Nuclear industry group leads efforts to overcome regulatory barriers to commercial success
Last winter the Nuclear Energy Institute (NEI) thought it might get 75-100 people to show up for a forum on small modular reactors (SMRs). The nuclear industry's flagship trade group was pleasantly surprised when 250 people signed up. One of the outcomes of the meeting is an NEI led task force on small reactors that involves the vendors, utilities (customers), and R&D centers like DOE national labs and the Electric Power Research Institute (EPRI). The task force is the leading edge of the nuclear industry's response to regulatory barriers to commercial success for small reactors, e.g., with output in the range of 300-350 MW (NEI Fact Sheet on SMRs)
In an exclusive interview with this blog, Paul Genoa, Director of Policy Development at NEI, (right) emphasized the serious nature of the work.
"This isn't a forum for people to trade marketing slides," he said. "We are looking for ways to meet the NRC's requirements, but in new or innovative ways that don't impose unnecessary costs on small reactors."
What NEI hopes to do, according to Genoa, "is to create a new regulatory paradigm for small reactors," and to do it in the next 18 months.
NEI's priorities are laid out in remarks Genoa made to the SMR conference last February. In this interview, he ticks off the items at the top of the list including annual fees, decommissioning costs, emergency response, and modularity, e.g., how to manage multiple small reactors at a single site.
Other issues include design certification, the licensing application process, and Price-Anderson liability issues. The last one will be tough, Genoa said.
"It is hard any time you have to make a statutory change."
That doesn't mean it will be easier to change the regulatory requirements to adapt them to SMRs. The NRC has a mature view of reactor safety issues especially for LWRs. Genoa said the NRC "is doing a good job to encourage the industry to organize itself to address the issues." Despite this assessment, the industry still has to make its case with the agency.
Part of it is what the NRC calls a “chicken and egg” issue. The agency wants to see customers showing interest in SMRs before it commits itself to diving deep into the regulatory issues for them.
In a speech to a Platts Energy conference in Washington DC June 28, 2010, NRC Commissioner William C. Ostendorff said:
“On the one hand, you have the industry and vendors seeking a high level of certainty and assurance from the federal government that related legislation and regulations will provide for a future return on their investment. On the other hand, you have the federal government looking to the industry and vendors for actions and signals that indicate the existence of a market for SMR technology . . .”
NEI using ANS white papers
NEI is expanding the scope of its search for ideas by using a series of white papers being developed on SMR licensing issues by the American Nuclear Society (ANS) . Genoa notes that ANS members participate in the drafting process as private individuals and don't represent their employers.
"The ANS is not directly engaging the NRC in dialog about how to regulate SMRs. NEI is using the ANS papers to help develop industry positions that will represent our membership's interest with the regulator."
However, Genoa noted that Phil Moor, who co-chairs the ANS SMR committee, is a member of the NEI task force.
"The paper on fees was particularly useful," Genoa said, " but as is the case with any white paper, you use what matters most to your association's members."
NRC policy review of small reactor issues
The drive to seek innovative solutions has the attention of the Nuclear Regulatory Commission (NRC) even if it is officially skeptical about customer interest. Small reactors may not need a mirror of all the requirements as those imposed on their larger cousins, or at the same scale, in order to be safe.
The NRC has published a policy paper (SEC-10-0034) (PDF full text) which takes up these issues. Genoa says this paper is "essential reading for anyone who wants to understand the regulatory issues from the NRC's point of view."
While the paper takes note of nine small reactor designs, it doesn't speculate on which ones will be most likely to hit the regulator's desk first. The paper divides the world of regulatory issues into four parts. The paper ranks each regulatory issue with these four groups as high, medium, or low importance.
· Licensing issues
· Design requirements
· Operational issues
· Financial issues
It takes note of all three generic classes of small reactors including light water (LWR), high temperature gas (HTGR), and liquid metal fast (LMFR) though it doesn't used these acronyms. Also, the paper does not address R&D or technical issues that small reactor vendors need to address to complete their designs such as fuel design or testing.
Financial issues are first for industry concerns
What's interesting is that while the NEI task force picked ten issues which match many of those on the NRC's list, the first two white papers NEI wrote are on financial issues – fees and decommissioning funding.
Genoa says a key example is that a large, 1,000 MW reactor will pay $5 million a year in fees to the NRC for basic licensing activities. He says the NEI white paper asks the question whether this is the "right fee level" for a 300 MW reactor with a much less complex plant to regulate?
On the issue of the size of the decommissioning fund, Genoa says the white paper is exploring the question of whether it can be smaller, for a small reactor, if the design on the front end takes into account the decommissioning of the reactor on the back end 60 years later?
"We've learned a lot of lessons about pumps and pipes. If we incorporate them into design, can it reduce the cost of decommissioning and thus the size of the fund needed to cover these costs?"
The industry has taken this approach for large BWR and PWR plants. Now it wants to extend the idea to SMRs.
Emergency Response
One of the key objectives in any reactor emergency response plan is to protect the public from exposure to radiation. Responses can include evacuation or shelter. In the case of SMRs, if the reactor is underground, and any release is contained there, how does that change the emergency response plan? Genoa says this might change the size of the evacuation zone from 10 miles to 2 miles.
"Our going in position is that there may not be a change to the size of the zone, but rather what happens inside it in terms of utility response."
"SMRs will have to meet the NRC's requirements, but in different ways. Different levels of risk depend in part on the size of the reactor."
Once you get a 'six-pack' of these small reactors they start to look like a big one, but until then specific issues, based on size, need to be addressed. Genoa says placement of reactors underground is is a game changer when it comes to deciding how to handle a whole range of issues including security.
"If you secure the reactor that way, how many guards and guns do you need on the surface? Also, are sirens still the best way to notify the public about an emergency?"
Another aspect of this issue is how control rooms will be set up. One of the features of SMRs is that vendors hope to offer economies of scale to utilities by being able to manage multiple modules from a single control room.
The railroad industry tackled this issue when it developed multiple diesel units to be controlled by a single engineer. While nuclear reactors are a lot more complicated than a railroad locomotive, the metaphor illustrates the idea.
There are human factors involved, Genoa says, that have to be worked through. Another issue is how to license a new module at a site where there is one that is already licensed and in operation.
Next steps in dialog with NRC
NEI plans to hold a series of public workshops with the NRC as it completes the white papers. The next one is scheduled for Sept 22-23 which will address fees and decommissioning costs.
NEI plans to make top level presentations at the meeting. It hopes the meeting will be the start, not the end, of dialog with the NRC.
Genoa says NEI doesn't expect NRC heads to go north and south or east and west at these meetings. That would be unrealistic. The objective of the meetings is to discuss alternative approaches to regulating SMRs based on industry buy-in as represented in the NEI white papers.
"These discussions are intended to establish a technology neutral framework for a final decision. We don’t expect the NRC to make up its mind one way or the other the first time they see an idea from us on SMRs."
Genoa said the members of the NEI task force have been impressed that the NRC is serious about the industry's concerns about changing regulatory paradigms for SMRs.
"They've put their "A" team on it," Genoa said, and he mentioned several by name.
Will the white papers be published at the these meetings? Genoa says some documents, like presentations, will become part of the public record of the meetings and eventually will be accessible through the NRC’s web site.
Genoa is hoping the NRC will consider having web access to the audio portions of the meetings, or a webinar format, so that people outside the DC area can follow the discussions as they happen.
Fuel is a critical success factor
Resolving regulatory issues won't clear away all the barriers facing SMRs in terms of time to market.Genoa says other critical success factors, especially for HTGR and LMFR, include fuel testing.
"Fuel is the long pole in the tent for advanced reactors. For instance, I expect NGNP will complete their fuel work by 2018."
LWR designs are obvious candidates for earlier success Genoa says. The manufacturing base is there in the U.S. and LWR designs, including fuel, are well-understood by the NRC.
"You can't expect perfect alignment in terms of R&D priorities by the government and the vendor community. There are a lot of tasks to put in one basket which is why we are tackling the three types of reactor designs as distinct for regulatory purposes."
Another issue will be that the NRC may eventually decide to license the manufacturing facilities for SMRs which could speed up plant licensing at reactor sites. However, Genoa says the first few SMRs will be built one-at-a-time.
“The industry will learn from the front end and then be able to move to producing them in a factory setting based on customer requirements.”
NEI is focused on opening new market opportunities. The NRC and the industry know that new American jobs, and the potential for export earnings, are riding on how to license, manufacture, and operate SMRs can be made more cost effective without giving up anything on safety. That's the industry consensus Genoa is driving to achieve.
Prior coverage on this blog
- 06/22/10 – Opening running room for small reactors
- 07/28/10 – Licensing small reactors
Video Link
- Platts on SMRs Platts Energy Week 7.11.2010 - Bill Loveless holds a panel discussion with Mike Anness from Westinghouse Electric Company; Paul Genoa from the Nuclear Energy Institute and Edwin Lyman from the Union of Concerned Scientists.
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The Tennessee Valley Authority (TVA) decided Aug 20 to spend nearly $900 million on development of nuclear energy in 2011. 
