PBMR (Pty) Ltd proposes pre-application review schedule

On Monday, 12 December 2005, I had the opportunity to attend a public meeting held at the Nuclear Regulatory Commission (NRC) headquarters in Rockville, MD on the subject of pre license application reviews proposed by PBMR (Pty) Ltd. for their Pebble Bed Modular Reactor (PBMR).

The company proposed a series of workshops and white papers scheduled between February 2005 and December 2007. Some of these interactions would be open to the public, while others would contain information that the company requests would be protected as trade secrets. Since PBMR (Pty) Ltd. and its predecessor organizations have invested about 4 million man hours so far in the process of their engineering designs, that appears to be a pretty reasonable request.

The expected end result of conducting these workshops and sharing the white papers would be a readiness of both parties, the NRC and PBMR (Pty) Ltd, to begin the 40-60 month process of obtaining a design license using the Design Certification process.

Both organizations recognize that the proposed pre-application activities will help produce a better application and review since the NRC is far less familiar with gas cooled reactors than they are with light water reactors and since PBMR (Pty) Ltd is not familiar with the NRC’s current licensing practices. Both organizations will learn a lot during the upcoming two years that will aid in producing a high quality application.

As an observer to the process, however, I could not help but notice that the NRC representatives thought that the schedule was overly optimistic, particularly given the constraints on their resources and the increased demands that are being placed by activity in more conventional light water reactors with recognized domestic customers.

The resource constraints seemed a little strange to me, since applicants – after one free introductory meeting – pay the US government $207 for every man-hour that the NRC devotes to their project. It seemed pretty obvious to me that the increased licensing activity should increase the agency’s budget, thus allowing them to hire additional support. Even in Washington, DC, that fee amount should make it is possible to hire highly qualified engineers.

Though it takes time to train new hires fresh out of school, there are hundreds of very experienced nuclear trained engineers who have been “right sized”, “made redundant”, or simply “laid off” during the recent consolidations at nuclear power facilities. It would seem that there is a fairly robust pool of workers that could help the NRC through its crunch time.

So I asked the question during the few minutes that were set aside at the meeting for public involvement. Since I was one of the only members of the “public” at the meeting, it was not hard to get recognized. Mr. Prasad Kadambi, the NRC PBMR project lead informed me that the NRC budget was completely isolated from the fees. The fees go into the US Treasury – apparently like any other tax – and the agency has to go through the same budgetary process as any other federal agency.

PBMR (Pty) Ltd, for example, has already been “docketed” so its interactions with the NRC are already being billed. According to the roster from the meeting, there were 10 NRC employees at the meeting and the meeting lasted for the scheduled 2 hours. In other words, the meeting cost PBMR (Pty) Ltd. at least $4140.00 in fees, but I assume that the bill is actually higher since the agency employees will probably account for some additional time in preparation and reading the provided materials.

I know a little about the federal budget cycle from my day job, so I was not surprised to learn that the agency is in the process of programming its fiscal year 2008 request and that the total size of the 2006 and 2007 budgets, not to mention the 2005 budget that is already being executed, have already been largely determined.

Here is my first call for action – please write to your Congressman and Senators and suggest that they take a fresh look at the NRC budget allocation in light of the increased fee revenue that is being generated by the licensing activity that has been encouraged by the energy crisis and the Energy Policy Act of 2005.

It would be foolish if the US failed to invest a relatively small amount of money into ensuring that applications for new nuclear power plants received their proper review in a timely manner. That is especially true since applicants are paying rather dearly for the priviledge of getting that regulatory service.