A year into new plant licensing, NRC and industry look to future

The use of standardized designs for licensing and construction of anticipated new US nuclear units presents challenges but also offers the benefits of streamlining NRC reviews and better allocating project risks, NRC and industry officials said at a nuclear power conference last month.

"Using a certified design and obtaining an early site permit would maximize the benefits of the new licensing process and contribute to an effective and predictable licensing process," NRC Chairman Dale Klein said July 24 at the Global Nuclear Renaissance Summit in Alexandria, Virginia, sponsored by ExchangeMonitor Publications and Forums.

"However, so far, only one of the five designs currently being referenced in the COL applications -- the Advanced Boiling Water Reactor at the South Texas Project -- is a certified design and it is only referenced in one COL application," Klein said.

Klein reiterated that NRC would not be the "stumbling block" in the licensing process. But there is the possibility that some design certification rulemakings may not be completed before the reviews of some of the first COL applications that reference those designs, Klein said. If that occurs, it may be necessary "to hold open some unresolved issues" in hearings on those COL applications. Those issues would be resolved outside the hearing process in the design certification rulemakings, he said.

David Matthews, director of the division of new reactor licensing at NRC, said that COL applications are "improving over time" but changes in designs now undergoing certification review have led to "rework and extending schedules." Incomplete applications and delays in application filings continue to "challenge" NRC staff resources and planning, he said.

As for new plant designs, schedules for certification reviews for the ESBWR and amendments to the AP1000 design "are being rebaselined" because of changes made to those applications, Matthews said.

Marilyn Kray, president of the industry consortium NuStart and vice president of new project development at Exelon, said in her presentation at the summit last week that both Westinghouse and GE-Hitachi "have been very responsive" to utility input on their standardized designs for the AP1000 and ESBWR, respectively. There has also been "excellent cooperation to date" among the NuStart members, she said. The goal is 65%-75% standardization, and so far there have been "minimal" design deviations from the reference COL application in subsequent COLs, Kray said.

Masahike Kaneda, senior vice president of Mitsubishi Nuclear Energy Systems, said that a COL application referencing his company's APWR design will be submitted to NRC in September for two new units at Comanche Peak. Some challenges faced by the project include "first-of-a-kind" issues, such as translating the plant's design and supporting documentation into English and transferring Japanese construction methods to the US. Other challenges include possible public opposition to the project, supply chain issues, and "uncertainty" in the areas of regulation, scheduling, and cost, Kaneda said. Despite these challenges, Kaneda expressed optimism about the potential for US-Japanese cooperation on new reactor projects.

Michael McGough, senior vice president of UniStar Nuclear Energy, emphasized the value of maximizing standardization "from the wallpaper to the carpet" because, "as soon as standardization starts to decay, so will some of the benefits you would expect to reap." UniStar selected Areva's EPR because at least two units of the design would be built overseas before the first US unit, McGough said. Also, design features such as enhanced protection against aircraft impacts are "important when it comes time to talk to the public" about safety and security issues, he said.

UniStar, a Constellation Energy-Electricite de France joint venture, is negotiating an engineering, procurement and construction, or EPC, contract with Areva, and it is working on an application to DOE for a loan guarantee request, McGough said. He said he hopes that a decision will be made "in the next year" on whether to build a third unit at Constellation's Calvert Cliffs site in Maryland and that project would not move forward without a loan guarantee and favorable outcomes from state and local permit processes.

George Davis, Westinghouse's manager of new plant government programs, said that resolving design details "up front" means there will be a lessened risk of surprises during post-construction inspections. Some $400 million was spent developing and certifying the AP600 design, and additional $600 million has been spent so far on the AP1000, Davis said.

Some ways that risk can be "allocated" among the parties in an EPC contract, Davis said, include use of "target pricing" and references to commodity indexes instead of fixed prices and "pinning down" component specifications with "100% detailed specifications," Davis said. The key issue is to identify risks up front and allocate them to the entity in the project that is best able to bear those risks, he said.

Until recently, neither the industry nor NRC had anticipated the large number of simultaneous COL application submissions planned for the next few years, Davis said. But the advantage is that issues that arise can be "resolved once and for all, which leaves the minimum amount of risk after construction starts," he said.

Created: August 1, 2008

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