Former Nuclear Regulatory Commission (NRC) member Jeffrey Merrifield has called for a comprehensive new framework for advanced reactor licensing reform in an issue brief outlined at the National Press Club in Washington, D.C. on Feb. 23.
Merrifield, who served two terms with NRC, chairs the Advanced Reactors Task Force of the U.S. Nuclear Infrastructure Council, an industry business consortium. The Council is the founder and organizer of the Advanced Reactors Technical Summit, most recently held at the Oak Ridge National Laboratory earlier this month. Merrifield is a Partner with Pillsbury Winthrop Shaw Pittman law firm.
The NRC needs to develop a staged conceptual design review process for the review of Advanced Reactor designs similar to that developed by the Canadian Nuclear Safety Commission (CNSC).
The Canadian approach requires vendors to reach discrete milestones that allow investors to assess the technology’s potential for license approval and identify any significant concerns. It features an upfront vendor design review to provide an early verdict on the licensing feasibility of potential designs for less than $5 million (US), Merrifield said.
The early phases of this program would provide interim indications to allow the investment community to understand the “licensablity” of the design without having to wait until the end of the licensing process, which can take eight to10 years, the official said.
“It is time to make dramatic changes in the way we pursue, support and license Advanced Reactor technologies to achieve the full measure of their promise and the success the nation needs for the future,” Merrifield said.
Merrifield said a confluence of environmental and other issues are accelerating the need for the expedited development of advanced reactors domestically and worldwide.
“Deployment of this new generation of reactors,” he said, “will require a new model, one that is more dynamic and capable of forming private-public partnerships in support of private-sector innovation driven initially by private-sector investment,” Merrifield said.
“The current framework of U.S. government policy, legislation, regulation and requirements, research and development support, and fee-based licensing is more aligned with past development efforts than what is needed for the future to commercialize a new generation of Advanced Reactors,” Merrifield said.
The NRC licensing process, “presents one of the largest risk factors confronting private developers of Advanced Reactors as it does not accommodate a staged investment approach as the technology development and licensing risks are addressed and resolved,” Merrifield said.
Both the Department of Energy (DOE) and NRC must be proactive in developing their capabilities and engaging with the advanced reactor community, Merrifield said. An updated and modernized NRC design review and licensing process, added the former commissioner.
Among the specific reforms proposed in the licensing modernization framework are:
•A mandate for a 36-month advanced reactor licensing review by the NRC;
•General revenue funding to allow the NRC to waive the fees for the review of advanced units (such as molten salt, gas cooled) through their final design approval;
•Establishment of a phased design review and licensing process that would provide intermediate milestones towards a design certification that would include an early determination of “licensability;”
•Development of a risk informed licensing process for advanced reactors that recognizes their unique properties;
•Resolution of generic policy issues pertinent to advanced reactors within two years.
Merrifield said that the views expressed in his white paper “represent a consensus of the USNIC’s Advanced Reactors Task Force and the Council, but do not necessarily represent the specific views of individual member companies and organizations.”