NRC requires licensing approval before testing can take place
NRC design review prioritizes approval for theoretical models over real-world testing for emerging technology
Details
Core information and root causes
Standard engineering practices entail building prototypes, testing them, and iteratively solving problems and adding improvements. This real-world testing is important when designing new technology, but the NRC design review process relies on modeling and scenario analysis instead.
Jason Crawford (summarizing arguments from Jack Devanney) notes that:
“[The] NRC relies on a method called Probabilistic Risk Assessment: enumerate all possible causes of a meltdown, and all the events that might lead up to them, and assign a probability to each branch of each path. In theory, this lets you calculate the frequency of meltdowns. However, this method suffers from all the problems of any highly complex model based on little empirical data: it‘s impossible to predict all the things that might go wrong, or to assign anything like accurate probabilities even to the scenarios you do dream up…
In practice, different teams using the same method come up with answers that are orders of magnitude apart, and what result to accept is a matter of negotiation. Probabilistic models were used in the past to estimate that reactors would have a core damage frequency of less than one in a million years. They were wrong.”1
Approach
Strategic approach and implementation plan
Vectors to address the bottleneck:
“Don‘t regulate test reactors like production ones. Rather than requiring licensing up front, have testing monitored by a regulator, who has the power to shut down test reactors deemed unsafe. Then, a design can be licensed for production based on real data from actual tests, instead of theoretical models.”1
