Starting a new nuclear construction industry is hard work

By Rod Adams

Construction at Vogtle units 3 and 4 and VC Summer units 2 and 3 is not going as well as many nuclear advocates would like. I’m not surprised, but neither are most people who have been involved in complex construction and technology projects that involve a lot of moving parts and numerous interested parties. Nothing that happens at those projects will change my mind that atomic fission is a superior way to produce heat and boil water. There is little chance that events at those individual projects will convince me that there is something fundamentally wrong with the advanced passive reactor plant design.

There are some important lessons that need to be shared widely so that the chances of them recurring is minimized, but it is difficult to completely eliminate the challenges that will inevitably be a part of all major construction projects. For the nuclear industry and all nuclear advocates, it is important to recognize that even if things were going perfectly, there would still be plenty of negative publicity coming from the professional opposition to what we do. We are involved in starting up a new nuclear construction industry, almost from scratch.

For the sake of brevity, I will put the current issues at Vogtle and Summer into three categories—backlog of design changes from the certified design, delays that were partially caused by licenses and permits whose issuance was resisted at every step of the process, and an error that resulted in laying concrete rebar that did not match the licensed standard requirements.

Licensing

Soon after the issuance of the AP1000 design certification and the associated combined operating license for Vogtle, the project leaders began the process of submitting design license amendments so that they could implement changes and refinements. Many of the requested design modifications are based on lessons learned during the construction of similar units in China. Unfortunately for the project owners, the Nuclear Regulatory Commission has no process for handling license amendments that can keep up with the needs of a construction project.

The “one step” licensing process that is described in 10 CFR 52 (CFR–Code of Federal Regulations) results in the issuance of an operating license based on a certified design. The underlying assumption by the regulators is that the design is complete and will not be changed during construction. Any changes to the design as certified need an operating license amendment.

Even if the change is an improvement, it requires a rigorous NRC evaluation and approval process designed to prevent unintended negative consequences directly affecting reactor safety. The operating license amendment process is quite different from the one used to process changes when the owners build based on a construction permit and request their operating license after completing construction and low power testing.

The problem with one step licensing is that it is a poor assumption to believe that it is possible to build first-of-a-kind (FOAK) construction projects without making any changes to a design that was completely conceived on paper and inside computers. Reality often does not match models. In addition, construction codes and standards are continuously evolving; even though the process is slow, there are inevitably going to be changes that might affect a design that was first submitted for certification 10 years before construction actually started.

The backlog of potential changes for Vogtle and Summer developed because the leaders were understandably reluctant to submit any changes while the design certification work was still in progress. There is not much that the project leaders can do at this point other than to be even more reluctant than they already are to accept any suggestions that would require a license amendment.

With the clarity made possible by hindsight, the Part 52 one-step licensing process might not be the best choice for any FOAK nuclear power plant, even if similar units have been built outside of the United States. US licensing requirements are different enough to require what is essentially a new design and a different construction process.

The opposition’s strategy: delay

It is hard for nuclear advocates to fail to notice that the organized opposition—which did everything in its power to slow the licensing and permitting processes required for Vogtle and Summer—are engaging in “I told you so” crowing about the high cost of new nuclear plant construction. Every story about a potential cost overrun is accompanied by quotes from groups like Southern Alliance for Clean Energy and Arjun Makhijani’s Institute for Energy and Environmental Research. (Note: Makhijani is famous for fantasizing about a carbon free, nuclear free energy supply.)

Arjun Makhijani, the president of the Institute for Energy and Environmental Research, said efforts to rush such a complex project to completion set the scene for delays and rising costs.

“The cost increase should not be a surprise; rather it is déjà vu all over again,” he said. “It would be much better if construction were suspended until all design issues were resolved.”

(Source: Augusta Chronicle (May 11, 2012) Price of Vogtle expansion could increase $900 million)

There is no secret to the opposition’s recipe for making any construction project excessively costly. All they have to do is to force schedule delays and costs inevitably increase due to financing, idle labor, labor force reconstitution, issues associated with supply chains, and inflation. Project managers are rarely applauded for missing deadlines, even if they adhere to a carefully prepared, logical schedule that gets pushed to the right (on a timeline) by external forces. Once delays have been imposed, costs will increase again if efforts are made to revise schedules and accelerate work to attempt to get back on schedule.

Supply chain issues are especially difficult to explain to people who have not worked in an industrial setting. When the parts that are needed are large and custom made, they need to be ordered months to years in advance. Once those parts are finished, the manufacturer needs to ship or needs to get paid for storage.

If the parts require special environmental controls to ensure that they do not deteriorate, storage charges increase dramatically. Suppliers who have to delay order shipments or who receive purchase orders several months after they expected the orders to arrive become more reluctant to do business. (That means that they start negotiations for the next order at a higher unit price.) Suppliers also logically delay investing in production capacity until after the orders—and the associated payments—actually arrive.

Rebar

The final current issue associated with Vogtle and Summer is a specific error that resulted in rebar (reinforcement bars of steel that strengthen concrete) being laid at both projects that did not match the concrete standard that was included as part of the certified design. Correcting the error will result in a several month delay at both projects while rebar is removed, new rebar is cut and the new rebar is laid. No concrete can be poured before that happens and there are many steps in the construction process that cannot take place until the concrete is in place. Management is going to be distracted.

The source of the error has not been determined and the results of the investigation may never be made public. What seems to have happened is that someone or some group on the project team decided to use a reinforced concrete standard that was updated after the license was approved. That standard specified a different rebar configuration. The design change was prepared, but never approved by the NRC. Somehow, the rebar was installed to the newer standard even though the license amendment had not been approved. I suspect that there was a communications breakdown that prevented the installers in the field from knowing the exact status of the design. It might have been as simple as a drawing or specification that specified a standard without specifying the exact revision of the standard.

It is going to be an expensive lesson. It is one that can be avoided by projects that have not yet begun construction. In nuclear construction projects, effective change control and effective communications plans are essential.

Reviving a slumbering giant of an industry is hard work. There will be plenty of successes to celebrate, but I would not be a “nuke” if I did not seek to learn as much as possible from the difficulties experienced by others and if I did not seek to document those lessons so that others can also avoid making the same errors. That is part of our learning culture.

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Adams

Rod Adams is a nuclear advocate with extensive small nuclear plant operating experience. Adams is a former engineer officer, USS Von Steuben. He is the host and producer of The Atomic Show Podcast. Adams has been an ANS member since 2005. He writes about nuclear technology at his own blog, Atomic Insights.

10 Responses to Starting a new nuclear construction industry is hard work

  1. James Greenidge

    This was a good educational report! It hintsa lot about the fate of small module reactors I think!

    ANS: I’m gleaning a few scattered reports on line that respiratory disease cases, especially among youth, are rising around major Japanese cities ringed by fossil fuel plants. Can your resources and contacts confirm this and/or do a report on this? Thanks!

    James Greenidge
    Queens NY

  2. bill eaton

    Good article, Rod. Thanks.
    The complexity of resurrecting an industry in any case is very difficult; but even more so when the opposition is organized and has the ear of the “pseudo-journalism” crowd that the U.S. media has become. Any negative is noteworthy, and all positives are suspect.
    But, I figure if anybody can do it, those folks in Southern Nuclear can.

  3. Has anybody heard of efforts in Congress to administer a painful to spanking to NRC bureaucrats for these stupidities?

    I thought the lessons of the 1980’s had been learned and the processes that cost extraordinary delays had been fixed and that process streamlined.

    Can’t the NRC commissioners overrule this nonsense?

    Makes you want to hold your nose and vote Republican so this stupid bureaucracy can be brought up to a least FAA standard.

    That rebar story is simply too disgusting to bear. America will be eaten by the Chinese if this can’t be fixed.

  4. If I understand correctly, the installed rebar was according to the later, updated standard. Presumably a notch better. And now you Americans remove the better rebar and replace it by stuff that complies to the previous standard? Seen from a distance, that action is incomprehensible (let me not use the word crazy). Did nobody figure out that updating the license to the updated standard is less wasteful, costly and time-consuming and should be a relatively small additional loop through the licensing process ?
    Get your act together, please ! NRC to improve the COL process and/or create appropriate licensing paths to accomodate design changes. Constructor to implement Corrective Action re design control and communications . Some business process analysis followed by improvement, on both sides, should solve the issue.
    And yes, Adams’ piece is required reading for project managers.

  5. @Geert F de Vries

    Thank you for the kind words; I hope that your regulators will also read the piece and recognize that they can do a better job if they learn from the errors that our regulators often make.

    One of the real challenges that we have here is that people are very reluctant to change their minds, even when presented with new information. It might shock you to learn that our current plants still use analog control systems; the very first digital control system was just recently licensed to be used, and I think even that one has limited applications within the overall plant control system.

    The thing that is really weird about that is that I was the Engineer Officer on an old sub that installed a digital protection and alarm system – and I left that job in 1990.

  6. I think there’s a far deeper problem here. The NRC is a procedure based organisation; it doesn’t care if the rebar being not up to specs is a safety issue or not, it just cares that it isn’t according to procedure. This is a recipe for disaster. If it turns out that a few simple design changes have to be made such as moving a pipe a few inches to allow more room for valves inspection or something, that is rarely ever a safety problem. It is however considered a serious rule violation by the NRC so this will require a formal acceptance by the NRC, which is known to be slower than a snail in licensing even the simplest changes.

    I think that, for nuclear energy to truely make a difference in the USA, the NRC must be abolished and the AEC re-instated. The AECs technology and safety based approach is superiour and faster than the NRCs procedure based approach.

    As long as the focus is on procedures rather than actual safety issues or not, these kind of errors will continue to bite the economics and schedule of new nuclear builds.

  7. @Cyril – That is a conversation worth having. It is pretty disheartening to be inspected by someone who really does not understand the technology, but is happy to write a finding when they determine that you did not follow procedures to the letter.

  8. @Cyril – I forgot to mention that I am not advocating that anyone violate procedures, but I have found that many technical types cannot comprehend the notion that words may have more than one interpretation. They like numbers that are always the same and have no changes in meaning depending on the context.

  9. Hello Rod. I’m not advocating the violation of procedures, either. Rather I’m saying that we must keep in mind the purpose of the procedures; the procedure itself should not become the purpose, as it has become for the NRC. There are no doubt some very clever people in the NRC, but if their final verdict is always based on procedure, they are a bureaucratic nuissance and have no added value.

    The added value of a regulator is that it brings a know-how and perspective to the table. It can then use this know-how and perspective to decide whether, for example, new rebar should be laid or the change is only a paper procedure. Procedures can help a regulator is the company isn’t cooperating and the regulator perceives a safety issue. If neither are the case, a good regulator would realize that the formal procedure is of no added value and only does damage to the process.

    I should tell you my professional occupation at the moment,, which is in safety analysis for large industrial petrochemical installations. As a safety professional I’m saddened by the NRC response to the rebar issue. They’re not being a good regulator at best, and are displaying incompetence at worst.

  10. @Cyril – The NRC response to the rebar issue seems to be traceable to the philosophy of the single individual who was politically appointed to be the Chairman despite a lack of any managerial or technical experience.

    That is one of the reasons why I am so adamant that his replacement should be someone who does not have those weaknesses. Unfortunately, the current nominee is at least as bad, if not worse and runs with the same antinuclear crowd.