The Nuclear Innovation Alliance (NIA) late last week published two papers on recommendations for addressing regulatory challenges related to advanced reactor licensing:
- Nuclear Innovation and NEPA (the National Environmental Policy Act)
- Establishing Interface Requirements for “Major Portions” Standard Design Approvals
The blog authors had the pleasure of working with NIA to contribute to the first article, on NEPA reform, leveraging years of experience with NRC licensees and advanced reactor innovators on this challenging topic. NEPA, as implemented by the NRC, requires that an environmental impact statement (EIS) be created for every reactor license application—an extremely costly and time-consuming process as currently structured, with uncertain benefits. The NRC’s environmental review process, which has increased in scope over the years, can take up a third of agency resources related to the licensing of a new reactor, and delay licensing—and yet it remains an often underlooked area of potential improvement in the NRC licensing framework.
NIA’s paper examines NEPA’s impact on nuclear licensing, and how it could hamper advanced reactor innovation if left out of the regulatory reform conversation. It then makes four recommendations to help Congress and the NRC right-size NEPA reviews for the future:
- Reevaluate the Presumption that Advanced Reactor Demonstration Projects Require EISs
- Tailor the Scope of NEPA Reviews for Demonstration Projects
- Increase Use of Generic Environmental Impact Statements to Address Common Advanced Reactor NEPA Questions
- Allow Applicants to Draft EAs and EISs
NIA’s second paper, developed with contriubtion from Jensen Hughes, tackles the establishment of interfaces for Standard Design Approvals (SDAs). SDA’s are being explored as a method to stage NRC licensing, specfically by seeking SDAs for “major portions” of a reactor design in separate chunks, as opposed to submitting an application for approval of a reactor design all at once. In that regard, “[i]nterface requirements can be thought of as boundary conditions for the portion of the design for which an SDA is being sought.” The paper provides guidance on the creation of these interfaces, so SDAs can be better leveraged as part of an advanced reactor licensing plan.
For more questions on the application of NEPA environmental reviews to advanced reactor licensing, and on licensing of advanced reactors generally, please reach out to the blog authors.