In a blog post on the agency’s web site, Deborah Jackson, Deputy Director, Division of Engineering Infrastructure and Advanced Reactors, explains what the agency has done so far, what it plans to do, and why public input is needed now.

Before a company gets down to the nuts and bolts of a reactor design, it has to consider the big picture of protecting the public. The NRC asserts in a blog post this week that it addresses this mandate through a combination of regulatory requirements and guidance. “General Design Criteria,” or GDC are a key part of the regulatory requirements. The agency says it is at the point where public input will help it develop Advanced Reactor Design Criteria (ARDC) for the next generation of advanced reactors.

The agency has come under considerable criticism by developers of advanced reactors for its slow progress and for forcing developers to go offshore first rather than spend huge amounts of money to pay for the agency’s learning curve at home.

A case in point is TerraPower which is building its first of a kind prototype in China. Even NuScale, which is developing a small modular reactor using conventional light water reactor technologies, says it expects to spent at least $400 million on safety design review and licensing of its 50 MW reactor. NuScale says it will submit its design to the NRC for review later this year.

Some developers of advanced reactors have no intention of trying to get the NRC’s “gold standard” review. Simon Irish, the CEO of Terrestrial Energy, a Canadian firm, told this blog in an interview there are night and day differences between the way the Canadian Nuclear Safety Commission approaches nuclear safety and that of the NRC.

Irish praises the Canadian Nuclear Safety Commission which he notes “uses a graduated risk assessment model.”

“It creates less work for us, Irish said, and he added, “it helps us address a lot of the realities of meeting regulatory requirements in the shortest possible time.”

See also the post on this blog describing the proposals of the Nuclear Innovation Alliance to reform the NRC’s regulatory approach to advanced reactors.

NRC working with DOE

The current GDC concepts at the NRC include protecting against severe natural events and putting multiple barriers between radioactive material and the environment. Designers and operators use that basis for designing, fabricating, building, testing, and operating a reactor’s safety-related equipment. The NRC says it is now moving towards adapting the GDC so that it can conduct safety reviews of these new advanced designs.

The NRC reports that it has been working with the Department of Energy on this issue since 2013. At its initiative it has examined where the GDC could apply to advanced designs, and where new or revised criteria make sense.

A DOE report from late 2014 parts one and two) lay out Advanced Reactor Design Criteria, which could fill the GDC role for non-light-water-cooled reactors. (Note to readers: Parts 1 & 2 are both pieces of the same document broken into two PDF files.)

In the report the DOE set out criteria independent of any specific technology, but also specific criteria for reactors cooled by liquid sodium or an inert gas. These ARDC will not be binding requirements.

The NRC has asked DOE additional questions while developing draft regulatory guidance on the ARDC. This is the first step in strategically preparing for the review of non-light-water reactor applications.

The preliminary draft of the ARDC will provide stakeholder insight into the NRC staff’s current views on how the GDC could be interpreted to address non-light-water reactor design features. Ultimately, a risk-informed, performance based advanced non-light water reactor regulatory framework is envisioned by the agency.

A specific question the agency says it is looking at involves whether NRCs generic criteria are broad enough to cover the spectrum of designs being considered. It is also asking whether the proposed criteria appropriately address some new concepts described in DOE’s documents.

No timetable to complete the new GDC

The NRC has not announced a timetable for completing this work. Congressional funding would be needed as a line item since the agency cannot pay for this kind of forward looking activity out of the pool of licensing fees it collects from operators of the current U.S. fleet of reactors. The outlook for such funding is uncertain and the agency is cutting money and staff (-185 FTE: -$49 M) across the board this year and next.

It creates a risk that by the time the agency has gotten itself ready to do safety reviews of new designs, frustrated developers, and their investors, will have taken their work, and the jobs that they would have created, overseas.

It is up to Congress, having passed policy level legislation about the agency’s regulation of advanced reactors, to put its money where its mouth is. It must fund the work of change management with regard to the way the NRC conducts design reviews of new reactors and the overall licensing process.

NRC / DOE Joint Conferences on Advanced Reactors

Last September the NRC and DOE held a jointly sponsored conference on advanced reactors. The agency posted presentations from the 1st workshop on its web site. A second workshop is planned for June 7-8 in Rockville, MD.

Comments due by June 8

Public comments, which can also be sent to AdvancedRxDCComments.Resource@nrc.gov, will be accepted through June 8. After the NRC addresses these initial public comments, a draft regulatory guide will be developed and published in the Federal Register for public comment.

You can find detailed information on the best way to submit comments on the agency’s website. Comments are due by June 8th.

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