The Urgency of NRC Reform_July 2023_1.pdf Guest Post

TheUrgency_NRCReform_Draft - The Urgency of NRC Reform_July 2023_1.pdf The Urgency of NRC Reform by Judi Greenwald, Executive Director, Nuclear Innovation Alliance There is growing recognition that advanced nuclear energy is needed to meet our climate and energy security goals, and that Nuclear Regulatory Commission (NRC) reform is needed to enable advanced nuclear energy. Our mission at the Nuclear Innovation Alliance (NIA) is to help create the conditions necessary for development and deployment of advanced nuclear energy, including NRC reform. Two things are required to make reform happen: (1) a shared sense of urgency and (2) a shared willingness to roll up our sleeves and dig deeply into removing the operational and organizational barriers that are getting in the way of meeting this moment. NRC’s job is to license new reactors and oversee existing ones to ensure the public safely benefits from nuclear energy. NRC has many organizational strengths. It has a highly technical and dedicated staff. As an independent Commission with a bipartisan set of five commissioners, it is relatively insulated from changing political winds. It has a proud history of overseeing a remarkably safe nuclear industry. But it is not doing its job efficiently enough. Historically, public debate around NRC has been between anti-nuclear voices advocating for slower licensing or fewer nuclear power plants, and industry advocating for streamlined regulations and more nuclear power plants. NIA and others are injecting a new voice and message into this conversation: that there is a public interest in efficient and effective licensing because there is a public interest in solving climate change and achieving energy security as quickly as possible. NRC licensing efficiency is just one example of a broader challenge for all clean energy, not just nuclear energy. Our country’s infrastructure permitting rules implicitly assume that it is okay if it takes years or even decades to build new infrastructure. This premise is no longer acceptable and, in retrospect, it probably never was just or correct. Solving climate change and ensuring energy security requires that we replace and build new clean energy infrastructure rapidly. NRC reform is a set of actions that need to be taken by NRC staff, the Commission, Congress, the nuclear industry, and civil society to improve the effectiveness and efficiency of advanced reactor licensing. Work is needed to reform NRC licensing on three timescales: short-term, medium-term and long-term. In the short term, about a dozen advanced reactor developers are engaging one-on-one with NRC to obtain approvals under existing rules. This is challenging because the current licensing pathways have been tailored to conventional, large, light water reactors. There are many things that NRC and industry license applicants can do to make these early engagements go well. (See the recommendations in NIA’s most recent licensing efficiency report). NRC staff and applicants have been making good progress on licensing the Hermes test reactor and the Abilene Christian University research reactor, incorporating lessons learned from NuScale’s design approval, which took too long and cost too much. But licensing timelines and costs are uneven, often attributable to inconsistent quality in mundane but important practices like disciplined project management and clear internal and external communication. The NRC Commissioners are beginning to dig into the details to improve licensing efficiency. For example, then-Commissioner Baran proposed in June that the Commission request staff input on a proposed Commission policy statement to communicate the Commission’s expectations to the NRC staff, the Advisory Committee on Reactor Safeguards, and external stakeholders on the effectiveness, efficiency, and timeliness of new reactor licensing reviews. In a complementary effort, Commissioners Wright and Caputo are working together on a proposal to establish performance metrics to measure NRC’s progress in improving licensing efficiency. Commissioner Crowell has said NRC is not successful if it is not timely, and Chairman Hanson is digging into the reasons why subsequent license renewal costs are increasing. For the medium term, NRC is in the midst of a multi-year rulemaking on risk-informed, performance-based and technology-inclusive licensing (referred to as "10 CFR Part 53”, or more simply “Part 53”). This rulemaking is required under the 2019 Nuclear Energy Innovation and Modernization Act (NEIMA), and a draft rule is before the Commission. As described in NIA’s Part 53 paper, the rule is flawed but fixable with