Last week I discussed why the Russians might be asking the NRC for a Design Certification of the VVER. I concluded it had little to do with the supposed “gold standard” of certification the NRC provides. In reality the Russians need any independent certification to participate in the international market with smaller countries that lack resources to do their own certification.
Why should we care? Is this a good thing or a bad thing? Let’s look at the puts and takes.
The Gold
- Having the NRC certify the VVER would at least assure the design has a similar safety level and attention to quality that we demand in the U.S. This would be the “gold standard” we believe we have in the US.
- The Russians would have to pay for the review for this certification, bringing outside capital into the government. Estimate vary on how much, but the NRC charges a hefty $274/hr to the applicant for the privilege of reviewing their application. The work involves many dozens of reviewers and extends for several years. The AP1000 took five years in the latest round. The VVER would likely take longer. Only twenty full time reviewers can make the costs exceed $10MM.
Note: I’ve heard this phrase from some folks that “the NRC has never rejected a license application”. Here’s what really happens. The reviews are extensive and iterative. The NRC asks many, many questions (for DCD’s they can run to hundreds). And the applicant is paying $274/hr, plus all of their own people’s time in responding. At some point it becomes clear to the applicant that the license is not going to be satisfactory as is. Then the application is withdrawn to stop paying the NRC for further reviews. Sometimes, the applicant will fix the issues and resubmit, but sometimes the request is never resubmitted. So the NRC never rejects an application, but the thing they approve will have been modified to address their concerns and/or the concerns of members of the public who have chosen to intervene (called Intervenors).
The Dross
- The NRC has limited qualified resources to do these kinds of reviews. Nuclear expertise is not a quick study of a few months or years. To do a thorough review of a design requires significant expertise in this industry. However, the NRC rarely hires from industry, except at the lowest levels of reviewer. This means that leadership, oversight, and project management have to be grown from within the agency.
If the NRC chooses to perform a review of the VVER, these highly trained individuals will not be available to perform reviews of designs and other licensing applications for projects that impact the U.S. industry directly. - Providing this certification for the VVER without some commensurate US project means that the U.S. government has helped a competitor to US industry without any benefit of long term jobs and/or security for the United States.
Conclusions
The NRC has in the past demanded that someone demonstrate interest in a design before significant resources are applied to moving the application forward in the process. If they stick to this policy, the VVER may never see the light of day within the NRC.
That is, if the US industry keeps moving new reactor designs and licenses forward. If that effort stalls out, then the VVER may well be a way for the NRC to keep staff on board. You see, the NRC staffed up in anticipation of the dozen or so stated interests in new reactors around the U.S. Rather than lay people off (difficult to do in the government), I’m sure the NRC will fill its time with reviews of these reactors.
All-in-all, I don’t think the U.S. government should be helping Rosatom, a Russian owned and operated company, compete against companies that at least have a major presence and work-force in the U.S, like Westinghouse, GE-Hitachi, B&W, and Nu-Scale. These companies are creating U.S. jobs, and developing U.S. infrastructure as well as competing for international opportunities that will keep the U.S. out there influencing the development of nuclear around the world. A goal that I think is a good one.