- Regulatory engagement plan will help reactor developers’ early interactions with NRC staff
- Such plans can reduce regulatory uncertainty, add predictability to licensing advanced technologies
- NEI developed the guidelines with input from the industry and NRC, and support from Nuclear Innovation Alliance
The Nuclear Energy Institute has issued a document offering advanced nuclear reactor developers guidance on how to engage with the Nuclear Regulatory Commission as they prepare pre-licensing and licensing interactions with the regulator.
The U.S. nuclear industry is currently enjoying significant interest in advanced nuclear technology development. As noted by organizations such as The Third Way and the Clean Air Task Force, there are dozens of organizations—ranging from innovative venture capital startups and established nuclear companies to government research establishments—currently working on innovative reactor designs.
These designs offer the potential for lower construction and operating costs, the capability for rapid modular manufacture and deployment, enhanced safety and operational efficiency, and more efficient use of fuel resources. While existing nuclear plants are best at producing near-constant baseload electricity, many advanced reactors promise more versatile applications. They could more easily operate in “load-following mode,” adjusting their output as needed to a future electric grid with substantial amounts of intermittent wind and solar power. Many advanced reactors operate at much higher temperatures and thus could also provide high-quality process heat for the chemical, refining, food processing and steel industries, as well as for applications like large-scale desalination and hydrogen production.
Many of these reactor designs are based on different coolant choices such as gases, molten metals or molten salts. The designs and their operating characteristics are radically different from the large light water-cooled reactors currently in use in the U.S. and worldwide. As a result, both the industry and the NRC are preparing for necessarily different licensing and regulatory processes.
So far only one advanced reactor concept is in review with the NRC—NuScale Power filed a design certification application for its 50-megawatt integral pressurized water reactor design on Dec. 31, 2016. Even based as it is on proven light water reactor (LWR) technology, pre-application interactions with the NRC were not as effective as desired, taking more than eight years and costing $12 million in regulatory fees.
Other pre-application interactions with several advanced non-LWR developers are ongoing with the NRC.
Given the large differences in these new reactor designs from the existing LWR fleet, as well as wide variations in the extent of development of each design, NEI’s ”Guidelines for Development of a Regulatory Engagement Plan” (NEI 18-06, Rev. 0) recognizes the need for early interactions between NRC staff and prospective reactor developers, vendors or site applicants. The guideline proposes steps toward developing a plan with the purpose of enhancing communications and decision-making and in doing so minimizing regulatory risk in an overall program to develop and deploy new reactor technologies.
“Such licensing interaction and guidance early in the design process will contribute towards minimizing complexity and adding stability and predictability in the licensing and regulation of advanced reactors,” the NRC noted in its 2008 policy statement on the regulation of advanced reactors.
NEI’s guideline provides suggested topics for a prospective NRC applicant to consider in developing a Regulatory Engagement Plan (REP), as well as outlining supporting information associated with the suggested topics. It notes that there is no regulatory requirement for a REP, and that the topics and appropriate level of detail a prospective applicant would wish to include are entirely voluntary and should be agreed upon in discussions between the applicant and NRC staff.
”The development of the REP is an important accomplishment in NEI’s activities toward creating a stable and predictable licensing framework for advanced reactors,” NEI Senior Director for New Plant, SMR and Advanced Reactors Mike Tschiltz noted. ”The support from the Nuclear Innovation Alliance in getting the document finalized was very helpful.”