ML24152A324
| ML24152A324 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 05/31/2024 |
| From: | Nichol M Nuclear Energy Institute |
| To: | Renee Taylor Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML24152A323 | List: |
| References | |
| Download: ML24152A324 (1) | |
Text
Marcus Nichol Executive Director, New Nuclear Phone: 202.316.4412 Email: mrn@nei.org May 31, 2024 Mr. Robert M. Taylor Deputy Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
NEI Concept Paper: "Regulation of Rapid High-Volume Deployable Reactors in Remote Locations" Project Number: 689
Dear Mr. Taylor:
The Nuclear Energy Institute (NEI)1 and its members appreciate the Nuclear Regulatory Commissions (NRC) efforts to establish a modern and efficient regulatory framework for new and advanced reactors consistent with the 2019 Nuclear Energy Innovation and Modernization Act (NEIMA). We also appreciate that the NRC is considering how to enable alternative business models in these efforts, while continuing to assure that public health, safety, and the environment are protected.
The purpose of this letter is to transmit a concept paper on the Regulation of Rapid High-Volume Deployable Reactors in Remote Locations to inform the NRCs work to prepare the regulatory frameowrk for advanced reactors. As discussed in this paper, many substantive changes are needed to create processes and alternative regulatory approaches to enable this business model. Our work to date indicates that this can be done in a way that provides reasonable assurance of adequate protection of the public health, safety and environment.
NEI identified that enabling alternative business modles is an industry priority in our May 12, 2024, letter to the NRC, NEI Input on Regulatory Priorities for New and Advanced Reactors (ML24043A249). In that letter we stated that the NRC may need to take more aggressive steps to modernize the regulatory framework to meet the varied carbon-free energy needs of the nation. Some current business plans envision widespread deployment of approved micro-reactors within a matter of six months.
1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
Mr. Robert Taylor May 31, 2024 Page 2 Nuclear Energy Institute Subsequently, Shepherd Power, in a February 14, 2024, letter to the NRC (ML24068A021), identified that they are pursuing a novel business model to enable rapid, high volume deployment of clean, reliable and affordable heat and power to oil and gas operations. In that letter, Shepherd Power identified micro-reactors as the best technical option for achieving their decarbonization and, aggregated together, imply a very large and immediate domestic market.the size and importance of this opportunitycannot be overstated. Shepherd Power has also stated, in their letter and in the May 14, 2024, public meeting (ML24130A196) that the Industrial Customers see licensing & regulatory uncertainty as chief risks, so much so that it is Impossible to have price and delivery conversations [with customers] based on the current state of regulation. Shepherd Power has identified two business case requirements relevant to the NRC regulatory framework that are necessary to enable the business model 1) takes no more than 180 days from the date a precise location is identified for a microreactor to the time it is deployed and operating and 2) the overall licensing and ongoing oversight costs need to be less than 1% of the total cost of manufacture and operations. Finally, Shepherd Power has been clear in the urgency for gaining clarity on regulatory feasibility, with the stated need of Sufficient clarity by the end of 2024 on a licensing pathway supporting scaled microreactor deployment.
Development of a regulatory framework for rapid high-volume deployable reactors for remote applications, which would meet the business case requirements identified for the oil and gas applications, could also enable business models for other industries that are hard to decarbonize. The market potential for nuclear energy in markets that would utilize this type of business mode could be in the multiple 1,000s of operating reactors by 2050. Therefore, enabling these business models is important to meeting the U.S. needs for more nuclear energy to achieve our climate, energy, environmental, economic, and national security goals.
The NRC has developed several papers on topics related to this business model, and NEI has also provided input to inform the NRCs work on those topics, including the following:
NRC SECY-24-008, Micro-Reactor Licensing and Deployment Considerations: Fuel Loading and Operational Testing at a Factory (ML23207A252)
NRC White Paper, Micro-reactors Licensing Strategies (ML21235A418)
NEI 2021 Paper, Manufacturing License Considerations (ML21197A103)
NRC SRM-SECY-23-0021, Proposed Rule: Risk-Informed Technology-Inclusive Regulatory Framework for Advanced Reactors (ML24064A039)
NEI Comprehensive Comments on Part 53 (ML22243A257 - 8/31/22) and (ML21309A578 -
11/5/21)
NRC SECY-20-0093, Policy and Licensing Considerations Related to Micro-Reactors (ML20254A363)
NEI 2019 Paper, Micro-Reactor Regulatory Issues (ML19319C497)
Mr. Robert Taylor May 31, 2024 Page 3 Nuclear Energy Institute The attached concept paper describe features of a notional business model that is being considered for such a class of rapid high-volume deployable reactors. Specifically, the paper discusses the technology capabilities, concept of deployment and operations, and the concept for an alternative regulatory approach. The focus of this paper is on the endpoint required to support the volume anticipated, not the steps to reach that endpoint. While it will eventually be necessary to outline the steps to be taken toward this endpoint (e.g., FOAK deployment, additional early deployments, etc.), the key issue at hand is whether it is feasible to deploy high volumes at the pace needed to meet the business needs. If that endpoint cannot be foreseen, then there is no purpose to pursue a journey toward that end.
To this end, the paper also discusses a set of 31 regulatory topics that would need to be addressed to enable the novel business model. These topics are framed by a topic discussion, desired outcome, and potential priority as it relates to enabling the business model. Of these 31 regulatory topics, about half have not been included in prior NRC papers, and of the topics identified in previous papers, many of those topics did not fully consider the concepts of this new business model. While others business models and permutations are possible, it is believed that this construct will be broadly applicable to the range of technologies and commercial strategies under development.
The NRC staff in the May 14, 2024, public meeting stated that they have plans to develop a paper addressing the regulatory topics related to the rapid high-volume deployable reactor business model later this year for the Commissions approval. The attached concept paper is written to provide input to the NRC paper by describing the emerging concepts for these alternative business models. NEI and our members are continuing to develop the concepts in this paper into a more detailed and actionable proposal paper that is expected to be submitted to the NRC around the end of July 2024. As these concepts are relatively new and cover a broad set of topics, NEI anticipates that NRC public workshops to discuss these concepts in more detail would foster mutual understanding and transparency to all stakeholders yielding more timely and well-considered alternative regulatory approaches.
If you have any questions concerning our input, please contact me, or Hilary Lane at hml@nei.org.
Sincerely, Marcus Nichol Executive Director, New Nuclear Attachment C:
Mr. Mohamed K. Shams, NRR/DANU, NRC Mr. Steve Lynch, NRR/DANU/UARP, NRC John Lubinski, NMSS, NRC Mirela Gavrilas, NSIR, NRC Susan Vrahoretis, OGC, NRC NRC Document Control Desk