ML24295A113
| ML24295A113 | |
| Person / Time | |
|---|---|
| Issue date: | 10/16/2024 |
| From: | NRC/EDO |
| To: | Michele Sampson, Mark Yoo Office of Nuclear Reactor Regulation |
| References | |
| Download: ML24295A113 (1) | |
Text
From:
ADVANCE-Act Resource To:
Michele Sampson (She/Her/Hers); Mark Yoo Cc:
Subject:
FW: Response from "Contact Us About the ADVANCE Act of 2024" Date:
Wednesday, October 16, 2024 7:23:09 AM Good morning, Michele and Mark,
The message below was submitted to the Contact Us form of the public ADVANCE Act page in regard to Section 401. Providing for your consideration in implementing the Act. We are under no obligation to provide a specific or detailed response to submissions.
-Aaron
From: do-not-reply@nrc-gateway.gov <do-not-reply@nrc-gateway.gov>
Sent: Monday, October 14, 2024 9:17 AM To: ADVANCE-Act Resource <ADVANCE-Act.Resource@nrc.gov>
Subject:
[External_Sender] Response from "Contact Us About the ADVANCE Act of 2024"
ContactUsID: 6775 ContactUsNotificationRecipient: ADVANCE-Act.Resource@nrc.gov ContactUsNotification
Subject:
Response from "Contact Us About the ADVANCE Act of 2024" Category: New Technologies ContactUsDocumentTitle:
ContactUsNumberTitle:
Question or Comment: Purpose The Breakthrough Institute seeks to provide clarification to the NRC on the relevant provisions within the ADVANCE Act, particularly those related to rapid improvement and iterative innovation processes for nuclear energy projects. This memo outlines the intent of Section 401 as discussed and established during the development of the ADVANCE Act, ensuring consistency with the objectives agreed upon by key stakeholders. The goal is to provide the NRC a guide to interpret and operationalize these provisions, identifying potential regulatory issues or requirements and associated impacts, to enable innovation. (c)
Contents (1) IN GENERAL.The report shall (A) examine any unique licensing issues or requirements relating to the use, for nuclear energy projects, of- (i) advanced manufacturing processes; Definitions Rapid improvement - The ability to implement improvements quickly to in-process or subsequent units. Changes may be applied to units that are in the production
stage when necessary or optimal. Iterative innovation processes - A process that achieves innovation by optimizing a design or process across multiple units in a series. This process is characterized by refinement and improvement through updates to a design across multiple versions or generations. (ii) advanced construction techniques; and (iii) rapid improvement or iterative innovation processes; Rapid improvement and iterative innovation are common processes for learning by doing associated with technological learning rates. These processes are part of a core design approach to high-volume manufacturing that allows for further innovations (i.e., airplanes, cars, reusable rockets). Major design characteristics are generally maintained while further optimizing the design. It is important to note that rapid innovation and iterative improvement, while often considered part of research and development, can extend well into production. This continued optimization and learning post-construction can yield significant cost savings and performance enhancements. Why This Matters Opportunities to refine and improve reactor designs are often identified when the design is tested in the real world when manufacturing, constructing, and operating. The ability to apply lessons learned to subsequent units or phases can lead to considerable gains in efficiency, whether that be in licensing, manufacturing, construction, or operation. There is potential to incorporate innovations as soon as they are identified, enhancing both safety and performance. When multiple units are developed in parallel rapid deployment of innovations would be applied at a variety of project phases. The potential deployment of new nuclear energy technologies with smaller units in a higher-volume production paradigm increases the opportunity for iterative innovations (i.e., the newest Boeing 787 is not the same as the first one built). This is contrary to historical practices where a single project was fully completed, followed by a multi-year lessons learned review before a later project was initiated. Key Considerations for the NRC The ADVANCE Acts provisions necessitate careful consideration within the current licensing frameworks and draft Part 53. The NRCs interpretation of these provisions is critical to their successful implementation. By aligning its regulatory processes with the goals of the ADVANCE Act, the NRC can support developers in deploying advanced reactors more eefficiently while maintaining safety and reliability. The prescriptive nature of Parts 50 and 52 creates unnecessary hurdles. The NRC encourages standardized nuclear power plant designs to help enhance safety and improve the licensing process.1 The current regulatory approach emphasizes licensing a single common design to reduce approval time and uncertainty; a core component of improving licensing efficiency under Part 52. This pathway offers developers the assurance of a certified design that can be replicated with minimal regulatory risk, as long as the reactor design is identical. 1New Nuclear Plant Designs, NRC Oce of Public Aairs, Page 1 https://www.nrc.gov/docs/ML0402/ML040220421.pdf However, many developers have expressed concerns about the rigidity of Part 52, particularly regarding the requirement for a completed, finalized design. Even the NRC has identified that switching from the Part 50 framework to the Part 52 framework with a standard design may result in delays because a
Part 52 application would require a completed and final design. This is why a significant number of license applications are opting for the Part 50 framework for new projects, as it allows for more flexibility during the manufacturing and construction phases to accommodate innovation and design adjustments. Potential Issues and Challenges 1. Limiting Iteration: a.
Current regulatory requirements limit iteration. As such, successive optimization on standard designs is limited by additional time, cost, and regulatory risk. b. Specificity is required in a licensing application that may be limiting to rapid innovation or iterative improvements.
Regulatory requirements can limit the substitution of components with equivalent or superior alternatives. This restrictiveness discourages innovation and results in higher costs, especially in existing plants where identical replacements for outdated parts must be custom-made. 2.
Hindering Innovation: a. Some manufacturing and construction phase improvements, particularly those aimed at error reduction and rework minimization, could be applied to future projects without further regulatory approval. However, more substantial design changes or innovations often require license amendments, adding complexity, time, and cost. b. For example, if an innovative safety feature or a more efficient system component is identified after licensing, it may necessitate regulatory re-approval, impacting timelines. 3. License Amendment Request (LAR) Procedures and Timeline: a. Timelines and costs to submit and process a LAR for design changes create additional barriers for a developer. The scope of a standard or certified design restricts the ability to introduce cost-effective improvements to subsequent plant designs or license applications. Clarity on when LARs are required will reduce applicants submitting unnecessary LARs intended to mitigate regulatory risk, which will reduce resource needs for both the applicant and the NRC b. A streamlined LAR process for small-impact changes could reduce resource needs and enable more innovation. 4. Regulatory Process Inefficiency: a. The efficiency of the regulatory process (its timelines, direct and indirect costs, and clarity) affects the ability to rapidly introduce innovative designs.
Developers often encounter challenges when trying to balance regulatory compliance with innovation, especially when navigating ambiguities around when or if additional regulatory approval is required. b. Developers have to weigh estimated time, cost, and regulatory risk against the potential value of an innovation to the design 5. Performance-Based Regulation: a.
The extent to which prescriptive or deterministic requirements may limit rapid improvements or iterative innovation compared to performance-based requirements. b. The potential for regulatory resource reduction for design changes that meet the same performance objective.
- c. The potential to reduce the need for license amendments when performance objectives are met despite design changes d. The potential for design changes that do not deviate from performance objectives in a performance-based rule, including proposed Part 53.1470, to be considered an identical design (common design). Recommendations for the NRC Under Section 401 of the ADVANCE Act, the NRC is tasked with preparing a report on advanced methods of manufacturing and construction for nuclear energy projects. This report should address potential improvements in efficiency and cost reduction during power plant
construction. The report must clarify how to balance these two pathways: facilitating improvements that can be implemented without regulatory delays while identifying when license amendments are necessary for more substantial innovations. Improvements identified during the manufacturing of construction phase often face challenges, including: Ensuring that any changes during construction still conform to the facilitys licensed design.
Determining when a license amendment is required to address design changes or issues that arise during construction. The NRC must provide guidance on these areas, defining when license amendments are needed and ensuring that processes are efficient and predictable.
With this clarification, the NRCs report should offer detailed guidance on how to apply said ADVANCE Act provisions to ensure that nuclear energy projects can benefit from innovation and lessons learned in real-time without unnecessary hurdles. *** BTI appreciates the opportunity to express our thoughts and to comment on Section 401 of the ADVANCE ACT to the NRC Sta. Sincerely, Dr. Adam Stein Director, Nuclear Energy Innovation The Breakthrough Institute Joy Yue Jiang Nuclear Energy Innovation Analyst The Breakthrough Institute Spencer Toohill Nuclear Energy Innovation Analyst The Breakthrough Institute Would you like to remain anonymous?: False Name: Joy Jiang E-mail: joy@thebreakthrough.org Organization: The Breakthrough Institute Address: 923 15th St, 3rd floor City: Washington DC State: DC State:
ZIP/Postal Code: 20005 Country: United States of America Phone: 5718676083 ContactUsCaptcha:
Form inserted: 10/14/2024 2:16:35 PM Form updated: 10/14/2024 2:16:35 PM