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  1. “No other owner would have the ability — without a change in state law — to move the output from the facility to the market. Without any path to customers, no other owner would consider buying the facility.”

    Just curious. Could a buyer have legally purchased the plant, under a contract to sell the output to OPPD, who would then distribute the energy?

    1. The “work-around” that came to mind for me was to build a factory right next to the plant that uses huge amounts of electricity: aluminum smelting, calcium carbide production, etc.

      1. Already is a big Ethanol plant sharing fences with the plant. That plant, a Fertilizer plant and another uses a majority of FCS’s power.

        1. The EtOH plant should have been using Ft. Calhoun’s low-pressure steam to do all its mashing and distilling.  That would have made it one of the lowest-carbon EtOH plants in the world.

  2. “The uprate plan was far enough advanced that the needed new high-pressure steam turbine has already been delivered and is sitting inside the building.”

    Your article brings to mind many questions, particularly for someone like myself, who is very unknowledgable about plant operations and equipment. I’m curious how much of the facility apparatus is resaleable. If this steam turbine is unused, will it simply be scrapped, or will OPPD attempt to find a buyer? And do the regulations about decommissioning a plant allow for the sale of operational equipment, both new and used??

    “Maybe it’s time to do more than just think and write articles like this one published in 2013 on ANSNUCLEARCAFE. Why don’t we “mothball” shutdown nuclear plants?”

    “Anyone interested in helping should make direct contact.”

    Here is another area where comment from Ms. Korsnick would be a barometer of her intentions and strategies. Will an active and robust effort be waged to inform the public that a non-polluting power source is being sacrificed, with an end result of clean power being replaced by polluting power? If not, its a huge mistake in PR efforts.

    1. I doubt there is a plant (at least Nuclear) that would be able to use the High Pressure Turbine of a <500 megawatt Combustion Engineering Reactor.

      However, I do know that equipment is bought and sold between utilities. For instance, the Reactor Coolant Pump motors (RCPs) for our never completed Unit WNP-3 and WNP-5 were sold to the Plant I'm currently working at as a shared resource……Palo Verde. WNP-3 and WNP-5 were to be Combustion Engineering System-80 Reactors, the exact same design as the 3 units at Palo Verde.

      1. I’ve been reading Ron’s blog for 5 or 6 years now and this is my first ever reply. Just wanted to comment that I continue to work at the site for WNP 3&5 and even to this day checks continue to come in from our nuclear assets.

        1. I work at WNP-2…..aka The Columbia Generating Station.

          “I’ve been reading Ron’s blog for 5 or 6 years now”

          Well….after that long you should know that his name is Rod 🙂

  3. My guess is that some kind of NRC rule change may be necessary to improve the situation with respect to mothballing plants.

    To anyone here who is attending the ANS fall conference, that may be a good venue to discuss this idea with industry leaders (in ANS, NRC, DOE, NEI, etc…). I’ve looked over the conference program and found several sessions that could be considered related to this idea (and may be good sessions to attend).

    Perhaps the most interesting session is the “ANS President’s Special Session: Identifying the Nuclear Grand Challenges”, which is described as follows:

    “At this session, President Andy Klein will kick off a Society-wide project to identify 6-10 ANS Nuclear Grand Challenges that need to be addressed by 2030. An interactive brainstorming session in roundtable format will follow speakers discussing current advanced nuclear technology directions. Ideas submitted during the session will be analyzed and vetted by ANS Professional Divisions, and the selected ANS Nuclear Grand Challenges will be announced at the ANS Annual Meeting in June 2017.”

    Someone could raise the mothballing issue as a challenge that could be addressed, at their tables brainstorming session. Unfortunately, I’ve heard that the ANS (predictably) is looking for technological problems to solve. Never mind that nuclear’s most significant problems are not technical in nature (alas, everything looks like a nail, to nuclear engineers). So, I’m not sure how receptive they will be to “solutions” or “challenges” in the policy or regulatory sphere.

    Other sessions that look interesting are:

    Monday 1:00-4:00: Roles of Regulatory Organizations

    Tuesday 1:00-4:00: US Reactor Fleet Viability in Challenging Financial Markets

    Tuesday 2:00-4:00: Understanding ANS Position Papers

    Wednesday 8:00-9:45: Nuclear Politics: Advocacy

    Thursday 8:00-11:30: NRC Decommissioning Rulemaking: An Update on the Progress and Issues Coming Out of the Rulemaking Process–Panel

    These sessions either have a related topic or are places where the right people to talk to (e.g., NRC leaders) may be present. Thus, they may be a good place to make the case for this idea, either during the session, or afterward in private conversations. I would encourage anyone who is going to the meeting to attend one or more of the sessions above, and take a stab at pitching this idea to important people.

    1. The ANS focus on “technical” problems is a major problem. I understand the limits of what a technical society can do, but this is now completely out of hand. It is another example of the most prominent group in our industry squandering an opportunity to make things better now or within a few years, not a minimum of 15 years from now.

      Why is it that other (usually newer) groups are the ones that are directly attacking our problems. For a quick run down, the NEI is attacking our current cost issues (though, they can be doing more…), Environmental Progress is attacking the anti-nuclear green groups that conspire to shut down nuclear plants (they are doing more than that as they are also rallying to support the existing plants), and the Nuclear Innovation Alliance is attacking the licensing issues with a proposal on a new way to license our plants (one that is cheaper and faster than the current method). Where is the ANS in all of this? They, as usual, have their head stuck in the clouds of our glorious future — if only we could have that better mouse trap and then the whole world will see how great we are! Then they will come rushing to us and all will be good! — Hogwash!

      Our problems are cost, cost, cost, and then perception. I have perception last because I believe that if nuclear were cheap (not cheaper…I mean cheap, like the current cost of natural gas kind of cheap), people would pony up for all the nuclear power they could get regardless of how safe it is (or is not). So, how do we cut our costs? The first place that I would look to is the NRC and all the associated regulation. Yes, I agree with the ANS that new plant designs would eliminate much of the reason we have the costs we currently have (e.g., walk-away safe plants), but we need to get a grip on reality. It is possible that after Summer and Vogtle, there might not be another new plant in the US. NuScale looks to be actually happening, but that is still years away. So we could be stuck with a slowing dying fleet of reactors each trying to eek out its last days in silent productivity before the solar-wind-natural gas powered Grim Reaper arrives to turn them off. And who would want to work there in that type of environment anyway?

      We need to be thinking and acting as though these were out lasts days alive on Earth, because that is what it could turn out to be. We need to grow a backbone and start pushing back against unnecessary costs imposed by unnecessary or excessive regulation. Who is doing that? Anyone? If you all know for a group that is doing that, please let me know since I have not heard of them. (Seriously, are we the only industry that does not push back? Look at the auto industry. They push back all the time. They actually have a dialog with their regulator, a heated dialog, but a dialog none the less. And they have that dialog all of the time (!!!) and not just every now and then in response to some particularly egregious regulation).

      1. We can start by demanding the NRC severely relaxes the Security requirements at Nuclear Power Plants to match the actual risk…..which is very…..very….very low OR if they feel these vital energy structures REALLY require these ridiculous security staffing numbers and procedures, then it should be the Federal Government who is responsible for protecting them from the attacks of foreign organizations. These goddamn plants are already militarized supermax prisons as it is…..having the National Guard responsible instead of the Utility only makes sense.

        The Federal Government should be paying every dollar (millions….maybe billions) that Utilities are being forced to spend on “spent” fuel dry cask storage because they have failed to supply the promised storage facility.

        The Federal Government should reimburse the Millions (at each site) that the NRC’s required “Fukushima” mods have cost the utilities due to beyond basis changes. Fukushima was a Natural Disaster…..not a Nuclear Disaster.

        Dismiss INPO from their job of making Nuclear Power safer. Good work boys, but we are being forced to cut back and being Nuclear Power is already the safest (has been for a while now) and most efficient method (capacity factors 90+%) for producing power…..its time to go.

        1. That’s a good start. As mentioned below, let’s include revised radiological controls for work at the plant (higher limits, longer stay times, etc.). Let’s also address the radiological release requirements and the exclusion zone distance.

          I agree about the INPO statement. Do they actually provide a useful benefit anymore? Folks, please fill me in on this because I have yet to see the benefit we get for the money we spend on them (and meeting their requirements).

          1. “and meeting their requirements”

            See…..we have given INPO so much power that we have forgotten that it’s actually “suggestions” not “requirements”.

            You know its time to do something when a plant does more to prepare and get ready for an INPO evaluation than they do for a NRC evaluation.

            Every time I see “AFI” (area for improvement) I want to vomit. Here is an AFI for you INPO……the area we need to improve is lowering our operating costs, of which you are directly responsible for increasing. Bye bye.

          2. The information sharing that INPO provides is useful but I’m sure this can be done without the rest of the baggage that INPO carries. While it’s true that nuclear capacity factors have increased since INPO was created, is this a coincidence of did INPO help bring it about?

        2. Average NPP has a larger security force than the typical city within 25 miles of it. Next read the NRC qualification and training requirements for the security force as detailed in 10 CFR.
          When I retired, the plant had more administrative personnel in the Security Department (managers, supervisors, instructors, secretaries, etc. that perform NO security function) than the total number of security personnel for the first plant I worked at.

        3. “Fukushima was a Natural Disaster…..not a Nuclear Disaster.”

          Such a message is a marketing and PR disaster on so many levels, a book could be written about it.

          You might as well write “We can’t make a plant that will withstand a natural calamity. It ain’t our fault we can’t make a safe plant.”

          Like or not, the public sees Fukushima as a plant safety failure. They believe, perhaps mistakingly, that the industry told them “it can’t happen”, and it DID happen. So now you are gonna tell them “oops, gee, the earthquake and tsunami did it, hasn’t got nuthin’ to do with plant safety”(?) Because thats what it sounds like you are saying.

          Sometimes I think you guys are on a different planet. Heres the deal. The public believes radiation is deadly. They wanna hear you say “You won’t be exposed to radiation”. They ain’t interested in, or receptive to, being told “It ain’t gonna hurt if you are exposed”.

          And the public believes Fukushima was a nuclear disaster They wanna hear you say “Fukushima taught us valuable lessons about plant safety, and we are making changes that will protect against it happening again”. They do NOT wanna hear “Fukushima ain’t no big deal, nothing to see here folks, move along, move along”.

          Seriously, some of you really need to keep your mutterings in house, and leave the PR and marketing to those amongst you that have half a clue. And if you can’t find anyone like that, you better pony up with the funds, hire proffessionals, and get your PR act together. Soon, before you go under.

          1. @poa

            Brian is no longer participating, so I’ll have to step in and remind you that you are welcome to share your point of view, but it is a bit vain to believe that you represent the public. You do not live in a representative area; it doesn’t appear that you spend much time traveling to diverse parts of the country; and you do not work in a field that gives you constant contact with a wide variety of people and opinions.

            The message that you suggest, by the way, is exactly the message that I hear constantly from the top levels of the nuclear enterprise at DOE, NRC, NEI and INPO (that last group doesn’t speak to public, but it does to people in the business.)

            It is, in my opinion, an expensive message that is not exactly true. We think we learned lessons and we have invested more than $3 billion so far in implementing what we thought were solutions. However, we have not faced up to and tackled the most important lesson that is available for learning.

            That lesson is that nuclear plants are pretty well designed to fail gracefully and to retain enough of the dangerous materials in the various layers of the plant that even complete core melts in three power plants where a lot of things didn’t go well did not release material that caused harm any member of the public.

            That is not to say that no member of the public was harmed by the RESPONSE to the event and to the fear and confusion that resulted. The lesson that we must learn is that our response plans and training are wrong and need major revision. We need to stop investing money into confusing sirens and evacuation response plans and start investing it into planning immediate and long term actions that will actually protect people from harm – including the harm caused by stress based on bogeyman fears.

            We need to spend more time and energy doing exactly what our opponents have been doing for decades; we should assume that another event is on the way so we should be preparing our responses now to take advantage of it when it happens.

          2. “You do not live in a representative area; it doesn’t appear that you spend much time traveling to diverse parts of the country; and you do not work in a field that gives you constant contact with a wide variety of people and opinions.”

            I will, next year, be working on a home on Whidbey Island, Washington, and another in Jackson Hole, Wyoming. In California, in the last two years, I have worked on homes in Beverly Hills, Pismo Beach, San Fransisco, Bakersfield, Sacramento, and Malibu. My customers include people in the entertainment industry, doctors, accountants, farmers, ranchers, the owners of large construction companies, and huge oil field maintainance companies. I do not “represent” the public, I AM a member of the public. And I discuss NE energy with my friends, customers, family, etc.. I know, first hand, of the fears that are ingrained and reinforced about radiation, and nuclear power plants. Your messages about plant safety, the true effects of radiation, and the exaggerated and sensationalized effects of events such as Fukushima ARE NOT getting out to the mainstream. You might imagine they are, Rod. You might wish they are. But sometimes, reality, and optimism, don’t exactly meld. I don’t know where you draw your opinion about how John Q feels about NE, but it sure as heck ain’t the opinions of the John Q I talk to.

          3. My customers include people in the entertainment industry, doctors, accountants, farmers, ranchers, the owners of large construction companies, and huge oil field maintainance companies. I do not “represent” the public, I AM a member of the public.

            … who gets his feedback from a very narrow, rich, White and almost certainly ideologically-conformist sector which does not and include anyone in the nuclear industry, health physics or radiological medicine.

            I’ll bet dollars to donuts you’ve never sat down with a real climate scientist either.

            Your messages about plant safety, the true effects of radiation, and the exaggerated and sensationalized effects of events such as Fukushima ARE NOT getting out to the mainstream.

            Yes, we know about the propaganda apparatus.

            Since you’re out there, what are YOU doing to counteract it?

          4. Insult removed by editor
            Where did I say Fukushima wasnt a big deal? Fukushima was a plant caught in the wrath of an EPIC natural disaster that killed 20,000 people. Fukushima hasnt directly killed a single person from the radiological release or associated exposures. How can something that hasnt killed, or most likely will not kill a single person be considered a “disaster”. I 100% do not agree with my plant being required to spend 80+ million on mods that, in general do not make the plant that much safer and are an incredible financial burden on the operating Utility. Nuclear Power Plants (outside of idiotic soviet russia) are already INCREDIBLY safe…..even in the WORST CASE scenarios that they are unable to cool the core. Fukushima has proven this beyond a doubt.

          5. “…..which does not and include anyone in the nuclear industry, health physics or radiological medicine.”

            If thats your target audience for your PR, expect failure on changing the mainstream narrative.

            “I’ll bet dollars to donuts you’ve never sat down with a real climate scientist either.”

            Nope, sure haven’t. Your point? Do I need to do that, to hear what the John Qs I come in contact with think about NE?

            “Since you’re out there, what are YOU doing to counteract it?”

            Well, I am trying to relay the message that Rod has relayed here on this website. At the very least, when I discuss NE I encourage an open mind, and exploration of advocacy sites such as this one. Trust me when I tell you that I don’t mention the rude, judgemental, and partisan reception the are almost assuredly going to recieve from some of you.

            1. @poa

              And your effforts and questions are appreciated. However, the members of the public that you mention probably do not struggle with paying for gasoline to the point where they talk about stations that sell for a few pennies per gallon cheaper than their competitors. They probably don’t get a shock with they receive their power bill after a particularly hot or cold month. They probably do not wonder how life will be for their children in a world where fossil fuels are getting ever more expensive while night and windless days still happen as they always have.

              I’m a patient man who understands inertia quite well. There is progress happening even though it might not be as visible as I would like it to be. I agree that we need to do a better job of marketing out excellent product.

              We need to convince customers that it is valuable, that it makes their lives better, and that it helps improve their environment. We need to find new customers so that we are not abjectly dependent on a small segment of the overall energy market. We need to build strong alliances with others who recognize the importance of reliable, abundant energy in enabling the American dream that you and I grew up with, not the very limited and blinkered world that is promoted today as the best that we can do.

              I’ll keep working to improve my output and develop new ideas and new audience members. I will retain my optimism and my love and respect for humanity.

              At the same time, I’ll continue telling the truth as I see it about the ways that SOME rich, powerful and exceedingly self-centered people are harming the rest of us by suppressing the use of some of the most incredible tools our creator provided.

          6. “Fukushima was a plant caught in the wrath of an EPIC natural disaster that killed 20,000 people.”

            Yes, “EPIC”, indeed. If you live off planet. Tell me, how many MAJOR earthquakes have we experienced, globally, in the three decades? And tsunamis, with mass casualties? And, you might comment on the seismic zones, such as Southern California, that are long overdue for just such an “epic” event”. Earthquakes and tsunamis are not global anomalies, despite your attempt to convince us otherwise. The only thing “epic” about the Japanese quake, occurring in a highly active seismic zone, was the fact that a nuclear facility was rendered inoperable by the event, resulting in a nuclear meltdown, and a humungous PR disaster. I would think that those such as yourself, concerned advocates, would pay careful attention to how you remedy the PR disaster, rather than making it worse by employing unthinking industry bluster.

          7. poa,

            The points you raise are valid and serious. You’re largely right about everything you say. This is kind of a Catch-22 situation for the industry.

            The problem is that if we take the attitude that nuclear releases (meltdowns, etc.) are unacceptable and must never happen again, it will result in the death of nuclear power, due to it being too expensive to compete.

            As Rod points out, that actually IS the attitude, and message, of the industry leadership. And look where it’s gotten us (i.e., what’s happening). New reactors are nowhere near economical, and even existing reactors are struggling to compete and are shutting down.

            I’ve thought long and hard about this dilemma (the points you raise vs. the need to be economically competitive), and my conclusion is that we have no choice but to face the real issue head on and try to change public attitudes and perspectives concerning nuclear releases. It is the only path forward, because attempting to meet a standard of perfection (i.e., to avoid any releases in the future) will doom the industry by pricing it out of the market.

            We have to teach the public about the relative health impacts of nuclear vs. fossil fuels (fossil generation’s impacts are many orders of magnitude higher). We have to get the message through that very rare releases of pollution are far better than the continuous release of pollution. We have to defeat the prevalent mindset that radiological pollution is *qualitatively* different than all other forms of pollution, such that it must be avoided at all costs.

            The first step in this is to stop drastic over-responses by industry and govt. to such releases. One example is Japan declaring areas that may pose a ~1% lifetime cancer risk as “uninhabitable”, and actually moving people out of the area, when living in most major cities actually represents a greater lifetime health risk. Mankind routinely faces much higher risk factors, for which nothing at all is done about.

            The public watches what we do, not what we say. So, when they hear us say that Fukushima didn’t cause any deaths, etc.., but they then observe actions and responses that suggest it is a uniquely severe hazard (e.g., long-term evacuations), they see the inconsistency and conclude that our words are lies. Just today, I responded to a comment pretty much to that effect (“if it’s not that hazardous, why did they evacuate the area”).

            I understand that this will be a huge uphill climb. To be honest, I think our chances of success are fairly small (i.e., that the industry may indeed be doomed – too much damage has been done). But we have to try. It’s our only chance of success.

            Continuing to promise that radiological releases will never happen again is not the path forward. Not only will the attempt to avoid them (at all costs) make nuclear uncompetitive, but if and when a future lease does happen, it will result in another complete loss of credibility and trust in the industry, since we had promised (once again) that no such releases would occur ever again. Other industries don’t make such promises. Airplane crashes actually result in more loss of life than nuclear plant meltdowns, but you never see the airline industry promise that there will never be another crash.

      2. RTK,

        Couldn’t agree more. ANS, and most in the industry, keep trying to find technical solutions to non-technical problems. (Because they’re engineers, and that’s what engineers like to do, and is how they view the world.) Either they think that lack of technical merit is nuclear biggest problem, or they think that an even greater level of technical merit can overcome an unfair regulatory and policy playing field. Or do they (actually) think that some wonderful Gen IV reactor will be so safe than the antis will stop saying nuclear is dangerous?

        My personal view is that no reactor design would be able to withstand the hugely unfair, unlevel regulatory and policy playing fields that exist today, which are the result of deeply prejudiced attitudes against nuclear and potential radiological releases, held by much of the public. Unless things change, none of the wonderful new reactor designs will be competitive either. (Note that most of the new reactor designs actually give up economy of scale.) In order to be economic, they must insist on using these reactors vast, inherent safety advantages as a justification for greatly reduced requirements (regulations, fab QA, etc…).

        Environmental Progress is more on the mark, although their efforts are limited to addressing the unfair policy playing field (i.e., to give nuclear credit for its non-polluting nature, similar to renewables). I personally, however, think that the regulatory playing field is the bigger issue. I find the NIA initiative you describe interesting, but I somehow doubt it will be enough, or go as far as what would really be justified. I have a fear that if we give nuclear subsidies, w/o having the industry change its (cost-escalating) ways, the subsidies will just allow costs to go up that much further.

        As for really cheap nuclear, I agree. Studies show that people are willing to accept risks if they perceive a benefit. If the public viewed nuclear as a means of reducing power bills, that would go a long way. Right now, however, their impression is the opposite (they associate nuclear with higher costs). Who would support a source that may be risky and is also high cost? Spending more on safety will not stop the antis from saying that nuclear is dangerous. It merely allows them to (now) say that nuclear is dangerous AND expensive.

        1. Jim,

          I agree that the NIA initiative might not be enough. In fact, I have often wondered what would be enough. Every time I start think about this subject, I end up coming to the same conclusion. We need to completely start over with nuclear regulation in the US. I do not think that simply tweaking it will be enough (sometimes simply starting over is the best option, especially if one can learn from the mistakes of the past) . In my opinion, we should think about the pros and cons of our current system and set about designing a new regulatory structure that encourages safety while enabling the industry to thrive. I am sure that there are others who have ideas on how to do this, and I would love to hear from them. Now, the NRC is not the only problem, but they are probably the place to start.

          I also agree that, in the current regulatory environment of absolute perfection, the new reactor designs are probably going to be more expensive than what is planned (and, as a result, dooming them in their infancy). Even more of a reason to reform the NRC.

          In regards to our industry’s abysmal public relations, perhaps we should take a page from Donald Trump and just start attacking the media for being so incompetent. I realize that it is a risky strategy, but the little outreach that we do does not seem to be working (and I am not sure if a significant increase in outreach would work either). The facts are on our side and we can prove it. Perhaps an open fight might draw in enough onlookers in the general public that we can actually get some real attention (one that we can somewhat control) and actually inform the public. Otherwise, why would they care? Global warming? That has not worked so far. The hazards of emissions from the combustion of hydrocarbon fuels? That might work (I’m thinking of the anti-smoking ads that show the consequences of lung / throat cancer).

          One thing that has always bothered me is our industry’s complete lack of advertising. Yes, I know that the NEI does some in and around Washington D.C., but that does not count for much. If the natural gas industry can air television and radio advertisements boasting about their job creating abilities, “clean” power, and energy independence, then why can’t we? We live in the age where good advertising can be done cheaper that before (since there are many more options than just TV and radio), so where is it? We have plants getting shut down that could last for 20 – 30 more years and yet we do nothing. Simply pathetic. If we do not care about ourselves, why should anyone else?

  4. BTW, the “ANS President’s Special Session: Identifying the Nuclear Grand Challenges” is 4:30 to 6:30 on Monday.

  5. And yet another thing…, As for arguments in support of this idea, I have two thoughts.

    Nuclear plants should be able to go into a mothballed state which results in ongoing (maintenance) costs that are very a small fraction of the operating costs (when the plant is in operation). At a later date, the plant should be able to re-enter service at a modest cost, with little if any licensing activity. In other words, it should not work too much differently than it would for a fossil plant.

    When deciding whether to allow a nuclear plant to resume operation, NRC should consider overall impacts, as opposed to being solely focused on maximizing nuclear safety only. In other words, they should have to consider that if a nuclear plant does not reopen, its output will largely be replaced by fossil generation. Thus, they need to compare the risks/impacts of nuclear plant operation vs. those of the fossil generation that would be used instead. They should have to evaluate that before they impose such a large burden for restarting that the restart doesn’t happen.

    My personal view is that they shouldn’t even have the right to disallow a nuclear plant restart unless they can produce a rigorous evaluation showing that the risks/impacts of the nuclear plant operation would exceed those of fossil generation.

    1. [the NRC] shouldn’t even have the right to disallow a nuclear plant restart unless they can produce a rigorous evaluation showing that the risks/impacts of the nuclear plant operation would exceed those of fossil generation.

      I think this should be a general principle for regulation.  The NRC should have to show that existing regulations are worth what they cost in terms of safety compared to fossil fuels, and that any new regulations increase safety compared to the dirtiest, most dangerous energy in competition with the affected plants.  Last, the NRC should have to use the best available science when calculating risks.

      When the statistic for fata; car-train collisions with coal trains is put up against actual risks from nuclear, I suspect that very few regulations would survive such scrutiny.

      1. I understand the sentiment, but realistically the NRC cannot regulate that way. They know even less about the safety of fossil burning units than they do about the safety of nuclear units.

        1. If they can calculate fault probabilities, they can sum up mortality and morbidity from US Department of Transportation and EPA statistics to get a floor figure.

          They can also look at US and foreign disease statistics to determine a floor for a tolerance dose for radiation.

          1. I just realized that would put the radio-phobes in the EPA in a pickle.  Every time they raised the risk assessment of a criteria air emission from a FFPP, they’d shift the externalized-cost assessment at NRC further in favor of nuclear.