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APPA’s Adrienne Lotto Emphasizes Importance of Layered Defenses for Grid Security

December 12, 2022

by Paul Ciampoli
APPA News Director
December 12, 2022

When it comes to grid security, the importance of layered defenses cannot be overstated, and while the power sector has a good overall understanding of the risk it is facing in this area, to the extent that more information can be shared from the federal government to entities and utilities, that is helpful for utilities to understand their risks and respond accordingly, said Adrienne Lotto, Senior Vice President of Grid Security, Technical & Operations Services, American Public Power Association (APPA), on Dec. 7.

She made her comments at a joint Department of Energy-Federal Energy Regulatory Commission supply chain risk management (SCRM) conference in Washington, D.C.

Lotto was a panelist at the conference that examined current supply chain risk management reliability standards, implementation challenges, gaps, and opportunities for improvement.

Other panelists were Jeffrey Sweet, Director of Security Assessments, American Electric Power, Shari Gribbin, Managing Partner, CNK Solutions, Scott Aaronson, Senior Vice President of Security and Preparedness, Edison Electric Institute, and Lonnie Ratliff, Director, Compliance Assurance and Certification, North American Electric Reliability Corporation.

Panelists were asked whether they think the currently effective supply chain risk management standards are sufficient to successfully ensure bulk power system reliability and security in light of existing and emerging risks to the cyber security supply chain.

“The simple answer is yes,” Ratliff said. “The standards provide a foundation to address and mitigate some of the supply chain challenges that we have across our industry. With this foundation, there’s always opportunities to improve so as we look at the effectiveness” of the standard, “NERC has taken several opportunities to assess those standards, bring up teams and evaluate the effectiveness and propose change to those standards.”

Lotto said that NERC and the power industry have shown a willingness to continue to partner and examine the NERC Critical Infrastructure Protection (CIP) standards as it relates to supply chain security and are continuing to do so.

As threats continue to evolve, the utility sector and NERC have also shown a willingness to evolve and take a second look at those standards and “that risk-based approach remains ongoing.”

At the same time, Lotto highlighted jurisdictional limitations to FERC “and the burden that that then places on the utilities trying to gain insight into the suppliers that they are utilizing in their systems.”  

“I do believe that the standards that are in place today are effective and are appropriate,” said Sweet. “They provide the flexibility for the utilities to be able to address the risks that they realize within their organizations.”

The supply chain risk management standard requires entities to have a supply chain risk management plan.

Supply Chain Risk Management Plan

Panelists were asked to address the question of whether it would be beneficial to provide additional clarity for the supply chain risk management plan in a couple of areas.

“One is in identifying and assessing risks,” said David Ortiz, Director of the Office of Electric Reliability at FERC. “Identifying triggers that would require activation of the plan and then requirements in that plan to respond to risks that are identified.”

Addressing the question of whether the power sector needs help in identifying and assessing risk, Lotto said, “the short answer is yes.”

She said that to the extent that more information can be shared from the federal government to entities and utilities, large or small, that is helpful for utilities to understand their risks and respond accordingly.

Lotto cautioned against an idea floated earlier in the conference that proposed throwing out the definition of high, medium and low in the risk-based approach currently being used at NERC.

She warned against making a holistic change in this approach. “The NERC CIPS standards are effective. They are working and that is sound risk management practice in any sector – to understand what your high, medium, low impacts are, so a holistic change like that at this time I think would actually set us back, as opposed to enable NERC to continue doing what it’s doing with the utilities and move us forward towards greater supply chain security.”

Prior to joining APPA, Lotto was vice president, chief risk and resilience officer at the New York Power Authority, where she led a team of risk management professionals.   

Meanwhile, Puesh Kumar, Director of the Department of Energy’s Office of Cybersecurity, Energy Security, and Emergency Response, noted that utilities “are trying to manage risk, but to do that they first need to understand the risk.”

He asked Lotto whether utilities “know the risk well enough and, if not, what are the gaps? What more could we be doing?”

Do utilities “have a good understanding of the risk that they’re managing to?”

“I would say holistically the answer is yes,” Lotto responded. There has been a “tremendous amount of work” done at the DOE, Department of Homeland Security, the Electricity Information Sharing and Analysis Center and the Multi State Information Sharing and Analysis Center “that helps to inform and provide industry insight into the risks. Now, that said, could we always do better? Of course.”

Lotto said that a recent incident involving an attack on Duke Energy substations in North Carolina “is a physical example where you see the risk in day-to-day life that the grid is exposed to, so continuing to foot stomp and provide situational awareness in a timely fashion with context and suggested solutions or guidelines, I think is important.”

She noted that APPA provides resources and guides and partners with the DOE through agreements “that enable us to do that. Particularly for the smaller members, it’s exceedingly helpful.”

EEI’s Aaronson said that “we understand the risk, but risk is always changing. Risk is a factor or a function of threat, likelihood and consequence.”

He said that “what is the consequence of something is also evolving, not just because the threat is evolving but the grid is constantly evolving.”

At a later point, Lotto emphasized the need for layered defenses when it comes to grid security. She said that while FERC and NERC have done a good job in addressing the baseline, the energy sector continues to collaborate, which includes discussing baselines and focusing on “getting even better and stronger.”

This continued coordination, not just in the regulatory arena, but also in terms of best practices, needs to continue to happen, she said.

“I think the greatest power that the federal government has is the power to convene,” Lotto said. Continuing to bring industry experts together with the federal government “to solve critical problems has to continue to evolve.”

She also said that the importance of economies of scale must not be overlooked “because individually we can’t do it alone. Our members can’t do it alone. The cyber threat, unfortunately, is advancing to the front lines where, fundamentally, our members are getting asked on a day-to-day basis to act as frontline defenders of networks and that’s an almost impossible task. They’re not set up to defend networks on a day-to-day basis from nation state adversaries that are attacking them.”

The power to convene at the federal government level, both through the NERC process “wherein they’re continuously looking and trying to evolve to meet the threat, together with best practices and advancing through groups that already exist or at the federal government level to achieve economies of scale and layered defenses is critical.”

ERCOT Creates Curtailment Program for Large Flexible Customers during Peak Demand Periods

December 10, 2022

by Paul Ciampoli
APPA News Director
December 10, 2022

The Electric Reliability Council of Texas (ERCOT) is implementing a voluntary curtailment program allowing large flexible customers, such as bitcoin mining facilities, to reduce their power use during periods of high demand, it said on Dec. 6.

“Our goal with this program is to work with large customers in supporting the reliability of the Texas power grid,” said Woody Rickerson, ERCOT Vice President of System Planning, in a statement. “These customers are large power users but have the flexibility and willingness to reduce their energy use quickly, if needed. By working with these large loads during peak demand periods, we will better serve all Texans while keeping the grid reliable and resilient.”

The program is primarily intended for large flexible customers, but any large customer directly connected to a transmission service provider’s facility can participate, subject to approval by ERCOT.

The program is temporary and completely voluntary until ERCOT establishes a long-term set of rules.

Registration for the program began on Dec. 6 and ERCOT anticipates the program going live in January 2023.

More information can be found in our Market Notice, including the registration form to participate.

Salt River Project Using Inflation Reduction Act to Build and Own Solar Plant

December 8, 2022

by Peter Maloney
APPA News
December 8, 2022

Arizona public power utility Salt River Project (SRP) is building a solar power project that will take advantage of recent changes in federal law that allows public power utilities to use tax benefits that were previously out of reach.

SRP’s board of directors recently approved the second phase of the 55-megawatt (MW) Copper Crossing Energy and Research Center in Florence, Ariz.

The utility-scale solar project is the first the utility is developing and will own and operate itself.

Historically, SRP has contracted for generation from renewable resources through power purchase agreements with developers that have access to federal tax credits for renewable energy projects.

The federal Inflation Reduction Act passed in August extended and expanded various energy tax incentives and gave public power utilities direct access to those credits by allowing allows public power utilities to receive direct federal incentive payments for renewable projects.

SRP said the change will give it greater ability to develop, operate and advance more renewable resources and potentially reduce costs for customers.

The first phase of the Copper Crossing project will add two natural gas-fired turbines with a total output of less than 100 MW, which SRP’s board approved in September. A third proposed phase for small-scale, long-duration energy storage system is expected to go to the utility’s board for approval in 2023.

SRP has not yet completed the design of the new solar portion of the Copper Crossing site. Engineering, material procurement and construction activities for the solar facility are expected to take approximately 24 months. The solar project is sited on land SRP owns next to its Abel substation adjacent to an existing 20-MW solar plant.

With this development and other recent awards, SRP is contracted for over 2,000 MW of our goal to add 2,025 MW of new utility-scale solar energy by 2025, SRP noted.

Puerto Rico Substation Modernization Initiative Gets Underway

December 7, 2022

by Paul Ciampoli
APPA News Director
December 7, 2022

LUMA Energy recently announced the launch of Puerto Rico’s federally funded Substation Modernization Initiative (SMI) with the modernization and reconstruction of the Manatí Substation in the municipality of Manatí.

In June 2020, Puerto Rico Electric Power Authority (PREPA) and the Puerto Rico Public-Private Partnership Authority selected LUMA Energy to operate, maintain and modernize the electricity transmission and distribution system of PREPA for fifteen years through a public-private partnership.

The Manatí SMI project represents an investment of more than $2.3 million in federal funding approved for phase one and over $55 million in federal funding estimated for the entire rebuild of the Manatí substation.

At the SMI launch event with LUMA were representatives of the Central Office for Recovery, Reconstruction and Resiliency and the Federal Emergency Management Agency (FEMA).

As part of the first SMI project, LUMA will replace outdated and obsolete oil circuit breakers with the industry standard 230-kilovolt gas circuit breakers, which it said will improve reliability and strengthen operational safety.

The Manatí SMI project, which is the first major work on this substation in the past 20 years, will include multiple phases with future improvements designed to replace aging equipment and reconfiguration of the entire substation, utilizing FEMA funding.

When completed, the Manatí SMI project will directly improve resiliency and reliability for the municipalities of Manatí, Barceloneta, Florida, Ciales, Morovis and Vega Baja, which are some of Puerto Rico’s most important industrial centers, LUMA noted.

Substation Modernization Initiative Details

The modernization of the Manatí substation is one of five substation modernization projects currently underway with a total of $58 million in already approved federal funds.

Among the projects that are estimated to begin construction in Q2 2023 include:

Over the last 17 months, LUMA has advanced federally funded FEMA projects, with 251 projects initiated representing over $6 billion in federally funded projects. A total of 23 projects are already under construction or in service.

Lansing Board of Water & Light Retires Last Coal-Fired Plant

December 7, 2022

by APPA News
December 7, 2022

The Lansing Board of Water & Light (BWL) has retired its last coal-fired power plant, which the public power utility said makes it the largest utility in Michigan to generate coal-free power by 2022.

The Nov. 27 retirement of the 160-megawatt (MW) Erickson Power Station aligns with the integrated resource plan BWL released in August 2020 that calls for the utility to deliver 50 percent of its power from clean energy sources by 2030 and to be a carbon dioxide neutral utility by 2040.

“In 2012, BWL burned 1.2 million tons of coal,” Dick Peffley, BWL’s general manager, said in a statement. “Today, 10 years later, BWL’s coal consumption is zero.”

The retirement of the Erickson plant, which began operation in 1973, was preceded by BWL’s retirement of its 350-MW Eckert station in 2020.

BWL is replacing its coal-fired power plants with natural gas-fired plants, as well as a mix of wind and solar generation. Compared with coal, natural gas generation represents an 80 percent reduction in carbon dioxide emissions, as well as a 99.9 percent reduction in sulfur dioxide emissions, BWL said.

BWL replaced the Erickson plant with the 250-MW natural gas-fired, combined-cycle plant Delta Energy Park that came online in August 2022.

BWL also has an agreement with Michigan Public Power Agency to purchase power from DTE Energy’s Belle River coal-fired plant in southeast Michigan’s St. Clair County. DTE has announced plans to convert Belle River to natural gas in 2025-2026.

“These coal-fired plants generated power that allowed Lansing’s automobile industry to grow and flourish and made the Lansing area a terrific place to live, work and raise a family,” Peffley said. “Now it’s time for the next generation of cleaner energy to power the region’s electric vehicle future and beyond. I started my BWL career at Erickson and the plant has had a great run. We appreciate its service to our community and all the employees that kept it operational throughout the decades.”

BWL recently issued an All-Sources request for proposals that the utility plans to use to evaluate electric supply or demand-side resources including wind, solar, battery storage and energy savings programs that can help meet all or part of the BWL’s capacity and energy needs.

The BWL has about 100,000 electric customers, 58,000 water customers, 155 steam customers and 19 chilled water customers.

Officials with Iowa’s Denison Municipal Utilities Detail Utility’s Response to Transformer Shortages

December 7, 2022

by Paul Ciampoli
APPA News Director
December 7, 2022

In a recent interview with Public Power Current, Rory Weis, General Manager of Iowa public power utility Denison Municipal Utilities (DMU), and Electric Manager Mike Wight, detailed how the utility is responding to delays for acquiring transformers due to ongoing supply chain challenges.

DMU’s Board of Trustees recently voted to allow utility staff to seek bids for a power transformer for a substation.

When asked to describe how supply chain issues have impacted the utility in terms of seeking bids for this transformer, Weis said, “the last substation transformer that we replaced approximately two years ago took close to a year to get. Supply chain issues now have pushed that out to, we’re being told, close to a two-year timeframe. We started the process a little sooner due to that fact so we can keep that project moving forward.”

Wight said that the utility has faced delays in orders for distribution transformers, noting that DMU ordered distribution transformers that were supposed to be delivered in July 2022 “and then we were told November and they’re still not here.” Wight said that the last email DMU got from its supplier indicated that the distribution transformer would be shipped this week.

With respect to the topic of pricing for transformers, Wight said that the last bid the utility received for the substation transformer was around $670,000 “and they’re estimating between $1.1 and $1.2 million on this one.”

As for the cost for distribution transformers, DMU has seen an increase in costs for 50 KVA single phase transformers in recent years.

With respect to the outlook for supply chain challenges and transformer delays, Weis said, “We hope we’re at the worst of it right now” and that it starts getting better, “but we have nothing to reference that to.”

Groups Urge DOE to Move Quickly to Alleviate Supply Chain Challenges With Transformers

December 6, 2022

by Paul Ciampoli
APPA News Director
December 6, 2022

The Department of Energy (DOE) should use Defense Production Act (DPA) authorities to prioritize distribution transformers, large power transformers, and other critical grid components ahead of other technologies, and it should act quickly to alleviate the most acute supply chain challenge with distribution transformers, the American Public Power Association (APPA), the Edison Electric Institute (EEI), and the National Rural Electric Cooperative Association (NRECA), said in joint comments submitted to DOE on Nov. 30.

The comments responded to a DOE request for information (RFI) that sought input from stakeholders on how DOE should use its authority under Title III of the DPA to address supply chain issues for clean energy technologies and distribution transformers.

“Recent surveys show our members are waiting longer than ever for transformers of all sizes, conductors, meters, circuit breakers, and other products,” the trade groups noted. “Industry cannot solve this challenge alone and thus we are pleased to see the government may use its authority under the DPA to address challenges created by shortages of transformers and other key components of the energy grid.”

“We respectfully urge DOE to prioritize distribution transformers, large power transformers, and other critical grid components ahead of the other technologies considered in the RFI,” APPA, NRECA and EEI said.

“Until we can address the shortages and supply chain challenges that are directly impacting reliability, we may not be able to accomplish many of the goals this administration has laid out for advancing clean technologies or expanding electrification,” they said.

“Most urgently, in the near-term, we urge DOE to act quickly to alleviate distribution transformer shortages, as this is the most acute supply chain challenge the electric industry is facing,” the groups said.

“We also ask DOE to establish longer-term efforts dedicated to supporting expanded domestic manufacturing capacity for large power transformers and other grid components that may take longer to address but are nonetheless critical to grid operations and therefore national security.”

The RFI comments also note that DPA authorities could be used for financial assistance, loan guarantees, and purchase commitments for transformer manufacturers that would help address labor shortages and the availability of materials that are hampering manufacturers’ ability to increase production.

Groups Urge Congressional Appropriators to Fund DPA Authorities to Address Supply Chain Shortages

APPA and the electric trades augmented their comments on DPA with a letter for action on Capitol Hill. The electric trades, along with building trade organizations, recently sent a joint letter to Congressional Appropriations leadership requesting funding for DPA.   

The groups request that Congress appropriate $1 billion this year for the implementation of DPA authorities to specifically address the supply chain crisis for electric distribution transformers.

“Throughout 2022, the electric sector and representatives from residential and commercial building sectors have been calling attention to the unprecedented supply chain challenges both industries have been facing in procuring equipment used to maintain and grow the electric grid,” wrote APPA President and CEO Joy Ditto and leaders of the other groups. DPA authorities should be prioritized to immediately address increased production of distribution transformers.

APPA Says FERC Communications Proposal is Overly Broad, Should be Withdrawn

December 5, 2022

by Paul Ciampoli
APPA News Director
December 5, 2022

A proposal by the Federal Energy Regulatory Commission (FERC) to add a new provision to its regulations that would impose a “duty of candor” on any entity communicating with the Commission, its staff, or certain other entities is overly broad and would likely chill communications while presenting significant enforcement challenges for the Commission, the American Public Power Association (APPA) said in urging FERC to withdraw the proposal.

APPA submitted comments on Nov. 10 to FERC in response to a FERC Notice of Proposed Rulemaking (NOPR) that would amend the Commission’s regulations to add the new provision.

APPA noted that it has long been a proponent of Commission rules that guard against market manipulation and that promote just and reasonable market outcomes for consumers, consistent with the Commission’s obligations under the Federal Power Act (FPA).  “APPA also recognizes the need for the Commission to be able to rely on accurate information in executing its duties under the FPA and other statutes it is tasked with administering.”

APPA “can understand the appeal of trying to ensure this goal by adopting a generic requirement simply ‘to tell the truth,’” it added.

“APPA is compelled, however, to express serious concerns with the NOPR and the Proposed Regulation.  The proposed rule would be exceptionally broad – both in terms of the entities to which it would apply and the scope of communications it would cover.” 

There is no intent element, nor is there any materiality requirement — except as to factual omissions, which the Proposed Regulation would also encompass, it said.

“The rule would apply to unintentional and immaterial mistakes, subject only to the ability of a target of an investigation to demonstrate that it exercised ‘due diligence’ to assure the accuracy of the communication.”

APPA said it concurs in FERC Commissioner James Danly’s assessment “that the breadth of the proposed rule would likely chill communications while presenting significant enforcement challenges for the Commission.”

APPA said it is particularly concerned by the NOPR as it relates to communications with entities other than the Commission and its staff. 

The Proposed Regulation would likely apply to essentially all communications with Regional Transmission Organizations (RTOs), Independent System Operators (ISOs), market monitors, the Electric Reliability Organization (ERO) and its Regional Entities, as well as a sweeping array of communications with utilities.

The NOPR “does not provide a reasoned basis for such an expansive candor regulation,” APPA argued. It said there is no discussion of any specific instances where the lack of a general duty of candor obligation has undermined the Commission’s ability to carry out its obligations. Moreover, the NOPR’s description of the existing statutory, regulatory, and ethical requirements for honest communications “tends to show that any problem the Commission is attempting to solve is a narrow one that would be better addressed through a more targeted response.”

Even if there were a clearly identified need for the rule, the NOPR fails to establish the legal authority for adopting the Proposed Regulation or for enforcing it against entities that are not generally subject to the Commission’s jurisdiction, such as APPA’s public power utility members, the trade group said.

The NOPR indicates, for example, that authority to adopt the duty of candor is grounded, at least in part, in section 206 of the FPA.

The Commission’s authority under section 206 is limited to “public utilities,” however, and the NOPR does not explain how it could extend liability to a non-public utility for a violation of a rule based on FPA section 206.

Public utilities refers to those entities regulated by FERC, not non-jurisdictional utilities such as public power utilities.

“Nor do the other FPA provisions cited in the NOPR provide a basis for the generically applicable duty of candor. In addition to these problems with the statutory underpinnings of the proposed rule, the rule is overly broad and presents significant due process concerns, particularly in the context of communications with jurisdictional transmission or transportation providers.”  

APPA urged the Commission to withdraw the NOPR. “Any specific gaps in the coverage of existing candor requirements should be addressed by more targeted proposed rules to address those particular circumstances,” it said.

If the Commission proceeds, however, “APPA recommends that the proposed duty of candor be limited to written or recorded communications of factual information to the Commission or its staff, and that the rule include a materiality requirement.”

Regardless of the scope of any final rule, the Commission should, at a minimum, specify that non-public utilities would generally not be subject to enforcement for violation of the duty of candor under FPA section 316A, APPA said.  Section 316A of the FPA allows FERC to assess significant financial penalties against entities that violate certain FPA provisions or FERC rules or orders issued under those provisions.

Duke Energy Responds to Outages Caused by Substation Vandalism

December 5, 2022

by Paul Ciampoli
APPA News Director
December 5, 2022

Duke Energy over the weekend said that it was responding to power outages caused by vandalism against utility equipment in North Carolina.

Duke Energy on Dec. 4 said that crews were responding to widespread outages in Moore County, N.C. The company experienced multiple equipment failures affecting substations leaving about 45,000 customers without power.

Media reports on the vandalism reported that two electric substations were damaged by gunfire.

The utility crews are working 24-hour shifts to make repairs and restore service to all impacted customers. Several large and vital pieces of equipment were damaged in the event, the utility said. “Repairing the equipment is a multi-step process that will take several days to complete. Once repairs are made, the company must test the equipment before beginning the final restoration process.”

Due to the nature of the damage, the company is working with local, state and federal agencies on their ongoing investigation into this incident.

On Sunday evening, Secretary of Energy Jennifer Granholm tweeted that she has been in contact with Duke Energy about the vandalism and the DOE’s Office of Cybersecurity, Energy Security, and Emergency Response (CESER) is working with federal partners.

“Law enforcement is investigating this serious incident and Duke is working around the clock to restore service,” she said.

Rich Glick, Chairman of the Federal Energy Regulatory Commission, also sent a tweet over the weekend saying that FERC is monitoring the events in North Carolina. “The security & reliability of our grid remains the top priority” as Duke Energy works to restore services, he said.

Reliability, Resiliency, Safety and Affordability Flows from Small Modular Reactor Technology

December 5, 2022

by Peter Maloney
APPA News
December 5, 2022

New nuclear technologies, such as small modular reactors (SMR), have reached a point where they are able to help utilities address growing concerns about fulfilling their core mission: delivering safe, affordable, and reliable electric power.

Several industry trends are challenging utility executives’ abilities to balance those three key objectives.

A July report from the North American Electric Reliability Corp. (NERC) highlighted the growing threats to reliability, including extreme weather events, the growing proliferation of “inverter based resources” such as photovoltaic solar power and energy storage, and increasing reliance on natural gas-fired generation.

The growth of renewable resources aimed at meeting state and federal goals aimed at addressing greenhouse gas emissions has been impressive. In the first half of the year, 24 percent of utility-scale generation in the United States came from renewable sources, according to the Energy Information Administration. However, as NERC pointed out this summer, as renewable resources have proliferated, gas-fired generators are becoming “necessary balancing resources” for reliability, leading to an interdependence that poses “a major new reliability risk.”

In this environment, if utilities are going to stay on track to meet their clean energy targets while providing secure, safe and reliable electric power to meet growing demand, they are going to need a new solution.

“NuScale Power’s SMR technology offers a carbon-free energy solution with features, capability, and performance not found in current nuclear power facilities,” Karin Feldman, Vice President of NuScale’s Program Management Office, said in an interview.

Several utilities have already begun exploring the potential of a new generation of nuclear technology to help them meet both their clean energy and reliability needs as they work toward meeting growing demand.

NuScale’s project portfolio includes a six module, 462-MW VOYGR™ SMR power plant. Utah Associated Municipal Power Systems (UAMPS) plans to develop at the Department of Energy’s (DOE) Idaho National Laboratory in Idaho Falls for their Carbon Free Power Project (CFPP).

NuScale also has memorandums of understanding to evaluate the deployment of its SMR technology with Associated Electric Cooperative in Missouri and Dairyland Power Cooperative in Wisconsin.

“What we bring to the table is a technology that is smaller and simpler; that lowers total costs while providing high reliability and resilience, and greater safety,” said Feldman, who develops and manages NuScale’s portfolio of projects and establishes and maintains project controls, cost estimating, and risk management standards. She is also NuScale’s primary interface with the DOE.

Cost Comparisons

The smaller scale of NuScale’s reactors – 77 MW versus 700 MW or even 1,600 MW or more for conventional reactors – brings several cost advantages, Feldman said. Smaller reactors can be fabricated in a factory, which is cheaper than field fabrication, because it involves repetitive procedures that foster iterative improvement and economies of scale, she said. Smaller reactors also take less time to build, which lowers construction costs.

Because they are modular, an SMR does not force a utility to commit to participation in a nuclear project in the 1,000-MW to 2,000-MW size range. An SMR project can be scaled to meet demand, and modules can be added as demand requires, Feldman said. That helps reduce financial risk for a utility, she said.

Another, related consideration, highlighted by the supply chain disruptions in the wake of the COVID-19 pandemic, is that much of NuScale’s technology can be locally sourced. “We are taking advantage of the U.S. supply chain to the greatest extent possible,” Feldman said. “We have some overseas manufacturers, but we are also engaged to develop additional U.S. capabilities in areas such as large-scale forgings.”

Reliability and Resiliency

Nuclear power plants generally have high reliability, over 92 percent, nearly twice the reliability of coal and natural gas plants, but the smaller, compact design of SMR technology can offer additional reliability advantages, Feldman said. Because NuScale plants are designed to scaled up in incremental steps, if any one of the individual reactors has an issue, the other reactors can continue to generate power, she explained.

NuScale’s SMR technology also enhances resiliency, Feldman said. The design calls for the reactors to be housed in a building below grade, hardening their vulnerability to airplane strikes and very large seismic events, she said.

An SMR plant also is designed with black start capability so that it can restart after a disruption without using the surrounding electric grid. “So, in the event of an emergency, it could be a first responder to the grid, one of the first generators to start up,” Feldman said.

And because the design calls for multiple reactors, a problem with one reactor does not require the entire plant to shut down. An SMR plant can also operate in island mode, serving as a self-sufficient energy source during an emergency, Feldman said.

In some ways, a NuScale SMR power plant resembles a microgrid. In fact, NuScale’s technology team has done a lot of analysis on microgrid capacity, Feldman said, noting that the analysis found that a 154-MW SMR plant could run for 12 years without refueling. “The technology is very good for mission critical functions and activities,” she said.

Safety First

Cost and resiliency are important considerations, but if a power plant, especially a nuclear power plant, is not safe, other considerations pale in comparison.

Safety is built into NuScale’s SMR design, Feldman said. “The SMR has a dual walled vessel design that gives it an unlimited coping period,” she said. “If an incident does occur, the plant can shut down without operator intervention or action and be safe and secure,” she said.

NuScale’s integrated design encompasses the reactor, steam generators and pressurizer and uses the natural action of circulation, eliminating the need for large primary piping and reactor coolant pumps.

If needed, the reactor shuts down and self cools indefinitely without the need for either alternating current or direct current power or additional water. The containment vessel is submerged in a heat sink for core cooling in a below grade reactor pool housed in a Seismic Category 1 reactor building as defined by the U.S. Nuclear Regulatory Commission (NRC). In essence, the unit continues to cool until the decay heat dissipates at which point the reactor is air cooled, Feldman said.

In 2018, the NRC found that NuScale’s SMR safety design eliminates the need for class 1E power, that is, power needed to maintain reactor coolant integrity and remain in a safe shutdown condition.

In August 2020, the NRC approved the overall design of NuScale’s SMR. In a next step, the NRC in July directed staff to issue a final rule certifying NuScale’s SMR design.

If approved, the certification would be published in the Federal Register and have the effect of law, providing even greater comfort to any entities exploring SMR technology to provide clean, emission free, reliable and affordable power, Feldman said.

The rulemaking is on NRC’s docket for a decision in November.

Finally, after a rigorous years long review by the NRC, the Final Safety Evaluation Report (FSER) regarding NuScale’s Emergency Planning Zone (EPZ) methodology was issued. This is another tremendous “first” for NuScale’s technology. With the report’s approval of our methodology, an EPZ that is limited to the site boundary of the power plant is now achievable for a wide range of potential plant sites where a NuScale VOYGR™ SMR power plant could be located.