- NRC requires unnecessary levels of detail in its licensing reviews
- Slow, cumbersome, costly reviews could discourage U.S. innovators
- NEI recommends NRC use risk insights, focus on safety-significant items
The licensing of advanced reactor designs must be tailored to account for the inherent safety characteristics of those designs, the Nuclear Energy Institute said this week.
NEI’s paper, “Recommendations for Enhancing the Safety Focus of New Reactor Regulatory Reviews,” was transmitted to the U.S. Nuclear Regulatory Commission as a follow-on from a January 2018 joint letter from NEI, the Nuclear Innovation Alliance and the U.S. Nuclear Infrastructure Council, which sounded a warning about the need to streamline the NRC’s regulation of new and innovative advanced reactor technologies.
Last month NEI also submitted a set of general recommendations on how the NRC could focus its Transformation Initiative to achieve a more risk-informed, agile, predictable and results-driven regulatory framework. NEI’s new paper provides additional insights for transforming the agency’s processes and regulatory culture.
The new paper provides more details of lessons learned from the industry’s interactions with the NRC on its reviews of new reactor projects under 10 CFR Part 52. It assesses new reactor licensing reviews, including information from an ongoing review of a small modular reactor, and provides recommendations on how the NRC can be more effective in adapting its reviews to account for the benefits of safer designs.
NEI urges the agency to focus its licensing reviews on areas that are safety-significant and reverse a demonstrable trend toward requiring increasing levels of detail in license applications—the paper provides specific examples. It also recommends using risk-informed principles to more systematically align the regulatory framework for advanced reactors to be commensurate with the inherent enhanced safety of those designs.
Without significant regulatory reform, U.S. advanced nuclear technology developers are likely to become discouraged about developing and deploying safer new reactor designs, putting at risk the future of nuclear technology in the United States and the nation’s role as a leader in technology innovation, NEI warns.
The assessment found that in spite of simpler and safer advanced reactor designs, the NRC has required the same if not more detail in its licensing reviews. The agency also is reviewing applications against redundant regulatory requirements and reassesses matters that previously had been approved.
In general, NRC staff tends to regulate to a standard “beyond that needed for reasonable assurance of safety,” NEI notes.
As a result, over the past 20 years the costs of NRC reviews have increased significantly—by more than a factor of four for design certification reviews and by a factor of three for early site permits.
“NRC reviews of these safer designs have not evolved to become more efficient. Inefficiencies only unnecessarily lengthen the NRC review time and cost … and the amount of information licensees must maintain over the life of the plant,” NEI said.
The unintended consequences of inefficient reviews are actually counter to safety and negatively impact the design, licensing and deployment of advanced reactors.
Voices across the policy spectrum, from Third Way and the ClearPath Foundation to the American Action Forum and the R Street Institute have identified the need for the NRC to undergo a transformative change in how it regulates nuclear technologies. They agree that not to do so is to risk the country’s future.