NuScale SMR cost headed off-scale?

Nuscale SMR-DOE

True to form, every new generation of commercial nuclear power development project thus far has grossly failed to control its construction cost-to-completion and maintain estimates construction time-to-completion. It was certainly the death knell in the United States for Generation III designs and the “nuclear renaissance” launched by Congress in 2005. Seventeen years later, only two of the 34 units for which utilities submitted applications to the Nuclear Regulatory Commission (NRC) to construct and operate “advanced” reactors, are now approaching completion and commercial operation. Georgia’s Vogtle Units 3 and 4 are more than double their original estimated cost and many years behind schedule. The rest of those units have been suspended, withdrawn or abandoned mid-construction with $10 billion ratepayer dollars lost to sunk cost.

So it comes as no surprise that Generation IV’s lead candidate, NuScale’s “Carbon Free Power Project” (CFPP), recently issued its first dramatic announcement that the estimated cost for electricity generation from its Small Modular Reactor VOYGR design (a yet-to-be certified 77-MWe unit) has increased nearly 100% with new projected construction costs.

What is more, on top of the appearance of NuScale’s runaway cost, is the NRC staff’s public release of a disturbing non-proprietary analysis of the VOYGR  “Preapplication Readiness Assessment Report of the NuScale, Power, LLC Standard Design Approval Draft Application,” November 15, 2022, that reveals the unproven reactor design’s “not ready for prime time” safety review.

Originally, NuScale signed an agreement in January 2021 with 36 of the 48 members in the western public power consortium Utah Associated Municipal Power Systems (UAMPS). CFPP first envisioned 12 units of NuScale Small Modular Reactor (SMR) clustered into one facility and control room on federal land at the Department of Energy’s (DOE) Idaho National Laboratory (INL). The estimated cost was set at $55 per megawatt hour (MWh).

By Summer 2021, CFPP subscribers dropped to 27 UAMPS members after some municipalities abandoned the project on cost concerns. When UAMPS then downsized the project to six units CFPP raised the estimated price to $58/MWh.

Because of rising construction costs that have always plagued nuclear development, CFPP now projects the estimated cost range will be between $90 and $100/MWh. This first dramatic cost increase includes a DOE award of $1.4 billion to the UAMPS pilot program and an additional $30/MWe through the Biden Administration’s Inflation Reduction Act 2022.

One municipal representative described the cost increase announcement as “a punch to the gut,” while another member told his board of directors that CFPP will “probably fail” the economic competitive test.

What happens next is a question as more municipalities ponder the odds of other UAMPS members abandoning the project without attracting new members?

As for NuScale securing the required the design certification and completing a pre-licensing application review by NRC, things are not going smoothly either. Just as would-be customer financial confidence has been shaken, the NRC staff has issued findings of “several challenging and/or significant issues” in the NuScale VOYGR reactor safety review. Dr. Edwin Lyman with the Union of Concerned Scientists is quoted in the trade journal, UtilityDive,  to say, “The NRC’s assessment clearly shows that NuScale’s standard design approval draft application for the 77 MWe module is not ready for prime time”. He continued, “Of most concern, there is no evidence that NuScale has done the hard work yet to fully evaluate the major safety impacts of its uprated design.”

In the NRC readiness assessment letter to NuScale, NRC staff has identified a number of significant unaddressed safety concerns, gaps and deficiencies related to public health and safety that have been downplayed in industry and government promotions for the unproven Generation IV reactors. The findings are likely to introduce significant delays to the NRC certitifaction process. Here are a few examples of their findings:

1) The VOYGR design’s containment vessel material/reactor vessel material would be comprised of types of stainless steel that lack operational experience and material data for application in  nuclear reactors. NRC staff identifies that NuScale’s analysis is not sufficient to support the NRC’s  “reasonable assurance” standard for a public health and safety determination under the reactor core’s harsh operational conditions (combined neutron bombardment and thermal attack) that can embrittle the pressure vessel wall base metal and weld material. The staff will require NuScale to provide the technical basis to support NRC General Design Criteria requirements for the proposed novel material selections;

2) The NRC staff found that NuScale has also apparently “removed information needed to support a reasonable assurance of public health and safety determination” relating to the VOYGR design’s seismic qualification of other safety-related systems, structures and components without adequate explanation;

3) The staff further found deficiencies in NuScale’s technical analysis for “aircraft hazards” and “explosion pressure waves” on  reactor safety-related systems, structures and components.

These questions raise significant public concerns as the nuclear industry and the NRC are preparing to remove federal requirements around Generation IV reactors for utility, state and federal planning, coordination and maintenance to reasonably execute offsite radiological emergency plans in the event of an accident or security-related event. This departure from a decades of practice of “defense-in-depth” would discontinue state and federal involvement and financing to maintain emergency public notification systems, offsite population evacuation zones beyond the reactor property line, designated evacuation routes to offsite radiological decontamination and recovery centers and the predistribution and stockpiling of potassium iodide (KI) for prophylactic protection of the thyroid from radioactive iodine gas that would be released during a nuclear accident.

The timing of these revelations comes with the November 28, 2022  publication of an opinion piece “Small modular reactors will not save the day: The US can get to 100% clean power without new nuclear,” by Dr. Arjun Makhijani with the Institute for Energy and Environmental Research (IEER).  Dr. Makhijani presents a clear rebuttal to the industry and government argument that extremely expensive nuclear power is necessary to decarbonize our electricity sector in order to mitigate a climate crisis.  In order to have any chance of successful mitigation, significant carbon reduction on a large scale,  while necessary, is not the only critical factor but equally important are least cost per megawatt hour and quick reliable deployment, critical factors that nuclear power has repeatedly failed to accomplish.

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