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.