Who’s Afraid of the NRC? Part I: The Nukebro
Is the NRC standing in the way of an American nuclear resurgence? Nuclear entrepreneur Josh Payne says “yes.”
Welcome to the Decouple Dispatch. I’m your correspondent Angelica Oung, and we are going to be taking deep dives into all things atomic. We’re kicking off with a controversial topic: The US Nuclear Regulatory Commission (NRC). Depending on who you ask, the regulatory body has either reformed from the bad old days, or it remains a foundational stumbling block on the development of nuclear. Part 1 of a 3 part series.
Imagine an advanced reactor designed, built and ran in three and a half years for US$17.5 million dollars. That’s millions, not billions. By a team of just 10 to boot. This isn’t science fiction, it’s NASA’s KRUSTY Kilopower reactor. Admittedly, it’s only a 1KW electrical output reactor intended to produce power in space. But it gives us a tantalizing glimpse of what could be possible when nuclear engineers are allowed to build and iterate quickly.
Here on earth, reactors of all sizes, even tiny ones like the KRUSTY, are subject to Nuclear Regulatory Council (NRC) rules as long as they are going to plug into the US grid. Their regulations are onerous and do not take the massively lower risk profiles of small reactors into account, according to nuclear entrepreneur Josh Payne.
“The way the KRUSTY team got it done was by totally bypassing the NRC and pissing a lot of people off along the way,” said Payne, a proud ‘Nukebro’ who is working on a nanoreactor concept of his own.
“Why do I have to spend a million dollars doing seismic studies for my nanoreactor, which I can literally put on the back of a truck and drive down the road?” asked Payne.
CAN 100 REACTORS BLOOM?
After the Nuclear Renaissance starting from around 2001 failed to materialize, the US is gearing up for another nuclear resurgence. This time, the interest has shifted away from the standard gigawatt-scaled Light Water Reactors (LWRs) that form the fleet that currently produces almost 20 percent of the electricity in the Land of the Free.
Small Modular Reactors and advanced nuclear concepts such as Molten Salts and High-Temperature Gas-Cooled (HTGC) reactors are garnering all the interest in new-builds just about exclusively.
“This is where we are now as a nuclear industry, we have to go to the really tiny stuff,” said Payne, “the problem is, small reactors still have to conform to all the big-plant stuff.”
In Payne’s view, the “prescriptive” approach to regulation by the NRC, with granular and inflexible rules tightly patterned after existing gigawatt-scale LWRs, is in danger of strangling a generation of new nuclear power.
“If you look at all the regulations, they are all super site-based. This effectively make all the plants a first-of-a-kind,” said Payne, “there isn’t anything in their regulatory framework to give industry credit for smaller impact sizes and less materials, and if a reactor deviate from the light water reactors, they won’t have a validated model to deal with them.”
HOW TINY CAN BE BEAUTIFUL
Most nuclear startups from the best known, Nu-Scale, on down are planning to do some kind of contract manufacturing. This is pretty standard in a lot of industries, and there are big companies that do CNC machining and pressure vessel manufacturing. The problem is, as soon as “nuclear” is involved”, all the components have to pass what is called the NQA1, the quality control standard for nuclear manufacturing. Obtaining an NQA1 certification is an intense process that can increase the cost of everything by “a factor of 10 to 100,” said Payne.
“When they get an order that has to be NQA1, that is not an off-the-shelf component,” said Payne, “they have to build it from scratch in order to have the pedigree that NQA1 requires.”
The contract manufacturer has to order all their components and supplies from NQA1-certified vendors before building their own sub-assembly that has to be NQA1 certified, all adding a massive amount of cost and potential supply-chain delays.”
“Say you’re one of those startups and you partner with a machine or fabrication shop. You spend a bunch or money helping them pass the NRC audit for the NQA1. Then just as you’re about to place your first order, this shop goes out of business for whatever reason and now your critical supplier is gone.”
This was the problem that Boeing had with the 787, which also had to deal with a highly regulated environment. In the end, they dealt with the problem by buying up their subcontractors and integrating them, something no nuclear startup is in a financial position to do.
Payne is getting around the problem by building very, very small nuclear reactors and keeping the manufacturing in-house and vertically-integrated.
“We are trying to build a machine shop manufacturing business with a nuclear engineering problem,” said Payne.
The power from Payne’s nano reactors will not be cheap, but it doesn’t have to be. “People pay different prices for energy with different sub-values to it,” said Payne.
Remote islands, for instance, might pay US$10-20 for diesel, meaning nanonuclear, even at $1000/MWh, might prove competitive based on their dependability and transportability. Other high-value uses include emergency power supplies for disaster relief and military use.
“LET PEOPLE BUILD THINGS!”
According to the NRC’s “10CFR50.43E” or “Additional standards and provisions affecting class 103 licenses and certifications for commercial power,” the commission is not going to license any reactor with advanced safety systems unless they have data behind them from a physical plant.
This creates a chicken-and-the-egg problem. It’s not possible to build a physical plant without a license, but without that physical plant, it’s impossible to get the data that will allow the NRC to issue a license.
“Until you give people the ability to build things, no amount of modeling is going to solve the problem,” said Payne.
Payne’s proposal for squaring this circle is to make it radically cheaper and easier for industry to build reactors for the purpose of research by creating a “playground” of sorts for nuclear reactors.
“If you melt down a reactor that is a week old, there’s no fission product buildup to release because you haven’t made it yet,” argued Payne, “you do this in the middle of nowhere, with a nuclide inventory that is smaller than in a hospital.”
In Payne’s reactor “playground” concept, prototype reactors can be thrown up quickly for experimental purposes to get data for a few months. Fresh fuel can be swapped out regularly to prevent a buildup of harmful fission products like Iodine-131 or Cesium-137. The lightly-used fuel can even be reprocessed to use in commercial reactors.
“We can do this in places we’ve nuked about a thousand times,” said Payne, referring to Nevada, where more than 900 nuclear weapons have been detonated.
In 1965, a GW scale nuclear reactor was even blown up in Nevada in the Kiwi TNT project. Nobody knew about it for a long time, because it was the 60s. And also, as Payne pointed out, there was hardly any radioactive material because it was a fresh core.
Payne even questions, is it necessary at all to have an NRC?
“It’s a bit of a modest proposal,” said Payne, “but there’s nothing that the NRC does that can’t be handled by the Environmental Protection Agency or the Department of Energy.”
Though he’s too young to have experienced it, Payne speaks of the days before the NRC with a keen sense of nostalgia, for the days when it was possible to not only blow up a gigawatt scale reactor but give the project a wacky name like Kiwi TNT (short for Transient Nuclear Test). But even for the regulators, Payne points out, knowledge is power.
“If we make it easier to build research and prototype reactors that are not connected to the grid, that would expand the regulator’s knowledge of the novel reactors too,” said Payne, “otherwise they will be regulating in the dark and exposing themselves to risk.”
ANGELICA’S TAKE
You don’t have to agree with Josh’s modest proposal to do away with the NRC to see the problem with a prescriptive approach in a field that is crying out for innovation and revitalization. If, as the Biden administration repeatedly signals, the future of new-build nuclear in the USA is going to be in SMR and advanced reactors, we need to find a way to test them so that they can be perfected and studied away from the NRC’s stringent prescriptions. This will help us control the cost and project timelines of First Of A Kind commercial builds, and help NRC write better regulations.
Next week, we will hear a very different take on the NRC from nuclear consultant and advocate, James Krellenstein. So stay tuned, and let us know in the comments what other atomic issues I should look into next as your Decouple correspondent.
With the NRC totally and completely whiffing on their advanced reactor regulations so that industry players said they would prefer the current ones to that, I think the time has come for the US to put out a tender for bids from third parties to craft new regulations
At the very least the NRC would realize that if they don't adapt the making of the new regulations could be yanked from under them
Prescriptive regulation can work well for things where the design space is very well known, and the regulations are covering that part of the design space.
The ASME boiler and pressure vessel code is a prime example of this. The fired boilers section is EXTREMELY prescriptive, but so detailed that designing to it is not that hard.
But it has a less detailed process vessel section, with more onus on proving that your design meets the broader requirements.
This is the balance we need.