The Nuclear Regulatory Commission has published its vision and strategy for preparing to review applications for permission to begin building reactors that do not use light water as the coolant.
Policy makers who are interested in ensuring that American reactor developers have the opportunity to lead in the nascent – but potentially very lucrative field – of advanced nuclear reactor technology development and manufacturing should demand improvements to the plan. Funding appropriators should follow through with support for an implementation process that enables a quicker, less tortuous path to initial deployment, especially for those designs that allow simpler, less costly approaches to protecting public health and safety.
Current State Of The NRC Strategy
The document, released the first week of January, is titled NRC Vision and Strategy: Safely Achieving Effective and Efficient Non-Light Water Reactor Mission Readiness. It claims that “The NRC could review and license a non-LWR design today, if needed,” but also makes it clear that the process would not be effective or efficient.
It would be plagued with deficiencies in people, processes, organization and infrastructure, tools (hardware and software), policies, decision criteria, transparency and clarity of requirements, and communication with stakeholders.
The NRC’s roadmap for addressing its deficiencies in the above listed areas includes two phases. Phase 1 is a conceptual level development of goals, objectives, strategies and contributing activities. The activities needed to achieve objectives are binned into “near” term (0-5 years), “mid”-term (5-10 years) and long-term (beyond 10 years) categories.
The description of Phase 2 is something only a seasoned bureaucrat can understand. It relies on Implementation Action Plans (IAPs), budget battles, task approvals, task completion and public feedback for every step in the process. It would require a host of cost estimation specialists, project management software experts, human resources practitioners, and an unlimited number of coordination meetings.
NRC’s Claim Of “Capable” Not Equal To “Ready”
After reading through the listed deficiencies and strategy for developing plans to potentially (budgets and priorities permitting) address those deficiencies, it’s difficult to understand why the authors and reviewers of the document repeatedly state that “The NRC is fully capable of reviewing and reaching a safety, security, or environmental finding on a non-LWR design if an application were to be submitted today.”
According to the document, the agency’s claim of being capable rests on the fact that the NRC — more accurately the Atomic Energy Commission (AEC), its predecessor as a nuclear energy regulator — successfully licensed three commercial non-LWRs in the United States.
That claim would be laugh out loud funny if it wasn’t for the fact that the chosen leaders of an important government agency meant for it to be taken seriously. The AEC ceased to exist at the end of 1974. That was 42 years ago.
It is unlikely that there are more than a handful of employees at the NRC whose resumes including positions in the AEC. Every member of that handful would have been too junior at the time to have any idea how the agency decided to license Fermi 1, Peach Bottom 1 or Ft. St. Vrain. The last U.S. non-LWR commercial power plant was shut down in 1989.
The documents describing those activities were created in the days of typewriters and microfiche, so they are not readily obtainable and are unlikely to be in anyone’s readily accessible knowledge base.
One thing that current employees should know is that the AEC did not issue a vision and strategy document that described Implementation Action Plans with task completion dates extending more than a decade into the future.
The NRC has a long history of claiming to be ready to review advanced reactors. Its institutional history, however, also includes at least half a dozen advanced reactor reviews that began and proceeded part way to completion before being abandoned.
Developers Poised To Go Elsewhere
Though the NRC claims no responsibility for the decision to abandon any of the aborted projects, participants in the PRISM, PBMR and NGNP reviews disagree.
They have stated that the cost and schedule uncertainty for obtaining a license and resolving other long-unresolved regulatory issues like emergency planning boundaries, insurance requirements, annual fee structures and control room manning requirements played a major role in their decision to quit trying.
About 28 years ago, the NRC published a document titled Development and Utilization of the NRC Policy Statement on the Regulation of Advanced Nuclear Power Plants (NUREG-1226). It identified many of the same issues, capabilities and challenges as recently issued vision and strategy document.
If a non-LWR applicant showed up at the NRC’s door tomorrow with a complete, high-quality application, with sufficient resources and patience to help the NRC overcome its existing deficiencies, it might eventually succeed in obtaining the required permits to begin building its first unit.
Unfortunately, the NRC hasn’t displayed any understanding of the near impossibility of producing a complete design and high-quality application without access to any published criteria or a proven process of efficiently communicating the application requirements.
Not surprisingly, none of the 50 companies that are working on advanced reactors in the U.S. have announced any plans to apply to the NRC for permission to build their designs in the U.S.
The best hope for a change in that situation would be a clear declaration by the federal government that the widespread use of advanced nuclear energy systems is vital for protecting public health and safety, contributing to common defense and security of the United States and protecting the environment.
With that declaration, the NRC would be required by its existing mission statement to produce a more workable plan to review and approve advanced nuclear power systems. The people on the staff at the NRC are fully capable of completing that task as long as they are told that they can stop being agnostic about whether or not nuclear technology succeeds.
That does not, by the way, introduce any conflicts by making them responsible for producing designs or marketing any particular technology. The process of enabling technology development through good regulatory practices is not the same as promoting any commercial products or special interests.
Note: The above piece first appeared on Forbes.com on Jan 9, 2017. It is republished here with permission.
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