NuScale Getting Ready For Design Certification Submission
NuScale remains on track to submit a high quality design certification application to the Nuclear Regulatory Commission by the end of 2016. That statement might surprise people who follow small modular reactor developments closely enough to be aware that the company received a status report earlier this week from the NRC that gave a grade that can best be described as an “I” — for incomplete.
That status report was in the form of a letter dated October 7 summarizing the results of a document review that assessesed the readiness of the company’s DCA for the NuScale Power Plant.
The four-page letter includes a number of specific examples, but the part that provides extra ammunition to the already well armed critics of the nation’s investment in small modular reactor development is the following paragraph.
NRC staff made two over-arching observations from the readiness assessment as described in more detail below. The first observation is that substantial information gaps currently exist in the draft DCA. The second observation is that even for the sections of the draft DCA that were available during the readiness assessment, the NRC staff identified many areas that were not technically sufficient or complete.
When I spoke to Mike McGough, the Chief Commercial Officer at NuScale, about the report, he cautiously told me that NuScale isn’t surprised that the NRC found that their current draft isn’t complete. The company knew that well before asking for the review. After all, if they thought the document was ready, they would have submitted it already.
The company requested the readiness review as part of its long-running effort — begun in 2008 — to actively engage with the NRC before submitting a formal application.
Even the regulators acknowledge that it is virtually impossible to comply with the nuclear regulatory system in place in the United States by simply following all of the written rules; many requirements are subject to interpretations that sometimes depend on the assigned reviewers. NRC leaders frequently emphasize the importance of pre-application engagement in producing documents that can be efficiently reviewed and approved.
The part of the readiness review summary report that seems to have been most frustrating to the future applicant was what it didn’t say. Nothing in the letter indicates that ten out of 21 sections in the application were considered to be essentially complete, including some of the more contentious parts of the application, like digital control systems, human factors engineering and control room staffing.
Students around the world may empathize with a company that is somewhat frustrated with a grader that publishes a public report card accessible to anyone — including funding sources — that emphasizes the amount of work a paper needs. That might be especially true knowing that the student voluntarily submitted an early draft — with the teacher’s encouragement – to ensure she was making progress towards the expected product.
Even greater empathy might be engendered by noting that the grader failed to make any positive observations about the amount of progress that the student has made or the number of areas in which work is nearly complete.
The review the NRC conducted wasn’t a freebie whose cost is included in some kind of fixed price application fee. The NRC is a bit like a accounting or law firm; they track billable professional staff hours at a current rate of $265 per hour.
There were nearly 80 regulators involved in the NuScale DCA readiness review; they began their work on September 18 and completed it on September 28 with a September 29 debrief.
Though neither the contact listed on the letter nor the NRC Public Affairs office was able to provide an estimate of the total number of professional staff hours spent performing the review, McGough said the company is bracing for a bill of perhaps $500,000. I suspect NuScale wouldn’t be completely shocked if the invoice approaches $1,000,000 for the inconclusive and, so far, rather unhelpful report. After all, the observations still have to be written up and reviewed.
Some of the NRC reviewers who visited NuScale’s Rockville office gave company employees the impression that they had only recently been assigned to the project. They knew very little about the NuScale design. That must have been disappointing considering the number of meetings and volume of correspondence generated during the past 8 years of pre-application interactions.
McGough made a number of positive statements about the learning experience associated with the readiness review. He told me his team is looking forward to the detailed report so that they will be able to use it as a partial checklist during the final reviews of their finished document. As of today, the delivery date of the final report has not been released.
Aside: As is so often the case among NRC applicants and licensees, McGough did not provide any direct criticism. The conventional approach to regulators from the nuclear industry is almost obsequious. Regulators have an immense amount of power and discretion that can add a virtually unlimited level of difficulty and cost to any project or plant. End Aside.
Nuclear energy critics often point to the time it takes to design and build reactors and to the amount of money that the process takes. They often shrug their shoulders when a nuclear energy advocate tries to explain the weight of the burden imposed by the way that nuclear energy is regulated and the way that the monopoly provider of regulatory services in the United States functions.
People who appreciate the qualities of nuclear energy but dismiss it because they think it’s too expensive and takes too long should take a hard look at this story. Perhaps they will realize that a more constructive thing to do than to complain is to recognize there is a solvable problem here. With cooperation and rather well known techniques, this process can be greatly improved to provide a better outcome with fewer resources.
Note: The letter discussed above was made available in the NRC ADAMS system on October 18, three weeks after the readiness review was completed.
Former or current Navy Nukes should be thankful that their inspections are conducted and reported with a substantially higher level of efficiency.
A version of the above was first published at Forbes.com under the headline of NuScale Readiness For Design Certification Submission. It is republished here with permission.
What depressing reading.
What with all the debilitating delay, the undermining uncertainty, the exorbitant expense, the endless escalatory clicks of the ratchet on the regulatory rack, and sheer glued-up glaciality of this process, it’s a wonder the NRC doesn’t re-christen itself the NSC – Nuclear Strangulatory Commission.
Come on NRC, you’ve got some good and clever people. Why not go and study your friends in the CNSC – they can show you a better way!
Wow, this was not enjoyable to read, particularly considering the excitement around this technology.
A “debrief” the day after a review is completed is probably meant to be an informal product. You wouldn’t expect them to have a final report the day after their review, would you?
I guess I was spoiled by having my oversight provided by an exceedingly competent, hard-working group that assigned inspectors with deep operational experience. They really could do a complete review in a short period of time and produce a coordinated report to provide – admittedly in “draft” form – before they left the ship.
My nuke school experience was also a bit spoiling. We were given intensive, essay and “show all your work” tests. Those tests were graded before the instructors left for the day.
Did you get any feedback on the Adams Atomic design from the NRC, Rod ?
No. We never achieved sufficient capitalization to make it worth while to become docketed and to begin paying NRC fees. We took the opportunity for our “free” meeting, but the staff was quite reserved in its response.
We had better interactions with DOE, including a significant meeting in 2006 chaired by Bill Magwood. That was when we learned that the HTR fuel qualification program was on a path to have certified fuel ready to go by the 2021-2024 time frame.
As you might imagine, our team determined that was a VERY long runway.
And NuScale is just dealing with NRC in Rockville. Try dealing with Rockville and one of the Regions, particularly when they don’t agree with each other.
The deck is so blatantly stacked against you guys, that I don’t understand the lack of a coordinated and proffessionally waged media counter attack. Surely, there must be some pretty well heeled heavy hitter entities within the industry that could afford to pony up the funds for a decent media counter-attack. In the mainstream media, its really quite easy to find positive NG or renewable PR, and anti NE hit pieces. But finding positive PR or media exposure in the mainstream, about NE, is like trying to find a needle in a haystack. I really think the ongoing demise of NE is due to incompetency within the industry. People like Rod, with limited financial resources, and with very limited media access, simply cannot speak in a loud enough voice to compete with the deep pockets that oppose NE.
Problem is, there is no Uranium Council to pay for advertising their product. Instead, the nuclear plants have been quietly burning off the high-enriched U created by Russia and the US during the cold war. You’d think that would be a worthy effort, even without the thousands of megawatt days of electricity produced in the process. Yet few, if any, people outside the industry even know that that’s been going on for 20 years.
that would be a violation of licensed fuel design
You’re wrong. Weapons HEU was blended down to LEU and turned into commercial fuel for 20 years. During that program, 1 out of every 10 kilowatt-hous consumed in US was helping destroy Russian weapons material.
silverbase-metal lining dept, EEnews has a piece up reporting a rare agreement among the Clinton and Trump camps, during a debate 25 October in Richmond. FWIW:
(Clinton energy policy adviser Trevor) Houser said natural gas has an important role to play in the U.S. transition away from coal, “if the right safeguards are in place.”
He said zero-carbon nuclear power should also be valued for its climate benefits, for those existing plants that are safe to operate.
The United States should invest in advanced nuclear technologies, he said, as well as renewable power, energy efficiency, biofuels and carbon capture and sequestration for fossil fuels.
“Climate change is too important an issue to take any technology solution off the table,” Houser said.
( Rep. Kevin Cramer R-N.D., energy policy adviser to Donald Trump) said nuclear power is “a very exciting option because it is emissions-free.”
Each and every individual here can write editorials in local newspapers and respond to inaccurate assessments in whatever venue they are found. I have seen some of the responses people on this thread have made…excellent responses. Sometimes choir members need to venture out into hostile waters to expand their melody.
A well written post, Rod ! I’m of the view that the whole regulatory safety prescriptive bureaucratic process will need to implode and when the dust settles after the next Fukushima type-accident, the industry will need to look for a new approach, what about assessing managing the risk versus the pinochle safety game.
Rod — How to fix this? Does it take congress rewriting the NRC law?
It’s astonishing that it will take almost $1 billion to license and almost 25 years to design, license and build a tiny LWR that is so similar to and so *obviously* safer than our current fleet of large LWRs.
That said, the most important battle of all does not have to do with the costs and time of licensing. It has to do with regulatory and component fab QA requirements. This, more than anything else, will determine the future competitiveness of this reactor. Has NuScale been putting up the necessary fight (against NRC) on this issue?
Is NuScale arguing that most, if not all, components that make up their reactor system should be classified as NITS? I’m not joking. I’m dead serious. At a minimum, they should be fighting tooth and nail to get as many components so classified as they can. This will dramatically affect cost.
How many people did the full meltdown of three large reactors at Fukushima kill, again? How small is the maximum potential release (even in the case of a completely non-mechanistic loss of coolant and meltdown scenario) for this reactor, compared to the Fukushima release? (It’s a few percent at most.)
Given this, how can NRC claim that a component failure (or even a meltdown) for a NuScale module would threaten “public health and safety”? I’m not sure that any event with a NuScale module (from component failure or anything else) could cause radiation levels in excess of the range of natural background, over any land area at all.
As many of you know, my view is that NQA-1 should be eliminated. The same fab QA standards that are used in other heavy industries (e.g., the gas plants nuclear competes with) should be used. “Nuclear grade” should be eliminated. Barring that, NQA-1 or any other special nuclear grade requirements should be limited to the assembly line where the modules are fabricated (where the experienced, professional full time staff that is all set up and is simply making many copies of the same thing can probably deal with it w/o adding to much per module cost). But that’s as far as they should go (or offer). It is absolutely imperative that all on site activities be held to QA standards and operational requirements no more strict than those applied to gas plants.
Jim Hopf says October 28, 2016 at 4:49 PM
I’m not sure what you would be considering as NuScale “arguing” their design case. But their Design Certification Submittal Package will contain several design considerations right in line with your proposals. For example, they have no 1E power in their design, including the station battery system is not 1E grade (it’s non-Q, commercial grade). But what’s to “argue”, NRC reviews against the Standard Review Plan. All NuScale can do is spend a ton of money preparing “Position Papers”, etc. trying to convince NRC the NuScale design should be exempt from X or Y reg or requirement of the SRP. NRC will either agree or not. On some issues NRC Staff has already told NuScale they don’t feel an issue is an NRC Staff decision, rather a full NRC Commission policy decision.
With respect to accident source term, NuScale is proposing a whole new ball game, especially with regard to the size of the EPZ, to allow NuScale siting near large population zones closer to the power demand. NuScale feels that is a very desirable selling point.
But that’s where the rubber hits the road so to speak. The NRC will be under extreme external pressure from who only knows where, to not relax any requirement. There has been progress made in some areas.
At this point it is really hard to predict an outcome. And the whole thing is almost a catch 22 for NuScale. NRC won’t/can’t express an opinion on “talk”; they want the Design Submittal to review before they give a firm opinion. NuScale has to complete a design for that, but they are shooting for an invisible design target because they can’t get a “fixed” position out of NRC on the more contentious issues. On some issues, if NuScale looses, they about have to start over, especially if it directly affects the Control Room design.
“How many people did the full meltdown of three large reactors at Fukushima kill, again? How small is the maximum potential release (even in the case of a completely non-mechanistic loss of coolant and meltdown scenario) for this reactor, compared to the Fukushima release?”
Didn’t stop the NRC from making us (a plant 3.5 hours away from the coast) spend 80+ million on “Fukushima” mods. But hey, when we melt down at least we can now vent our drywell/wetwell and we wont blow our refuel floor apart. Thanks NRC!!
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