Licensing demonstration reactors in the United States
During the joint DOE-NRC workshop on advanced non-light water reactors held last week (Sep 1-2, 2015), John Adams of the Nuclear Regulatory Commission (NRC) Office of Nuclear Reactor Regulation gave a presentation on reactor license classification terminology.
It made me squirm in my chair with the desire to interrupt. Probably because he has read and studied the regulations he is tasked to enforce with a different lens than the one I have used in my 25 year long quest to figure out how to license non-LWR reactors, he had overlooked a key provision that marks a perfectly valid, but not recently used licensing path.
Aside: I have a confession and an apology; I didn’t actually wait until Mr. Adams was finished, but I sheepishly put my hand down after being given a “look” by the man introduced to us as the master of ceremonies slash sergeant of arms. I apologize to Mr. Adams for disrupting his presentation. End Aside.
Once he finished his presentation, I stepped up to the microphone to ask Mr. Adams why he had stated that demonstration reactors were not allowed to be able to generate any electricity. I pointed out that was not what the regulations stated for a class 104(c) license.
Mr. Adams took my question for a “look-up,” and returned at the end of the workshop to report an interim answer. Based on a read from the General Counsel’s office, he agreed that the provision I cited existed and might be able to be used for reactors that have inconsequential commercial uses. He said there was more research needed to fully flesh out and understand the implications of the language.
It might help the process if I share more of the detailed thought process and research underlying my question.
Since this is a fairly complex explanation that could cause a MEGO (my eyes glaze over) response among important readers, I’m going to attempt to liven it up using some metaphors and analogy to a treasure hunt with mysterious, obscured clues and a faded, but carefully protected map. Forgive me, I’m a technically trained guy with a not-yet-realized dream of becoming a best selling author of exciting novels.
Finding an obscured path for R&D reactor licenses
The marker for the trail to the useful and valuable treasure of NRC permission to build and operate a reactor that can fully test a complete system designed to sell to commercial customers is easy to miss, especially if you are not looking carefully, knowing it must be there somewhere.
I found the marker and followed a short part of the trail a few years ago when working for B&W mPower, Inc. I was in the envious position of leading the effort to develop formal procedures needed to document our design effort and quality assurance steps. Success in that assignment required me to refine my ability to read and understand the “nuclear regulatory” language. Because of some common roots, there were similarities between the new language and one I had learned reasonably well during a 33 year long career in the US Navy and Naval Reserves.
As is often the case in developing language fluency, my understanding of “nuclear regulatory” was enhanced by studying the history and culture that have influenced the unfamiliar words and phrases found in the voluminous documents, regulations, letters, legislation and associated literature that nuclear regulators and legislative overseers have published during the 70 years since the passage of the Atomic Energy Act of 1946 and the even more important 60 years since the passage of the Atomic Energy Act of 1954.
My history and culture studies told me that the creators of The Act recognized that atomic energy was a new and powerful technology with almost boundless potential for both benefits and harm. They wanted to establish a system that would ensure adequate safety while not stopping the exciting and challenging work of continuously improving the ways we use this incredible source of power.
With wide ranging understanding of technological development and the need for aggressive learning and testing, the drafters of The Act of 1954 established provisions designed to encourage research and development. They were inspired by President Eisenhower’s “Atoms for Peace” speech. It was the basis for the massive changes between the 1946 version and the new Act. The following inspirational vision apparently led to various provisions related to the development of innovative technology.
Who can doubt, if the entire body of the world’s scientists and engineers had adequate amounts of fissionable material with which to test and develop their ideas, that this capability would rapidly be transformed into universal, efficient, and economic usage?
Unfortunately, some of the enabling paths they created have become overgrown or purposefully obscured over time. Faded blazes marking some under used trails, however, have not been completely removed. The one I discovered a few years ago might turn out to be especially valuable.
Since I did not take any of the documents I wrote with me when I departed from B&W — they were not mine to take — I’ve recreated the research work I did on this particular issue. (My 2011 vintage paper was virtually ignored by the project leaders. They decided there was too much effort and risk associated with trying to clear a path that had not been used in more than 40 years.)
The nearly forgotten trailhead marker is in 10 CFR 50.21 Class 104 licenses; for medical therapy and research and development facilities. It states:
A class 104 license will be issued, to an applicant who qualifies, for any one or more of the following: to transfer or receive in interstate commerce, manufacture, produce, transfer, acquire, possess, or use.
(c) A production or utilization facility, which is useful in the conduct of research and development activities of the types specified in section 31 of the Act, and which is not a facility of the type specified in paragraph (b) of this section or in § 50.22.
Of course, that clue doesn’t mean much without contextual knowledge, new research and the determination to tease out the meaning.
When I found the provision, I had recently finished one of my treks through the Atomic Energy Act of 1954 with some special focus on section 104. That section contains encouraging and supportive language for innovative developers. The part of section 104 that excited me was the following:
c. The Commission is authorized to issue licenses to persons applying therefor for utilization and production facilities useful in the conduct of research and development activities of the types specified in section 31 and which are not facilities of the type specified in subsection 104 b. The Commission is directed to impose only such minimum amount of regulation of the licensee as the Commission finds will permit the Commission to fulfill its obligations under this Act to promote the common defense and security and to protect the health and safety of the public and will permit the conduct of widespread and diverse research and development.
One of the challenges of understanding “nuclear regulatory” is that there are many concepts and phrases that are defined more by what they are NOT than by what they ARE. In this case, a research and development facility licensed under section 104(c) can be any facility that helps in the research and development activities described in Section 31 (we’ll come back to that criteria soon) but is NOT a facility of the type described in section 104(b) and is NOT a facility described in § 50.22.
Section 104(b) abuses and controversy
Many currently operating nuclear power plants were initially licensed as research and development facilities under section 104(b). At the time many of those licenses were issued, there was only one operating nuclear power plant in the US, the Shippingport reactor built under the supervision of the Naval Reactors branch of the AEC.
The organizations developing the designs and building the Section 104(b) plants were planning to use them to produce commercial quantities of electricity if they worked as planned. They were not, however, sure that they would work reliably or last as long as expected because no complete systems had been built and operated for an extended period of time.
There were an number of advantages granted licensees who chose to build and operate under Section 104(b). The projects were not subjected to anti-trust review, the operators could lease fuel under favorable terms (sometimes with no cost at all), the Atomic Energy Commission (AEC) would guarantee payment at a favorable rate for the fissile plutonium produced during operation, and the projects could qualify for certain kinds of advantageous relationships with AEC laboratories.
Not surprisingly, class 104(b) licenses were both popular with applicants — to the point of abuse — and unpopular with competitors. Those competitors, logically enough, opposed the policy of the government using their tax dollars to subsidize the commercial construction of additional sources of power that would reduce sales of their products.
There is an excellent discussion of the political struggles over class 104(b) licenses and the associated AEC encouragements in pages 202-212 of Balogh’s Chain Reaction: Expert debate & public participation in American commercial nuclear power. 1945-1975. That section of the book describes the incentives and the nature of the bandwagon market that resulted in dozens of firm orders for power plants between 1963-1968 that were, paradoxically, described by the AEC as not yet having demonstrated “practical value.” It also describes the concerted effort by politicians and lobbyists to question the AEC’s refusal to recognize that the systems must have “practical value” if companies were ordering them and investing hundreds of millions to billions of dollars into their construction.
The root of the issue was a provision in Section 102 that told the AEC that it could no longer subsidize and protect developers from outside scrutiny of anti-trust rules once the Commission had issued a document determining that specific types of nuclear power plants were sufficiently developed to be of “practical value.” Here is a sample quote:
Quick to market commercial nuclear power as economically competitive, the Atomic Energy Commission was in no hurry to rule on its “practical value.”
One unintended consequence of the AEC’s successful marketing strategy, however, was to increase pressure on the AEC to rule that reactors did have practical value. Why else, asked the coal boys, were utilities spending hundreds of millions of dollars to construct them? Thus, when head coal boy Stephen Dunn, president of the National Coal Association, wrote to Glenn Seaborg in December 1963 and insisted that the AEC perform its statutory duty by issuing a written finding as to whether commercial power had “practical value,” much of Dunn’s evidence rested on statements made by the AEC and the Joint Committee on Atomic Energy. Testifying at JCAE authorization hearings several months later, Joseph Moody, president of the National Coal Policy Conference, presented a powerful case, again built upon AEC and JCAE statements, of the competitive nature of nuclear power. To this rhetorical evidence, he added some impressive behavioral data. The utilities were investing heavily in nuclear power. Several, Moody pointed out, had publicly stated that their reactors, when completed, would compete favorably with conventional fossil fuel-burning plants. “The current sense of ‘urgency’ in expanding the commercial atomic industry,” Moody told the JCAE, “represents a new, and inexplicable, phase in the various justifications that have been used for the government’s program.”
Moody demanded an immediate halt to the subsidies.
As the National Coal Association’s general counsel, Brice O’Brien, put it, “Thermal reactors have reached the point where they should be placed in the mainstream of commerce to stand on their own feet without the artificial stimulation and artificial distortion of taxpayer-financed subsidies.”
In December 1970, legislation was passed that eliminated section 104(b) as a licensing option for any new reactor projects. Plants that had already been issued class 104(b) licenses could continue using those licenses, but their ability to lease fuel from the AEC was halted as of 1973. My guess is that delay was inserted to account for leased fuel that was already being used in operating reactor cores.
Not a facility described in § 50.22
The same legislation that eliminated class 104(b) licenses and references to a Commission finding of “practical value” established specific limitations on class 104(c) licenses. Those limitations were written into 10 CFR § 50.22 as follows:
Provided, however, That in the case of a production or utilization facility which is useful in the conduct of research and development activities of the types specified in section 31 of the Act, such facility is deemed to be for industrial or commercial purposes if the facility is to be used so that more than 50 percent of the annual cost of owning and operating the facility is devoted to the production of materials, products, or energy for sale or commercial distribution, or to the sale of services, other than research and development or education or training.
(Emphasis in original.)
That paragraph calls for a translation by someone fluent in the “nuclear regulatory” language. It says that a research and development facility can produce and sell materials, products, or energy (a term that includes electricity) and can sell services that reactors can provide — such as providing neutrons for testing materials and fuels — as long as the total revenues from these sales do not exceed 50% of the total ownership and operating costs of the facility. Those costs include financing, reserves set aside for decommissioning, land acquisition, construction, equipment, and maintenance.
This provision is important, because some of the testing that can be used to prove safety, performance and durability for a demonstration of an innovative reactor design will require the facility to operate at high power levels for sustained periods of time. Though building and operating a demonstration plant to fully test the nuclear, mechanical and electrical engineering design and the safety provisions is an expensive proposition, the activity creates useful byproducts like electricity or heat.
The drafters of the 1970 legislation recognized that it would be patently unfair, not to mention wasteful, to force plant owners and operators to throw away their products instead of trying to find a market for them. Selling inevitable byproducts could help defray some of the unavoidable expenses of developing and fully testing a product intended for sale to third parties. By inserting the 50% revenue generation provision, legislation drafters struck a balance that would prevent the kinds of section 104(b) abuses seen throughout the 1960s. There are legitimate reasons to prevent facilities that are not really innovative and are intended to be used solely for commercial production from being labeled as R&D facilities in order to qualify for special subsidies and anti-trust exemptions.
For plants that are roughly analogous to the Navy’s prototype facilities, owners and operators might be able to operate them at close to a break even situation because they don’t have to count revenues associated with education and training as part of the 50% limitation. With a well-thought out business strategy that mimics portions of the highly successful Naval Reactors training program, a developer can use a prototype to fully test designs and improvements before selling them to customers, to generate and sell power and/or heat, provide irradiation services, produce isotopes and other materials, train operators, and even participate as a resource for university education programs.
Section 31 of The Act
The final step in recognizing that Section 104(c) marks a valid and potentially useful path to the goal of an operating facility licensed by the NRC for research, development and complete design testing required a careful reading and rereading of Section 31 of the Atomic Energy Act. Section 31 is referenced in both 10 CFR 50.21 and 10 CFR 50.22 and in Section 104 of the Act. The most pertinent provision of Section 31 is quoted below:
SEC. 31. RESEARCH ASSISTANCE.—
a. The Commission is directed to exercise its powers in such manner as to insure the continued conduct of research and development and training activities in the fields specified below, by private or public institutions or persons, and to assist in the acquisition of an ever-expanding fund of theoretical and practical knowledge in such fields. To this end the Commission is authorized and directed to make arrangements (including contracts, agreements, and loans) for the conduct of research and development activities relating to—
(1) nuclear processes;
(2) the theory and production of atomic energy, including processes, materials, and devices related to such production;
(3) utilization of special nuclear material and radioactive material for medical, biological, agricultural, health, or military purposes;
(4) utilization of special nuclear material, atomic energy, and radioactive material and processes entailed in the utilization or production of atomic energy or such material for all other purposes, including industrial or commercial uses, the generation of usable energy, and the demonstration of advances in the commercial or industrial application of atomic energy; and
(5) the protection of health and the promotion of safety during research and production activities.
There is no doubt that developing and testing non-LWR reactors and associated power plants fits into the above categories of research and development. Though an unfamiliar concept to many nuclear plant developers, most commercial product developers recognize the vital importance of building complete prototypes that can fully test all components of a design in an integrated fashion before selling the product to customers. That is especially true if the target market is not experienced in operating similar products or if the product is so new and innovative that no one is experienced in operating it.
Need for a Class 104(c) process
Finding the trailhead marker that allows the NRC to issue licenses under class 104(c) and directs the commission to “impose only such minimum amount of regulation of the licensee” as necessary to ensure adequate protection of public health and safety is only the first step in a grueling effort to clear a path that can be traversed successfully to reach the goal of a licensed, built and operating facility. The NRC needs resources and direction to establish the processes and requirements. It will take more time than some would prefer, but the task does not get any shorter or easier by indefinitely putting off the start.
It is important to understand that building complete, fully integrated demonstration or prototype plants should be a part of the strategy for any truly innovative design effort.
The complete design provides the opportunity to develop and test operating procedures by people who have the responsibility and experience of hands on operation. It provides maintenance personnel the experience of fixing equipment, predicting failure modes, and working with designers to refine access strategies and identify weaknesses that can be addressed. It gives customers confidence similar to that provided to people who walk through model homes, watch test pilots fly near-commercial aircraft, or test drive automobiles.
This concept may seem foreign to nuclear plant developers and regulators because nukes have been seeking economies of scale for so long that they have forgotten that it’s possible to build and approve equipment that is small and simple enough to build, operate and test all the way to the breaking point if necessary.
Not only is it possible, but when developing and introducing innovative solutions, it’s almost a required step to enable successful commercialization.
Update: (Posted September 8, 2015 1:45 pm EDT) After rereading the above, I recognized the need to make it clear that creating a licensing path for research and development reactors under section 104(c) is absolutely within the NRC’s area of responsibility. It has nothing to do with promoting or marketing nuclear energy or pushing products into the market. It has everything to do with enabling the development and adequate product testing for innovative, valuable, emission-free atomic energy and radioactive material products that can contribute to the common defense and security of the nation, protect public health and safety, and protect the environment.
In your opinion could NuScale be considered new tech due to 12 reactors controlled from a single control room?
Absolutely. There are many aspects of the NuScale design that have never been fully tested.
The concept of a demonstration/prototype plant is about specifics, not general technology. Sure, light water reactors have been done before, but nothing even close to a NuScale has been built and operated. Nearly every component will be new, even though it will be based on known materials and principles.
Experienced designers know the difference between a new model and one that merely has some tweaks from a previous version.
You make a very strong case. Have you spoken with anyone about a lawsuit?
I would be glad to help out — pro bono. At fist glance, it seems that it is a situation that would be appropriate for a court to issue a Writ of Mandamus. Before a lawsuit could be filed, though, there would have to be a party with “Article III standing.” That essentially means that there has to be someone (most likely a corporation) with “a dog in the fight” — something to gain by a court issuing the Writ of Mandamus.
Also, as regards that 50% limitation: I would be willing to bet that a good Hollywood accountant could be very useful if they would but turn their craft from the Dark Side.
Thank you for the compliment. I am not sure why you suggest a lawsuit, however. My point in writing this piece was to save the good people at the NRC a little work by letting them know that there is a path that can be cleared without seeking new authority through legislation.
Sure, they need leaders to allocate the required resources, but I’m betting they have that already. They just need a push in the right direction.
I’m an evolutionary thinker. Revolutionary processes involve too much breakage and too little opportunities for success. I’d like to encourage people to stop talking about leaving the country or creating a new agency and instead think of ways to use the resources we have already and enable them with some new perspectives on their mission and their statutory authorities.
You know that culture and I do not. If they are moving on it (or you expect them to move on it reasonably soon), then a lawsuit would be pointless. There are, however, agencies that have inertia that will not be moved except by a court order. There are also agencies (the EPA, especially) that have a symbiotic relationship with outside groups where the outsider files a lawsuit to give the agency the basis for doing what it wanted to do in the first place. I’m very sure that the NRC is NOT the latter sort of agency. Still, the point is that lawsuits are part of the process and each agency’s culture serves to determine how big a part of the process is with the courts.
As you say: “They just need a push in the right direction.” Lawsuits can be that kind of push. I’ve seen lawsuits filed SIMULTANEOUSLY with Consent Decrees.
I understand that in a parallel business, SpaceX took DoD to court because their rules were ginving Lockheed and Boeing a duopoly on space launches. It seems that thanks to the court case, DoD is going to use SpaceX.
Is that correct? It seems that in America, law suites can be used as friendly pushes. Which is unusual because suing potential customers is not normally a way to persuade them to be customers.
Rod thank you for your effort. This may be very useful to developers of advanced technology reactors.
If the regulations point to a valid entry for demonstration reactors, the first step seems to be contacting the NRC to find out their position on the issue. Or possibly coordinating with NuScale or any other nuclear start up to give the investigation a focus in the real world. Sometimes the solution to an intractable problem lies in plain sight and only needs to be recognized at the right time.I hope this is the case. It would be great if the regulations were already in place and just needed to be utilized. You might be on to something.
As described in the article, the first step was already taken. I raised the question at the joint DOE-NRC workshop on licensing non-PWR reactors. The presenter was a representative from the Office of Nuclear Reactor Regulation. He took the question as a lookup and got an initial read on the issue from the General Counsel’s office.
Though they do not participate in the conversation here, I know there are a number of regular Atomic Insights readers at One White Flint North.
There are also readers from NuScale, Terrestrial Energy, Transatomic Energy, Flibe, B&W mPower, StarCore, ThorCon, and probably several others. I expect this post will generate some discussion and strategizing. I know at least one of the innovators has indicated a strong desire to build a complete system demonstration here in the U.S., but did not think there was a way to move at a reasonable speed through the existing class 103 license process under either part 50 or part 52.
I’m not an accountant, but I am confused. Can design costs be amortized as part of annual “ownership and operating” costs for FOAK plant? GEH for example, has conservatively put something like 2 decades into designing S-PRISM, certainly an innovative technology, but one intended, by design, to sell electrical energy of annual value well in excess of its annual cost of operation.
Will the first of a kind PRISM be able to sell enough electricity at a high enough price to cover 50% of the owning and operating cost?
How many years of testing will be required to prove all of its safety assumptions?
To prove all it’s safety assumptions? I wouldn’t know — perhaps we should check with Sierra Club, NRDC, and Friends of the Earth.
Could the “annual cost” include a healthy allowance for the recouping of already-incurred expenses for the “research and development” (including the fat bill for NRC staff time) or would it be restricted to actual costs incurred in the given year only?
Opponents may argue, but the language clearly says “owning and operating.” By established laws, ownership costs include paying the capital cost plus interest distributed over a reasonable life expectancy as allowed by tax laws depending on the category of the depreciable property. Also by established laws, some portion of research and development costs is required to be capitalized and cannot be written off as a business expense in the year it is incurred.
You are correct in your summation of the accounting basics. Certainly, GAAP (Generally Accepted Accounting Principles) will be followed. There is, however, some more “play” possible. Suppose that the demonstration reactor can produce electricity at one half of the cost of otherwise available electricity. Now further suppose that the electricity sold by the reactor owner/operator is sold (all of the electricity) to a broker who buys the electricity “at cost” (and that “cost” is clearly defined). Now, the broker turns around and sells the electricity at twice what was paid. The substantial profit (less taxes) could then be invested in an interest in the reactor project. This flow of money could serve to mitigate the costs of the development reactor.
History mandates that you add substantial millions to the projected initial costs, and add an ample number of years onto the projected timeline for start up. The inability of the NE sector to complete a project on time and without massive cost overruns makes it almost impossible to predict economic viability and the earning potentional of a completed project.
Seems like you are stepping away from your persona of claiming no expertise in nuclear energy/energy topics in general.
If you want anyone to believe that statement, you are also asking that they trust that you have done a substantial amount of research of both historical costs and historical cost projections and have updated that with the most recent experiences in well-managed projects in China, South Korea, the UAE, and at Huntington Industries Newport News Shipyard.
Just in case you have forgotten, the very first nuclear power plant built in the US to supply commercial electricity took just four years from start to finish. Many of the early plants were constructed at a cost close to their initial budget.
Actually, Rod, you don’t have to be an expert to research cost overruns in the nuclear industry. John Galt’s comment on another thread perked my interest, so I looked into it via the internet, looking for news articles having to do with nuclear cost overruns. (Perhaps you would prefer that I only research your own claims, and ignore researching the claims of those that offer an opposing story?)
What I found in that search was a huge litany of overruns, and no recent nuclear projects that were brought in on budget and on time. Worse, the overruns seem to be huge in most cases, often with costs being passed on to the consumer.
So, lets just take the last two decades. Can you list a nuclear energy project that was completed within its projected budget and timeline?
News articles? Is that the source and extent of your research in this area? Aren’t you the guy whose spent the last year or so telling Atomic Insights readers that they need to look deeper than newspapers and television news?
Projects are a bit like travel – there is no normal distribution of arrival times. You are either on time or late, never early. Costs never fall below the budget, though there is almost no limit on how high above the budget they can go if obstacles keep cropping up – either unavoidable delays imposed by things like weather or true obstacles purposely placed in your path like new fences and immigration rules.
Btw, Rod, my concern in my searching was domestic NE. I didn’t concern myself with overseas projects, such as you list. I will try to inform myself about the Huntington Industries project you allude to.
If you limit yourself to US nuclear projects and ignore the successful completion of submarines and ships, there is no recent data to be had. The last reactor to start operating here was in 1996 and that was a special case project that took more than 20 years to complete because of fits and starts at the board level of the owning utility. The next project that will start is the twin of that one, only with another 20 years worth of delays and miscues.
The Vogtle and Summer projects are substantially behind schedule, but the reasons for that have been widely discussed here. They are all part of a First of a Kind tranche of projects using a design that has never been completed anywhere before starting 8 of them, four in China and four in the U.S.
My advocacy for building full scale, but much smaller demonstration/prototype plants is partially based on the hugely expensive lessons being learned on the first AP1000s.
“Navy Secretary Ray Mabus confirmed Thursday that the cost overrun for the aircraft carrier USS Gerald R. Ford is projected to reach $1 billion, bringing the ship’s total cost to some $12 billion — but said it’s on track to be delivered on schedule”
How much of that overrun is attributable to issues with the nuclear power plant and not the rest of the complex systems needed to operate an at sea air wing on a war ship?
Check out the cost experience of the Virginia class submarines.
You equate a Navy craft constructed under DoD authority with a civilian nuclear power plant regulated under NRC authority, as if they have anything to do with each other?
You truly are a pathetic, worthless troll. Do you post here because you get punched in the face when you show up in person? I have to agree with the sentiment of anyone who did.
No need to approach threats of physical violence.
The cost experience of building the power plant of an aircraft carrier is relevant to our discussion here, but it is not easy to obtain the information without some strenuous research.
Inside information also helps. For the record, the nuclear portion of the construction went pretty smoothly, but there were significant issues associated with other systems, especially the revolutionary electromotive catapult and arresting system.
“You equate a Navy craft constructed under DoD authority with a civilian nuclear power plant regulated under NRC authority, as if they have anything to do with each other?”
Take it up with Rod. I was responding to his input.
“News articles? Is that the source and extent of your research in this area? Aren’t you the guy whose spent the last year or so telling Atomic Insights readers that they need to look deeper than newspapers and television news?”
You musta missed it when I mentioned the internet. I did not mention TV or newspapers, did I? And, uh, Rod, you ignored the part where I asked you to provide an example of an NE project, undertaken in the last two decades, that wasn’t substantially over budget. I assume you ignored it because you cannot provide any examples.
Darn, the truth is incomfortable, isn’t it??? So, uh, tell me, how do you project the future viability and profitability of a project that has an unknown initial cost?? You might as well say to potential investers, “We have no idea what this will cost”, if the industry’s
……performance of the last few decades is any example of what to expect from them. This is not FUD, nor is it dishonesty, nor is it the opinion of a “troll”, which seems to be the common retort that those such as EP resort to when they get their nose rubbed in the facts.
Do you really think that these worthless projections of cost, that aren’t worth the paper they’re written on, are flattering to the industry? The nuclear industry, of all the enegy sectors, is reputed to have the highest percentage of cost overruns according to one report on energy costs that I found. Do you dispute that with actual data or example?
Costs, Delays Surface Again for New Attack Submarines
by Harold Kennedy
“Just a year after U.S. Navy officials assured Congress that they had taken steps to stem rising costs and production delays for the newest family of nuclear-powered attack submarines, they now concede that problems may not have gone away.”
“The first ship in the Virginia class, SSN 774, will cost about $42 million more than expected—a 2 percent increase—and the delivery date has slipped from June to October, according to the Navy.”
“The second vessel in the class, the Texas (SSN 775), is facing a possible cost overrun of $141.5 million—a 6.4 percent increase—and a six-month delay in delivery, from June to December 2005.”
“The Navy attributed these problems to “first-of-class construction issues encountered during final assembly and testing” and “unanticipated labor issues” at the two shipyards building the vessels, General Dynamics Electric Boat, of Groton, Conn., and Northrop Grumman Newport News, of Newport News, Va.”
“As a result of these issues, cost estimates for the first four subs in the class currently are running $419 million higher than expected, Navy spokesperson Lt. Pauline Pimentel told National Defense. To deal with the overrun, the Navy plans to ask Congress for authority to reallocate funds from its fiscal year 2004 and 2005 budget. At the moment, the Navy does not anticipate a need for additional funds, she said.”
Why are you introducing an 11 year old report about common FOAK issues? Once those were addressed and production rates increased, the VA class submarine costs have dropped from about $2.6 B to $2.0 B in constant year dollars.
I’m currently wading through this report…..
Given that any posted opinion, report, or data that gets posted here is immediately presented as biased if it doesn’t adhere to the groupspeak……
How about before I wade through this report, I give you all a chance to comment on the credibility of authors of this report? I already see, contained in this report, facts buttressing my argument, so I assume the authors will be attacked as nasty ‘ol anti’s, indoubtedly with an army of trolls attacking the blogosphere, financed by the anti-nuclear conspirators in the wind, solar, and fossil fuel energy sectors.
Yep. You’ve found a credible looking document produced and reviewed by “the usual suspects,” including Steve Thomas, Amory Lovins, Ian Fairlie and the NRDC.
“No need to approach threats of physical violence”
What if thats all ya got? Gotta love these internet tough guys, though. Grrrr, they growl ferociously from their dens.
Ok….so lets summarize this exchange……
1) Cost becomes an issue of topic on the thread.
2) I respond by bringing up the impossiblity of cost projection if a project cannot be depended on to come in on budget and on time.
3) Rod, rather than acknowledging an indisputable history of massive cost overruns, responds by pointing out my lack of expertise. And points out overseas projects as an opposing argument, and brings nuclear ship building into the exchange.
4) Citing the results of my internet search, I ask Rod to dispute my findings with an example of a project that has come in on budget withing the last twenty years. And I provide evidence thag the nuclear ship project he cited did in fact go way over budget.
5) EP, reacting to my apropos response to Rod’s reference to navy shipbuilding, ignores the fact that Rod brought it up, and spits out his usual ignorant ad hominem that contributes NOTHING to the exchange.
6) Meanwhile, the point behind my original premise offered in the exchange goes completely unaddressed. No examples of on budget nuclear projects are offered, and no explanation is offered about how accurate economical projections can confidently be forwarded about projects that are undertaken by an industry that has PROVEN itself to be incapable of delivering an on budget and on time NPP.
So, wheres the debate? Am I being inaccurate or deceptive by pointing out the dismal history the industry has in delivering promised results? And in pointing it out, does it just naturally follow that I’m an anti NE troll, as Brian or EP are so quick to use as an ” argument” when they can’t argue with facts, honesty, integrity, or common sense?
Sorry for bringing up an uncomfortable reality, boys. Perhaps, if you shut your eyes, the boogie man known as “Truth” will disappear. One can hope, eh?
I can’t dispute the fact that nuclear projects have gone way over schedule and budget in the past. I can’t promise better results in the future if the factors that contributed to the overruns aren’t addressed.
That is the point of my post and many of my efforts over the past 25 years.
By the same token, the usual suspects have chosen to make opposition to nuclear energy their career. Part of their effort includes putting up as many barriers as possible and doing everything they can to eliminate trust in nuclear professionals.
I see your recent series of posts as aligning with my opponents. I’m losing interest in sharing my expertise and experience with you.
“Yep. You’ve found a credible looking document produced and reviewed by “the usual suspects,” including Steve Thomas, Amory Lovins, Ian Fairlie and the NRDC”
“Reviewed by”? What about the authors, Rod? I realize your “usual suspects” seem to laud this annual report. But is that because the report is biased and just more FUD, or because the conclusions reached by the report are in line with the reviewer’s conclusions? Just because the report reaches conclusions you are uncomfortable with, doesn’t mean they are inaccurate. After I read the full report, I will be interested in seeing if you can actually dispute the report, or just simply malign the reviewers or the authors.
“I see your recent series of posts as aligning with my opponents. I’m losing interest in sharing my expertise and experience with you”
Oh, well, I value it when you share those things, Rod. And like I’ve said before, I have learned here. And I have been convinced that NE isn’t the boogie man under our beds that I thought it was when I first came here.
What I don’t value is the crap thrown my way by two or three posters whenever I don’t exactly see things their, (or your), way.
You accuse me of aligning myself with your opposition. In a way, I suppose you’re right these last couple of days. I am offering a more confrontational and opposing argument. But not science based. And if the last engagement, and this one, are any example, the reason should be obvious to you.
You don’t get the point? You seem wiser than that. Devote a bit more thought to it, and ask yourself if my increased angst might have something to do with a premise I have raised here for some time now. You’re a bright guy, I’m sure you can figure it out.
What if thats all ya got?
You’ve posted 10 out of the 38 comments under this post (before this one), more than 25% of the total. You’ve also indulged your obnoxious habit of posting multiple comments one-after-another, obviously not thinking through what you had to say. Sourcing disinformation from your echo chamber is the rotten cherry on top of this sundae of text-screment.
You have nothing to say except bogus talking points, trivially refuted just by looking at your sources, yet you belabor them at length. It’s obvious that you’re here because you have nothing more worthwhile or intelligent to do, and on-line is the only place you can’t have doors (or other things) slammed in your face.
I’ve been looking for more productive distractions, and I think I’ve just found one. I think I’m going to transcribe and debunk parts of that Bill Nye keynote address. Maybe I can persuade you to waste some time over at The Ergosphere trying to convince my readers that Bill Nye is The Man.
History says the same thing about new coal plants in the USA.
I was in Indiana at the time trying to build a different power plant. Notice that the new tech added substantially to the project and they still do NOT have the Carbon Capture installed.
New power plants are just expensive.
“You have nothing to say except bogus talking points, trivially refuted just by looking at your sources, yet you belabor them at length”
Actually, no one has refuted anything I’ve said on this thread. In fact, begrudgingly, even Rod admits that it is impossible to find an actual example of an NPP project that has been brought online without cost overruns and time extensions.
As far as you go, you not only haven’t refuted anything I’ve said, all you’ve done is spit venom. Stop drooling on yourself, its unseemly.
To jump in here with other examples of large projects that have incurred budget overruns to show that this issue is not exclusive to nuclear power:
Kemper Coal plant (one of two FOAK coal gasification projects in the US)
Original budget: $2 billion
Projected final cost: $6 billion
Expected power output: 582 MW
The Big Dig in Boston:
Original Budget: $2.2 Billion
Final Projected Cost: North of $20 Billion after interest charges, numerous lawsuits-some deserved, some not, etc.
Oh why bother listing each project individually. Here is a convenient list of large projects from around the globe that have gone over budget:
Point being is that cost overruns for nuclear power plants, especially FOAK plants are not a surprise to those of us who have worked on large-scale projects. It isn’t desirable but not a surprise. Budgeting large projects is NOT an exact science. Millions of words have been written about how to contain risk, scope etc. to keep budgets in line with original projections. Several professional associations such as PMI, ASME, ASCE, etc. spend considerable time developing workshops, seminars and other training material for their members who work diligently to control project costs.
Large-scale projects have many stakeholders who all have divergent requirements, needs, wants, etc. When one stakeholder’s goals collides with other stakeholders requirements, the result is an increase in project risk. When risk increases, the project cost increases.
Stakeholders such as Sierra Club, NRDC and Greenpeace have expressed publically they do not want nuclear power. Their official positions and their donations are based on fighting nuclear power. Therefore they will seek any means available to them to increase project costs, usually through the courtroom. Admittedly, in the past, some of those lawsuits provided sunshine to topics that needed to see the light of day. Now though, the goal of those groups is to use the legal system to dramatically increase the project costs to the point where the owners are forced to throw in the towel and cancel said project.
Imagine how much Ivanpah would have cost if Sierra Club had sued BrightSource about the desert tortoise issue or the birds that have died? Would it have been $2.5 billion? $3 billion? All for approx. 390-400 MW that has a capacity factor of less then 0.40.
Imagine how much a standard industrial wind facility would cost if the NRDC applied the same legal mindset to bird kills that they do to low level radiation? They have proven they will file lawsuits against nuclear and coal for these very types of issues but they do not pull those legal levers when it is their preferred source of power generation.
Risk is everywhere, not just in the nuclear construction arena. Unknown or unexpected risk will dramatically increase the cost of large-scale projects especially when some of the interested stakeholders are adversarial from the very beginning of the project.
When it comes to project overruns, few industries can approach the magnitude of the misses (in percentage terms) of the vaunted Information Technology (IT) industry.
You keep saying that nuclear projects are always behind schedule and over budget, but the 4-unit build at Barakah is on schedule. The difference is that the UAE does not have a host of pettifogging regulators throwing caltrops on the road to completion; UAE would rather sell its gas as LNG for cash than burn it to make electricity it can get cheaper from uranium.
All you’ve done is tell lies (a half truth is a whole lie). Now go away.
Thank you for the effort you put into your response. It is that kind of civil, concise, and informative rebuttal that demands and holds attention. Good points and a convincing argument.
As EP points out, between drools, it is possible to bring home a NPP project on time and within budget. I realize that burdensome regulations can cause delays and additional costs. I suspect the UAE project was accomplished because the government was onboard with the project in a positive manner. Of course, thats not the case here stateside. But the governmental hurdles are known to the industry here, and it is only reasonable that the bidding process should include a buffing considerable amount to account for hurdles, setbacks, and regulatory meddling in the process. Instead, and not just in the NE sector, bids are low balled, with the bidder, (and buyer), knowing full well that overruns will occur, and odds are the project will be far enough along that the only way forward is working towards completion, no matter the cost. And more oft than not, its no big deal to the contractor or buyer, because the consumer inevitably gets stuck with the costs, including the overruns. In other words, the process is corrupt from the beginning, from the lobbying process to the bidding process, and to the payment process.
In my small scale world of contracting, unforeseen costs are always considered, addressed on the bid via a safety net of projected cost. I do not low ball bids in an effort to sell a project, knowing full well I can’t complete the project for the bid price.
Probably, NE, and fossil fuel projects realize the looming huge overruns with open eyes, realizing if the true projected costs were presented in the bidding process, odds are the project would not be bought.
Without touting renewables as the wonder solution, one still needs to recognize that the overruns that do occur are rarely as huge, some projects DO get done within budget and on time, and the timeline to start up is miniscule compared to large fossil fuel or nuclear projects. This does not escape the attention of the general public.
“Without touting renewables as the wonder solution, one still needs to recognize that the overruns that do occur are rarely as huge, some projects DO get done within budget and on time, and the timeline to start up is miniscule compared to large fossil fuel or nuclear projects. This does not escape the attention of the general public.”
Except that the scale of the projects involved is much much smaller – thus the ability to control the costs more reasonably.
This is the argument for small scale Atomic Power. If permitted to build plants like NuScale size, the ability to control costs – and to bid correctly – would be much easier.
Yes, renewables can come on line quickly, but they always need backup. Always. Thus, by installing renewables such as wind and solar natural gas companies get a sale each time. The costs of that backup power are rarely quoted in the total cost of the project. They are un-reliable and they are being sold precisely because they are unreliable otherwise there would not be a sale for a NG power plant. One more thing, under current rules the cost of fuel can be passed on to a consumer while the cost of capital is rarely allowed. This gives a massive advantage to a generation plant whose operating costs are mostly fuel … NG.
Also, if you will look at the Duke project in Indiana you will see that 1 billion dollars of the construction cost was NOT allowed to be passed onto consumers in Indiana. Now that cost will be made up long term selling power, but it will take a while.
Your original point thus is refuted. The “problem” with Nuclear is not high costs, the cost of Nuclear construction is nearly the same as any other type of power plant that actually gets that power to the people. Including renewables with NG backup.
Re: “pettifogging regulators throwing caltrops on the road to completion”
Great imagery. I had not seen the “poet” side of you until now.
“The “problem” with Nuclear is not high costs, the cost of Nuclear construction is nearly the same as any other type of power plant that actually gets that power to the people. Including renewables with NG backup”
Except the “backup” energy infrastructure is already in place and online in most cases. So including the costs of those infrastructures when considering renewable projects is not really a valid argument.
And, a bit of an explanation here in reponse to EP’s flatulence….
For over two years I was working out of town projects. The first, a major remodel in Beverly Hills. For that one, I stayed in a motel in Studio City 5 days out of the week. The next jobsight was in small berg called Glenville, about thirty minutes out of Bakersfield. For that one I actually stayed onsite, set up a shop, and rarely commuted back to Tehachapi. So as a consequence, I have been enjoying a bit of time at home, working on my own place, and kicking back. Hence my prolific participation here lately.
And, I enjoy the banter. Its amusing to me, and I get to learn a few things as well. But EP and Brian, and perhaps Rod, (and whoever else) can take heart, as I am flying up to Whitby Island tomorrow to look at a project a local customer wants done on his summer home. So my participation is going to wane considerably. Particularly if an old friend is still racing J-24s up there. Gotta bone up my foredeck skills, its been quite a while since I handled a chute.
See, there is a merciful God, Brian.
Smile man. You and EP can give your salivary glands a well earned rest. And the time you would spend spitting in my direction can be expended in front of your TV, exercising your neck muscles as your head bobs up and down to the words of Sean Hannity. Consider it a gift, from me to you.
Except the “backup” energy infrastructure is already in place and online in most cases. So including the costs of those infrastructures when considering renewable projects is not really a valid argument.
Leaving aside the “free rider” issue, the other thing you haven’t considered is the need to continually maintain, fuel, and replace the “backup” generators and supporting infrastructure.
Suppose a family has a 2000 vintage minivan that has provided good service for 15 years performing a variety of tasks and carrying as many as 8 passengers. The family has accrued enough for a good down payment on a replacement since the minivan is getting a little long in the tooth.
Should they buy a Nissan Leaf or a new minivan?
“Should they buy a Nissan Leaf or a new minivan?”
Neither. I’ve got a real cool 1983 Wayne school bus I’ll sell em for pennies on the dollar. The mileage ain’t great, but 362 pound aunts’ll fit, with extra room for the great dane Barney and grandpa’s vintage bong collection.
“Leaving aside the “free rider” issue, the other thing you haven’t considered is the need to continually maintain, fuel, and replace the “backup” generators and supporting infrastructure.”
Are we now shifting the conversation to operating costs?
No. Notice last item in list – replace.
Are any NPPs under construction that, upon completion, can provide for ALL the energy needs of the grid they will be supplying? If not, can’t we call NG “back up” for NPPs as well? So, should we figure the construction and operating costs into the costs erecting an NPP?? Had San Onofre stayed online, in conjunction with Diablo, could they have supplied all of California’s energy needs? So, by your own argument, don’t we need to include “back up” costs?
Please be careful with Bill Nye. There may be a real possibility that he may someday soon see the light regarding Nuclear Power. I think he realizes (just my impression from one of his recent talks), that he is knowledge deficient in Nuclear Energy, and he seemed to know it. He had/has the full gamut of solar decorations on his house, so may begin to realize the effort, wear and tear, and near worthlessness received to soak your poorer neighbors of their hard-earned wealth.
It’d be better to try to bring him on board rather than challenge him in a way that may tend to promote his resistance.
“It’d be better to try to bring him on board rather than challenge him in a way that may tend to promote his resistance”
Gosh John, you mean telling Nye to stick it where the sun don’t shine doesn’t strike you as a winning strategy?
I’m just upping the incentive. He wants to be the science guy, and nothing helps people to see the light more than feeling the heat. Showing the science guy where he got the science wrong… if he wants to be right, he has to change his tune.
“Are any NPPs under construction that, upon completion, can provide for ALL the energy needs of the grid they will be supplying?”
Oh, so you want to compare a fully functioning NPP that feeds energy into the grid 90% of the time to a NG plant that also feeds energy into the grid 90% of the time?
If not, can’t we call NG “back up” for NPPs as well?
Sure, but that does not make them necessary. It is very possible to build a grid that is 100% NPP. Just like it is possible to build a grid that is 100% NG. The point I am making is that it is not possible to make a grid that is 100% Wind and Solar – at least not at any sizable scale. Coal, Natural Gas, Diesel and Atomic can all function alone without other energy sources. The reason they do not is competition over market share.
“So, should we figure the construction and operating costs into the costs erecting an NPP??”
The question does not make sense. Of course we put the construction costs there but not the operating costs. The point is that the portion of the operating costs that are the costs of fuel are passed on to the consumer. In the case of NG these costs may vary greatly, while in the case of NPP the costs of fuel are amazing low.
“Had San Onofre stayed online, in conjunction with Diablo, could they have supplied all of California’s energy needs?”
Not by themselves, but a 100% Atomic grid is very possible.
“So, by your own argument, don’t we need to include “back up” costs?”
What is the purpose of renewable energy?
A 100% NPP grid would be totally carbon free, totally reliable, and fairly low cost power.
It is not possible to get to 100% using wind and solar. They will always need a different form of backup. They are by nature not able to stay online all the time.
A 100% Coal powered grid is possible.
A 100% Diesel powered grid is possible
A 100% Hydro powered grid is thinkable but in a drought would be unreliable. (I have personally lived with the rolling blackouts from a grid which was designed as 100% hydro but had to use rolling blackouts in a drought).
What is the purpose of renewables? I say that the real purpose is to take market share away from Coal and give it to Natural Gas and diesel.
For the record, I’ve spent many months living on a 100% nuclear grid.
My thoughts exactly. I have also visited islands with 100% diesel generation. I have visited places with 100% Hydro. Atomic is the only one I am aware of that can have a 100% capacity factor for years with a very small amount of fuel. All the others – while capable are subject to needing external deliveries on a regular basis (even rain!).
Explain to me how this would effect the famous billion dollar entry fee. Would it be more of a “pay as you go” schedule of payment? A start up could proceed with minimum fees to insure local safety and security for that one facility. Nuclear will not advance in the US unless the NRC fees can be reduced enough that a new design has a chance to develope.
The answer to your question is a little complicated, but here goes. (Each of the following points could be prefaced with “in my opinion.” I’d hope any intelligent reader would make that assumption anyway.)
For investors, there is a substantial difference in a project built on paper and computer analysis and one that they can visit, inspect, and watch being tested.
The total expenditures required for a path involving a prototype/demonstration reactor built with a class 104(c) license and one that avoids that initial non-commercial reactor construction project might be lower, the same, or greater for the path involving a demonstration plant. The trust and confidence of the investors, however, should be much higher in the case where the endpoint is both a design certification AND a working demonstration/prototype.
There is also a greater chance for support and involvement of the supply chain since they will have to perform detailed design and then fabricate — and be paid for — the components required to build and operate a real plant.
Though I plead guilty to making a big deal about the NRC license fee structure, those fees are not the big noise in a development project. The real cost is in paying your own development team to produce the work required to anticipate and answer all of the questions that a competent regulator will need to have answered before they give you permission to build commercial products for sale and operation within the claimed performance limits of the design.
As a way of providing some support for that statement, during the non-LWR workshop, a representative from NuScale reported that his company had just passed the $3 million cumulative line for NRC fees while total project costs had exceeded $300 million. (Those numbers might not be quite right, but I am pretty sure I have the ratio correct.)
My reading of your post is that a Class 104 license is still part of 50.21 (but maybe not 50.22). Is that correct? If so there is this:
(w) Each power reactor licensee under this part for a production or utilization facility of the type described in §§ 50.21(b) or 50.22 shall take reasonable steps to obtain insurance available at reasonable costs and on reasonable terms from private sources or to demonstrate to the satisfaction of the NRC that it possesses an equivalent amount of protection covering the licensee’s obligation, in the event of an accident at the licensee’s reactor, to stabilize and decontaminate the reactor and the reactor station site at which the reactor experiencing the accident is located, provided that: (etc., etc.)
As you know, if this 104 License utilizes the NEIL insurance pool, INPO participation is required. All bets on O&M costs are now off, as likely just the INPO Certified Training Department alone will likely be larger than the Ops staff for an SMR.
Of course there are other liability (insurance) options allowed in 50.54(w). But likely never considered or pursued as an alternative to NEIL. Seems this is an issue to be resolved before considering the class 104 path. As INPO participation in this project will break the O&M bank long before any R&D can be realized.
for a layperson please translate INPO.
Sure, sorry. INPO is the Institute of Nuclear Power Operations. An Industry self regulating (or policing, if you will) initiative formed after the Three Mile Island event in ’79.
NEIL is Nuclear Electric Insurance Limited, provides the nuclear liability insurance required by the Price-Anderson Act.
Both explained with easy internet search better than I can do here.
I believe that you’re your thinking of American Nuclear Insurers (ANI), which provides the pooled insurance set up by Price-Anderson.
NEIL covers the extra costs incurred by a utility as the result of an accident or other long-term interruption of electricity supply and certain premature decommissioning costs. This is not the liability insurance mandated by Price-Anderson.
Thanks, I stand corrected. If a class 104 license plant did not participate in NEIL the NEIL/INPO requirement would not appear to be applicable.
INPO is the Institute of Nuclear Plant Operations. They are a self policing organization made up of Nuclear Plant operators. They were formed in the wake of the 3 Mile Island incident .
Why does this group need a very large staff? I am an outsider in terms of operations. I can understand the value of shared information and the need for this – but why would the staffing be so large just for this purpose?
@David September 11, 2015 at 9:03 AM
David, your question has been hanging too long on this post. The answer is in the current scope of INPO activities. You are correct that if they had just constrained their activities to information sharing it would not require huge staff by the plants. And note that NSAC had developed a functional information sharing system within a couple months of TMI2, which I don’t believe was ever implemented. The problem with INPO today is a textbook example of “mission creep.” They have their nose in virtually every aspect of commercial nuke power plant activity at Programmatic Requirement level. It takes large staffs just to maintain the formal administrative procedure networks required to do things the INPO way, much less to handle the “stuff” INPO sees as requiring action by the plants. They have become a huge “hammer” of influence, with no counter balance voice or power.
For true new nuke, the need for fullscale testing goes much deeper than impressing
investors. We need the results of the tests before the animal can be prudently licensed.
But we cant build a prototype without a license, Catch NRC.
A concrete example from MSR’s. Nobody knows where the “noble metals”, ie
the fission products that dont dissolve in the salt will end up. We presume most
of them will plate out on the cold end of the Primary Heat Exchanger, but
we cant honestly claim that. The MSRE results are ambiguous in part
because ORNL was not particularly concerned, in part because of rudimentary
redox control, and in part becuase of the difference in scale. There is no
computer model that can reliably help us. We need to do a fullscale test.
This is true of just about any new technology. It is taken for granted
everywhere but commercial nucelar.
I dont know if the Navy does a full scale prototype of their new reactors,
but if they dont its becuase they are incrementall changes on what they
are already doing. Rod, can you help us out here.
The Navy used full scale prototypes for essentially all of their truly new reactors starting with the STR-1 (Submarine Thermal Reactor 1) which was the land based prototype for the Nautilus. It was so close to the one sent to see that it included a large tank of water to simulate the ocean.
It’s been a long time since the Navy built a new reactor that was more than an incremental change from proven technology. I believe it was the S8-G, which was the prototype for the Trident submarines. That was built while I was in high school.
It’s easier to ask forgiveness than it is to get permission.
~Rear Admiral Grace Hopper, U.S. Navy’s Chips Ahoy magazine (July 1986)
Modern corollary regarding non-LWR reactor research seems to be, It is easier to ask permission than seek forgiveness because you know the default answer is ‘no’ and we lack the resources to discover the precise legal boundaries of ‘no’. So we just go with ‘no’. For years. It is a political embodiment of LNT, where even the slightest risk of public outcry by zero-tolerance radiophobes is enough to completely paralyze Congress.
Yet I remain an optimist. The part of Section 104 that most excites me is,
104b(3) A production or utilization facility for industrial or commercial purposes, when specifically authorized by law.
That is, a single stroke of the pen when the conditions are right.
Of note to this discussion is Flibe Energy’s Notice of Intent to Submit License Application for a Liquid-Fluoride Research Reactor and Mo-99 Production Facility [30-May-2013]. Here is Kirk Sorensen discussing transuranics and medical Mo-99, where warns a worldwide shortage is imminent when Chalk River in Canada shuts down. Chalk River has since been granted an extention to operate until 2018.
Ya gotta love Flibe Energy, Inc., a corporation that has not one… but two fellows named Kirk (Sorensen, Dorius).
Six years later:
While it is a federally regulated proposal, it still supports the path. Time to wake this tread up and update it for a legitimate test reactor!
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