Comments Received on the NRC’s Vision Statement for Advanced Reactors

The core of the NRC’s draft vision statement is the creation of a “conceptual design assessment,” along with a staged standard design approval process.   Speaking to the conceptual design assessment, the draft vision statement advertises that the scope and cost of these assessments can be designated beforehand, and that it will be flexible enough to offer valuable input regardless of the level of maturity of the reactor design.  For less-developed designs, the conceptual design assessment could provide “regulatory observations” such as potential impediments to licensing.  On the other hand, for well-developed designs the NRC could provide something akin to a “preapplication safety evaluation report,” finding that “no obvious impediments” exist to licensing.  Turning to the staged review process, the draft vision statement explains that advanced reactor applicants in the future will be able to engage in a segmented review process for a Part 52 “standard design approval,” with “major portions” of a reactor being approved at different times.   Bringing it all together, the NRC posits that applicants could engage in preapplication activities with the NRC, then file for a conceptual design assessment, and then apply in stages for a standard design approval, lowering regulatory risk at each step in the process.

The NRC set a goal to introduce this regulatory approach by 2025.  Near-term (within 5 year) goals include building internal expertise, developing industry standards, acquiring computer tools, creating closer relationships with national labs, and identifying critical advanced reactor policy issues.  By 2025 these and other issues will theoretically have been addressed, allowing for the new regulatory framework to come into effect.  The NRC set a goal in the draft vision statement of having two advanced reactor designs ready for construction by the early 2030s.

Four parties submitted detailed comments on the draft vision statement: the Nuclear Energy Institute (NEI) (a nuclear power industry group), Transatomic Power and X-energy (two advanced reactor startups), and Idaho National Laboratory (a U.S. Department of Energy laboratory).  All four parties applauded the NRC’s efforts but raised many suggestions.  Three are worth special mention:

• Timeline: As expected, the three industry parties sought a faster timetable from the NRC, with NEI putting forward a revised timetable that would have advanced reactors under construction in the United States in the early 2020s.   They also argued that the inherent safety of advanced reactors should lead to reduced review times. What is surprising, however, is just how quick the reactor startups wanted the NRC to be ready—X-energy implied that the NRC should be ready for preapplication submissions 18-24 months from now.  Transatomic Power noted that even for an advanced reactor to be under construction in the 2030s, preliminary and detailed design will have started before 2025, and thus the NRC should have its regulatory process in place by 2021.

• Related Facilities: All four parties took issue that the draft vision statement did not lay out a framework for licensing fuel fabrication facilities.  Transatomic Power also argued that increased attention be paid to developing an expedited process for licensing test or prototype reactors, lest it hold back commercial reactor design development.

• Regulatory Certainty: Both NEI and X-energy sought more clarity as to the preapplication process and conceptual design assessment, stressing that both must result in meaningful and predictable results to justify their time.  Transatomic Power, however, went much further and actually suggested the NRC ditch the whole conceptual design assessment idea.  It argued that the process was far more intense than industry had called for, which was simply an analysis of licensing feasibility.  Instead, Transatomic Power preferred that the assessment be replaced with a direct analog to Canada’s “Pre-licensing Vendor Design Review” program.  In a related tack, Idaho National Lab suggested that the NRC create “checkpoints” to periodically reconnect with industry and make sure it is delivering something useful.

The NRC is seeking engagement from interested stakeholders as it starts to pay increased attention to advanced reactors, and this draft vision statement is just the start of the process.  For example, in just a few days, on October 11, the NRC is hosting a public meeting on design criteria for advanced reactors.  Proactive involvement by industry and the public, as exemplified by the commenters above, can add critical momentum to the NRC’s efforts and help drive this nascent field forward.

Authored by Amy Roma and Sachin Desai.