The U.S. nuclear regulatory body, the Nuclear Regulatory Commission (NRC), is arguably the international gold standard of nuclear regulation. It is important that the safety and security standards of the NRC be the guiding philosophy of our design and engineering efforts.
Gen4 Energy has researched the nuclear regulators of several foreign countries with regard to speed of ultimate licensing for the customers, similarity of regulatory approach, relative ease of obtaining U.S. Export permission, and other criteria. Based on this research, Gen4 Energy has determined that our initial client/s will be best served by licensing in either the U.S., the UK, or Canada. Accordingly, we contracted a study to examine and compare the timeline, regulatory approach, and other aspects of the three countries. The current nuclear regulations and regulatory documents for new nuclear power plants in the three countries are focused on large facilities, with only a few exceptions. However, to varying degrees all three countries’ nuclear regulatory agencies are supporting efforts by industry to bring small reactors into the nuclear renaissance. A brief summary follows:
The U.S. Nuclear Regulatory Commission (NRC) has two key methods for licensing of nuclear reactors:
- 10CFR50: a two-step process in licensing nuclear power plants:
- Construction Permit
- Operating License.
- 10CFR52, established in 1989, includes:
- Combined Construction and Operating License (COL)
- Early Site Permit and Limited Work Authorization
- Provisions for a non-site-specific reactor plant’s Design Approval, Design Certification or Manufacturing License, issued to the reactor vendor.
The Design Certification and Manufacturing License are of most interest to Gen4 Energy. These approval processes provide an NRC certification or license for a specific reactor design located at any generic plant site. Thus, with a Design Certification or Manufacturing License, Gen4 Energy could provide a shorter and less expensive COL process to a power plant owner.
Beginning in October 2009, the NRC has held several workshops on small reactor licensing and meets regularly with Nuclear Energy Institute committees to develop small reactor licensing regulations. Some small reactor changes are beginning to appear, such as a reduction in NRC annual fee assessments. And a senior NRC manager has recently confirmed to Gen4 Energy privately that if Gen4 Energy approaches the NRC with a customer, a site, a detailed design and funding, the NRC will find a way to conduct a review.
The Canadian nuclear licensing process is led by the Canadian Nuclear Safety Commission (CNSC) and has two basic steps:
- Site Environmental Assessment (EA), followed by:
- Site Licensing Process
Of particular interest to Gen4 Energy is the optional reactor Vendor Conceptual Design Review, also called the Vendor Pre-Project Design Review. It covers 19 review areas and prepares the vendor for more fruitful discussions and for a formal application to the CNSC.
The CNSC has stated it is taking a flexible regulatory approach for small reactors and Canadian nuclear requirements appear to be more conceptual and less prescriptive than comparable NRC documents. CNSC is also willing to evaluate reports to and evaluations by other regulatory agencies.
The UK nuclear licensing process is managed by the Health and Safety Executive’s (HSE) Office of Nuclear Regulation.
The new reactor plant licensing process is carried out in two distinct phases:
- Generic Design Assessment (GDA), with focus on the reactor design, before a site is specified.
- Nuclear Site Licensing – Site license assessment
HSE contacts have shown interest in small reactors and distributed power and have indicated to Gen4 Energy that it would be happy to begin a GDA review of the Gen4 Module in 2012, even without a customer sponsor. And, like the CNSC, the HSE appears to take a more flexible, goal oriented approach, compared to the NRC.
Based on information that the GDA and environmental assessment may require 2.5 to 3.5 years and site licensing may require half to 1 year, then with site construction of about 1.5 years, the total time span to the start of Gen4 Energy reactor plant operation could be about 5 years. Thus, a Gen4 Energy reactor plant could begin operation as early as 2017 as UK regulatory timelines appear to be somewhat shorter than those of the USA or Canada.
United States Nuclear Regulatory Commission
Canadian Nuclear Safety Commission
United Kingdom Office for Nuclear Regulation