost by encouraging the regulators to remain focused on only their issues.

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