Part 2. Prototype Testing in Practice

Figure 1. The EBR2, a successful prototype and model for what needs to happen.

Underwriter Certification requires that the plants be insurable. This means the insurer must be able to gauge the risk he is assuming. Risk is a combination of the probability of a release of size X and the harm associated with that release. He needs:

1) A firm table of radiation harm compensation payments. The Gordian Knot Group (GKG) suggests using the Sigmoid No Threshold harm model to create that table. Once you have such a table; and you know the plant's location; estimating the harm associated with a given release becomes a reasonably straightforward exercise.

2) Enough information about the design, so he can estimate the likelihood of that release.

For new designs, he does not have that information. The only way he can get that information is through testing. And by testing I mean not only tests that confirm that the design behaves as predicted under normal operation; but physical imposition of the upsets and failures that the designers claim the plant can handle. This includes tests of back up safety systems. The only way back up systems can be fully tested is by disabling the frontline safety systems. If and only if the design passes all these tests, can underwriters have confidence in the design, and that design be insured.

The EBR2 is a prototypical example. The EBR2 was a 62 MW thermal/20 MWe fast breeder. In 1986, the operators brought the reactor to 100% power, gagged the control rods so they would not insert, abruptly shutdown all the pumps simulating a station black out, and then did nothing. They just sat there. The reactor shut itself down and took care of the decay heat. There was no damage. The EBR2 was restarted later the same afternoon.

How should we implement such testing? Here is the Gordian Knot Group proposal.

Infrastructure

The Feds designate a portion of some unpopulated federal reserve as a nuclear prototype testing park. Hanford Reservation in Washington would be my choice, but there may be better locations. Since some of the tests will require disabling safety systems, the test sites should be at least 10 km from the nearest residence. The park would be fitted with security, and infrastructure that is a common requirement for all or almost all concepts. This could include a heat sink for rejecting or better using the energy produced by the prototypes.

The test programs will create waste streams. The protopark must have a facility for disposing of Low Level Waste (LLW) and storing High Level Waste (HLW). The LLW facility will need to be able to handle Class C material. The HLW facility will look very much like the dry cask storage facilities that are currently handling the spent fuel from some 60 reactors around the country. Typically these pads are less than an acre in size.

Tenant pays.

Here's a key point. The park would be run on user pays basis. Each tenant would pay rent and other usage fees based on how much of the park's land and services it required. Each would build its prototype entirely with its own money. Each would also be required to leave its site in an approved condition at the end of its tests. This would mean that the market and not politicians would choose which concepts would apply. It also avoids the ugly situation where the moocher takes taxpayer money, but keeps the IP he developed with our money. It would also mean that, if the park is successful, it will cost the taxpayer little or no money.

Liability.

The government must decide on a reasonable, worst case, third party casualty cost. This can be based on a 100% release of the volatile fission products. But it must use a reasonably realistic dose-harm model do this. The GKG recommends Sigmoid No Threshold (SNT) for this purpose. Under SNT, the harm falls off at better than the third power of the distance. The harm 10 kilometers from the source is less than one thousandth the harm at 1 kilometer. The government would require that the tester post a bond for the worst case casualty. For sufficiently remote test locations, the amount of this bond should be affordable. The bond should also cover the costs of decommissioning and removal.

In the event of a release during testing, the actual compensation must be based on the Lost Life Expectancy for the dose profile each individual incurred and the same dose-harm model, and nothing else. Once that dose profile is established, the payment would be both automatic and not subject to dispute. The compensation procedure would be exactly the same as it the release occurred from a plant in normal operation.

This brings the market into play in a salutary way. If the bond is reasonably set and the tester cannot find an underwriter for this bond, then he should not be testing. Furthermore, it would be a requirement that the insurer have knowledgeable overseer(s) at the tests. The overseer has the authority to yank the bond if she is uncomfortable with how things are going. This feature would also make the bond much more affordable. If the bond is yanked, then all or almost all of the price of the bond would be rebated. This will keep the insurer honest if the tests are going smoothly. As soon as the bond is yanked, further tests would be illegal and the prototype would have to shut down.

Government oversight of the tests would be limited to setting the value of the bond and approving the insurer and the terms of the insurance including the identity of the overseer(s).

Test Protocols

The list of required tests and trials would be determined by the applicant's Certification Society, which would witness and sign off on the successful completion of each test. The Certification Society would have to balance the need to convince the insurers that the design can handle all the casualties and screw ups the designers claim it can against the costs of performing the tests.

The actual testing would proceed in a step by step manner in which undertaking the next test would require approval from the insurer and the Certification Society based on the results of the tests so far.

Selling Test Electricity

Long run, full scale testing required to confirm material life and equipment longevity will produce quite a bit of electricity. It would be economic and environmental crime to waste that power. But that is precisely what happens in the United States and other countries which restrict the marketing of electricity by test reactors. This nonsense must be corrected.

Ongoing Development

For the successful concepts, their prototype facility will become a permanent or at least semi-permanent operation. They will be testing improvements, reacting to feedback from the commercial plants, running very long term tests, and so on. Most technological process is incremental in nature. Little of this happens under current nuclear regulation, since even the smallest change involves tens of millions of dollars in licensing paperwork. By testing and demonstrating improvements in the prototype environment, almost all the current relicensing paperwork becomes superfluous.

Some of the new technologies are inherently flexible. They can operate on a wide range of fuels. They can be operated at different temperatures with different materials. They can operate with more or less on-line processing. In some cases, even the moderator can be changed. The intelligent venture will start out with a conservative version of its concept. After that is proven and in operation, all the paths forward can be explored at the protopark, leading to higher efficiencies and less waste. This is the natural and prudent progression to fuel cycles which once started require little or no enriched uranium. The protopark enables this process.

Multiple Countries.

Other countries including Argentina, China and Russia recognize the need for prototype testing. The KLT-40S, the HTR-PM, and the CAREM were given permission to begin building by their national regulators under special provisions. And in fact multiple protoparks in different countries would be a good thing}. If a country sets up a prohibitive regulatory system for a protopark --- in our case, this could be done by setting the insurance required at an excessively high level --- testers will have the option of moving to a country which does a better job of balancing risk versus benefit.

Legislation Required.

In the US, a protopark will require new legislation. Section 110 of the Atomic Energy Act (1954) contains a blanket exclusion from licensing for facilities built for the account of the AEC (later DOE) and the DOD. But Section 202 of the Energy Reorganization Act of 1974 pulls this back. The DOD exclusion stands. But the DOE exclusion does not hold for demonstration reactors ``when operated as part of the power generation facilities of an electric utility system, or when operated in any other manner for the purpose of demonstrating the suitability for commercial operation of such a reactor." This of course is precisely what the prototypes are trying to do.

There has been essentially no technological progress in commercial nuclear reactors in the US in the 40 years since 1974. This is quite remarkable. Section 202 is one of the reasons.

The NRC has made it clear that it is not willing to treat prototypes much differently than a standard commercial reactor. This puts new nuclear in an impossible quandary. We need rigorous, fullscale prototype tests in order to prudently license these new technologies. But we can't do the tests without a license. Unless this Catch 22 is eliminated, the potential bonanza of new nuclear will pass the USA by. The country that was in the best position to solve the Gordian Knot of electricity poverty and global warming will have kicked away the opportunity.