Plan puts the cart before the horse – SMR designs aren’t complete and guaranteeing a market destroys the review process
Rosner, 11 – director of the Energy Policy Institute at Chicago. He was the director of Argonne National Laboratory (Robert, “Small Modular Reactors – Key to Future Nuclear Power Generation in the U.S.” November, http://epic.uchicago.edu/sites/epic.uchicago.edu/files/uploads/SMRWhite_Paper_Dec.14.2011copy.pdf)
x The current state of the licensing framework for SMRs is less mature than that in place for GW-LWRs at the time of initiation of the NP2010 program. At that time, the NRC licensing process was fully developed on paper, and the objective of the program was to demonstrate the process through the development of lead COL applications. As a consequence, there remain considerable uncertainties regarding the economic impact of the licensing process, especially in regard to the next three points.
x Additional licensing issues may arise as SMR design and license applications are further developed. Although the ANS, NEI, and NRC efforts have developed systematic inventories of SMR licensing issues, SMR engineering design efforts are at a very early stage, and new issues may arise. The precise level of engineering design is “business proprietary.” Based on informal discussions with SMR industry representatives, the study team believes that current SMR designs are very preliminary in their evolution (i.e., less than 20% complete). By comparison, engineering design for GW-scale Gen III+ reactors was estimated to be about 30% complete at the time of submission of design certification applications to the NRC. Even at this level, NP2010 participants advised the study team that the review process for NRC design certification would have been more efficient if additional engineering had been completed prior to submission of DC applications to the NRC.
Accelerating SMR construction it during the review process leads to catastrophic accidents
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