Senator Inhofe – Please continue your efforts to improve the NRC's risk informed approach
My good friend Eric McErlain at NEI Nuclear Notes pointed me to an excellent op-ed piece by a new hero of mine – Senator James Inhofe. (Go to NEI Nuclear Notes: Senator Inhofe Has His Eye on the NRC for Eric’s article.)
The original op-ed piece is available at Expanding nuclear energy is a move we must commit to.
Senator Inhofe is the Chairman of the Committee on the Environment and Public Works, which is the Senate committee that has the responsibility of overseeing the Nuclear Regulatory Commission. In his op-ed piece he explains a number of steps that have been taken to provide a reliable and more risk aware approach to licensing and points with legitimate pride at the process that has been successfully used to relicense more than 40 of the currently operating reactor plants.
I congratulate Senator Inhofe, his committee and the NRC on their accomplishments, but I hope that they do not rest yet. There are still changes needed in the direction of the NRC, some of which must come by changes in governing legislation.
As the President of Adams Atomic Engines, Inc. I have a special interest in the workings of that important regulatory body.
Based on a number of personal interactions with members of the Commission, I have gained a deep respect for their technical knowledge and dedication to doing their job properly. I have also, however, experienced some frustrations with their organizational inability to take into consideration any risk to the public outside of the direct risks associated with nuclear power.
Of course, I am sure that there are people that will misunderstand me and some that will say, “of course that needs to be the NRC’s sole focus.” In my view, however, decisions about energy supply system risk are too complex to focus on only one source at a time in complete isolation from its impacts on other sources.
It would be possible, for example, to completely eliminate the possibility of any public risk from a new US nuclear power plant by simply refusing to allow any new US nuclear power plant project to even get started. If there is no dirt being turned by heavy equipment, no foundations being laid and no steel being bent, then there is absolutely no way that any person could be at risk as a direct result of a new plant.
From an energy system point of view, that decision could be quite dangerous, because it would mean that the US would be forced to build other types of power generating equipment and the fuel supply infrastructure to supply that equipment. It is probable, based on a number of years of actual experience with all sources of power generation that can do the same job as a nuclear power plant, to determine that the risk to the public would be much higher from building and operating those other types of equipment for the next 40-60 years.
Fortunately, the NRC does not seek absolutely zero risk and there is every indication that they have processes in place that will reliably lead to the eventual approval of new nuclear projects. The problem that I have, as a leader of a company that would like to enter that process very soon and obtain approval to build, is that the process is very lengthy.
The NRC currently expects it to take between 60 and 72 months to review an application and reach a decision. That timeline includes a number of mandated pauses in the process during which the applicant must simply wait and continue to pay for NRC time, pay its own work force, pay the interest on its loans, pay its power bills, its rent, its communications bills, and all of the other costs of running a business including the inevitable taxes.
That time line effectively PREVENTS any company other than a very large, established and politically well connected company from even beginning the application process. The company would have to have other lines of profit making products in order to stay in business during the 5-6 years of pure spending for their nuclear plant application, effectively eliminating the possibility of a focused, innovative start-up company with a new approach to nuclear plant design and operation. (Yes, I am talking about my own company – Adams Atomic Engines, Inc. there.)
The reason that I included the politically connected comment is because all of the license applications that have actually entered the process did so with a great deal of taxpayer support in the form of grants from the Department of Energy to pay the costs of the application to the Nuclear Regulatory Commission. It is very likely that most of the next round of applications will have the same or greater levels of taxpayer financial support, but actually obtaining that support is not automatic and requires a lengthy process of proposals and bureaucratic review of its own – along with the inevitable political pressures that come when the government gets to make technical choices on how to spend its money.
There does not seem to be any provision for speeding the NRC application review process even with significant refinements made in the system design. At AAE, our governing philosophy has been to work to simplify our plant designs so that they will not only be easier to build, but easier to operate and easier to ensure that they are safe under all conditions.
Our systems are designed to produce about 1% of the power produced by large commercial reactors, our projected coolant pressures are very low compared to all other designs, our equipment is projected to operate well within its material limits, the basic core design that we have selected has a proven capability to withstand a complete loss of cooling without damage, our coolant is an inert gas that minimizes any possibility of corrosion, there are only a few moving parts in our system, and we intend to build our systems with full secondary containment – just in case all of the other features are not enough.
However, even with all of those simplifying choices, our best advisors still indicate that we will face the same process, with its mandated delays, at the NRC. In fact, most of our advisors tell us that our plant design will take much longer than those that are designed to use highly pressurized or boiling water, since the NRC is used to pressurized and boiling water reactors and can more easily understand them.
I also have to mention that the NRC fee structure is also a concern, but I think I will make that discussion a post of its own.
If you think that there is room for discussions aimed at improving the timeliness of NRC reviews, especially when there are solid engineering reasons for recognizing that the system in question is simpler and has less absolute potential for hazard due to design choices like size, coolant pressure and containment, please join me in asking Senator Inhofe and his committee to take additional looks at the process in place to see if there is any room for speeding it up; perhaps by eliminating or shortening the mandated waiting periods.
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