For decades, winning regulatory approvals for nuclear power sites has been a daunting process. Dozens of studies spanning many years are typically required before an application can even be considered by the Nuclear Regulatory Commission (NRC). This has been standard operating procedure within the nuclear power industry since its inception.
Today, with the introduction of advanced nuclear technology and small modular reactors (SMR), the early site permitting (ESP) process defined within 10 CFR 52 has drawn more recent attention as an effective means for owners to qualify sites for future nuclear generation without making a technology selection. Along with the regulations, there are options in place that are intended to alleviate any concerns by the general public about whether a proposed nuclear power facility would be located in sensitive areas.
Technical studies establishing meteorology, seismic, geology and hydrology conditions are only a few of the early-stage evaluations required. Additional studies profiling the regional ecological profile, noise issues, socioeconomic and demographic conditions, archaeological or cultural concerns, local land use constraints and emergency planning procedures are also in the mix.
Understanding the Landscape for SMRs
Many advanced reactor technologies now nearing commercial scale deployment will offer greatly improved fuel design, operational performance and, above-all, significant safety improvements at these new nuclear facilities. Several promising technology pathways offer the potential for nuclear power to provide the safe, carbon-free electricity that will address significant challenges arising from decarbonizing power grids around the globe.
An SMR being developed by NuScale has received early-stage approvals from the NRC and is currently ahead of competitors in terms of development. This NuScale design benefits from a passive cooling system that requires no external source of water or operator actions indefinitely in the event of a design basis accident. Other technologies, such as X-energy feature improved fuel designs and high-temperature process heat applications and show great promise with similar safety profiles and operating advantages. These new SMRs offer the flexibility to be sited on parcels of land that will be ideal for co-generation.
It’s understandable that much attention has been focused on development of these exciting new technologies, but it’s time now to begin shifting some attention toward the critical steps of permitting these facilities in locations and on sites that will offer the most benefits for carbon-free grid support and other operational advantages needed by utilities, and the power sector in general.
New Vision for Siting Nuclear
As a result of the well-documented issues impacting the nuclear power industry, there has been very little permitting activity in recent years. The Tennessee Valley Authority’s (TVA) Clinch River site is an example of a location that has successfully moved through the NRC’s ESP process in recent years.
Though the NRC has stated that it will streamline its ESP process, it currently is projected to take approximately four years or longer to complete. Developing and submitting an ESP application is a complex process requiring input from multiple disciplines addressing all environmental, geological and safety characteristics of a proposed site. Applicants must conduct extensive site characterization studies to perform analysis required by the NRC. These requirements include a Site Safety Analysis Report (SSAR), an Environmental Report (ER) and numerous other formal reports as a prerequisite before an application can even be submitted. The SSAR establishes site-specific criteria needed to design and build a facility at the selected location, including defining seismic hazards, severe weather, and flooding, in addition to establishing weather and hydrogeology flow patterns that will define how a potential accident or release of radioactivity will impact the nearby environment and populations. The ER addresses the impact of the proposed facility on the surrounding community and environment, including water, air quality, noise, cultural resources, ecology, socioeconomic, and transportation.
A number of steps are being considered under an EPRI Early Site Permit Model Program Plan that could shorten the ESP timeframe substantially, possibly even to as few as three years. This will be enabled by a number of efficiencies, including certified plant designs that are pre-approved by the NRC. Though site characterization studies still would be required to certify that the site is suitable for standardized design, a limited work authorization to perform non-safety activities on the site also may be a possibility, under the EPRI-backed program.
Upon completion of required studies, an application is submitted to the NRC for completion of safety reviews. If the application passes muster, the site permit may be issued. Initial validity would range from 10 to 20 years, with the possibility of renewal for an additional 10 to 20 years. The goal is to establish certainty to license the site for a nuclear power plant.
Start Now or Risk Falling Behind
Currently, sites being considered for ESP vary from government owned land to private property owners, creating different considerations for utilities as well as NRC involvement.
Some utilities considering adding nuclear to their generation portfolio are looking at locating SMRs on the sites of retired fossil-fueled power plants, within areas of historical coal mining operations, or along large water bodies. With these sites in close proximity to existing high voltage transmission infrastructure and availability of large tracts of land that has already been through some level of environmental review and siting analysis, the ESP process could be shortened. Still, even with those advantages, additional updated studies will be required, primarily to verify whether any seismology issues could pose concerns for site safety, or whether there are other issues such as environmental and cultural sensitive areas, and local demographics. A proposed nuclear site has to be fully characterized to meet NRC requirements.
Manage Risk With Early Preparation
Even with the economies that are anticipated from smaller and more flexible advanced nuclear reactors, development and construction costs may likely run into the billions of dollars. A pre-site evaluation process represents only a small fraction of those later downstream costs and can help utilities and developers avoid sinking millions into development of a site that could eventually turn out to be unsuitable or not approved by NRC.
Much of this preliminary siting work can be performed as desktop reviews utilizing publicly available information such as land ownership records and water and wetlands datasets. This is a viable and cost-effective way to expedite the process. However, it must be noted that locations that rank as most favorable will still need boots on the ground with professionals working on-site to perform the actual data gathering, whether it be water samples, wildlife observations or drilling and core sampling.
Site selection can evaluate a specific area based on a business need or consider redeveloping a brownfield site. For instance, a utility may consider a former power plant location. These sites that are near inactive coal mines and have not completed reclamation could appear as good candidate sites, but until evaluated could be of concern for potential geology or ecological issues. Since NRC recommends that at least three sites should be considered as part of the ESP application, these sites will be subject to detailed survey work and analysis.
Furthermore, as part of the ESP application and NRC license approval process, owners need to be aware that a Siting Study that documents the site selection process will be required. From this analysis, the highest-ranked candidate sites will be identified and carried through evaluation in the Environmental Report (ER). NRC will be engaged throughout preparation of the ER, conducting pre-application site visits, readiness reviews and audits. Ultimately, the owner's ER must be deemed sufficient for NRC to rely on for preparation of their own Environmental Impact Statement (EIS) to comply with the National Environmental Policy Act (NEPA). Burns & McDonnell teams have direct experience navigating the NRC licensing process and preparing ERs and all levels of NEPA documentation, including requirements for decommissioning power facilities, mine reclamation, and closure of coal combustion residuals left on-site. The evaluation will need to consider the environmental impacts of proposed actions and reasonable alternatives (including site and energy alternatives). With a multidisciplined team conducting these studies in a timely manner and compiling the data into concise deliverables, the resulting efficiencies will assist with the NRC review and the eventual preparation of the ER.
All players within the power industry are working hard to address the siting requirements for future SMR facilities. Though most of these facilities are likely to be built on public land in the early going, some projects may shift to private land as well. For example, a proposed project calling for an advanced SMR nuclear facility designed by X-energy on a Dow plant site could establish a new model for the NRC to consider in issuing approvals.
The total acreage required for siting next generation SMR facilities is much smaller than traditional large nuclear plants and is being refined and reduced by technology vendors. Though it is reasonable to expect that smaller footprints would be allowed for SMR generating facilities, a permitting and siting team with a deep understanding of NRC requirements will help developers with the required studies and evaluations that will certainly be required for NRC approval.
The myriad of unknown factors ahead are why it is prudent to move forward now with a series of cost-effective studies. These due diligence steps will provide the data and analysis needed to move expeditiously through the NRC application process.
Though it currently appears owners have a 10-year window to prepare, those seriously considering adding nuclear to their resource mix may be far behind the pack if they do not start now. The chances of stumbling over site selection can be greatly minimized with an experienced team on your side.
A number of advanced nuclear technologies that are nearing commercial deployment could alleviate concerns over grid stability as fossil-based thermal baseload power facilities are retired.
