Happy New Year!  As we start off 2019, we want to motive the nuclear community by sharing a few legal updates and popular reports that have come out around the end of the last year.

  • Nuclear Energy Innovation and Modernization Act (S.512, NEIMA):  On December 21, Congress adopted NEIMA, legislation that addresses NRC licensing activities for current and next-generation nuclear reactors—and which the President is expected to sign in due course.  The text of the enrolled bill can be found here.  The legislation has a number of sections devoted to budget efficiency and reigning in NRC licensing fees “to the maximum extent practicable,” but also contains a number of provisions pushing the agency to develop a new regulatory approach for advanced reactors.  These include:
    • Prompting the NRC to “Develop and implement” a Staged Licensing Program (along with conceptual design assessments and licensing project plans).  The legislation also pushes the NRC to hasten research and test reactor licensing, further adopt risk-informed regulatory processes, and train staff and hire experts to support licensing activities.  The legislation requires the NRC to provide reports to Congress to monitor agency progress.  Many of these steps are things the NRC already is attempting—for example, the NRC’s advanced reactor licensing guidance, such as its “Regulatory Review Roadmap For Non-Light Water Reactors,” already speak to staged licensing, conceptual design reviews, and project plans.  However, NEIMA authorizes $14,420,000 for this effort per year, which if added beyond current allocations could help hasten all of these activities.
    • Requiring the NRC to Report on Creating a New Reactor Licensing Framework.  As opposed to the above activities, which would occur largely under the current regulatory framework, the legislation would also ask the NRC to draft a report to Congress on developing a new, technology-inclusive regulatory framework for advanced reactor licensing, to be completed by 2027.  This builds on suggestions already put forward by the NRC staff for a “10 CFR Part 53” process for licensing advanced reactors, which is also highlighted in an article recently co-authored by one of the writers of this blog.
    • Amending the Atomic Energy Act to Allow Research/Test Reactors to Sell Energy.  This interesting provision would amend 42 USC 2134(c), one of the core elements of the Atomic Energy Act, to permit licensing of a broader variety of research and test reactors under a “minimum amount of regulation”—including research and test reactors that also generate revenue from other sources, such as through sales of electricity (although such sales would be capped at a percent of annual facility ownership & operating costs).  A goal of this provision appears to be to enhance the economics for building research and test reactors, long considered a key roadblock to advanced reactor licensing.

There is much more to this legislation than described here, and we hope it will have a significant effect on advanced reactor licensing in the United States.

  • DOE to Use 2 of NuScale’s First 12 Modules:  The same time as NEIMA moved through Congress, DOE announced a memorandum of understanding (MOU) to draw on 2 of the planned 12 modules of NuScale’s first reactor project, for DOE research and facility use.  This MOU concerns NuScale’s first planned reactor project, to be procured by Utah Associated Municipal Power Systems (UAMPS) and sited at Idaho National Laboratories (INL).  According to the DOE press release, one module would “be designated strictly for research activities (referred to as the Joint Use Modular Plant or JUMP program),” focusing on development of integrated energy systems. The second module would then be used to provide power to INL under a Power Purchase Agreement (PPA).
  • National Academies Fusion Report:  In Mid-December, the  National Academies of Sciences, Engineering, and Medicine (NAS) issued a detailed new report on nuclear fusion, entitled the Final Report of the Committee on a Strategic Plan for U.S. Burning Plasma Research.  It highlights the significant progress made in fusion research, and provides guidance on a national strategy to achieve practical fusion energy.  Critically, along with supporting the multi-national International Thermonuclear Experimental Reactor (ITER) project in France, the report recommends a separate national effort “to build a compact pilot plant that produces electricity from fusion at the lowest possible capital cost.”  The report is technically focused, but also briefly discusses regulatory matters, pointing to past DOE safety guidance developed for the ITER project as a starting point.  It also posits that “[s]iting and licensing strategies for such facilities should be developed well in advance so as not to delay the progress toward the compact fusion pilot plant.”  Questions as to the final regulatory framework and regulator for commercial fusion facilities are still very much under consideration, although the report considers a transition to the NRC as the regulator for commercial fusion power facilities.

It also seems worth highlighting two other reports that came out earlier in 2018, that have been trending lately in the nuclear community.

  • The first is a U.S. Army-commissioned Study on the Use of Mobile Nuclear Power Plants for Ground Operations.  It is a thorough report that among other things, details past use of mobile nuclear reactors by the U.S. Army, including for providing power and fresh water at the Panama Canal Zone.  It also recommends the Army pursue mobile nuclear power plant acquisition through the National Defense Authorization Act, and suggests discrete performance requirements for any such plant.
  • The second is an MIT report, The Future of Nuclear Energy in a Carbon-Constrained World.  It covers a number of topics, and has a whole chapter dedicated to nuclear licensing issues.  Stepping back, a unique contribution of the report appears to be the way it leads with a very detailed discussion of nuclear power plant construction costs (including the huge costs incurred from site-specific construction activities), and uses this analysis to then drive many of its technical and regulatory recommendations: including on the use of modularized construction methods, regulatory standardization and harmonization, and government support for rapid testing and prototyping of new reactor designs—all with a general aim to improve the economics for advanced reactors.  One of the report’s principle authors, Jacopo Buongiorno, discusses this further in his Titans of Nuclear podcast.

For more about any of the above topics, please contact the authors.

A bipartisan group of nine U.S. senators has introduced the Nuclear Energy Leadership Act (NELA) (S 3422), a bill designed to help the United States return to its lead in nuclear energy technology.  The bill sponsors explain that the U.S. has yielded this position to Russia and China–weakening our energy security, economic competitiveness, and national security.  The blog authors, in collaboration with the Center for Strategic and International Studies, have recently published on just this issue in “Back from the Brink: A Threatened Nuclear Energy Industry Compromises National Security” (Jul. 2018).

The bill covers a range of activities to fund research, development and accelerated deployment of advanced nuclear energy technologies.  The one-page summary of the bill issued by the Senate Committee on Energy and Natural Resources explains–

To reestablish global leadership, the U.S. must have a healthy nuclear industry capable of designing and deploying the most advanced reactor concepts in the world at a competitive price. As we look for clean, safe, reliable, flexible, and diverse power sources to meet the nation’s energy needs, advanced reactors will play a critical role in that mix.

Notably, the bill would:

  • Direct the U.S. government to enter into long-term power purchase agreements (PPAs) with nuclear reactors.
  • Promote the development of advanced reactors and fuel by strategically aligning U.S. government and industry interests, which is intended to enable U.S. developers to compete with their state-sponsored competitors from Russia and China.
  • Construct a fast neutron-capable research facility, which is crucial to test important new nuclear technologies and demonstrate their safe and reliable operation. Currently the only two facilities in the world like this are in Russia and China.
  • Develop a source of high-assay low-enriched uranium, which is the intended fuel for many advanced reactor designs, from U.S. government stockpiles. Again, both China and Russia have these capabilities domestically, but the U.S. does not.

Section by Section Breakdown

The Senate Committee on Energy and Natural Resources also released a section-by-section analysis of NEAL, which we summarize below, paying particular attention to the PPA provision, which could be a near-term game changer for the advanced reactor industry.

  • S. Government Power Purchase Agreements (Sections 2 and 3). Notably, the bill would create a pilot program for the U.S. government to enter into long-term PPAs with commercial nuclear reactors.  Under the bill—
    • The Secretary of Energy must consult and coordinate with other Federal departments and agencies that could benefit from the program, including the Secretary of Defense and the Secretary of Homeland Security.
    • At least one PPA has to be in place with a commercial nuclear reactor by the end of 2023.
    • The maximum length of the PPA is extended from 10 to 40 years, and the PPAs can be scored annually. Currently, nuclear energy is at a disadvantage when competing for federal PPA, due to a law that pre-dates commercial nuclear power and limits PPAs to 10 years. Initial capital costs for nuclear reactors are paid for over a period beyond ten years, which means 10-year PPAs do not work for nuclear projects, so this change would be an important development for the industry.
    • In carrying out the pilot program, the Secretary of Energy must give special consideration to PPAs for “first-of-a-kind or early deployment nuclear technologies that can provide reliable and resilient power to high-value assets for national security purposes or other purposes…in the national interest, especially in remote off-grid scenarios or grid-connected scenarios that can provide capabilities commonly known as ‘islanding power capabilities’ during an emergency scenario.”

The other provisions of the bill, as described in the section-by-section analysis are summarized below.

  • Advanced Nuclear Reactor Research and Development Goals (Section 4). In order for the American nuclear industry to compete with state-owned or state-sponsored developers in rival nations – especially China and Russia – significant collaboration between the federal government, National Labs, and private industry is needed to accelerate innovation. This provision directs the Department of Energy (DOE) to establish specific goals to align these sectors and send a strong and coherent signal that the U.S. is re-establishing itself as a global leader in clean advanced nuclear technology.
  • Nuclear Energy Strategic Plan (Section 5). There has not been a cohesive long-term strategy for the direction of U.S. nuclear science and engineering research and development policy across administrations.  This section requires DOE’s Office of Nuclear Energy to develop a 10-year strategic plan that supports advanced nuclear R&D goals that will foster breakthrough innovation to help advanced nuclear reactors reach the market.
  • Versatile, Reactor-Based Fast Neutron Source/Facilities Required for Advanced Reactor R&D (Section 6). For the U.S. to be a global leader in advancing nuclear technology, we need the ability to test reactor fuels and materials. Currently, the only machines capable of producing a fast neutron spectrum are located in Russia and China. This measure directs DOE to construct a fast neutron-capable research facility, which is necessary to test important reactor components and demonstrate their safe and reliable operation – crucial for licensing advanced reactor concepts.
  • Advanced Nuclear Fuel Security Program/High-Assay Low-Enriched Uranium Availability (Section 7). A healthy domestic uranium mining, enrichment, and fuel fabrication capability that meets industry needs is another prerequisite for reestablishing U.S. nuclear leadership. Many advanced reactors will rely on high-assay low-enriched uranium (HALEU), but no domestic capability exists to produce it. This section establishes a program to provide a minimum amount of HALEU to U.S. advanced reactor developers from DOE stockpiles, until a long-term domestic supply is developed.
  • University Nuclear Leadership Program/Workforce Development (Section 8). The nuclear energy industry, the Nuclear Regulatory Commission, and the National Nuclear Security Administration all require a world-class, highly-skilled workforce to develop, regulate, and safeguard the next generation of advanced reactors. This section creates a university nuclear leadership program to meet these workforce needs.

The bill was introduced by  Sens. Lisa Murkowski (R-Alaska), Cory Booker (D-N.J.), James Risch (R-Idaho), Shelley Moore Capito (R-W.Va.), Mike Crapo (R-Idaho), Richard Durbin (D-Ill.), Joe Manchin (D-W.Va.), Sheldon Whitehouse (D-R.I.) and Chris Coons (D-Del.).

For questions on the bill or the links between national security and the commercial nuclear power industry, please contact one of the authors listed below.

On Sunday, the popular TV show Madam Secretary gave a starring role to the climate and security benefits of nuclear power. The episode, titled “Thin Ice,” which is still available on the CBS website, proffered a full-throated defense of the climate benefits of nuclear power, turned a grassroots activist organization into a supporter of nuclear energy, and showcased how a nuclear powered ice breaker protected the Arctic from a foreign incursion. It capped with Secretary McCord convincing the show’s President to revise the national nuclear policy. As Michael Shellenberger opined following the episode (he also walks through the episode in detail), this marks a turning point for Hollywood, and “represents a popular culture breakthrough for the pro-nuclear movement.”  We encourage everyone to watch the episode!

From there, the week has only gotten better for nuclear innovation. The U.S. Nuclear Regulatory Commission (NRC) completed “the first and most intensive phase of review for” NuScale’s Design Certification Application for its small modular reactor. The NuScale design review has six phases to its schedule; but the first review sets the tenor, as it establishes the NRC staff’s preliminary safety evaluation of the reactor and encompasses a large portion of the requests for additional information. NuScale performed admirably in both areas. Along with this significant milestone—which derisks the company’s regulatory path forward—NuScale also received US$40 million from U.S. Department of Energy to continue advancing its innovative new, passively safe reactor design. And even the issue of nuclear waste storage might see progress, as the Nuclear Waste Policy Amendments Act of 2018 will get a vote on the floor of the House soon. The bill will move forward interim storage of spent nuclear fuel, and seek resolution on the licensing of a final national repository.

And apart from advancements on earth, NASA successfully tested KRUSTY, or “Kilopower Reactor Using Stirling Technology,” a nuclear reactor for potential moon and Mars bases. NASA personnel stated after the successful Nevada trial that “[n]o matter what environment we expose it to, the reactor performs very well.” NASA, along with Hollywood and Congress it seems, has taken a renewed interest in the role nuclear power can play in space exploration.

If you wish to learn more about any of these encouraging events, please contact the authors.

The start of the month has proven to be an exciting one for nuclear innovation in D.C.  A number of legal and regulatory activities have taken place which have implications for the next-generation nuclear industry, just a few of which are noted below.  (And for those at the ARPA-E conference, see our blog author Amy Roma speak today at the 2:15 panel “Quantifying Technical Risk for Advanced Nuclear Reactors”).

  • Last week was “Nuclear Innovation Week” in D.C. It consisted of three events highlighting both nuclear innovation and legal/regulatory reform: (i) Third Way’s Annual Advanced Nuclear Summit, (ii) the Nuclear Energy Institute’s (NEI’s) Nuclear R&D Summit, and (iii) a joint symposium hosted by the Gateway for Accelerated Innovation in Nuclear, NEI, and the Electric Power Research Institute.  Recordings of events from the Third Way summit are available online, and Amy spoke there on the topic of “Will the US Be a Global Leader in Advanced Nuclear Energy.”
  • In Congress, the Nuclear Energy Innovation Capabilities Act (S.97) passed the Senate.  The legislation would help move advanced reactor concepts forward by encouraging the creation of a fast neutron test reactor, as well as a user facility called the National Reactor Innovation Center.  While it is unclear how money will follow, it is a step in the right direction and recognizes the critical need for test facilities for next-generation nuclear reactors. Of its other more notable elements, the bill would also push forward an “Advanced Nuclear Energy Cost-Share Grant Program,” under which DOE can make cost-share grants to applicants for the purpose of funding a portion of NRC licensing fees, including both pre-application and application reviews.
  • The NRC issued Regulatory Guide 1.232, “Guidance for Developing Principal Design Criteria For Non-Light-Water Reactors.” As we discussed when the draft regulatory guide came out, this is a critical guidance document for non-light water reactors.  Appendix A to 10 CFR Part 50 sets for the general design criteria for NRC-licensed reactors, which are essentially the bounding safety requirements every new reactor has to meet.  These requirements, however, are designed for light-water reactors and do not apply well to non-light water designs (e.g., Criterion 14 sets requirements concerning reactor “pressure” boundaries, but many advanced reactors would not operate above atmospheric pressure).  There are three appendices to the report, which set forth general “advanced reactor design criteria,” as well as specific design criteria for sodium-cooled fast reactors and modular high-temperature gas-cooled reactors.  This guidance document, which attempts to update the NRC’s general design criteria to address this disconnect, is the product of a years-long DOE-NRC effort, paired with industry and public input.

And the month is not letting up.  This week is the NRC’s annual Regulatory Information Conference, where advanced reactors are taking center stage.  This week is also the ARPA-E Energy Innovation Summit, with Amy speaking on the panel, “Quantifying Technical Risk for Advanced Nuclear Reactors” (2:15 Tuesday).  ARPA-E has established a program to fund enabling technologies for next-generation reactors, called “MEITNER.”  The program seeks to help nuclear innovators leapfrog in development by providing advanced modeling and simulation tools, access to subject matter experts from nuclear and non-nuclear disciplines, and collaborative design assistance.  APRA-E is in itself an novel concept for how to commercialize technology research, and uses unique funding mechanisms to more efficiently fund energy innovation.

For more on any of the above topics, or on what else is going on in the nation’s Capital in support of nuclear energy, please contact the authors.

The House Committee on Energy and Commerce, Subcommittee on Energy held a hearing February 6, 2018 to discuss the challenges facing America’s nuclear infrastructure, including advanced reactor development.  The hearing was called “DOE Modernization: Advancing the Economic and National Security Benefits of America’s Nuclear Infrastructure.” A video of the hearing can be watched here.

A background memorandum released in advance explained that the hearing would explore the following important topics:

  • National security implications associated with U.S. nuclear leadership and a domestic nuclear energy industry;
  • The outlook for domestic and international development of nuclear energy and application of nuclear technologies;
  • Challenges and opportunities regarding maintaining the components of a domestic nuclear fuel cycle; and
  • Options to develop and deploy advanced nuclear technologies

The hearing witnesses included (their statements are also provided below):

  • Mr. Art Atkins, Associate Deputy Administrator for Global Material Security, U.S. Department of Energy, National Nuclear Security Administration: Witness Statement
  • Mr. Victor McCree, Executive Director of Operations, U.S. Nuclear Regulatory Commission: Witness Statement
  • Mr. Ed McGinnis, Principal Deputy Assistant Secretary, U.S. Department of Energy, Office of Nuclear Energy: Witness Statement
  • Mr. James Owendoff, Principal Deputy Assistant Secretary, U.S. Department of Energy, Office of Environmental Management: Witness Statement
  • Dr. Ashley Finan, Policy Director, Nuclear Innovation Alliance: Witness Statement
  • Ms. Maria Korsnick, President and CEO, Nuclear Energy Institute: Witness Statement
  • The Honorable Bill Ostendorff, Former NRC Commissioner and Distinguished Visiting Professor of National Security, U.S. Naval Academy: Witness Statement
  • Dr. Mark Peters, Director, Idaho National Laboratory: Witness Statement
  • Mr. David Trimble, Director, Government Accountability Office, Natural Resources and Environment: Witness Statement

Summary of Key Issues for Advanced Reactor Community

During his opening remarks, Full Committee Chairman Greg Walden (R-OR) noted that “[a]t root today, is a question of our nation’s capabilities not only to propel nuclear innovation generally, but to ensure an infrastructure that is critical to our economic and our national security.” He promised to align U.S. policy with a changing world: “we must recognize the world looks different than it did at the birth of the nuclear age. Consequently, we must take steps to update the relevant policies. These policies must be forward looking to enable innovation and the development and deployment of new advanced nuclear technologies.”

Once witness questioning began, the Subcommittee quickly honed in on issues facing the advanced reactor community and expressed bipartisan support for U.S. government help to develop and deploy these innovative new designs. Among the issues discussed were the following:

  • SMR commercialization and deployment schedule

The first question asked at the hearing, by Subcommittee Chairman Fred Upton (R-MI), was on small modular reactor (SMR) commercialization and when the U.S. was going to see SMR designs being approved and deployed in the commercial sector. In response, Ed McGinnis, Principal Deputy Assistant Secretary, U.S. Department of Energy, Office of Nuclear Energy explained: “We are at a tipping point,” with the U.S. leading in design development but challenged in deployment of the technologies. He went on to note that NuScale project that can be “game changing” if successfully deployed.

Last year, reactor designer NuScale submitted to the U.S. Nuclear Regulatory Commission the first SMR reactor design certification application  in the United States. The NRC recently approved–in a first of a kind decision–that NuScale would not need a safety-related electrical power system. This means that the NRC believes the reactor can remain in a safe condition in the event it loses electricity. Currently, all nuclear power plants in the U.S. have safety-related electrical power systems. And the fact that NuScale does not need one is a testament to the inherent different nature of SMRs—and the first time the NRC has recognized as such during its review of an application.

On that front, Victor McCree, the NRC’s Executive Director of Operations, explained during the hearing that the NRC’s decision about NuScale reflects a “philosophical” change that will lead to more efficient and effective reviews. Mr. McCree continued on to explain that an NRC approval of the NuScale design would open the market in a way that large reactors cannot, including by being more affordable and improving grid reliability. Mr. McGinnis further explained that with a number of large-scale reactors facing shutdown, getting SMRs into the pipeline is an imperative, and among other things, DOE was working on integrating SMRs with wind turbines and solar plants. With SMRs versatility and fast ramp up ability, Mr. McGinnis explained, SMRs could be paired with renewables to firm up their intermittent power and delivery of emissions free power.

  • Concern with amount of DOE funding to support SMR commercialization and deployment

Several members expressed concern that—with less than US$30 million invested in advanced reactors—whether DOE is really pushing for commercialization of SMRs. In response, Mr. McGinnis noted that a lot of work was being performed at the national labs and DOE continues to work on deployment matters.

  • High-assay LEU and Test Reactors

Mr. McGinnis from DOE also explained that DOE was working towards development of a fast neutron reactor and growing a capacity for high-assay LEU. Mr. McGinnis acknowledged that next-generation nuclear innovators need a test reactor, which itself would require high-assay LEU. He added that NNSA is taking seriously the challenge of developing a high-assay LEU capacity for testing and eventual industry use.

  • Deployment of US SMRs overseas

A number of members asked about deployment of US SMRs abroad. In response, Mr. McGinnis remarked that a number of countries are interested in U.S. SMR designs and watching their progress. He remarked that the U.S. is the world expert in designing SMRs, and that if the U.S. was able to prove the technology domestically it would open up the international market. The hearing participants also discussed ways to speed up the U.S. nuclear export approval process. On that last point, Congressman Bill Johnson (R-OH) noted that he intended to introduce legislation soon to improve the export control authorization process. At the end of 2017, Chairman Upton and Congressman Johnson sent a letter to Energy Secretary Rick Perry saying that the slow pace of DOE authorizations for commercial nuclear energy exports is having harmful consequences for U.S. competitiveness and national security. “While DOE is in the process of implementing some targeted reforms, more work remains to accelerate agency decision-making so that our domestic nuclear technology leaders have timely answers necessary to compete effectively with other nations’ nuclear programs,” the letter said.

  • NRC fee reform

When asked about if the NRC is undergoing reviews of its fee structure and looking for ways to improve methodology especially when non-LWR reactors look for licensing, Mr. McCree confirmed that the NRC is looking at this issue.

With a flurry of attention on advanced reactors lately, the hearing brings welcome attention the advanced reactor community needs. Please contact the authors with any questions.

On Wednesday, November 15, the US Nuclear Regulatory Commission (NRC) staff published a revised and final regulatory basis document in support of its rulemaking to reform emergency planning requirements for small modular and advanced reactors, including medical isotope reactors.  This rulemaking promises to significantly reduce costs for next generation nuclear plants by employing individualized, risk-informed requirements as opposed to rigid deterministic ones.

Fifty-seven individuals, companies, and organizations commented on the draft regulatory basis document.  The NRC staff made a number of edits to respond to the comments, including further incorporating risk-informed concepts into the text of the regulatory basis, and increasing discussion of the agency’s framework for establishing the size of emergency planning zones for new reactor designs.  According to the NRC’s rulemaking schedule, a proposed rule is due to be published early 2019, with a final rule in 2020.

This action by the NRC coincides with exciting developments for the US Department of Energy.  This week the Transient Reactor Test Facility (TREAT) at Idaho National Laboratories successfully completed low-power operations after being brought out of standby since 1994.  As explained in industry press, the restart of TREAT is a big success story for the agency, which refurbished the facility a year ahead of schedule and $20 million under budget.  TREAT specializes in testing new reactor fuels under heavy irradiation conditions, to see how they perform particularly in accident scenarios.  Testing new fuel designs is a linchpin to commercializing new reactor designs, as many of them rely on completely new concepts for nuclear fuel.

TREAT may also be getting company.  This same week, the House of Representatives Committee on Science, Space, and Technology approved an exciting new bill markup, HR 4378, the “Nuclear Energy Research Infrastructure Act of 2017.”  This piece of legislation tries to deliver on repeated calls to build a new test reactor in the United States.  It calls for a fast-neutron test facility to be completed in the mid-2020s that supports (among other things) high-temperature testing, testing of different coolant types, medical isotope production, and which is designed to be upgrade-able over time.  Funding is set aside, with $35 million in 2018, scaling up to $350 million from 2023 to 2025.

For more on any of these topics, feel free to contact the authors.

In prior posts we have touched on the importance of prototype and test reactors in enabling the eventual commercialization of advanced reactors.  To help in those efforts, the NRC recently issued early draft guidance on “Nuclear Power Reactor Testing Needs and Prototype Plants for Advanced Reactor Designs.”  This document has been issued to support a public meeting on the topic, currently scheduled to occur sometime in August 2017.

As described by the NRC, this guidance describes the (i) “relevant regulations governing the testing requirements for advanced reactors,” (ii) “the process for determining testing needs to meet the NRC’s regulatory requirements,” (iii) “when a prototype plant might be needed and how it might differ from the proposed standard plant design,” and (iv) “licensing strategies and options that include the use of a prototype plant to meet the NRC’s testing requirements.”

To add, the document also provides some discussion as to the differences between prototype plants, demonstration reactors, test reactors, first-of-a-kind reactors, and other terms that are often thrown around in this space.  It also discusses different categories of tests to be conducted, and provides an FAQ on the use of a prototype plant as part of a testing regime.  Appendix A is an annotated reprint of a section of a 1991 staff paper, and is entitled “Process for Determining Testing Needs”; and Appendix B provides an interesting discussion on “Options For Using a Prototype Plant To Achieve a Design Certification or Standard Design Approval.”

For any questions on the above, please contact the authors.