Nuclear’s Fork in the Road
By Jim Little
Would you be willing to continue investing in an established business with flat revenues, increasing costs while competing against an agile field of competitors who enjoy a market advantage of lower costs, quicker deployment schedules and the support of government subsidies and favorable public opinion? Should you stay the course and focus on addressing those challenges or divest? This is the stark choice facing the nuclear power industry today.
The Curves in the Road Ahead
The current situation that the nuclear industry is experiencing is best captured in the familiar “S Curve” graphic below illustrating the life cycle that many industries undergo beginning with birth, through growth, expansion and maturity and a potential decline when later facing factors such as obsolescence, substitute products or a changing competitive or political environment. If conditions do not improve, they eventually come to a point where a decision must be made to either continue on in a declining business, make changes or go in a new direction.
The Current Road Ahead Isn’t Straight – It Might be a Dead End.
There is great concern over the continued viability of nuclear power in the United States going forward. It is facing threats to its very existence, ironically at a time when its performance has reached its peak and when its value could most be appreciated with its carbon-free generation, reliability of supply, and economic benefit. The utility industry is facing some tough choices. Will nuclear generation continue or decline? Will the nuclear industry turn its attention away from new plant builds and extended-life operation activities and rather focus on decommissioning as evidenced by the plethora of recent conferences focused on decommissioning as the new market opportunity?
These threats are multi-faceted and are due to factors both external and internal. The external factors are well known by now – a disruption in the formerly stable power market created by imbalance between supply and demand. The supply side has been disrupted by an abundance of extremely low-priced natural gas produced through technological advances such as fracking and horizontal drilling and the rapid growth of increasingly cost-competitive renewables, sometimes supported by favorable government policies and subsidies. The demand side has been affected by the recent economic recession which suppressed growth in demand for power generation, already being tempered by improvements in energy efficiency.
The internal factors affecting nuclear are both existing and new. As no significant additions to the nuclear fleet have been made in many years, the fleet is aging and has required significant capital investment for upgrades and license extensions. Compounding this further are ever increasing regulatory requirements, the largest of which are those resulting from the events at Fukushima some six years ago.
One of the more disconcerting and difficult issues facing the industry is a loss of talent and experience right at a time when it is most needed to transfer knowledge to the next generation. The nuclear workforce demographic contains a large percentage of experienced talent reaching retirement age within the next five to ten years. With fewer people entering the industry, addressing the needs of the operating fleet will become more and more difficult and expensive. Further efforts to reduce costs by trimming workforces would only exacerbate the problem.
With revenues remaining flat, cost increases are significantly squeezing the profit margins of these operations. The financial outlook for nuclear utilities is bleak in an investment environment which rewards growth in revenues and profits. A number of utilities with nuclear units in merchant markets have recently announced decisions to decommission those units which are no longer able to sustain profitability. Utilities with units in regulated markets are likewise feeling similar financial pressures.
This situation was recently described to me by one nuclear utility executive: “From a shareholder perspective, how can I justify a recommendation to continue to invest in a facility when facing a forecast of declining returns while there may be other more profitable uses of capital?” So, should the default decision be to retire that unit and fund those efforts through its decommissioning fund; i.e. a “Nuclear 401(k)”?
There are no easy choices. While the logic may seem straightforward, abandoning even a single unit could have cascading effects and far reaching implications. This same executive explained his concerns further: “How does one retain and attract talent going forward when there is a signal that nuclear may not enjoy full support going forward?” The inability to offset talent loss due to retirements in the workforce can affect performance on the remaining operations, increase costs, and further accelerate the departure away from nuclear. With a downturn in the industry there are other outcomes such as the reluctance of students to enter the nuclear field, university decisions to pursue other programs of study, research budgets reduced and grant applications no longer being sought. There are a number of other issues; the loss of existing, stable baseload generation and economic impacts such as those being experienced in host communities such as Zion, Illinois, and Vernon, Vermont. From a national policy perspective, it directly impacts the largest source of carbon-free generation in the United States, currently 63% of the nation’s total carbon-free generation.
Lastly, for the industry, the departure from nuclear is likely irreversible once made in the U.S. as the current talent and knowledge base is the result of over 50 years of investment and development. The situation may best be described by Stephen Wright, a comedian who is a master of the art of irony: “I live in a house halfway down a dead end street. It’s one way.”
The Industry Drives On
Challenges aren’t new to the nuclear industry which, since its inception, has successfully addressed numerous challenges throughout the past five decades. With a culture based on a need for certainty and a search for excellence, it has focused intensely its attention “head on”. Over the past few years significant investments have been made in improvements with upgrades, upratings, and efforts to improve regulatory processes through risk-informed approaches among others. In response to the recent market conditions, it has undertaken initiatives on multiple fronts. Legislative efforts focused on political and community support have begun in states such as Illinois, Ohio, Pennsylvania, New Jersey and New York highlighting the economic and environmental benefits of the nuclear facilities in those locations and the negative impact of early retirements opon communities and the need for the treatment of nuclear power on a level playing field with other competing sources of supply. Efforts are being made in the regulatory arena with the Nuclear Regulatory Commission (NRC) regarding the need to address the seemingly never ending increase in regulations without demonstrable need or benefit. A good example of progress in this area is the recent commission decision to uphold Exelon’s appeal for the NRC Staff to adhere to the cost-benefit analysis requirements of the Backfit Rule.
Under the leadership of the Nuclear Energy Institute (NEI), the industry has focused on internal issues with its cost efficiency initiative, Delivering the Nuclear Promise, which has an aspirational goal of saving one third of operating costs. Utility members are identifying cost improvements and sharing them with the membership in a series of efficiency bulletins for consideration and implementation. In the past year, the program has identified over thirty bulletins with a potential savings exceeding $650 million across the U.S. nuclear fleet. Not relying on this program alone, some utilities are taking direct actions to reduce costs by mandating fixed budgets and corresponding organizational streamlining and workforce reductions. The key question is whether these actions will identify enough remaining potential for improvements. Furthermore, will there be a sustainable benefit over the longer term to address future challenges not yet encountered? With a legacy focus on continuous improvement and efficiency, what’s really left to improve upon?
Did We Miss a Turn?
Faced with an uncertain path forward, these obstacles may seem insurmountable with success being elusive. Yet, there may be an option other than continuing to pursue a traditional method which uses robust, tried and true problem solving approaches. The answer might not lie ahead but along the side of the road already traveled. Did we miss a possible turn as we forged ahead during the past years in the search for excellence?
This possible option might be best described in Oren Harari’s book, “Jumping the Curve: Innovation and Strategic Choice in an Age of Transition”. He points out an alternative to the traditional approach which searches for answers to problems. After all, he was famously quoted saying, “The electric light did not come from the continuous improvement of candles.” This new approach is not based on finding answers but in asking questions. Curiosity is used as the tool to explore and find new opportunities. Rather than focusing on answers to lowering costs it focuses on asking “Why should we do this?” and “What are we doing and why are we doing it? Have we gone too far down that road in that search and find ourselves on an unsustainable road to “Excessilence”?
This New Path Isn’t Necessarily Straight Either
The nuclear industry operates with a psychology and tradition of ensuring certainty and having solutions to problems. There is a very strong drive to adhere to established practice. Take, for illustrative purposes, a simple example: the practice used for years to sign documents. It was always required that documents be signed using black ink. Quality Assurance would reject anything signed with blue ink. The simple reason behind this requirement was that in the past, copy machines were not able to capture the color blue; therefore the requirement to forbid the use of blue ink. In some cases, organizations were even not allowed to stock blue ink pens. Yet for some years later, even after copier technology evolved to capture the color blue, the prohibition remained in place.
New solutions may be found by questioning current practices and departing from tradition. Rather than look at the efficiency of those practices, are they effective? We need to probe deeper to look for improvement. Are our operations effective in delivering the value that we need to reliably and safely deliver cost effective nuclear produced electrical generation? So, we need to ask ourselves, are we still using “black ink”?
Let’s look deeper and question the scope and extent of programs and practices which have been developed and implemented over the past decades. Are they still appropriate or have they expanded further beyond their purpose and become part of tradition? There are lots of areas to evaluate but consider some sample questions in just three:
1. Have quality assurance programs gone too far? Are some records now produced primarily as a defense for potential audits? Are corrective action programs focused on correction or just protection?
2. In the area of security, are assessments and activities focused on credible threats that are possible and probable or have they been stretched to a hypothetical and theoretical limit?
3. In procurement, does a predominant focus on lowest cost with multiple bidders deliver the best result? Does an arms-length relationships ensure customer satisfaction (i.e. access to alternative solutions and the best result) and supplier success (i.e. stable workloads that keep companies with good talent available)?
The questions may seem simple, but actually the answers are complex when considering that those practices and processes that were validated and adopted years ago in the pursuit of excellence. Questions pose a whole new set of questions or concerns: How can we “back up” from our current methods? What will the reactions of stakeholders be to a perceived reversal of those practices solely for the purposes of saving money? How can we undertake such an effort and ensure that any revisions do not have unintended consequences?
Moving Forward on a New Path
Facing the need for change is not anything new. As a species, we have been exceptionally good at dealing with change. We are naturally skilled at assessing our environments and adapting to the changes we perceive. These adaptive skills have allowed us to find novel and useful solutions to complex challenges. Were we to stay in our comfort zones and hope things get better (or hope we don’t get eaten) we would not have become the dominant species on the planet.
We also know that change is difficult. Our brains are wired to pursue the familiar path. Our neural networks don’t have to work as hard when we are engaged in routine behavior. We fear that doing things differently will result in the loss of all that has been built and invested in. This is precisely why the process of change needs to involve the right people, working toward a clear set of goals that lead to a shared vision. The process also requires the courage to face uncertainty and to engage the imagination to figure out the best ways to get there.
One of Charles Darwin’s most often quoted phrases is: “It is not the strongest of the species that survives, nor the most intelligent, but the one most responsive to change.”
The time to act is now. We must address the issues facing the industry on all fronts to preserve nuclear as a valuable asset for the nation. Doing less is simply irresponsible and unacceptable.
We are beginning the start of this dialogue with a panel discussion to be held at in the executive session for the upcoming American Nuclear Society Utility Working Conference on August 6-9, 2017 at Amelia Island, Florida. I will moderate a panel of executives with utility, regulatory and supplier experience to discuss their opinions and perspectives of this path forward. In addition, this September, the Carolinas Nuclear Cluster which is part of E4Carolinas, a 501(c) energy industrial trade organization serving the Carolinas will undertake an effort entitled “Nuclear, What’s Next?” to further pursue this initiative.
As always, reactions, input, comments and questions (of course!) are welcome.
p.s. It’s ok to use blue ink.
Jim Little is an Executive Consultant, Nuclear Energy Programs
He’s a member of the State of South Carolina, Governor’s Nuclear Advisory Council. He earned an MS in Nuclear Engineering from Carnegie Mellon University
Editor’s Aside: Better ways to document acceptance and approval should be encouraged. Ink is so last century.
Note: The above article was originally published on Linkedin at Nuclear’s Fork in the Road. It is republished here with permission from the author. The author presented his thoughts at a well-attended session at the Utility Working Group. He gave Atomic Insights permission to share his slide deck.
“The electric light did not come from the continuous improvement of candles.”
Good article. There is no timeline on the graph. It could be 10 years or two generations. Some short term solutions were presented with improving the paperwork processes which are so abundant in nuclear energy.
I saw no mention of the true alternatives to the candles. This alternative would be the many different types of reactors being now developed and reexamining some of the past. I believe these will create the upper curve, but I have no idea as to when this will happen.
Why do they only use the great heat from nuclear reactors to generate electricity (and power naval ships)? Shouldn’t alternative marketing strategies be considered for the product?
These half ideas do not offer anything for the present nuclear plants, but when I left them a few years back, they were mired in the “best of 1960s technologies.” Maybe it’s time to stop trying to improve the old candles.
Though electric light required a completely different paradigm than candles or gas lights, just imagine the suffering that might have occurred if candle makers and gas light producers had given up as soon as they learned that Edison had successfully tested a light bulb.
Those products continued to be useful and even necessary for many years while Edison refined his bulbs and developed the infrastructure required to make them more accessible and universally useful.
The Edison bulb was just carbon heated to glowing-hot, like the soot particles in a candle flame.
The first real innovations were electric arcs and gas discharge tubes.
I would really appreciate your help in analyzing an innovative energy cycle. Rod has my contact information and I have asked him to provide it to you. Please let me describe the process and you can decide whether or not you are interested.
My contact information is available at my blog, The Ergosphere.
The great heat of water reactors comes at a modest temperature — approx. 300C — making them useful for little but spinning a turbine. Liquid metal, molten salt, and particularly HTGR are a whole ‘nother story… or would be were there any.
Sounds like a swan song, damned near, Rod. I note you have suddenly adopted, or conceded, to the premise that the public views the renewables favorably, more so than NE. I’ve spent a couple of years here having that premise challenged, constantly, rudely, and counter to all the evidence at hand. Sound science and technology isn’t what sells the public on a product, commodity, or idea. Marketing is what tittilates their sense of approval. You recently responded to a post of mine by opining that you and your compatriots don’t care who you offend when defending your particular energy darling. Well, the industry, and NE advocates like yourself, are now paying the price for failing to ingratiate yourself to the american public. You’re the bad guys, and the greens are the good guys. You blew it.
Renewables might be the current public darling, but opinions can change more rapidly than physical laws.
“Blew it” sounds like you think the final results are in. Race isn’t over. Supplying energy to power society isn’t a fad or a sprint.
In building coalitions and support, I’m not interested in aligning with weaklings whose continued existence depends on Congressional action every few years to extend tax credits that were initially supposed to have expired almost 20 years ago. My preferred partners are not other energy suppliers, they are the massively larger base of customers who care about their power costs.
So far, the nuclear industry – which I hope you notice gets criticized regularly here – has failed to build support among customers because they haven’t focused on controlling costs and on supplying a decisively more cost effective product. IMO, when we succeed in producing power cheaper than competitors, we will gain plenty of public support.
Here is a strong scientific indictment of Globull Warning and Unreliables
1) Every year the temperature swings about 60 degrees F. We are supposedly in a crisis because the temp rose 1.4F (.8C) over 100 years.
2) Greenland ice core data shows stable temperature for 10,000 years varying between 14-16C. The alarmist scare is based upon the thermometer temperature record that covers only 150 years or part of the current warm period that is unremarkable relative to the last 10,000 years.
3) Water vapor accounts for 75% of the greenhouse effect, CO2 for 19%. Man made CO2 emissions account for 1-2% of CO2 emissions.
4) The greenhouse effect of CO2 is exponentially reducing. From 0 to 20 ppm it is 1.5C. From 380 to 400 ppm, it is less than .05C.
5) From 1960 to today, CO2 ppm has increased steadily. From 1960 to 1980 temp decreased, from 1980 – 2000 temp increased, from 2000 – today temp has been stable.
6) Temperature predictions made by the global climate models are wrong and getting worse with every passing year.
7) Sea level increased 8 inches in the 19th and 20th century. It is likely to do the same in the 21st. Even if the Arctic melts, it is only 2% of the ice and it wont increase sea level because it is floating. Antarctica with 90% of the global ice is adding 8 inches of ice per year. During WW2 some airplanes crash landed in Greenland, recently they were found under 268 feet of ice.
8) At 280 ppm CO2, we were dangerously close to a mass extinction (plants start to die at 180 ppm). The increase in CO2 to 400 ppm has lead to increased food production and the greening of the planet.
Word of advice, please do not provide a YouTube or Wikipedia link to support a statement that begins with the words “Here is a strong scientific indictment …”
You better take another look , resistance to both wind and solar are increasing in both the U.S. and around the world. Many wind farms are successfully being stopped while natural gas and coal plants are proceeding. One way to help nuclear power is to work against wind and solar and work for fossil fuels to help preserve a high energy culture which will be needed down the road to build new nuclear plants. I see natural gas and coal as important resources for the nuclear and thermonuclear based industries. There are problems now but new policies can correct them.
The article made the following characterization of the industry:
“With a culture based on a need for certainty and a search for excellence..”
My reaction was to say that those very industry attributes are not a good thing, but are in fact the main problem. Later in the article, the author showed that he did understand this, with his coining of the wonderful term “excessilence”.
He also spoke about industry efforts to reduce costs, and some extreme examples of QA absurdity. But those industry efforts, and examples, only scratch the surface, and are nowhere near enough.
He quotes a savings of $650 million (over an unspecified time period), when what really needs to happen is a reduction of 1-2 cents/kW-hr, which corresponds to $8-16 billion, *per year*. Frankly, construction costs also need to be more like $2,500/kW, as opposed the over $10,000 that Vogtle and Summer are turning out to be. Lest you say that is impossible, both capital and operating costs WERE that low back in the ’70s (in real dollar terms).
As far as the changes that need to happen, we need a fundamentally different mindset.
A study of Northern States Power stated that staffing levels at their power plant literally increase by a factor of ~4 since the ’70s, and that the reason was escalating regulations and requirements. Instead of trying to improve things here and there, within the existing system, like the NEI / industry’s DNP initiative described in the article, we need to have the industry sit down with NRC and ask, how do we get staffing levels back down to what they were then. Any reasons why we “can’t” need to be pretty damn compelling (e.g., analyses showing that it would literally render nuclear more dangerous than coal).
Instead of demanding that NRC do cost-benefit analyses for new regulations and backfits, we need to demand that the entire body of nuclear regulations be subject to such analysis. (Most regs would fail.)
We need to ask why nuclear power needs a unique, and uniquely onerous component fab QA program (NQA-1) when the fact is that failures in other industries have actually caused *greater* loss of life than nuclear meltdowns. For SMRs (at least) if not large reactors, we need to demand that standard industrial QA programs and requirements be used.
I understand the arguments about loss of expertise and supply chain (i.e., ability and practice at nuclear construction). But I find myself asking if nuclear really is fundamentally that hard, or whether we are making it that hard. Instead of trying to maintain, or redevelop, the ability to perform what has become an extremely difficult endeavor, why can’t we make it less difficult?
I understand that reactor design requires real talent (as do iPhones), and that some amount of educated people will be required for some aspects of operation, but not nearly to the extent it does today. Once an SMR is designed, it shouldn’t require that much unique talent to build and operate it. A nuclear plant actually mainly consists of common industrial components. It is the QA requirements that are (unnecessarily) unique, which is why the supply chain is so “small” (instead of the industry being able to rely on the massive supply chains for standard pumps, values, piping, structures, etc…).
I’m afraid that any attempt to work within the existing system would be like “trying to improve on candles”. We need to start again from scratch, with SMRs, with a whole new (much smaller) set of regulations, standard industrial fab QA requirements, a new business model, and (I hate to say) perhaps a whole new group of people.
I believe that one of the major issues rests in the publics’ imagination that there is some better technology that will soon provide cheap low CO2 power. Whether they imagine a brilliant innovation in batteries or solar panels as the future of energy, the public does not think nuclear brings unique, tangible, and irreplacable benefits to society. If this is changed, the NRC and INPO would also shift in their perspective regarding QA, regulations and the like.
I’m afraid I can’t agree with that. Nuclear is not indispensable, and we have to get used to idea that we’re actually going to have to compete.
A lot of nuclear’s problems lie with the industry itself, in that they went along with excessive regulations and essentially agreed to be held to a standard of perfection. Many researchers have hyped tiny nuclear “issues” to justify research grants (containment of I-129, for example). Companies thought they could make more money by addressing all those “issues” (selling TEPCo technology to isolate tritium, for example).
I believe that they thought nuclear was special, and inevitable (due to fossil fuels running out, renewables never amounting to anything, etc..), and that it could therefore bear such high costs. Turns out that they were wrong. We now see that nuclear will have to compete, and cannot bear those costs. And we are left trying to backpedal on the necessity of all those expensive requirements.
Another mistake, by the industry, and many others, was to take the line of argument that whereas nuclear has all these “serious problems”, it is necessary (and inevitable). So, the answer is to continue with nuclear but give us all this money (R&D, etc.) to solve all those “very serious” problems (e.g., reducing meltdown risks even further, closed fuel cycles to solve those unacceptable long term risks from spent fuel disposal (lol), and reducing proliferation risks (an even bigger joke)).
You mentioned that nuclear support is dropping because people think that renewables can do it all. If one makes the above argument, that nuclear has all these serious problems but is necessary, one shouldn’t be surprised when support evaporates the moment people are given reason to think that it may not be necessary.
I don’t think we need to show that nuclear is unique or indispensable to make the case for regulatory reform. We just need to point out that it has tangible benefits (clean air, lack of CO2), and that those benefits need to be weighed against any risks, when evaluating nuclear requirements that may result in reduced nuclear use.
Interesting ideas. I’m thinking the nuclear over regulation is due in large part to the feds protecting themselves from liability. After all, they own the U235 and they “let” the power companies use it; but the feds are on the hook to make sure it is done safely since it is their Uranium. Compare that to the fossil plants — where boiler explosions are a real possibility and they used to kill people regularly. The fossil plant safety is a state responsibility; and they do that by 1) requiring the plants be built to the ASME code, and 2) requiring the plant operators have insurance. Then the insurance companies (eg, Hartford Steam Boiler) “regulate” the plant operators by telling them what they have to do to keep their insurance policies.
Now why can’t a similar system be done for nuclear? Especially the smaller SMR designs that are really no danger to anyone outside the fence? Isn’t that a lot like a coal boiler, where the danger is only to the workers?
I agree about using a similar setup as ASME BPVC for nuclear plant design (not just section III components) and have pushed that idea before.
I think it is time for a complete rethink of our nuclear regulations. We may not have to look far for good model of the regulations, though, as the “boiler code” model already is established. However, we still have a culture issue with the “establishment” not likely to want to change.
Specifically, Price Anderson exposes them to some liability, and is the reason they’re “on the hook”, although the industry covers up to $20 billion. I suppose one approach to limiting that liability would be to regulate nuclear out of existence, but one would think that another response would be to greatly reduce huge, open ended potential costs by promulgating sane post-meltdown dose and cleanup standards. Perhaps working to change hysterical public attitudes as well? Refraining from fear mongering? Perhaps I’m asking too much of politicians.
Fossil plant accidents don’t have a significant impact (or potential cost). Virtually all their harm is from the pollution associated with normal operation. The elephant-in-the-room question is why nuclear faces huge liability (demands for compensation, etc..) if it ever releases pollution, whereas fossil plants are not required to pay anything (in compensation, etc..) for continuously polluting the environment and causing huge numbers of deaths, etc..
We make so much out of the ~$100 billion Fukushima economic cost, but EPA estimates that fossil power plant pollution causes ~$100 billion in indirect *economic* damages every single year in the US alone. Worldwide, it’s closer to ~$1 trillion. But neither the industry or the govt. has to pay that, so it’s not a “liability”. It’s borne by the public, I suppose. The double standards are disgusting.
I will agree that unique and tangible benefits are essential. I still contend that the key to making NRC closer to the FAA or FCC is to capture the public moral imagination. Without that, any simplifications in regulation will be met with strong opposition.
As an aside, if there is no cheap energy storage, then nuclear becomes indispensable for a low CO2 grid that does not depend on excessive demand side management.
Well, besides the occasional sacrifice zone, the fact that each running nuke plant produces about 3 nuclear bombs worth of radiation, each day, makes it hard to justify nuclear in my book
Thank you for visiting and sharing your opinion.
Can you enlighten us about the consequences – as you see them – of the radioactive material (radiation is something different) produced in nuclear power plants?
Lots of long term costs of storage and monitoring.
potential release to the environment, cancers, morbidity, quicker mutations on bacteria, viral, and fungal. ionizing radiation comes from radioactive materials, so not sure why you want to draw a distinction, please elaborate.
It might sound a little geeky or esoteric to you, but there is a big difference between radiation and radioactive materials. When operating, nuclear reactors produce intense radiation fields that require thick, multi-layer shields to protect operators. That radiation is an integral part of the fission process, but nearly all of it disappears once the reactor stops operating. Dose levels drop by many orders of magnitude upon shutdown. Avoiding radiation is a simple matter of adding shielding, reducing exposure time, increasing distance from the source or a combination of the three.
Radioactive material is made up of unstable isotopes that need to go through at least one energy emitting nuclear transformation before achieving stability. Some radioactive material needs to go through a whole series of decays, each with its own characteristic emissions before they become stable. There are intensely radioactive isotopes that decay very rapidly and there are only slightly radioactive isotopes that decay much more slowly with thousands to millions of years required for half of the material to be transformed.
Costs that can be spread over many years are much easier to handle than costs that must be paid immediately. If you are a home or car owner, consider the affordability of payments compared to buying with cash.
Storage containers for radioactive material are simple structures that do not require much care or inspection to ensure they are safely doing their job.
Intense ionizing radiation may be a weak carcinogen, but low doses pose no risk to living creatures. The only radiation that has been proven to make a significant difference in the rate of mutation is on the order of 400 gy administered over a brief period of time. Doses lower than that can only be assumed to produce some variation, but the variations are too low to separate from the normal noise in the signal.
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