Anna Bradford, Chief
Advanced Reactors and Policy Branch
Office of New Reactors
We’re continuing to examine topics from the recent two-day public workshop we jointly hosted with the Department of Energy regarding non-light water reactor designs. One topic getting a lot of attention is the possible costs for NRC reviews of applications for these designs.
For instance, some people interpreted a DOE presentation on the Next Generation Nuclear Plant project as saying it costs $800 million to receive a final certification or license from the NRC. The bulk of that $800 million, however, falls outside of NRC fees and would be made up of the designer’s costs to develop and test its design to ensure that it works as planned.
In other words, the designer does not pay the NRC $800 million to review a reactor design. Looking at recent reviews of large light-water reactors, we see designers spent approximately $50 – $75 million for NRC fees to certify their designs.
A recent Government Accountability Office assessment, “Nuclear Reactors: Status and Challenges in Development and Deployment of New Commercial Concepts” says costs can be “…up to $1 billion to $2 billion, to design and certify or license the reactor design.” A different portion of the GAO report, however, pointed out most of these costs aren’t attributable to the NRC review. The largest part of the price tag would be research, development, and design work to develop and test a new reactor design.
We can also examine information from the public workshop on design development costs versus NRC review costs for the developer of a new small modular reactor design. The company said that of approximately $300 million in design investment to date, only $4 million of that amount (or slightly more than 1 percent) is from NRC fees for several years of pre-application interactions with the agency.
Here’s something to keep in mind: NRC review costs depend on the quality and maturity of the applicant’s information. The NRC always aims to efficiently and effectively review designs. Incomplete or inadequate information will very likely increase costs, however, since the NRC will spend more time and effort getting the data necessary to determine whether the reactor could operate safely and securely.
Everyone benefits from a common understanding of NRC costs as we discuss the next generation of reactor designs. The NRC’s website has more information on how the agency is approaching advanced and small modular reactor designs.
We regularly interact with various audiences from the media to the public and one question pops up often: Why does the NRC use colors to discuss issues found at a plant and what does it all mean?
The quick answer is that color-coding is a lot more understandable to people outside the agency than trying to interpret a probabilistic risk calculation of core damage frequency of 10-5. (The NRC uses probabilistic risk in assessing the potential safety significance of nuclear safety issues and plant performance indicators so inspections focus on those plant activities that could have the greatest impact on safety.)
The colors we use — green, white, yellow and red — are used to prioritize the findings with greater safety significance. A more risk-significant issue is called a red finding and that will move an operating plant into our highest category for oversight followed by thousands of extra hours of inspection. An example would be a failure in a key safety-related component.
A green finding might be given when an inspector finds that one of 10 bolts on a valve is looser than the others and should be tightened. While it may not sound like a big deal, the NRC has high standards for safety and a low threshold for issues.
White and yellow findings are medium risk. In 2015, 428 green findings, 13 white findings and two yellow findings were issued. An example of a yellow finding was one given for seals that were not adequate to protect a room housing electrical equipment from flooding. An example of a white finding was for improper maintenance that resulted in a failed emergency diesel generator fan belt.
Who decides the colors? Initially, the inspector determines the safety significance and assigns a tentative color. A green finding may not require additional analysis. But with the higher colors, there is a detailed assessment that could involve NRC risk experts and, in some cases, a discussion with the plant operator to obtain more information.
The final outcome of the review — evaluating whether the finding is green, white, yellow, or red — will be used to determine what further NRC action may be called for, such as moving a plant up in the columns that comprise the NRC’s performance “Action Matrix.” When poor performance lands a plant in one of these higher oversight columns with increased inspections, it takes a lot of hard work to return the plant to a better standing.