Nuclear Power 2010


The Nuclear Power 2010 (NP 2010) program1 was established by the U.S. Department of Energy (DOE) as a budget line item in 2002 to support the near-term deployment of new nuclear plants in accordance with the roadmap (NERAC, 2001) prepared for DOE by its Nuclear Energy Research Advisory Committee (NERAC). The overall purpose of NP 2010 is to help achieve the goals of the National Energy Policy Development Group (NEPDG, 2001):

  • Enhance long-term energy independence and improve the reliability of electricity generation, with minimal air pollution and greenhouse gas emissions;

  • Increase diversity in the U.S. energy portfolio;

  • Expand the contribution of nuclear power to the U.S. energy portfolio; and

  • Address technical, safety/regulatory, and institutional challenges to the deployment of new nuclear plants.

NP 2010 is a 50/50 government/industry cost-shared effort with the following objectives:

  • Identify sites for new near-term nuclear power plants and obtain early site permits (ESPs).

  • Complete detailed, first-of-a-kind design engineering on two advanced light water reactor (ALWR) plants and confirm the safety of the designs by obtaining design certifications (DCs).

  • Obtain combined construction and operating licenses (COLs) in keeping with the Standardization Policy (10 CFR Part 52) of the U.S. Nuclear Regulatory Commission (USNRC).

  • Develop an effective Inspection, Testing, Analyses and Acceptance Criteria (ITAAC) process to assure licensing compliance during construction.

  • Implement the standby support provisions of the Energy Policy Act of 2005 (EPAct05) for the construction of new nuclear plants.

  • Determine the capital costs and operation and maintenance costs, construction time, and levelized cost of electricity for the two plants.

  • Evaluate the business case for building new nuclear power plants and pave the way for an industry decision to build new ALWR nuclear plants in the United States. Construction would begin early in the next decade.

DOE’s responsibilities end with the issuance of the COL by the USNRC, completion of first-of-a-kind engineering for the AP1000 and Economic Simplified Boiling Water Reactor (ESBWR) standard plant designs, and implementation of the standby support and loan guarantee financial incentives of EPAct05.

Based on these results, responsibility for the procurement and construction of new nuclear plants rests solely with the nuclear industry.

Program Background

The NP 2010 program is the culmination of a cooperative research, development, and deployment (RD&D) effort in the 1980s and 1990s between DOE’s Office of Nuclear Energy (NE) and industry to develop improved light water reactor (LWR) systems for initial expansion, making them safer, smaller, and simpler, standardized and prelicensed by the USNRC, and competitive with nonnuclear alternatives. The program was initiated in the early 1980s by the U.S. utilities under the technical management of the Electric Power Research Institute (EPRI) and grew into a broad cooperative effort, the ALWR program2 (Taylor and Santucci, 1997). Participants included DOE, the U.S. utility members


Department of Energy, Office of Nuclear Energy, Nuclear Power 2010 Plan Overview, January 2006. Available at http://www.ne.doe.gov/np2010/neNP2010a.html.


G. Vine, EPRI, “DOE’s light water reactor R&D program: An industry perspective,” Presentation to the committee on October 17, 2006.

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2 Nuclear Power 2010 BacKGroUNd • Implement the standby support provisions of the Energy Policy Act of 2005 (EPAct05) for the construction of new The Nuclear Power 2010 (NP 2010) program1 was estab- nuclear plants. lished by the U.S. Department of Energy (DOE) as a budget • Determine the capital costs and operation and mainte- line item in 2002 to support the near-term deployment of nance costs, construction time, and levelized cost of electric- new nuclear plants in accordance with the roadmap (NERAC, ity for the two plants. 2001) prepared for DOE by its Nuclear Energy Research • Evaluate the business case for building new nuclear Advisory Committee (NERAC). The overall purpose of NP power plants and pave the way for an industry decision to 2010 is to help achieve the goals of the National Energy build new ALWR nuclear plants in the United States. Con- Policy Development Group (NEPDG, 2001): struction would begin early in the next decade. • Enhance long-term energy independence and improve DOE’s responsibilities end with the issuance of the COL the reliability of electricity generation, with minimal air pol- by the USNRC, completion of first-of-a-kind engineering for lution and greenhouse gas emissions; the AP1000 and Economic Simplified Boiling Water Reactor • Increase diversity in the U.S. energy portfolio; (ESBWR) standard plant designs, and implementation of the • Expand the contribution of nuclear power to the U.S. standby support and loan guarantee financial incentives of energy portfolio; and EPAct05. • Address technical, safety/regulatory, and institutional Based on these results, responsibility for the procurement challenges to the deployment of new nuclear plants. and construction of new nuclear plants rests solely with the nuclear industry. NP 2010 is a 50/50 government/industry cost-shared ef- fort with the following objectives: Program Background • Identify sites for new near-term nuclear power plants and obtain early site permits (ESPs). The NP 2010 program is the culmination of a coopera- • Complete detailed, first-of-a-kind design engineering tive research, development, and deployment (RD&D) effort on two advanced light water reactor (ALWR) plants and in the 1980s and 1990s between DOE’s Office of Nuclear confirm the safety of the designs by obtaining design certi- Energy (NE) and industry to develop improved light water fications (DCs). reactor (LWR) systems for initial expansion, making them • Obtain combined construction and operating licenses safer, smaller, and simpler, standardized and prelicensed by (COLs) in keeping with the Standardization Policy (10 the USNRC, and competitive with nonnuclear alternatives. CFR Part 52) of the U.S. Nuclear Regulatory Commission The program was initiated in the early 1980s by the U.S. (USNRC). utilities under the technical management of the Electric • Develop an effective Inspection, Testing, Analyses and Power Research Institute (EPRI) and grew into a broad co- Acceptance Criteria (ITAAC) process to assure licensing operative effort, the ALWR program2 (Taylor and Santucci, compliance during construction. 1997). Participants included DOE, the U.S. utility members 1 Department of Energy, Office of Nuclear Energy, Nuclear Power 2010 2 G. Vine, Plan Overview, January 2006. Available at http://www.ne.doe.gov/np2010/ EPRI, “DOE’s light water reactor R&D program: An industry neNP2010a.html. perspective,” Presentation to the committee on October 17, 2006. 

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 NUCLEAR POWER 00 of EPRI, major international utilities in Europe and Asia, The areas covered under program description include and qualified reactor suppliers, all of whom cofunded the primary milestones, licensing demonstration, costs, man- program. DOE established cooperative agreements with agement responsibilities and organizations, standardization, industry by which their management responsibilities could ITAAC, infrastructure needs, setting priorities, oversight be discharged. USNRC was kept fully informed of progress, methods and metrics, cooperative industry–government commented on the results of the program, and performed R&D, economic issues, and EPAct05. The program descrip- independent confirmatory analyses and experiments. A prime tions are derived from DOE and industry documentation, utility goal was to oversee the development of the utility presentations by DOE management, nuclear consortia lead- requirements documents (URDs) (EPRI, 1990) to provide ers, and industry representatives from the Nuclear Energy owner-operator guidelines to the designers of the new plants. Institute (NEI) and EPRI. The penultimate section brings the A key purpose of the URDs was to apply the lessons learned goals and timetables up to date and assesses progress. The in the first worldwide deployment of nuclear power, focused final section presents the committee’s recommendations. on increased safety, reliability, design, and operational sim- plification and integration. In 1992, a National Research oVerall ProGram descriPTioN Council (NRC) report on nuclear power encouraged continu- ation of that R&D effort on ALWRs (NRC, 1992). Primary milestones Testing was completed on two 600-MWe designs fea- turing passive emergency core and containment cooling The NP 2010 program includes the following technical goals7,8: ,8 8 systems: the Westinghouse pressurized water reactor (PWR) AP600 and the General Electric (GE) simplified boiling water reactor (SBWR), on which the power-upgraded West- • Demonstrate key untested regulatory processes. inghouse AP10003 and the GE ESBWR4 are based. Design —ESPs certifications were obtained from USNRC for the AP600, the ° Obtain three ESPs. evolutionary advanced BWR (ABWR),5 and the advanced —DCs for new reactors PWR System 80+.6 ° Obtain approval of AP1000 design certification With rising concern over global warming, rapidly increas- amendments. ing energy prices, greatly improved performance of existing ° Complete ongoing design certification of the LWR plants with average capacity factors exceeding 90 ESBWR. percent, and the stimulation of U.S. energy policy (NEPDG, —COLs 2001), DOE sponsored the NP 2010 program, cost-shared with ° Provide guidance on COL generic issues. U.S industry. The principal focus of NP 2010 was to move ° Obtain USNRC acceptance of AP1000 and ES- beyond R&D to the deployment of new nuclear plants. BWR COL applications. ° Complete ITAAC demonstrations. ° Obtain two COLs. approach to evaluation • Complete first-of-a-kind engineering (design finaliza- The criteria used in the evaluation of NP 2010 were those tion) of new standardized nuclear plant designs to provide provided in the committee’s statement of task. The remainder improved safety, reliability, and economy. of this chapter contains three main sections: • Determine the plant’s capital and O&M costs, construc- tion time, and levelized cost of electricity. • Overall program description, • Provide technical support for risk insurance definitions • Goals, timetables, and progress, and (standby support) for the first six new U.S. nuclear plants • Committee recommendations. (legislated in EPAct05). licensing demonstration 3 G. Davis, Westinghouse, “The certified AP1000 standard design,” Pre- Status sentation to the committee on November 8, 2006. 4 R. Kingston, GE, “New units: ESBWR and ABWR,” Presentation to DOE solicited proposals from industry for New Plant the committee on November 8, 2006. See also D. Hinds and C. Maslak, The Licensing Projects and design completions that would dem- next generation of nuclear energy: The ESBWR, Nuclear News, American Nuclear Society, January 2006: 35-40. 5 See Nuclear Energy Institute, New Reactor Designs: General Electric 7 R. Smith-Kevern, Acting Associate Director, Office of Nuclear Power Advanced Boiling Water Reactor, 2006. Available at http://www.nei.org/ Technology, DOE, “Nuclear Power 2010,” Presentation to the committee keyissues/newnuclearplants/newreactordesigns/. on August 24, 2006. 6 See Energy Information Administration, New Reactor Designs. Available 8 T. Miller, Deputy Director, “Light water reactor deployment,” Presenta- at http://www.eia.doe.gov/cneaf/nuclear/page/analysis/nucenviss_2.html/. tion to the committee on October 17, 2006.

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 REVIEW OF DOE’S NUCLEAR ENERGY RESEARCH AND DEVELOPMENT PROGRAM onstrate the validity of the USNRC 10 CFR Part 52 process power plant licenses by the consortia are shown in Table 2-1. and its related standardization policy in assuring a reasonably The USNRC has adopted as a planning assumption that the predictable path to completion of design, construction, and required public hearings on ESP and COL applications will start of operation of new nuclear plants. Two consortia of take up to 1 year to complete, following the issuance of the utilities responded to DOE’s request for proposal, accepting Safety Evaluation Report (SER) for a COL, before an ESP or the primary goals stated above. DOE subsequently entered a COL can be granted. This additional year is not included in into contracts with the two consortia. USNRC committed the dates for USNRC approval of COLs in the DOE estimates to the licensing reviews required. Congress provided incen- shown in Table 2-1. tives through EPAct05 to enable the utilities to make prudent As of August 2007, a total of 14 companies, including investments to build the first six plants. those in Table 2-1, had announced their intent to seek a COL The NuStart Consortium9 is made up of utilities, which for a new nuclear plant: TVA, Progress Energy, Duke, South include Constellation Energy, Duke, EDF-INA, Entergy, Carolina Electric and Gas, Southern, Dominion, Entergy, Exelon, FPL, Progress Energy, SCANA, the Southern Com- Constellation, Ameren, PPL, Amarillo Power, Alternate En- pany, and the Tennessee Valley Authority (TVA) and the ergy Holdings, NRG, and TXU. Four of these companies are reactor suppliers GE and Westinghouse. The NuStart coop- seeking, or have received, an ESP that could be referenced erative agreement provides for the preparation of two COL in a COL proceeding. applications and the submission of one application to the US- NRC following a down-selection process for one technology Design Finalization at one site. NuStart is currently preparing COL applications for the ESBWR at Entergy’s Grand Gulf, Mississippi, site A substantial portion of the plant designs will be com- as well as the AP1000 at Exelon’s Clinton, Illinois, site and pleted to obtain a COL, but much more remains to encompass TVA’s Bellefonte, Alabama, site. all features of the entire plant. The 5-year program plan of The Dominion Consortium10 comprises Dominion, Con- DOE’s Office of Light Water Reactor Deployment for NP stellation Energy, GE, and Bechtel. Its cooperative agree- 2010, issued in January 2007, schedules completion of the ment includes preparation and submission of a COL for full ESBWR design early in FY 2011 (DC in mid-FY 2010) the North Anna, Virginia, site with the GE ESBWR as the and completion of the AP1000 first-of-a-kind engineering selected reactor design. The designs of both the ESBWR design in mid-FY 2011 (DC in early FY 2006). Start of and the AP1000 are being funded with direct cost-sharing construction is set at the end of FY 2010 for both designs, agreements between DOE and the companies producing the before design finalization. reactor designs. A TVA-led consortium has completed a study,11 under costs NP 2010 sponsorship, of cost, schedule, and design changes needed to deploy the GE design-certified evolutionary The funding levels of the DOE cost share of NP 2010 for ABWR at the Bellefonte, Alabama, site (TVA, 2005). The FY 2005, FY 2006, and FY 2007 were $49.6 million, $65.3 consortium is not active at this time. Another consortium, million, and $80.3 million, respectively. The FY 2008 budget Unistar, made up of Constellation Energy, AREVA, and request for NP 2010 is $114 million. As of March 2007, the Bechtel Power Corporation, is not participating in NP 2010 DOE estimated cost to complete NP 2010 was $550 million, leaving $240.8 million for FY 2009 and FY 2010.12,13 ,13 13 but is planning to submit an application to USNRC for a COL and the design certification of the French 1,600-MWe This funding is matched by the Dominion and NuStart evolutionary pressurized water reactor (EPR) from AREVA consortia, including both GE and Westinghouse. The level (DOE, 2004). of funding is about equal for each consortium and includes the payments to the USNRC to cover their licensing work. The largest portion of the funding supports the design engi- Timetables neering effort. DOE reports that industry is current with its contributions.14 The overall schedules call for obtaining the ESPs this year, the DC for the ESBWR by April 2010, the DC amend- Industry has testified that NP 2010 funding will not main- ment approval for the AP1000 by July 2008, the COLs by tain the program’s momentum, recommending that DOE FY early FY 2011, and finalization of the two designs by mid- 2008 funding be increased to $183 million (Bowman, 2007). FY 2011. The milestones for completion of the new nuclear 12 R. Smith-Kevern, Acting Associate Director, Office of Nuclear Power 9 M. Kray, Exelon/NuStart, Presentation to the committee on October 17, Technology, DOE. “Nuclear Power 2010.” Presentation to the committee 2006. on August 24, 2006. 10 E. Grecheck, Dominion Energy, Presentation to the committee on 13 T. Miller, Deputy Director, “Light water reactor deployment,” Presenta- October 17, 2006. tion to the committee on October 17, 2006. 11 See also R. Ganthner, AREVA, Presentation to the committee on 14 Communication between the DOE and a committee member on November 8, 2006. September 11, 2007.

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 NUCLEAR POWER 00 TABLE 2-1 New Nuclear Plant Licensing Demonstration Project Milestones (as of April 15, 2007) Utility/Site Early Site Permit Design Certification Construction and Operating License USNRC approvala Dominion/ ESBWR application in; USNRC Application submittal November 2007; USNRC North Anna, Va. May 2007. approval April 2010. approval April 2010. Permita granted NuStart-Entergy/ As above. Application submittal February 2008; USNRC approval Grand Gulf, Miss. April 2007. April 2010. NuStart-Entergy/ USNRC approval As above. Application submittal November 2008; USNRC River Bend, La. December 2007. approval February 2011. NuStart-Exelon/Clinton, Ill. USNRC approval August Westinghouse AP1000 DC Application submittal February 2009; USNRC approval 2006; permit granted March received December 2005; September 2011. 2007. USNRC approval of potential amendments July 2008. NuStart-Duke/TVA- Not determined. As above. Application submittal October 2007; USNRC approval Bellefonte, Ala. July 2010. aAfter USNRC approval of the ESP application, the Atomic Safety and Licensing Board holds a public hearing; upon satisfactory completion of the hearing, the USNRC commissioners grant the permit. Industry Consortia Industry further recommends (Bowman, 2007) that the total NP 2010 funding be increased by $354 million to enable The industry consortia have responded to the DOE solici- completion of the full NP 2010 scope in a timely manner, tation, proposing projects, activities, and funding require- requiring a $177 million increase by both DOE and industry ments as partners on the licensing demonstration projects for to maintain the 50 percent cost-share agreement. ESPs, DCs, and the COLs. Pursuant to contracts with DOE, the industry consortia selected by DOE are responsible for management responsibilities and organizations the management and completion of project activities, includ- ing those activities subcontracted, interfacing with and re- Office of Nuclear Energy porting to DOE on project progress and financial status. DOE also entered into a cooperative agreement with the EPRI The Office of Light Water Reactor Deployment at NE to develop generic COL application guidance and resolve provides overall management of the NP 2010 program, generic issues that would affect the licensing demonstration including program planning and development, program projects. management and monitoring, preparation and approval of procurement solicitations, contractor award selection, con- U.S. Nuclear Regulatory Commission duct of program reviews and corrective action completion, program funding authority to the operations offices and the USNRC can issue an ESP for approval of one or more national laboratories, and dissemination of program informa- sites for one or more nuclear power facilities separate from tion to DOE management and stakeholders. NE staff serve filing an application for a construction permit or a combined as project managers for specific projects, where they are license. The review of an ESP application may address site responsible for overall oversight, performance monitoring, safety issues, environmental protection issues, and plans for and management of functions related to the projects. coping with emergencies, independent of the review of a NE has assigned NP 2010 staff to interface with their specific nuclear plant design. An ESP can be referenced for project counterparts from the power companies and reactor up 20 years and can be renewed for up to 20 years. USNRC vendors as well as other subcontractors during the course of review of a DC application addresses the safety issues sur- their project management and oversight duties. As part of rounding a new nuclear power plant design independent of a their management and oversight duties, NE-NP 2010 staff specific site. Once issued, the DC can be referenced for up to periodically meet with USNRC staff to advise them on the 15 years. It can also be renewed for an additional 15 years. status of NP 2010 and to be advised on USNRC plans for The USNRC will docket and, subsequent to satisfactory handling the licensing load. NE staff also participate in vari- review and comment on all safety aspects of the applicant’s ous industry committees and task forces coordinated by the power plant design and site, issue a COL to the applicant to NEI to assure that industry concerns are fully addressed.

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 REVIEW OF DOE’S NUCLEAR ENERGY RESEARCH AND DEVELOPMENT PROGRAM build and operate the plant. The COL will be consistent with Office of New Reactors to focus on licensing and building the relevant ESP and design certification. USNRC reports new nuclear power plants in the near term. It has also estab- that it expects 21 applications for 32 new units in the 2007- lished the Human Capital Council, which is preparing plans 2009 time period.15 In addition, four companies are pursuing to strengthen the workforce by upgrading their knowledge, ESPs at seven sites; GE, Westinghouse, and Areva are pursu- increasing their numbers, and qualifying their staff to per- ing DCs or amendments to existing DCs; and Mitsubishi is form specific review tasks. The Government Accountability planning to apply to USNRC for a SER and a DC. Office has completed an assessment of the personnel situa- This surge of interest in new plants arises from tion, observing that about one-third of USNRC’s workforce with mission-critical skills will be eligible to retire through • Financial incentives in EPAct05, including FY 2010 (GAO, 2007). —Requirement for first concrete by 2013 in order to be USNRC is holding periodic public meetings with the eligible for production tax credits, industry to provide a common understanding of the emerg- —Limitation of the risk insurance to the first six plants, ing licensing framework for new plants. The early meetings with a higher level of support for the first two plants indicate that considerable additional material will be required than for the next four plants, and from the applicants. For example, USNRC is proposing that —Availability of the financial incentives on a first- the applicant apply lessons learned in plant design and op- come, first-served basis. erational programs to minimize radioactive contamination, • Requirements for new base-load capacity by utilities in reduce radwaste by-products, and facilitate the ultimate the Southeast before 2015. decommissioning, through license termination after 60 years • The probability of some form of carbon constraint (or of operation. tax) in the near future. National Laboratories To support the anticipated number of new nuclear plants, USNRC is updating its regulations, regulatory guides, stan- The national laboratories, including the Idaho National dard review plans, and other guidance documents governing Laboratory (INL), provide limited support to DOE’s NP the licensing and operation of new nuclear power plants 2010 program. So far, laboratory technical support in several (Reyes, 2006), so that these will be in place prior to the key areas has been used for soil characterization, spent fuel receipt of the first COL application, expected in the fall of transportation analysis, and economic analysis. The national 2007. laboratories are also contracted by USNRC to provide tech- The USNRC is responding to needs for future application nical support on USNRC reviews of nuclear plant safety reviews by estimating the durations of the reviews and the issues. resources needed (in staff, dollars, and technical assistance) to complete the reviews, ensuring the availability of critical standardization skills within the agency or through contracts; and by develop- ing the regulatory infrastructure to support future licensing DOE and the industry have placed strong emphasis on reviews. On August 28, 2007, the USNRC published in the standardization of each family of nuclear power plants Federal Register the revisions to Part 52, effective Septem- (EPRI, 1990). The goal is that all plants of a design fam- ber 27, 2007, which establish key rules governing new plant ily will be the same, except for limited site-specific differ- licensing activities (USNRC, 2006). ences. Standardization covers the entire generating plant: In addition to the large number of ESP, DC, and COL nuclear and turbine islands and key supporting facilities licensing reviews for new plants discussed above, USNRC such as radioactive waste treatment and includes design, is also expected to review license extensions for many of the licensing, operations, maintenance, and decommissioning. current nuclear plants and to begin the licensing process for Form-fit-function specifications provide for standardization the Yucca Mountain repository in the same period. Because of components procured competitively from subsuppliers. of this increased workload, the USNRC is currently under- Standardization also applies to commonalities in safety and staffed and is planning to add 200 staff every year for the licensing for different families of designs. next 3 years. Additional staff members will help to handle the Standardization will reduce the licensing burden for extra work, but they must be trained for this purpose, which duplicate plants and will reduce their construction time and will take up to a year depending on the level of expertise operational costs as the learning curve proceeds. It will also required to process the applications. lead to greater efficiencies and simplicity in all aspects of Organizational changes are being made to better handle nuclear plant operations, including safety, maintenance, this heavy workload. In late 2006, USNRC established an training, and spare parts procurement. Consortia pursuing COLs under NP 2010 have endorsed a USNRC design- centered licensing approach that promotes standardization 15 From the September 11, 2007, version of http://www.nrc.gov/reactors/ new-licensing/new-licensing-files/expected-new-rx-applications.pdf.

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 NUCLEAR POWER 00 of license applications. A series of letters16 to the USNRC tion bases (IDBs) for closing ITAAC. Westinghouse worked have clearly laid out team-based approaches for each of collaboratively with USNRC construction inspection per- the plant designs currently undergoing initial or revised sonnel to develop guidance for defining IDBs. This process certification. The industry consortia are implementing this also included stakeholder participation through workshops, approach by outlining the proposed content of the applica- identified IDBs, and discussed types of documentation tions and committing to response times on USNRC Requests required for verification and various scenarios that could for Additional Information (RAI) during review of the COL impact ITAAC for AP1000 systems and buildings. Black & applications. This license standardization will help to reduce Veatch showed that the principles cooperatively developed the time required for review of COL applications and the by Westinghouse/USNRC are valid and could be applied time and costs for the subsequent license applications for to a larger range of the ITAAC process when determining the same standard design. compliance with ITAAC. inspections, Tests, analyses, and acceptance criteria infrastructure Needs A primary purpose of 10 CFR Part 52 is to eliminate Infrastructure Assessment unnecessary construction delays and start-ups of operation caused by preoperational licensing or litigation. This requires As part of NP 2010, DOE tasked MPR Associates, Inc., resolution of design and siting issues before the start of with deciding what infrastructure would be necessary to construction and continued attention to assuring compliance support construction of new ALWR nuclear power plants with the COL during construction. To achieve this purpose, in the 2010 timeframe (MPR, 2004a, 2004b, 2005). MPR’s the ITAAC process was formulated to verify conformance infrastructure assessment identified several infrastructure with the COL as the construction proceeds. weaknesses and recommended for actions to mitigate their ITAAC consist of license commitments (top-level key potential impacts on new plant construction schedules. design features and performance characteristics) and a list of MPR representatives held discussions with Nuclear Steam Supply System (NSSS) vendors; equipment manufacturers; inspections, tests, and analyses to confirm that the plant was built in accordance with these licensing commitments.17 A material suppliers; module fabricators; engineering, procure- set of design-related ITAAC are prepared and submitted to ment and construction (EPC) contractors; U.S. Department of the USNRC as part of the design certification process. The Labor; labor unions; trade organizations; and the USNRC to COL applicant is also required to submit a set of project- and investigate their ability to support the near-term deployment site-related ITAAC and performs the inspections, tests, and of new plants. These capabilities were then compared with analyses during and after construction. Once the acceptance the resource requirements associated with a hypothetical sce- criteria have been confirmed, the licensee informs USNRC nario involving the construction of up to eight nuclear units that ITAAC have been met. After USNRC determines ITAAC between 2010 and 2017 to identify any resource shortfalls. criteria have been successfully met, a notice is published in For this assessment, shortfalls were defined as insufficient the Federal Register. infrastructure resources or deficiencies that would require As part of DOE’s cooperative agreements with EPRI and actions more than 5 years before the commercial operation NEI focused on resolving generic new plant licensing is- date of the first new units, not including COL application sues, DOE supported an ITAAC demonstration project. This work, site-specific design work, and normal early procure- activity was divided into two main parts: (1) working with ment activities. Where shortfalls were identified, further USNRC to develop principles on how to meet ITAAC and investigations were conducted to develop recommendations (2) applying these principles to develop ITAAC determina- and lead times that would mitigate impacts on the construc- tion schedules. 16 Dominion (North Anna), NuStart (Grand Gulf), and Entergy (River Bend) COL application for USNRC Project Nos. 741, 744, 745, Response Availability of Large Forgings and Castings to RIS 2006-06, New Reactor Standardization Needed to Support the Design-Centered Licensing Review Approach, Letter 06-480 signed by Forgings for the large-diameter, thick-walled reactor pres- Grecheck (Dominion), Kray (NuStart), and C. Randy Hutchinson (En- sure vessels (RPVs) are difficult to procure. They require a tergy), July 17, 2006. NuStart (Bellefonte) COL USNRC Project No. 740, Response to RIS 2006-06, New Reactor Standardization Needed to Support long lead time, and orders must be placed several years prior the Design-Centered Licensing Review Approach, Letter signed by Kray, to installation at the plant site. The only facility worldwide July 17, 2006. USNRC Regulatory Issue Summary 2006-06, New Reactor that can produce these components is the Japan Steel Works Standardization Needed to Support the Design-Centered Licensing Review (JSW). It is reported that 20 percent of the facilities at JSW Approach, May 31, 2006. is for nuclear equipment, with the remaining facilities uti- 17 See SECY-02-0067, staff requirements memorandum (SRM), “Inspec- tions, Tests, Analyses, and Acceptance Criteria (ITAAC) for Operational lized for other heavy equipment. The next slot available for Programs (Programmatic ITAAC),” issued September 11, 2002; “Inspec- manufacturing a reactor vessel at JSW is in 2009. Some initial tions, Test, Analyses, and Acceptance Criteria for Operational Programs steps are being taken to commit and enlarge future capacity: (Programmatic ITAAC),” issued April 15, 2002.

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0 REVIEW OF DOE’S NUCLEAR ENERGY RESEARCH AND DEVELOPMENT PROGRAM UniStar announced in August 2006 that AREVA had arranged forming its intended safety function. All components are for the procurement of forgings for the EPR. In May 2007, furnished under a Nuclear Procurement Issues Commit- Dominion signed a contract with GE Energy to order heavy tee (NUPIC)-audited quality assurance program, with the forgings and castings and long-lead components for “a pos- third-party qualifying laboratory accepting 10 CFR Part 21 sible new reactor,” presumably the ESBWR. In connection responsibilities. Documentation includes direct traceability to with the plans to build the AP1000 in China, plans are being the original equipment manufacturer. It is probable that this developed to provide substantial component manufacturing process will be employed in part during the initial deployment capacity in China as well as in South Korea, where Doosan while the buildup of N-stamped manufacturers proceeds. Heavy Industries has been selected to fabricate many of the nuclear components for the AP1000s in China. The Personnel Problem A significant concern is the limited global capacity to manufacture reactor heads and other large components with The industry reports that if 15 new nuclear plants are worldwide demand for reactor vessels, large components for under construction between 2015 and 2020, it is estimated fossil plants, parts for scrubber upgrades, liquefied natural that 247,000 new jobs will be created. The demand for pro- gas (LNG) facilities, pipelines, and new refineries. fessionals, including engineers, designers, operators, health physicists, and technicians, will far exceed the current sup- ply. Freshman engineering enrollment has actually decreased Supply Chain for N-Stamped Components slightly since 2002 and is not expected to increase in the Construction of fossil power plants, LNG facilities, pipe- coming years. During the past two decades college graduates lines, and other infrastructure for the petroleum industry is grew by 20 percent; however, in the next two decades that growth is estimated to drop to 7 percent.19 currently at a very high level. Most suppliers have adopted the ISO 9000 quality programs that are required to compete A skilled worker shortage of 5.3 million is predicted by in the global marketplace. In comparison with the 25-year the industry in the United States by 2010, and this shortage absence of business associated with new nuclear plants, is expected to increase to 14 million by 2020. As NP 2010 many companies have not maintained the quality programs is completed, and especially when the first plant is autho- required for the N stamp certification of authorization. This rized, confirmation of the demand surge and evidence of certification confirms that the American Society for Me- new commercial and career opportunities may accelerate the chanical Engineers (ASME) has surveyed the operations of supply, including overseas sources, alleviating some of the shortages.20 the certificate holder and has authorized it to use the code stamps exhibiting compliance with ASME Codes.18 A large increase in nuclear power production and addition- Many manufacturers that want to provide nuclear compo- al nuclear R&D will necessitate the education of many new nents such as valves, headers, piping, pumps, pressure ves- engineers and scientists. DOE’s current support of university sels, and core supports will be required to adopt the quality research and educational infrastructure must continue. assurance program to meet the safety standards set by the The construction of 15 nuclear plants by 2015 is expected ASME. However, it is uncertain that a sufficient number of to create 29,000 to 32,000 new construction and operating manufacturers will adapt to the nuclear marketplace in time jobs. In addition, increased demand for electricity and other to meet the demand for components. energy-related facilities will place pressure on the construc- Financial considerations have caused many of the tradi- tion workforce. A shortage of welders, ironworkers, pipefit- tional manufacturers of nuclear plant electrical and control ters, and maintenance personnel is anticipated in 2007 and equipment to eliminate their special quality assurance pro- beyond. One-third of the construction workforce is expected grams for the nuclear industry. This has opened up a third- to retire in the next 5 years, and there are not enough train- party qualification process for off-the-shelf equipment for ing programs to replace these workers. If a large number of replacing, refurbishing, and upgrading the existing plants: a plants are under construction simultaneously, the supply of process where standard commercial equipment is procured qualified tradesmen and heavy rigging equipment may not from a manufacturer and then qualified to meet USNRC be adequate. safety standards. This process has been enabled by continuing improvement in the quality of standard commercial equip- setting Priorities ment due to processes such as the ISO 9000 international standard; it includes a series of functional, dimensional, and DOE reports that the priorities of the NP 2010 program qualification tests to verify critical characteristics of the are consistent with U.S. energy policy (Public Law 109-58) equipment; assuring that the component is capable of per- and further defined by the NERAC roadmap. In his presenta- 18 ASME Code Section III, Division 1, Nuclear Power Plant Components, 19 See http://ewc-online.org/degrees-data.asp. 20 requiring compliance with ASME QAI-1, Qualifications and Duties for Jim Reinsch, Bechtel, Presentation to the committee on January 8, Authorized Nuclear Inspection. 2007.

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 NUCLEAR POWER 00 tion to the committee, the assistant secretary for NE, Dennis challenge, but subsequent deployments must be competitive Spurgeon, stated that NP 2010 has top priority in the NE in the prevailing rate, regulatory, and market environments. development portfolio. Within the constraints of funding, the Legislation to constrain the release of carbon dioxide NP 2010 program is following the high-priority roadmap rec- (CO2) is likely to be implemented within the next 10 years. ommendations to demonstrate the 10 CFR Part 52 process. For example, states in the Northeast have already taken ac- tion through the Regional Greenhouse Gas Initiative21 to establish a mandatory CO2 cap-and-trade program in the oversight methods and metrics electric power sector. In addition, California has enacted an DOE reports on the methods and metrics it uses for over- aggressive greenhouse gas control law (California Senate sight of its projects to ensure progress and accountability, Bill 1368 and Assembly Bill 32 [Nuñez/Pavley]). Federal including semiannual project reviews, periodic progress legislative proposals to limit CO2 emissions have been put report and schedule evaluations, invoice review, as well as forth in the U.S. Senate and House [S. 280, The Climate participation in periodic project meetings and conference Stewardship and Innovation Act of 2007, July 2007, and calls. H.R. 5049, the Keep America Competitive Global Warming DOE has negotiated individual interface and oversight Policy Act, August 2006]. Evaluations of these bills (EIA agreements with NuStart and Dominion to define the prac- 2007, EIA 2006) by the Energy Information Administration tices to be implemented on the COL demonstration projects. project substantial increases in the growth of U.S. nuclear These agreements required implementation of the project power capacity as a result of such CO2 emissions control management principles outlined in DOE Order 413.3 (DOE, legislation. 2003). Various project reviews are performed, including 6- The increased economic competitiveness of nuclear power month and annual review, participation in periodic project if CO2 limitations are imposed is clear from comparing es- status conference calls, and, in the case of NuStart, participa- timates of the LCOEs with no carbon tax with a $50/MT tion in the meetings of NuStart’s Management Review Com- carbon tax or its equivalent, assuming that the average natural mittee. In addition, DOE conducts monthly financial reviews gas price will settle at $6 per million Btu (Specker, 2006). using earned value data submitted by NuStart and Dominion The present state of technology is assumed in these compari- and monthly invoices. DOE has also conducted external in- sons except it is assumed that in 2020 the technology will dependent evaluations of the project baselines. The NP 2010 provide economical carbon sequestration for the Integrated program evaluates the earned value data, which measures Coal Gasification Combined Cycle (IGCC) and pulverized cost and schedule to ensure that adequate progress has been coal systems. The cost estimates (in 2005 $/MWh) are for made (EIA, 1998). DOE has also had independent program nth-of-a-kind units in a series of standard plants. The ALWR assessments performed periodically by either NERAC mem- would stay constant at $46/MWh; natural gas combined bers or outside experts. cycle (NGCC) would move from $55/MWh to $75/MWh; pulverized coal without carbon sequestration would go from $40/MWh to $81/MWh; IGCC without carbon sequestration cooperative industry–Government r&d would change from $47/MWh to $90/MWh; and advanced DOE reports that the goals of the NP 2010 program IGCC with carbon sequestration would remain constant at could not be accomplished effectively unless the program $55/MWh. is cooperative, cost-shared, and governed by cooperative Independent of the legislative resolution of CO2 emis- agreements. The success of NP 2010 depends on effective sion controls, NP 2010, as well as the EPAct05 incentives, melding of the capabilities and responsibilities of industry are needed to establish that the COL process, in the actual and government. practice of licensing and building the first six plants, will permit prudent investments in new nuclear power plants. economic issues energy Policy act 2005: Provisions for New Nuclear Plants Economic competitiveness is the primary challenge faced in near-term deployment of new nuclear plants. Studies on Loan Guarantee the economic prospects of new nuclear plants have been completed by the Massachusetts Institute of Technology Title XVII of EPAct05 conferred broad authority on DOE (MIT, 2003) and the University of Chicago (UC, 2004). The to provide loan guarantees to projects that reduce, avoid, or MIT estimate for nth-of-a-kind levelized cost of electricity sequester emissions of air pollution or greenhouse gases (LCOE) is $51-$67/MWh, and the University of Chicago and employ a new or significantly improved technology. estimate is $31-$46/MWh, indicating that coal presently Although the first solicitation does not invite preapplications has the competitive edge. Incentives provided in EPAct05, for advanced nuclear and petroleum refinery projects, future when fully defined, will allow the first plants to meet the 21 See http://www.rggi.org/agreement.html.

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 REVIEW OF DOE’S NUCLEAR ENERGY RESEARCH AND DEVELOPMENT PROGRAM loan guarantee solicitations under the final loan guarantee facilities to ensure against certain delays in attainment of program regulation could help utilities interested in nuclear full-power operation and to indemnify 100 percent of covered power raise the substantial up-front capital associated with costs up to $500 million for each of the initial two reactors these major energy projects and, combined with delay risk and 50 percent of covered costs up to $250 million for each insurance (standby support), reduce uncertainty and reduce of the subsequent four reactors after an initial 180-day delay. the cost of obtaining capital for sponsors of new nuclear In August 2006, DOE issued a final rule on standby sup- port23 that sets forth three types of events (Congress calls plants. The Loan Guarantee Office has yet to announce how it will administer the first loan guarantee, but it has said that them “inclusions”) for coverage: (1) ITAAC-related delays, additional requests for solicitations are forthcoming. (2) preoperational hearings, and (3) litigation based on this The Loan Guarantee Office issued a Notice of Proposed statutory delineation. DOE’s final rule on standby support Rulemaking (NOPR) in May 2007, which capped the total states that any ITAAC-related event, preoperational hearing, amount of loans at 80 percent of that allowed in EPAct05 or litigation that delays the commencement of full-power and limited to 90 percent the share of a loan that would be operations is considered a covered event and would therefore guaranteed. DOE will gather stakeholder input in connection be covered under a standby support contract. DOE defines with the NOPR. It values such input and believes that DOE litigation to include only adjudication in state, federal, lo- will be best served by a collaborative process for establishing cal, or tribal courts, including appeals of USNRC decisions the loan guarantee program. After resolution of the public related to the combined license to such courts and excluding comments on NOPR, the final rule will become the basis for administrative litigation that occurs at the USNRC related to future solicitations. the combined license process. Goals, TimeTaBles, aNd ProGress Production Tax Credit Production Tax Credit-Section 1306, Credit for Produc- strategy for accomplishing NP 2010 Goals tion from Advanced Nuclear Power Facilities, permits an entity producing electricity at a qualified advanced nuclear Key strategic elements of NP 2010 bode well for its power facility that is placed into service before January 1, success. A good working relationship has been achieved be- 2021, to claim a credit equal to $0.018/kWh of electricity tween DOE and its contractors in accordance with the related produced for 8 years. Among other requirements, the statu- cooperative agreements and their statements of goals, mile- tory provision specifies a national megawatt capacity limi- stones, project controls, responsibilities, and accountabili- tation of 6,000 (MWe), which will be prorated among new ties. The selection of the projects funded is, appropriately, plants that apply for licenses by 2008 and enter construction market driven. The cooperative agreement allows industry to by 2014.22 This production tax credit has been granted to convey its request for projects it deems will address the tech- renewable sources, and nuclear energy is included in this nical, regulatory, and institutional challenges to new nuclear category. The limitation is subject to an allocation process plant deployment. There is a strong focus on demonstrating to be prescribed by the Department of the Treasury. The the regulatory processes, finalizing and standardizing the statutory provision further states that the process governing designs, and implementing the EPAct05 standby support the approval and allocation of production credits is to be provisions, all of which are essential front-end activities. developed in consultation with the Secretary of Energy. Yet, other activities essential to ultimate success do not The production tax credit is administered by the Internal seem to have achieved that same focus in planning, let alone Revenue Service. The NP 2010 program will provide tech- implementation. Whereas standardization within a family of nical support for determining the eligibility requirements. designs is progressing well, it has not progressed discern- Industry has responded favorably to the program to reduce ibly on common safety, regulatory, power reliability, and financial and regulatory risk and to the incentives package. operational issues among the families. Construction planning NEI reports that utilities and reactor vendors have spent or that uses the most practicable and advanced digital simula- committed $1 billion to $1.5 billion on their preparations to tion software is not discussed in the programmatic material. build additional generating capacity using nuclear reactors. Standardization protocols, such as form-fit-function do not seem to have been established to permit competitive bidding on the great variety of smaller plant components. Subsequent Risk Insurance sections identify in detail the main deployment and infra- Section 638, Standby Support for Certain Nuclear Plant structure issues that should be addressed in the NP 2010 Delays, of EPAct05 authorizes the Secretary of Energy to strategy to assure ultimate success. enter into six contracts with sponsors of advanced nuclear 22 23 Final See http://www.irs.gov/irb/20068_IRB/ar07/html: Notice pertaining rule on standby support, Section 638(c) of EPAct05, August 13, to EPAct05, Section 1306. 2006. Available at http://www.nuclear.gov/.

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 NUCLEAR POWER 00 Progress vs. Goals and Timetables 3. Generic guidance needs to be developed to ensure efficient, safety-focused implementation of key Part 52 pro- cesses, including ESP, COL, and ITAAC verification. Overall Progress These key dimensions and solution objectives contribute Although progress has been made on the licensing dem- to an important goal of NP 2010 and are predicated on as- onstration projects, the pace is far slower than that proposed suring, through the industry’s design effort and USNRC’s in the near-term roadmap (NERAC, 2001), and there has licensing effort, that the new plants are even safer than the been further slippage against the original NP 2010 schedules. present ones. The central importance of this objective was This slippage does not suggest the high priority DOE has reiterated by the Secretary of Energy Advisory Board,24 given to NP 2010. The NE budget for FY 2008, submitted to when they wrote that “the new regulatory process has not Congress in January 2007, has begun to correct the funding been completely tested, and generating companies have un- shortfalls with an NP 2010 request of $114 million. Congress derstandably been reluctant to be the first in line to exercise has added $26.3 million to NP 2010 under the FY 2007 the new system.” Continuing Resolution, bringing the FY 2007 total to $80.3 million. Additional funding is needed to accelerate design COL Schedules. The president and CEO of Southern finalization and to pave the way for an industry decision to Nuclear Operating Company noted in testimony25 before build new nuclear plants. Industry has recommended a total Congress that timely and predictable licensing was critical of $727 million in spending by DOE to complete the NP to investor confidence in new nuclear units. A key litmus 2010 program. test for the program would be the ability of DOE and in- DOE has asked the consortia for preliminary life-cycle dustry, through the NP 2010 program, to demonstrate that baseline (cost, schedule, and scope through project comple- ESPs, DCs, and COLs can be obtained through the untested tion) data. A detailed review of this information by an USNRC processes within a reasonable and predictable time independent review team should assist DOE in putting in frame. This, in turn, would be an important bellwether of establishing baselines, which will improve out-year project the industry’s willingness to pursue a new generation of planning and lead to more effective monitoring of project nuclear plants. performance. Recognizing that substantial effort and funding are cur- rently being devoted to preparation of COL applications Licensing Demonstration for submission to the USNRC in 2007, aggressive attention should be paid by DOE and the consortia to ensuring that Solution Objectives Endorsement. The objectives of the li- the COL applications are complete and of high quality and censing demonstration projects come from recommendations that they will be evaluated in an efficient and timely manner. in the near-term deployment roadmap that action be taken to USNRC currently estimates that the review of COL applica- “resolve the uncertainties regarding the new plant regulatory tions will take about 30 months, with an additional year to approval process through actual use, and secure regulatory complete the public hearings. It is unclear to the committee approval for several reactor designs and siting applications what the basis is for the 30-month estimate. on a time scale that will support plant deployments in this Equally important, there appears to be no integrated decade” (NERAC, 2001, p. 44). In discussing the gaps that schedule laying out how the technical and legal reviews, need to be closed to achieve this goal, the roadmap identi- including any contested hearing, will be conducted and fied “key dimensions and solution objectives,” including providing a detailed schedule for achieving each milestone. three that require essentially complete resolution to achieve Other recent licensing efforts involving substantial interven- near-term deployment and which are strongly endorsed by tion suggest that detailed milestones and schedules need to the committee (NERAC, 2001, pp. 3-4): be established at the outset of the proceeding and reflected 1. The DC process must be expedited to help resolve the in a binding order issued by the USNRC at the time the ap- “time to market” obstacle to nuclear plant orders in a de- plication is formally docketed. This will require substantial regulated market. In all instances of a design submittal that effort by the industry, DOE, and USNRC in advance of the is complete and high quality, the DC process should take no formal submission of the application. With the applications more than three years, including the rulemaking phase. Experi- of two NP 2010 consortia slated for submission in the fourth ence gained from the first three DC rulemakings during the quarter of 2007, this issue requires aggressive attention. In 1990s should provide a solid basis for achieving this goal. For the absence of an effort to clearly define and establish sched- DC applications that rely significantly on design information from a previously reviewed and/or certified design, the goal should be to complete the process in less than two years. 2. ESP and COL processes must be demonstrated suc- 24 Secretary of Energy Advisory Board, Moving Forward with Nuclear Power: Issues and Key Factors, January 2005, pp. 2-3. cessfully for new plants to be built. The must be shown to 25 J. Barnie Beasely, Jr., President and CEO of Southern Nuclear Operat- be stable and predictable processes that can be completed ing Company, Testimony before the Committee on Environment and Public efficiently, in no more than 1-2 years each. Works of the United States Senate, June 22, 2006.

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 REVIEW OF DOE’S NUCLEAR ENERGY RESEARCH AND DEVELOPMENT PROGRAM ules and milestones, there is a possibility that the conduct projected by the utility commissions and independent service of these reviews, including the formal legal review required organizations in the affected area. to be undertaken by USNRC’s Atomic Safety and Licensing Vendors of nuclear steam supply systems (NSSSs) have Board, will suffer from inefficiency and unpredictability. specified the function but not the specific design of digital USNRC has not yet finalized Regulatory Guide (RG) 1.206 plant control systems and plant simulators in their DCs. Cur- on COLs, which is needed to clarify the finality of environ- rent USNRC guidance endorses older versions of Institute of mental reviews, the change process for new plant designs that Electronics and Electrical Engineers (IEEE) standards, and have already been certified, and the requirements related to the software safety analysis is too general to support efficient construction and inspection. design and USNRC review of control system software. US- Further attention should be paid to streamlining the COL NRC needs to be given adequate lead time to develop new schedule considering the ongoing efforts to standardize the guidance. This action would need to begin now to meet the COL application. The number of person-years required to start of construction assumed in the NP 2010 program. DOE process the COL application is not known at this time. It will should consider cost-sharing efforts with the IEEE and the depend on the successful resolution of all the issues arising nuclear industry to revise standards and provide advice on in the development of the standardized COL application. Pro- revision of applicable regulatory guides by the USNRC. cessing information, including time, cost, and level of effort, for the standardized COL is not available; however, process- Standardization ing the information USNRC required to certify the design of the AP600 required 6 years and 3 months. The USNRC DOE and the consortia have all emphasized the impor- review effort required 110 person-years. Westinghouse sub- tance of standardization. While standardization of the COL mitted a 6,500-page safety analysis report and a 4,500-page application is stressed for each reactor design, it is not clear probabilistic risk assessment report. Westinghouse responded that the COLs would be standardized with respect to com- to 7,400 formal written questions and attended 380 USNRC mon safety and licensing issues from one family of reactor meetings. The USNRC safety evaluation report (NUREG design to another. This seeming lack of focus on standardiza- 1512 of September 1998) was 2,700 pages long. To obtain a tion among different families of reactors is a concern. DC for the power-upgraded version, AP1000, an additional 31 It is encouraging that USNRC has adopted the design- person-years of USNRC effort was required over 2.5 calendar centered review approach. It is also helpful that agreements years, and its SER (NUREG 1793 of September 2004) was are being reached on the length of time it takes the USNRC 2,400 pages. Additional reviews of amendments to AP1000 and the applicants to respond to questions and answers. Suc- are scheduled to take more than 2 years.26 cess in this approach requires high-quality design and license Despite their efforts to prepare, it is probable that US- application preparation, supported by a thorough effort in NRC’s Office of New Reactors will be overloaded in the code scaling, applicability, and uncertainty analysis. first several years.25 Similar circumstances existed in the late 1960s, when a sudden spate of new nuclear plant orders Design Finalization caused a large backlog of construction license applications, which led to significant schedule delays and cost increases. With completion of the new plant regulatory framework The present plan is to deal with everyone on a first-come, and standardization processes discussed above, more atten- first-served basis, which may seem fair but might lead to tion has to be given to completing a standardized, first-of-a- long and indeterminate delays.27 The USNRC has already kind design of the AP1000 and ESBWR, because prudence established criteria, set forth in a November 16, 2006, staff requires that full construction should not begin without it. requirements memorandum, for prioritizing its reviews in the Design completion should be accelerated. The new Five event that budgetary resources are constrained. These crite- Year NP 2010 Program Plan schedules completion of the ria should be adapted to provide a COL queuing process to design for mid-FY 2011, but scheduling the start of construc- avoid conflicts between applicants, to ease the USNRC work- tion for late FY 2010 violates the notion of completing a load, to maintain standardization, and to assure satisfactory design before construction starts (DOE, 2006). Further, one USNRC reviews. Such an adaptation should give priority to of the most important outputs of NP 2010, a dependable cost companies that have made major financial commitments to and construction schedule estimate, is scheduled for the end deployment and have fully defined plans to build plants im- of FY 2008, some 2.5 years before design completion. mediately upon receipt of a COL. In addition, the USNRC The time squeeze between first-of-a-kind engineering could establish priority based on the shortages of electricity design completion and meeting the deployment schedules will require ordering some components a long time before full attainment of the COL. Means of avoiding the long lead 26 GeorgeDavis, Westinghouse, Information provided to the committee, time should be planned for more explicitly. Standardization November 8, 2006. protocols are also needed to permit competitive bidding on 27 USNRC, Regulatory Issue Summary on COL Prioritization, April plant components such as form-fit-function. Standardiza- 16, 2007.

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 NUCLEAR POWER 00 tion can be maintained when ordering components on a construction completion to preoperational systems testing, competitive basis by establishing the space within which the and preparation of operating instructions and employment component must fit, the type and location of its connection of simulators for operator training. to the overall system, and the function that it must provide. NSSS vendors and EPC contractors should complete the The details of design within that envelope can be determined plant design (including the routing of small bore piping, by the supplier in conformance with industrial standards and tubing, and conduit to the maximum amount practical) prior safety regulations. to starting construction, prepare a detailed critical path con- Greater attention to efficiencies of construction, opera- struction schedule, and plan for sufficient staffing for rapid tion, and maintenance in the design finalization effort will response teams at the point of work for problem resolution. lead to more efficient construction. Although focus on the Not having this level of design completion and project COL design issues is appropriate, parallel effort on the first- preparation in the past often doubled labor requirements and of-a-kind design issues outside the COL can speed up design construction schedule durations. completion. Nuclear utilities, NSSS vendors, component suppliers, material suppliers, and EPC contractors should ensure that appropriate quality assurance (QA) and quality control ITAAC (QC) programs are in place and properly implemented for Demonstration of ITAAC is not assured. The effort to the design, fabrication, construction, and inspection of new fully define the ITAAC process has been dormant for almost plants. Experience detailed in NUREG-1055 shows that QA a year but is now being reactivated through a NEI supplier and QC problems caused major difficulties in earlier nuclear committee. It is of crucial importance to economic deploy- plant construction projects. These steps ensure that the work ment that these definitions be completed promptly. With the gets done right the first time so that additional labor and construction of 15 reactors from four or possibly five manu- construction time are not needed to correct deficiencies. facturers by 2015, the demands on the USNRC to support the In sum, notwithstanding the high priority that must be ITAAC process will be significant, particularly considering maintained on first-of-a-kind design completion, plans and ASME’s requirements28 for authorized nuclear inspectors. processes for the actual steps in deployment need to be The ITAAC process may be particularly difficult to imple- established now to provide a complete basis for investment ment because of the large number of modules involved. The assessment, to assure timely initiation of construction with AP1000 involves 342 different modules (including structur- a sufficiently supportive infrastructure, and to provide guid- al, piping, and equipment modules). If the other four reactor ance to the designers on construction, operation, quality plants have about the same number of modules, the USNRC assurance, and maintenance issues. DOE’s present Five-Year will have to inspect more than 1,700 different modules. NP 2010 Program Plan does not address these issues. The Moreover, these modules will be provided by a supply chain plan terminates NP 2010 when the COL is issued, when with plants in many countries. Clearly, inspection, testing, many of these deployment actions should be ongoing. In- and analysis of this many different modules manufactured by dustry and DOE should seriously consider increasing the a large number of N-stamped companies in several foreign scope and funding of NP 2010 to address these deployment countries will be a serious challenge. issues. Critical Deployment Issues Infrastructure Needs Other than a generally stated commitment to using mod- The de facto 25-year moratorium on new plant construc- ern construction processes, DOE and the consortia have not tion in the United States, along with a prolonged period of devoted sufficient effort to critical deployment issues such as reduced government and industry funding of nuclear energy preoperational testing, advanced construction technology or R&D, has badly weakened the infrastructure needed to sup- processes, and operational training. Examples are the use of port a major expansion of nuclear electric generation capac- advanced multidimensional CAD-CAM methodologies for ity. To date, NP 2010 has devoted little effort to this issue. planning and monitoring construction and component instal- The plan seems to be to wait until plant design and USNRC lation, application of advanced digital information systems reviews are completed. A parallel rather than a series ap- to monitor and assess construction quality assurance and proach to infrastructure revitalization should be pursued to plant status, provision of a complete, construction-interac- assure that NP 2010 provides the basis for construction for tive database to assist the ITAAC process, planning for the which it is intended. NP 2010 should include work to develop preoperational testing necessary for a smooth transition from construction plans in parallel with design finalization. These plans should include the transition from construction to pre- operational systems testing, operational procedures, and 28 ASME Code Section III, Division 1, Nuclear Power Plant Components, operator training. Such planning is needed to ensure that the requiring compliance with ASME QAI-1, Qualifications and Duties for Authorized Nuclear Inspection.

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 REVIEW OF DOE’S NUCLEAR ENERGY RESEARCH AND DEVELOPMENT PROGRAM consortia’s construction time goal of 4 years or less will be the manufacturing capacity needed to achieve the ultimate met. goal of NP 2010. The construction infrastructure assessment provided by MPR Associates, Inc., for NP 2010 (MPR, 2005) contains In view of the importance of these recommendations, important recommendations bearing on this issue: DOE should follow up on them as part of the NP 2010 program. 1. The NSSS vendors should monitor the availability of large ring forgings and adjust their evaluation of Priorities procurement schedules to ensure that they will be available The priorities are appropriate and are derived from U.S. for RPV fabrication. If necessary and with financial support from their customers, NSSS vendors should purchase the energy policy, the DOE and NERAC assessments, and large ring forgings early and arrange deliveries to support management guidance for top-level utility executives. It is normal RPV fabrication schedules. If the demand for new important to monitor progress in light of those priorities nuclear units is sufficient, NSSS vendors should develop ad- and devise recovery actions in the event of program delays. ditional capacity for the supply of nuclear-grade large ring Close follow-up and guidance are needed from DOE top forgings. (MPR, 2005, p. iv) management, the industry’s top-level Nuclear Power Over- Perhaps the demand for very heavy forgings could be al- sight Committee, and the NEI New Plant Task Force and leviated by considering fabricating the cylinders and reactor should be a focal point for the independent reviews that are vessel heads from weldments. The use of weldments would planned. reduce the size of the forging equipment required and expand the supply chain. Advance ordering of these key components evaluation of oversight and metrics should be given serious consideration. A good system has been established to ensure progress 2. Reestablishment of the N-stamps by ASME should take and accountability, although limited funding has had a nega- into consideration upgrades in ISO 9000 formulated in recent tive impact on progress. Consideration was given to updating years. It should be noted that the passive plants—AP1000 the NERAC roadmap, but it was concluded that the goals and ESBWR—have significantly reduced the amount of for NP 2010 for the next 3 years are clear and no update is equipment requiring such qualification capabilities. needed. 3. Hiring highly-skilled construction workers needed to build nuclear units is expected to be a challenge. Qualified role of Joint industry–Government r&d boilermakers, pipe fitters, electricians, and ironworkers are expected to be in short supply in local labor markets…. The DOE–industry cost-sharing using cooperative agree- All other construction trades (i.e., laborers, insulators, ments is an effective way of performing R&D for nuclear equipment operators, teamsters, etc.) should be available plant development and preparing for their deployment. Past in sufficient numbers to support the new plant construction experience with that approach gained in the DOE-industry projects…. EPC contractors as a group should negotiate and ALWR program proved cost effective and valuable for pro- sign a national labor agreement with major labor unions to ducing an R&D foundation for the near-term deployment of provide flexibility in staffing nuclear construction projects new nuclear plants. (e.g., allowing union members from different areas to work at any nuclear plant construction site). This step helps ensure the needed construction workers will be available. (MPR, The most meritorious elements of NP 2010 2005, p. v) 4. Nuclear power plant operators should recruit and train The beneficial elements of NP 2010 are as follows: health physicists, operators, and maintenance technicians at their existing nuclear plants to serve as replacements at their • The focus on licensing demonstrations, including joint existing plants and to staff the new GEN III+ plants. This planning with USNRC, ensures that the plant operator’s staff is available for training • Commitment to standardization, and for supporting the start-up, commissioning, and testing • DOE–industry partnership through cooperative agree- of new GEN III+ units. (MPR, 2005, p. v) ments, which offer 5. Interactions are needed among the stakeholders, reac- —DOE program management and authority, tor manufacturers, utilities, architect engineers, construc- —Industry experience in design, operations, costing, tion firms, NEI, the Institute for Nuclear Power Operators and the marketplace, (INPO), DOE, USNRC, and universities to expand their —Provisions for completing plant design so that real- efforts to increase the number of professional staff and istic plant cost and construction time estimates can skilled craftspeople and construction personnel as well as be made.

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 NUCLEAR POWER 00 Balance of r&d Within scope of resources As important and necessary as these elements are, they considering NP 2010 objectives are not sufficient to assure success without increased effort on planning for, and initial implementation of, subsequent Although there is a substantial amount of development deployment needs. work needed to assure that new safety issues are addressed and that timely and cost-effective deployment is brought ePact05 incentives about, little research is being performed under the NP 2010 program. As discussed, the essential research has been com- EPAct05 provisions for the first six new nuclear plants are pleted. In the 1990s, DOE cost-shared the R&D that defined, essential to paving the way for the multi-billion-dollar private tested, and obtained licensing acceptance for advanced LWR investment needed to construct and operate these first plants. designs. The total cost of that R&D was ~$800 million, The definitions of the incentives have not yet been fully including in-kind contributions from the U.S. vendors, and spelled out, nor have the qualifications for recipients or the DOE funding of ~$200 million. administration of the incentives themselves been completed The mission of NP 2010 is to complete the licensing and and should be expedited. DOE needs to take all necessary final design of new plants and prepare for their deployment; steps to ensure that the guidance for the incentives authorized no further research is needed to accomplish this purpose. by EPAct05 is finalized. Additional research on these new designs could impede Although the direct responsibility of NE for managing deployment. NP 2010 is limited to standby support, all of the EPAct05 incentives for which DOE shares major responsibility are identifying Promising New r&d Not currently key to the success of NP 2010. The loan guarantee program, included in NP 2010 critical to new plant construction, has not yet been finalized. The reason cited is that industry has not yet committed itself No research is proposed by DOE or the industry for NP to building a new plant. Yet, the incremental funds expended 2010. NE has been sponsoring a small amount of additional by industry to date exceed $1.5 billion. Recent progress has R&D, cost-shared with industry, to improve the performance, been made by issuance of the loan guarantee NOPR, but the operating cost, and long-term operational reliability of proposed caps are lower than had been anticipated and al- existing nuclear plants under DOE’s Nuclear Energy Plant lowed by EPAct05, raising concern about their adequacy to Optimization (NEPO) program. But no funding has been assure deployment of the first plants. provided for relevant new projects for FY 2008. A small NP Effective application of the EPAct05 nuclear standby 2010 research effort on high burn-up fuels was cost-shared support provisions will contribute significantly to lowering with industry in the FY 2005 budget, but none is planned for the busbar costs of the first six plants, and it is essential that the next 3 years. NP 2010 develop the contract terms for insurance against the Substantial R&D on safety, aging of materials, component potential risk of delays with these plants. reliability, coolant chemical controls, inspection/monitoring, and the man-machine interface is currently being funded by commercial implications of NP 2010 Portfolio the utilities in support of the current operating plants. The results from this R&D can also be applied to the new plants The commercial implications of NP 2010 and the EPAct05 when they are deployed. A DOE-industry cost-shared R&D nuclear incentives are immense. Successful demonstration of effort expanding this program and including R&D on high- the new regulatory process will remove much uncertainty burn-up LWR fuel would be of significant value. Recently, from estimates of construction cost and the time-to-market EPAct05 authorized a new cost-shared R&D program, the for building nuclear generating stations. Loan guarantees and Nuclear Energy Systems Support Program (NESSP), with production tax credits are essential for increasing the avail- the same purpose as the LWR R&D program described ability of capital at a much reduced cost for the first six new above, but no action has been taken on it by DOE. The R&D plants. Risk insurance protects companies from the financial needed to improve operational plants was defined in the joint losses caused by unexpected regulatory or litigation delays. DOE/industry LWR Strategic Plan (DOE, 2004). If the goal The incentives may lead to the building of several privately of high-burn-up fuel is achieved, not only will fuel economy funded nuclear plants every year from 2015 to 2020. improve, but capacity needs for the spent fuel repository will Commercial deployment of the new plants would entail also be reduced (EPRI, 2006). sizeable private investment. NEI estimates that a $727 mil- This R&D should be pursued by NE outside NP 2010 lion total government investment in NP 2010, matched by through NEPO or NESSP to help assure the safety and reli- equal industry funding, will stimulate over $40 billion of ability of U.S. nuclear plants. This R&D should be given a investment commitments to new nuclear projects by 2015, relatively high priority in the overall DOE nuclear energy assuming that a substantial fraction of the plants scheduled R&D portfolio. But, adequate funding of design finalization for COLs are constructed in that time frame. in NP 2010 should have higher priority than cost-shared

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 REVIEW OF DOE’S NUCLEAR ENERGY RESEARCH AND DEVELOPMENT PROGRAM LWR R&D if funding conflicts arise. The value of such R&D license applications and meet schedule commitments for would come from enhancing the effectiveness of a growing response to questions. In spite of the substantial effort that U.S. nuclear fleet by USNRC and the industry are devoting to preparing for the COL reviews, the planned schedules are still too long. De- • Assuring continuing and improved safety and reli- tailed milestones and schedules need to be established at the ability, a sine qua non for sustaining the nuclear role in the outset of the COL hearings and reflected in a binding order nation’s electric energy portfolio; issued by the USNRC at the time the application is formally • Increasing the investment value of the fleet by extend- docketed. The ITAAC process needs to be defined fully and ing its productive life; and demonstrated to ensure against construction delays caused • Reducing capacity requirements for the spent fuel by questions about licensing compliance or by litigation. repository. The recent surge of interest in new plant construction, with 15 companies planning to apply for COLs for as many as 33 plants in the 2007 to 2009 time frame, will greatly in- relationship of r&d Program to the idaho Facilities crease USNRC’s workload. To address this crunch, priority Program and Nerac should be given to applicants that have made major financial The Operations Office of the Idaho National Laboratory commitments to deployment and have fully defined plans to (INL) provides technical and administrative support to the build the plant immediately upon receipt of the COL. NP 2010 program. This support includes solicitation and Recommendation 2-2. DOE should propose and support procurement activities, contract administrative activities, and headquarters project management and technical activities. a joint DOE/industry/USNRC high-level working group to INL has provided technical support to NP 2010 in soil char- ensure that the following transpire: acterization, spent fuel transportation analysis, and economic analysis. NP 2010 also cost-shared fuel research in 2005, • High-quality, complete applications are submitted and when DOE transferred funds to INL to pay for facility usage. response times to requests for additional information (RAIs) Currently, however, no technical support is being provided are met as stipulated in USNRC’s design-centered licensing to NP 2010 by INL. review approach. • Schedules for review of DC, ESP, and COL applica- tions, including the legal review by the Atomic Safety and FiNdiNGs aNd recommeNdaTioNs Licensing Board, are clearly established, complete, contain mechanisms for monitoring progress, show 3 years or less strategy for accomplishing Goals for review and approval of the initial COL applications, Finding 2-1. Unless the commercial fleet of LWRs grows, and show shorter durations for subsequent same-design nuclear power will be a diminishing energy resource for the applications. United States and there will be little need for all of NE’s • ITAAC is being developed so that its implementation longer-term research programs. will minimize interruptions in construction and preopera- tional litigation delays. To foster growth of the commercial fleet of LWRs, the • Common safety and licensing issues among the families committee recommends the following: of reactor designs are fully standardized. Recommendation 2-1. NE should make the successful standardized design completion completion of the NP 2010 program its highest priority. It should take all necessary steps to ensure that guidance for the The present schedules for completion of the full designs loan guarantee program authorized by the EPAct05 is final- need to be accelerated to be consistent with the goal of de- ized. NE should immediately initiate a cooperative project termining cost and construction time estimates scheduled for with industry to identify problems that arise in the construc- mid-FY 2008 and completing first-of-a-kind design before tion and start-up of new plants and define best practices for the start of construction. In addition to standardization across use by the industry. the families of reactor designs, as recommended above, design standardization efforts also need to be expanded to cover: licensing demonstration USNRC and industry need to improve the presently • Construction, operational, and maintenance efficiencies, planned pace of COL reviews, avoiding review of already- • Protocols such as form-fit-function to permit competi- settled issues and setting a more challenging schedule that tive bidding on the great variety of smaller components for assumes the applicants will submit high-quality design and plants, and

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 NUCLEAR POWER 00 • Change processes and operational standards for the extension beyond 60 years. If the goal of high-burn-up fuel plant life. is achieved, not only will fuel economy improve, but also the capacity requirements for the spent fuel repository will be Recommendation 2-3. DOE should work with the industry substantially reduced. The R&D can be applied to new plants consortia to increase efforts to standardize safety and licens- when deployed. Although Congress has authorized funding ing issues across all families of reactor designs. DOE should for this kind of R&D (NESSP), DOE has not submitted also provide additional cost-shared funds to accelerate the budget requests for that purpose. schedules in the NP 2010 Five-Year Plan. Recommendation 2-7. DOE should evaluate the need for a reinvigorated R&D program to improve the performance of deployment and infrastructure issues existing nuclear plants in a DOE-industry cost-shared effort The 25-year-long suspension of new plant construction separate from NP 2010. The estimated benefits to society in the United States has badly weakened the infrastructure should substantially exceed the government investment. In the needed to support a robust and growing nuclear power in- event of funding constraints, NP 2010 funding for new plant dustry. A vigorous and comprehensive program to strengthen deployment should have priority over this R&D for LWRs. it should be carried out to assure that NP 2010 provides the basis for construction for which it was intended. reFereNces More intensive construction planning and the applica- Bowman, F.L. 2007. President and CEO, Nuclear Energy Institute, Testi- tion of advanced construction technologies are needed to mony for the Record to the House Appropriations Subcommittee on assure that construction time will be no more than 4 years. Energy and Water Development, March 16, 2007. The scope of this planning should cover the transition from Department of Energy (DOE). 2003. Manual 413.3-1, Project Management construction to preoperational systems testing, operational for the Acquisition of Capital Assets, Implementation, Deputy Secretary procedures, the man–machine interface, and operator train- of Energy Order 2003-004184, March 31, 2003. DOE. 2004. U.S. DOE/Nuclear Industry Strategic Plan for Light Water ing. The impact of these issues on the success of the NP 2010 Reactor R&D, Washington, D.C., February. program calls for reconsideration by both DOE and industry DOE. 2006. Department of Energy Five Year Plan, Office of the Chief of the decision conveyed in the present DOE Five-Year Plan Financial Officer. March 2006. to terminate NP 2010 when the COL is issued. Energy Information Administration (EIA). 1998. Earned Value Management System, ANSI/EIA 748-A-1998. Recommendation 2-4. NE should immediately initiate a EIA. 2006. Energy and Economic Impacts of H.R. 5049, the Keep America Competitive Global Warming Policy Act, SR/OIAF/2006-03. August. cooperative project with industry to identify problems that EIA. 2007. Energy Market and Economic Impacts of S. 280, the Climate have arisen in the construction and start-up of new plants and Stewardship and Innovation Act of 2007, SR/OIAF/2007-04. define best practices for use by the industry. Electric Power Research Institute (EPRI). 1990. Advanced Light Water Re- actor Utility Requirements Document, Volumes I, II, and III. March. Recommendation 2-5. DOE should include within the NP EPRI. 2006. Program on Technology Innovation: Room at the Mountain, Analysis of the Maximum Disposal Capacity for Commercial Spent 2010 program a DOE/industry workshop to identify activi- Nuclear Fuel in a Yucca Mountain Repository, EPRI 1013523. ties that would revitalize infrastructure for the construction Government Accountability Office (GAO). 2007. Human Capital Require- of new nuclear plants, including the nuclear qualification of ments and Anticipated New Reactor Applications Will Challenge NRC’s vendors and constructors; manufacturing capacity; and the Workforce. GAO 07-105. July. Massachusetts Institute of Technology (MIT). 2003. The Future of Nuclear availability of professional staff and skilled craftspeople and Power, An Interdisciplinary MIT Study. construction personnel. Additional tasks that merit further MPR Associates, Inc. (MPR). 2004a. Construction Schedule Evaluation, DOE support should be identified at this workshop. MPR Report 2627. September. MPR. 2004b. Application of Advanced Construction Technology to New Recommendation 2-6. DOE should fund a taskforce to Nuclear Plants, MPR Report 2610. September. MPR. 2005. DOE NP 2010 Nuclear Power Plant Construction Infrastructure work with industry groups on construction technology and Assessment, MPR-2776. October. planning to ensure that consortia construction time goals of National Energy Policy Development Group (NEPDG). 2001. National 4 years or less will be met. Energy Policy. May. National Research Council (NRC). 1992. Nuclear Power: Technical and Institutional Options for the Future. Washington, D.C.: National Acad- r&d relevant to the NP 2010 Program emy Press. Nuclear Energy Research Advisory Committee (NERAC). 2001. A Road- R&D needed to improve operational plants has been car- map to Deploy New Nuclear Power Plants in the United States by 2010. ried out primarily by industry and supplemented by joint Washington, D.C., October 31. cost-shared efforts with DOE under the NEPO Program. The Reyes, L. 2006. Semiannual Update of the Status of New Reactor Licens- work includes advanced materials, high-burn-up LWR fuel, ing Activities and Future Planning for New Reactors, SECY-06-001, January 31. coolant chemical controls, equipment reliability, and life

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0 REVIEW OF DOE’S NUCLEAR ENERGY RESEARCH AND DEVELOPMENT PROGRAM Specker, S. 2006. Emission-free Electric Generation Prospects, Resources University of Chicago (UC). 2004. The Economic Future of Nuclear Power. of the Future Policy Forum. Washington D.C., March 30. August. Taylor, J.J., and J. Santucci. 1997. The advanced light water reactor U.S. Nuclear Regulatory Commission (USNRC). 2006. Standard Review programme: An international endeavor. Nuclear Energy 36 (4): Plan (NUREG-0800) Proposed Revisions and Combined License (COL) 313-321. Application Guidance, November 27. Available at http://www.nrc.gov/ Tennessee Valley Authority (TVA). 2005. ABWR Cost/Schedule/COL reactors/new-licensing/col-appl-guide.html#draft. Project at TVA’s Bellefonte Site. August.