In this article, we consider the role of small modular reactors (SMRs) in energy infrastructure-challenged jurisdictions such as Puerto Rico. Special Adviser to the firm, Paul Murphy, recently interviewed Eddie M. Guerra, co-founder of the Nuclear Alternative Project (NAP). Gowling WLG has been providing pro bono legal support to NAP as the organization works to provide long-term, sustainable energy solutions for the island. 

Gowling WLG's global nuclear energy practice, anchored in our Toronto, Canada and London, UK offices, is engaged in projects around the world, from North America to Eastern Europe and the Middle East.

NAP is a non-profit organization composed of professionals within the US nuclear industry who are working to change public perception towards nuclear energy, with a primary focus on creating awareness for the next generation of nuclear reactors. Motivated by the idea of transforming Puerto Rico's energy infrastructure into one of resilience and flexibility, and spurred on by the country's devastation in the wake of 2017's Hurricane Maria, NAP has been promoting SMRs as a path to energy sustainability and reliability for Puerto Rico, and for other energy infrastructure-challenged jurisdictions.

Born and raised in Puerto Rico, Eddie M. Guerra is a structural engineer for energy infrastructure, primarily nuclear, wind, and LNG. As part of his notable accomplishments, Eddie served as technical lead and project manager for the first group of seismic risk evaluations performed for nuclear plants in the U.S. in response to the Fukushima Daiichi accident. He has been involved in more than a dozen seismic risk evaluations in the U.S. and internationally and serves on writing committees for the American Society of Mechanical Engineers (ASME) Probabilistic Risk Assessment Standard and the American Society of Civil Engineers (ASCE) Seismic Design and Analysis Standard. He currently serves as industry practice advisor to PhD candidates at the University of Puerto Rico Nuclear Infrastructure Program. Recently, he served as a member of the Civil Nuclear Trade Advisory Committee (CINTAC), which advices the U.S. Secretary of Commerce on the Competitiveness of the U.S. nuclear industry.

His seismic expertise for nuclear power plants has taken him to consult around the world with clients in India, China, Korea, Spain, South Africa, Argentina, Canada, Japan, and the United Kingdom.

1. How did NAP start?

NAP started because of Puerto Rico. First, it is important to understand that Puerto Rico has struggled with an energy crisis for decades. Growing up in Puerto Rico, we struggled with high costs of electricity, total dependency on oil and coal, and continuous blackouts. This was the norm and I witnessed how it worsened as years passed. Rethinking Puerto Rico's energy infrastructure has always been on my mind. This sentiment moved me to start NAP with colleagues and very good friends from Puerto Rico. In 2015, after travelling around the world and learning about the trends and safety features in advanced reactors, I saw an angle for Small Modular Reactors as an alternative to reinvent Puerto Rico's energy portfolio.

I still remember that day when I decided to email all my network of Puerto Rican engineers in nuclear. My pitch to them was simple - first, SMR technological advances makes sense for this technology to be considered for Puerto Rico's energy needs, and second, who better than Puerto Rican engineers to educate about SMRs in Puerto Rico. My idea was to tap into a resource not many in the U.S. nuclear industry know about- there are hundreds of Puerto Rican engineers working in the U.S. nuclear industry, including utilities, the Nuclear Regulatory Commission, technology vendors, and consultants like myself.

I was lucky to start this project with very good friends from Exelon, Westinghouse, Bechtel, and Enercon, among other firms. Of course, I still wanted to work as an engineer, so my thought was to do this in my personal time on a volunteer basis. My group of colleagues and I paid a consultant to help with all the paperwork related to articles of incorporation and IRS 501c3 tax exempt status. NAP was formally incorporated in the State of Pennsylvania on April 2016 and received IRS tax exempt status a year later in 2017. This is how NAP started. As you can see, all of this materialized before Hurricane Maria. How NAP mobilized in response to Maria was an amazing story.

2. Focusing on the situation in Puerto Rico, describe the impact that Hurricane Maria had on Puerto Rico and how it influenced your thinking.

I traveled to Puerto Rico with supplies for my hometown just two weeks after Maria made landfall. I still remember how tears built up as soon as I neared San Juan. What was always a bright city at night, San Juan was so dark that it was unrecognizable from the sky. From that moment, I realized that the Puerto Rico I grew up would never be the same and would be transformed forever.

Now, all my colleagues and volunteers at NAP who had family on the Island wanted to do something. Remember that prior Maria, NAP volunteers were already reaching out to people in Puerto Rico, presenting the option of SMRs; Maria just fueled and transformed what was a passive educational effort into an activist campaign. We all simply saw an opportunity to transform Puerto Rico through modern nuclear technology - not just energy-wise but economically as well. Immediately after Maria, it was amazing to see plant operators, designers, and consultants - all Puerto Rican born talent - wanting to put their nuclear skills to work for a future vision of an SMR for Puerto Rico. This is a vision of a Puerto Rico with a vibrant economy, a strong manufacturing sector, a hub of technology. That vision guided NAP volunteers, and we knew that the reliability provided by SMRs was the perfect solution to sustain such vision for a modern infrastructure.

So, to answer your question, first, my thinking after Maria for NAP shifted towards activism rather than a passive education campaign. And, second, what mobilized more than a hundred Puerto Rican engineers to support this initiative was a common vision of a strong economy and infrastructure where SMRs represented a reasonable option to power critical infrastructure in Puerto Rico.

3. It has been over a year since Hurricane Maria devastated the island. How are things now, and what can we learn from events over the last year?

Today, although the tourism and manufacturing sectors are back on track, people in mountainous regions are still struggling without electricity and access to clean water. A year after Maria, you still find families living under plastic blue roofs. On the positive side, communities took charge and showed the world the toughness of the Puerto Rican people. For example, I'm so proud of the people from my home town of San Sebastian and its Mayor Javier Jimenez. They made national headlines because they formed their own utility brigade and started restoring power to people in need across the town. People were dying and they didn't wait for PREPA (Puerto Rico's state-owned utility).

Among the many lessons learned, there is something cities in U.S. mainland could learn from what happened in Puerto Rico - don't wait to invest in your communities' essential infrastructure until after the disaster happens. This was a clear example of what happens to cities and communities when our essential infrastructure is down - communications, hospitals, airports, water facilities. Why wait to invest in revitalizing our infrastructure until after these are destroyed?

4. Who are the members of the Nuclear Alternative Project?

NAP is a volunteer-based organization with a leadership board and volunteer membership. The leadership consists of Angel Reyes, Jesabel Rivera, Jesus Nunez, Olgamarie Toledo, Ediberto Guerra, and me. Membership consists of professionals and college students interested in educating communities about advanced reactors. Currently, NAP has about 150 members with diverse backgrounds, including engineers, lawyers, and community activists, among many others. Most of our members are college students from Puerto Rico and Puerto Rican-born engineers working in the U.S. nuclear industry.

5. What are the goals of the Nuclear Alternative Project?

For every country or territory where we see application for advanced reactors, we set our goals in three specific phases: engagement, education, and collaboration. We engage volunteers interested in our cause. Through our volunteer base, we then educate communities and leadership about advanced reactors and their potential to empower communities. We then serve as collaborators between industry and community representatives to help understand mutual needs and priorities.

6. You recently went to Puerto Rico, on a trip organized by the Nuclear Alternative Project. Can you tell us a bit about the trip? Who went? With whom did you meet? What was the reception like in Puerto Rico?

How all this came to be was amazing, so please allow me to start from the beginning. I presented the idea of SMRs for Puerto Rico to my good friends at the U.S. Department of Commerce Civil Nuclear Trading Advisory Committee (CINTAC) on November 2017, shortly after Maria. Specifically, my request was for CINTAC to send a position paper to Puerto Rico's leadership urging them to consider the huge economic and export potential of SMRs for Puerto Rico's economy.

The position paper was published on March 2018 and a letter was sent to the U.S. Secretary of Commerce, asking for his help to urge follow-up meetings with leadership in Puerto Rico. The idea was to bring U.S leaders in nuclear to talk to local leadership in Puerto Rico about SMRs.

It was not until summer of 2018 when the trip with a U.S. delegation in nuclear started to materialize. I was able to secure a meeting with the Puerto Rico Energy Commission, which is the utility's regulator in Puerto Rico, the University of Puerto Rico, and the Mayor of San Sebastian. Then, Donald Hoffman offered his support through his organization United Nuclear Industry Alliance (UNI), to co-sponsor this trip to Puerto Rico. Mr. Hoffman was always a phone call away, and his experience guided us in the development of this trip. Then, to even make things more interesting, I was introduced to Mr. Carlos Fernandez, who is a leader in energy law in Puerto Rico. He offered to support the trip by arranging meetings with policy makers and leadership on the Island. In a matter of one month, an unprecedented trip of Puerto Rican engineers, organized by NAP, together with U.S. industry leaders and leadership in Puerto Rico, occurred, with the purpose of discussing SMRs for the Island. This was mind blowing!

The U.S. executive delegation was composed of Donald Hoffman (Excel Services Corporation), Jeffrey Harper (X-Energy), David Sledzik (GE-Hitachi), Jose Reyes (NuScale), Christian Galvez (NuScale), Abdul Dulloo (Westinghouse), and Scott Singer (PAR Systems). The delegation of Puerto Rican engineers was composed of Angel Reyes, Jesabel Rivera, Thommy Santiago, Jesus Nunez, and me. I also want to mention that Olgamarie Toledo was a leader in organizing this trip. She couldn't make it to Puerto Rico but was supporting us remotely from Florida.

It was an intense week of meetings. We met with House of Representatives' Whip Gabriel Rodriguez Aguilo, Senate Vice President Larry Seilhammer, Mayor of San Sebastian Javier Jimenez, Vice Mayor of Villalba Marena Navarro, PREPA's CEO Jose Ortiz, PREPA's Board Chair Eli Diaz, the governor's infrastructure advisor Maria Palou, University of Puerto Rico Faculty, University of Puerto Rico Dean of Engineering Agustin Rullan, and Puerto Rico's Energy Bureau Chief Edison Aviles. The image of Puerto Rican engineers coming to contribute to the Island's infrastructure resonated throughout the local media. By the end of the week, we had interviews with almost every newspaper outlet in Puerto Rico, TV interviews, and we appeared in two of the most popular radio talk shows in Puerto Rico.

Every leader received us with open arms and was willing to listen to our message. The fact that NAP representatives were born and raised in Puerto Rico really opened the doors for an objective and open conversation. Then, coming to the meetings with the U.S. nuclear leadership showed the local leaders that this is not just an idea, but a movement that enjoys the support of the U.S. nuclear industry. Having top executives there with NAP was the key to show the seriousness behind the idea of an SMR for Puerto Rico.

7. What are the key takeaways from the trip? Have there been any developments in Puerto Rico that give you reason for optimism?

Local communities, represented by their mayors, want micro grids and decentralization of the electricity market in Puerto Rico. People are craving for independence from the current PREPA structure.

Solar is very popular in Puerto Rico and is rapidly providing households with the energy independence they want. This is positive for SMRs because of its flexibility to blend with renewable energy generation.

Most people are not afraid of nuclear; they simply don't know nuclear. This was a key finding for us because we knew the word "nuclear" was going to make people cringe, and we were prepared for more difficult conversations. However, people were willing to listen and that is important. Right now, we want to make sure we keep the conversation transparent, collaborative, and objective (evidence-based). Moving forward with our initiative in Puerto Rico, no one could discourage us by saying that people are afraid of nuclear. That is simply not true. People simply don't know and are open to learn.

We saw mixed reactions from local media. From one side, the anti-nuclear media showed photos of Fukushima and Chernobyl at their cover page. This was complete opposite of our message of advanced and small reactors for Puerto Rico. These misrepresentations and the overall tone of prejudicial media are the ones that will trigger fear in people. On the other side, the more open media outlets stuck to one message - information is power. Still weeks after we returned from Puerto Rico, radio talk shows were talking about us and the need to learn more.

8. What are the short term actions for the Nuclear Alternative Project?

First and foremost, we are seeking funding for a feasibility study. With our trip, we confirmed the openness from both the local leadership and communities to the option of SMRs. Now we need a feasibility study to answer the key questions for stakeholders and community in general: Would seismicity be a deal-breaker considering new SMR safety issues? Could SMRs provide a competitive levelized cost of electricity when compared with other base load fuel imports? What are the financing options for Puerto Rico and the role of the Federal Oversight Board? How would SMRs fit into the future vision of Puerto Rico's micro grids? Could SMRs deliver on the need of Puerto Rico to revitalize its economy? These and other key questions are important to determine whether an SMR makes sense or not.

Second, NAP is currently developing collaborative arrangements with local community-based organizations for educational purposes. We are betting that knowledge will eradicate fears in people. Who better than Puerto Rican-born nuclear engineers to lead this initiative and connect with the people?

9. In the longer term, how do you define success for the Nuclear Alternative Project, and what is your long term vision for Puerto Rico?

We want to stick to the name of the organization. Advanced nuclear could represent an alternative to islands and small territories looking towards decarbonization. Therefore, for every territory and island we go to, success for NAP will mean first, to address whether advance nuclear makes economic and practical sense, and second, to work towards a well-informed public so that advance nuclear is accepted by the community. NAP has its own community involvement strategy which has been successfully implemented in the healthcare industry and which promises to lay the foundation for SMRs to deliver on their promise.

As to my long-term vision for Puerto Rico, I have always envisioned a Puerto Rico with a vibrant economy that can serve as a role model for the Caribbean, Latin America, and the rest of the world. Such an economy will require a resilient and modern infrastructure - ports, high speed transportation systems, hospitals, communications, etc. I do believe SMRs, in combination with other energy sources, could provide the resilient energy base to support such infrastructure. A diverse portfolio of LNG and SMRs for essential facilities and solar and storage for residential could be the launch pad for an economy of the 21st century. No one can tell me that such vision is too big for Puerto Rico. I am 33 years old and have travelled to more than a dozen countries. I have seen that Puerto Rico's engineering human capital is unique around the world. The vision for a great infrastructure in Puerto Rico is possible, and we have the people to go there.

10. For those that want to learn more about the Nuclear Alternative Project, where can they go?

Please register at our website and get involved!

Website: https://www.nuclearalternativeproject.org/

Email: info@nuclearalternativeproject.org

Involvement form: https://www.nuclearalternativeproject.org/get-involved

11. As a non-profit organization, what sort of help does the Nuclear Alternative Project need, if people want to get involved?

Right now, we need help from funders and bloggers. First, funding is needed to pay travel expenses for our volunteers and second, the amount of technical questions we are getting from Puerto Rico is staggering and we need people to help us respond to such questions in an objective and culturally-sensitive manner.

* Gowling WLG supports the Nuclear Alternative Project on a pro bono basis.