Journal of Critical Infrastructure Policy Volume 1, Number 2, Fall/Winter 2020 | Page 63

How Nuclear Power Can Transform Electric Grid and Critical Infrastructure Resilience
of much greater Grid resilience value than a 1 GWe traditional NPP that achieves none of the six rNPP functional requirements in Table 1 . This issue , of course , is a subset of the general over-arching reality that electricity markets do not explicitly value resilience . The flexible operations capabilities of rNPPs and their potential for providing ancillary services other than baseload electricity could enable rNPPs to increase their revenue streams relative to today ’ s NPPs .
Nuclear Energy Regulation Barriers
After some experimentation in the 1950s and 1960s , the electric power industry rapidly narrowed its focus to Light Water Reactor technology and build on-site / economy of size paradigms as the guiding principles for harnessing the atom . This dynamic led to a commercial nuclear power fleet characterized by medium-to-very large LWRs . The reasons for this are complex , controversial , and beyond the scope of this paper . However , there are two aspects of this history that are very relevant to the development and deployment of rNPPs and rCIIs .
All regulatory frameworks employ assumptions ( some explicit , some implicit , some unrecognized ) with respect to that which they regulate — technologies allowed or disallowed , acceptable approaches and procedures for meeting / demonstrating regulatory compliance , etc . The maintenance of technology-neutral regulatory processes is inherently more challenging than technology-specific processes . In the case of the nuclear power industry , the NRC ’ s regulatory framework evolved over several decades to one that largely assumed LWR technology .
A LWR-dependent regulatory structure creates immense regulatory and cost uncertainty for any entity wishing to develop and deploy non-LWR technologies . With this in mind , the NRC launched an effort in 2002 to develop a risk-informed , technology-neutral , performance-based regulatory framework of future reactors ( NRC 2002 ). The regulatory processes and protocols that have emerged from this two-decade effort have evolved in conjunction with NuScale ’ s SMR design certification effort , and are receiving more extensive testing via the NRC ’ s ongoing interactions with SMR , Advanced Reactor , and MMR vendors . Still , the new regulatory framework is largely untested for non-LWR concepts , and is likely to evolve as lessons are learned from ongoing SMR , MMR and Advanced Reactor licensing activities . Thus , entities seeking to develop and deploy novel LWR and non-LWR technologies will continue to face elevated regulatory uncertainty for the foreseeable future .
Regulatory-induced technology-lock or “ lock-in ” ( Cowan 1990 ) is a phenomenon in which the cost and uncertainties associated with regulatory compliance create an environment where “ good-enough is the enemy of better ”— an environment that is hostile to innovation . It is the “ other side of the coin ” of technology-dependent regulation . This dynamic has been in play in the commercial nuclear power industry in the United States for most of the industry ’ s history . Ad-
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