Three companies developing small nuclear power reactor technology have debated whether US and UK regulators – the Nuclear Regulatory Commission (NRC) and the Office for Nuclear Regulation (ONR) – ought to work together to smooth their path through the licensing process.
Bill Fox, chief executive of Generation mPower LLC, Thomas Mundy, vice president of the Program Office at NuScale Power LLC and Eric Loewen, chief consulting engineer at GE-Hitachi Nuclear Energy (GEH) spoke at an evidence session on small nuclear power held by the UK parliamentary Energy and Climate Change Committee on 8 July. The committee published a transcript of the session on 14 July.
Asked by committee chairman Tim Yeo how the two countries might collaborate, Mundy said: "NuScale Power are receiving considerable support from the US Department of Energy (DoE). There are opportunities where the two governments could collaborate on that kind of support and also in the licensing and export areas for the technology itself, particularly between the NRC and the ONR and the licensing of this technology and also on the development side."
But the two regulators differ in their approach, he said. The NRC approach is "very prescriptive", while the ONR is "more performance based", he said. "Ultimately, their goals are the same - to approve designs to the utmost safety in the course of that review," he said.
Fox said his company had already spent nearly $500 million on work toward licensing and detailed design and testing of the mPower reactor though it has yet to make its submission of a design certification application to the NRC. There should be collaboration between not only regulatory bodies, but also governmental bodies to help fund the detailed design engineering "that is absolutely required to provide cost certainty and schedule predictability in any deployment model or any deployment type of program," Fox said.
mPower's owner, Babcock & Wilcox Company, said in April it expects to invest up to $15 million annually, beginning the third quarter of 2014, in its small modular reactor program. The B&W mPower reactor design is a scalable, modular, advanced light water reactor system in which the nuclear core and steam generators are contained within a single vessel.
Loewen said he did not see any challenges with licensing small modular reactors compared to large nuclear reactors in the UK. The ONR has about 350 safety analysis principles, he said, and his company's PRISM reactor design are "very much in concert" with those.
In October 2010, Savannah River Nuclear Solutions signed a memorandum of understanding with GEH to jointly explore the development of a PRISM reactor at the DoE's Savannah River Site in South Carolina. In November 2011, GEH proposed to build its PRISM at Britain’s Sellafield nuclear site and the UK's Nuclear Decommissioning Authority said in January that GEH’s sodium-cooled reactor technology is a "credible option" for managing the UK's plutonium stockpile.
Mundy said the NRC has not licensed an SMR but the design NuScale Power is developing is based on "tried and true" 50-year-old technology, but "whatever regulator you are dealing with, you need to make sure that you give them a full and complete application so they can do a thorough and timely review of it."
Fox added that "there are quite a few safety case analyses"” that are not required in an SMR that may be required in a large reactor. There are obvious differences in scale with, for example, control room staffing, emergency planning zones, and loss-of-coolant accident (LOCA), he said.
It would be an advantage if the ONR modified its Generic Design Assessment (GDA) to suit SMRs. In the USA, mPower has its "design specific review standard", a deviation from the standard review plan on which the NRC licensed all prior large reactors. "I think it would be advantageous for the UK to adopt a similar type of approach," he said.
Licensing experts at NuScale Power "“are advising that because the UK process is very performance-based that it should be processed similar to what we will experience ultimately to get through the NRC's review of the application," Mundy said. There would be "greater efficiency and benefit"” if the two organisations could collaborate on their examination of the same technology.
"It is the first time in a generation where the UK can be on the front foot"
Dame Sue Ion
Chair, Nuclear Innovation and Advisory Board
Loewen does not see the need to change the GDA process "per se". "The ONR has a great history of licensing a wide variety of technologies. They also work on the military technology, so I think they have that skillset to be able to enter in with the current process that they have," he said.
Representatives of the ONR visited mPower’s design centre and testing facilities in Lynchburg last November, Fox said. "I think they are getting an appreciation for the challenge as far as what the resources they may need. I cannot address their capacity to address those needs," he said.
Asked why it takes about five years to license a new reactor design, Fox said, there is certain timescale before a company submits a licence application and then regulators "will want two, three or four years to do the review."
The NRC is committed to trying to review and approve design certification applications within 39 months "on the premise", Mundy said, that it receives a full and complete application. "What that means is debateable but they have established a very extensive process that takes a lot of time, not only for them to review it, but to prepare the application to make it full and complete takes several years before you are in a position to submit it," he said. One of the things that "“drives the process" in the USA is the activities associated with public comment and intervention, Mundy said.
Loewen said that "it is best in the nuclear industry to be second" in terms of licensing. "It is like the Tour de France, you do not want to lead the whole way. So what we need to do, when we look at the licence or the big reactors in the United States and the GDA process in the UK, find out what the regulatory agencies did not like so that when we submit our application it is a quality submittal that addresses those sorts of thing," he said.
Dame Sue Ion, chair of the UK’s Nuclear Innovation and Research Advisory Board, agreed there is scope for greater collaboration between the UK and other countries.
"It is difficult to see how we could do an SMR from scratch ourselves. Clearly it is possible but, in terms of the cost and the time that it would take to do that, we are starting from behind. The Americans have already pumped hundreds of millions of dollars, both corporate investment and state investment, into moving the SMR projects along. Other nation states are also with their governments financing small modular reactors design, with the intention to deploy," Ion said.
Fiona Rayment, director of Fuel Cycle Solutions at the National Nuclear Laboratory, said there is a real opportunity to "bring best practice together" to streamline processes, both through key vendors working with various manufacturing organisations and by looking at the whole regulatory regime. A number of SMR units "that are being offered up at the moment" are still going through the design phase, she said. Any new technology "needs to get beyond first of a kind before you can start to determine how economic it is," she said.
SMRs still have some way to go before completion of detailed design work, Ion said, "which is why there is always a trade‐off between when do you submit for a licence assessment or not because the more design that you have done the easier it is from the point of view of the questions back and the adjustments that you might have to make."
The "alternative", Rayment said, is "to do the full design upfront and then push that through," but then there is a "risk associated with the vendor in terms of how much time and effort they would need to put in before engaging the regulator in terms of how that design could be applied within a particular country."
The UK regulatory system is flexible and goal oriented, and not "tick-in-the-box based," Ion said.
"One of the real benefits of the opportunity that SMR gives us now is that they are going through licensing in the United States to design and, therefore, there is an incredible opportunity for the two regulators to work together with respect to global regulation of this particular type of technology. It is the first time in a generation where the UK has got an opportunity to be there and on the front foot, especially if a first deployment were to occur here in the United Kingdom. It would give us an enormous competitive advantage as a nation on the global stage," she said.
Ion is working on an SMR feasibility study for government. She told the committee an interim report on that study will be completed next month. The study is a project set up by the Department of Energy and Climate Change and the Department for Business, Innovation & Skills. Companies involved in the report to date include, she said, Atkins, Rolls-Royce and Amec, together with the National Nuclear Laboratory, which is leading on the project. The project has no international partners so far, she said, "because the purpose of the study is to examine the potential of SMRs for the UK by looking at whether there is genuinely a global market for SMRs, what the route to market in the UK might well be, what the options are in terms of technology, realistically, and where the opportunities are for capture of UK manufacturing capacity and intellectual property."
Researched and written
by World Nuclear News