No, this is not a post about the upcoming Olympic Games, although we will talk about some of the countries playing in those games. This is a different set of games and one that affects the nuclear industry playing fields.
The recent announcement of Rosatom’s intent to seek Design Certification for the VVER in the U.S. has created some discussion about why they might be doing this and whether or not it is appropriate for the NRC to review such a submittal. While the NRC will review any acceptable application put before it, NRC staff and the commissioners have mentioned time and again that they are resource constrained and that some activities will have to be deferred while the commission deals with issues arising from events at Fukushima Daiichi in Japan.
So, why might Rosatom request such a certification?
The first reaction was that they are going to seek customers in the U.S. This seems highly unlikely. The market in the U.S. for new reactors has slowed considerable from the high number of announced intentions in 2005. They are also approaching the market with yet another PWR design. There are several already approved (AP-1000) or in review (EPR, APWR, etc). This would seem to be a pretty saturated market for them to successfully compete in. In addition to fighting the uphill battle of willingness to actually buy Russian technology in the U.S., my crystal ball says they are not planning to actually sell any VVERs here in the U.S.
So what’s the real plan?
Some have speculated that Rosatom is seeking U.S. NRC certification in order to sell reactors in a wider market. To date, almost all VVERs have been sold to former USSR states, or nations that have been more closely aligned with Russia in past years (India, for example). Some in the U.S. believe that the NRCs certification is a “gold standard” of sorts with smaller nations that have insufficient resources to perform such detailed certification assessments. In years past, I would have agreed with that assessment. Certainly, Mexico and Taiwan have largely relied upon U.S. regulatory reviews. To a lesser degree, Japan, Switzerland and Spain have as well.
Today, however, the U.S. position as a “gold standard” is in serious doubt. Other regulators have grown up and created their own high standards of review. The French government while perhaps in its earliest days relied up the U.S. has gone their own way for many years, as has Germany, Sweden, and the U.K. In addition, the U.S. has not built a new commercial reactor for many decades, and has never completed a reactor under the new 10CFR52 licensing regime.
All of that said, many smaller nations considering nuclear power for the first time, lack resources and expertise to do a thorough assessment of a design. Thus, in their requests for proposal, they’ve asked that the design be already certified in another country.
What countries are doing certifications of reactors not of “domestic origin”? It turns out, not a whole lot. France has only certified and built designs by AREVA (or its predecessors). South Korea has only certified in country designs as well. China doesn’t really certify designs as near as I can tell. Same in India. I don’t think the Russians actually certify their designs either. Other countries have limited programs with reliance on other countries.
The U.K. has created a robust program of certification in that past few years after several years reorganizing and rewriting its nuclear regulation. The U.S. has the 10CFR52 process that provides a clear certified design.
So Rosatom is requesting certifications from the two countries that really provide those things, most likely to allow them to go after those other markets. Not that the U.S. is a gold standard. It’s just one of a very few countries that fulfill the potential need.
So what might be the next question. Why should we care whether or not the Russian Design gets certified? That is for the next blog. There’s more to that question that meets the casual observer.
Margaret,
an excellent summary, as I’d come to expect.
One small note to add – there have been considerable efforts within the EU (and to a lesser degree externally) to implement at last a partial recognition of certification work done by other regulators, and to allow an element of worksharing. Probably the strongest demonstration of this to date was a joint approach by the Finnish, French and UK regulators to resolving the issues of separation of control and shutdown functions in the EPR.
I expect this to extend further, if only on the basis of cost savings.
There are probably a couple of “test cases” forthcoming which will test this. Mike Weightman, the head of the UK’s ONR (Office of Nuclear Regulation) has stated he expects to start work on ESBWR certification in the relatively near future – and that design appears to be in the running for the next Finnish development, and for Poland. It’ll be interesting to see if more formal and closer cooperation emerges.
The other test will be the bidding for the Temelin reactors in the Czech Republic. If the VVER plays strongly, it’s not clear what approach the Czechs will take to this – it’s hard to imagine that as a country they have resources to undertake a full design review alone, so will almost certainly have to seek support from elsewhere in the EU.
Of course, the world does not stand still. I’m certain that other countries will increasingly move into this game. However, only a few countries have a large enough regulator to really handle such an effort. I’m expecting the EU to find a common method like you’ve done in so many other areas.
I certainly hope that’s the case, Margaret – although it probably won’t be through EU structures per second. There’s simply too much divergence between the perspectives of the variousmember states.
What’s more likely to emerge is a less formal structure of bilateral mutual recognition and agreements on a case by case basis. Which will probably in one sense reduce the external attractiveness of a “European certification”, but might make extending cooperation to bodies outwith the EU somewhat easier.