This white paper provides an assessment of Part 52 construction experience to date. It concludes that adjustments can and should be made to optimize the change process and provide the flexibility licensees need to construct new nuclear plants. This would allow for changes that are expected and inevitable in such large and complex projects.
The white paper includes examples that illustrate how prior regulatory approval of departures have caused disruptions to construction and higher costs. The disruptions to construction took various forms, including work resequencing, shifting of resources, adjustment of priorities and delays to planned work.
Although the Part 52 process is fundamentally sound, changes in implementation are needed to provide the flexibility needed by licensees to construct the facility in an efficient way. The white paper recommends that NRC adopt an alternative approach that allows for ongoing reconciliation of the licensing basis during construction. Under this approach, licensees, as they do today, submit updates to their FSARs annually, and white papers on departures from the standard design certification every six months. The difference with ongoing reconciliation is that for emergent conditions, the licensee may, for a limited period, proceed at-risk with construction that departs from the licensing basis, while a required LAR is developed, submitted and reviewed by the NRC.