SMRs/NuScale
The real SMR problems have not even been mentioned in any discussion of the SRM’s future potential to be viable. Or if they have been discussed, I’ve never seen it. The June 5, 2015 NRC letter from Michael Mayfield (NRC) to Dale Atkinson (NuScale), ML15146A088, was a start, but a strange one indeed. The crux of that letter, under the guise of future Design Certification review schedule delay, was that certain “features” firmly embedded in the NuScale SMR design are considered by NRC Staff to be more policy issues than technical issues. These features were described in the letter. As such NRC Staff is implying that NRC Staff will likely not be able to decide these issues, rather it will have to be elevated to the full Commission for resolution likely affecting (delaying) the Design Certification review schedule. A very strange attitude indeed from NRC Staff; as they recognize a potential problem within their own organization but put the onus (initiative) of getting it resolved on a paying customer.
But a more difficult, and potentially “show stopper” issue with SMRs in general is here:
QUOTE
10CFR50.54(w) Conditions of licenses
“Each power reactor licensee under this part for a production or utilization facility of the type described in §§ 50.21(b) or 50.22 shall take reasonable steps to obtain insurance available at reasonable costs and on reasonable terms from private sources or to demonstrate to the satisfaction of the NRC that it possesses an equivalent amount of protection covering the licensee's obligation, in the event of an accident at the licensee's reactor, to stabilize and decontaminate the reactor and the reactor station site at which the reactor experiencing the accident is located, provided that:
(1) The insurance required by paragraph (w) of this section must have a minimum coverage limit for each reactor station site of either $1.06 billion or whatever amount of insurance is generally available from private sources, whichever is less.”
END QUOTE
Now I’m just an ex-operator but even I can understand, even if the NuScale SMR design gets certified (at the current proposed NuScale licensed operator manning level), the next step is finding a customer for the design. Or all has been for naught. And I am also a shopper, so I know before I commit to buying something (with the exception of health care services) I want to know what is the initial-up-front-cost and what are the continuing costs (O&M) of ownership. My current understanding of NuScale’s proposal is a buyer of a twelve reactor NuScale unit will apply for a COL for one NRC license, not twelve. But is that going to fly? If I’m a buyer I want to know in advance what is my annual NRC license fee; one fee or twelve?
Granted this is an issue for a potential licensee, not a “Design Certification” issue. But in the grand scheme of all things SMR is it an issue that will likely need full Commission approval? My guess is yes. But I guess we have an “excuse” for not addressing it at the full Commission level at this time. Probably a good thing, as the full Commission is still operating on four Commissioners at this time, so a split vote is still possible on any policy issues. But for a potential SMR multi-unit buyer this is a substantial issue as the continuous yearly NRC License fee is a significant O&M budget cost. For a twelve unit NuScale design generating 600MWe, having to pay twelve NRC License fees may be a show stopper. What exactly is “in it” for the NRC to approve one license, and thus one license fee for a twelve reactor site? If it is OK for NuScale then why isn’t it OK for the Palo Verde three unit station? At least in theory a license fee should reflect the level of effort required by NRC to regulate a reactor. Except in actual practice it doesn’t. It is based on the current year annual approved NRC budget, times 90% (recoverable expense, required by law), divided by the number of reactors being regulated. Are twelve reactors more work for NRC than one, regardless of reactor size? Again, what is in it for NRC to accept one license for twelve reactors?
But the insurance issue required by 10.CFR50.54(w) is even messier for a potential twelve unit NuScale buyer. Currently the required insurance is supplied by Nuclear Electric Insurance Limited (NEIL), a private insurance company. Except is not really a “private” insurance company, it is owned by the current fleet of nuclear generating electric companies. As such the NRC doesn’t really have any say over NEIL policies other than acceptance of NEIL participation by nuke utilities complies with the requirements of 10CFR50.54(w). Even if the full NRC Commission approves one license for a NuScale twelve reactor unit site, will NEIL recognize it as one reactor for insurance purposes? I think insurance companies make decisions based on total risk, not the number of paper licenses issued. And what if NEIL (really the other nuclear utilities) decides a potential NRC approved reduction in Licensed Operator staffing levels (and other potential policy issues) is “risky”, to the point of requiring one NEIL membership per NuScale reactor? After all the more NEIL member licenses there are the cheaper everyone’s annual insurance premium will be. So what exactly is the benefit to a current NEIL member to agree allow a potential economic competitor to run twelve reactors for one insurance fee? It seems final resolution of this issue might affect the future O&M budget of a multi-unit buyer.
Again, thinking like a potential buyer of a multi-unit SMR, I want to understand future costs before I commit to buy. There is a not-so-hidden O&M cost in participation in NEIL; namely you have to pay “ransom” money by participating in INPO in order to be eligible to partake of the NEIL insurance pool. Now back in the day when INPO was formed you could pretty much swing a dead cat in any direction and hit something needing improvement, despite the fact there was an NRC. INPO has done a great job; the plant operating records speaks to the effectiveness of doing it the INPO way. But it wasn’t really ever the INPO way at all! It was the navy way. And “back in the day” there were plenty of ex-navy nukes in commercial nuke power, including very high staff positions at most plants, who understood how to do the navy way, but we were constrained by corporate controlled budgets for “just another power plant.” I’ll give INPO credit where credit is due; they facilitated getting done what we knew needed to be done, but couldn’t get done on our own. But to think INPO saved nuke power is a myth. We saved it, they facilitated getting done what we knew needed to be done.
When I look at the staffing levels of some economically troubled plants I don’t see a huge per MWe variance between the older ~600MWe units and the newer 1000+ MWe units. So something other than MWe size is driving the total site staffing levels. One of NuScale’s selling points is supplying a small size unit, near the demand (including process heat), to eliminate costs like transmission infrastructure. If I want to buy a single NuScale “module” site unit consisting of four reactors am I going to need a full 1000+ MWe site staffing level just to implement INPO (and NRC) required programs? Forget it, I can’t make money at 200 MWe! Hey INPO, here’s a news flash… your motto of “striving for excellence” has been achieved. If you applied that motto to yourself, you should be gone. It’s not like “your way” is a secret that you need to constantly tell us, it has three decades of documentation. As a potential buyer of a multi-unit SMR my guess is the INPO overhead will end up being based on per reactor not per site, just implementing and tracking the required INPO paper. And are the current INPO participation fees based on per site or per reactor?
I don’t want to sound like I’m picking on NuScale because I don’t intend to. I actually like and am encouraged by their NSSS design. I’m more looking at the potential marketing issues for any of these proposed multi-unit SMR designs. The issues I cite above are potential marketing issues for any SMR (but only in a US market). In order to turn any NRC certified paper reactor design into a working plant you need an actual buyer. Who’s willing to write a blank check for a FOAK unit, especially a one module 200MWe unit, if the future O&M budget based on site staffing levels, insurance, and NRC license fees is going to be similar to a fully capitalized experienced crew Kewaunee or Vermont Yankee plant? It’s not going to be that way you say? Oh, who’s working on those issues or in who’s house should the discussion start, I want to talk with them.
More specific to the potential NuScale design I see a couple technical (with policy overtone) problem issues that I have not seen discussed to date. Namely if someone buys a one-unit four reactor “module”, with no intent to ever expand it to the three-module twelve reactor site; how many control room designs is NuScale proposing and certifying? Do I have to buy a control room designed for the full potential site scope? And that also comes right back to affect the Licensed Operator manning, which is based on the twelve reactor site. What’s the proposed manning for a four reactor site? Even at very reduced Licensed Operator manning levels, these days the required training, Licensed Operator requalification, plant specific training simulator, etc. staffing levels may have to be larger than the operator staff. That is all part of long-term O&M. And I still have seen no discussion in the public NuScale documentation of plans for a Remote Shutdown Facility (for control room evacuation). Does a plant that is “walk away safe” not need one? Again, these issues affect the whole concept of SMR viability.
