Surest way to crush nuclear power’s growing momentum would be to decapitate the Nuclear Regulatory Commission

7 Comments

1. Rod, the previous Blue Wave interview, shows license processes can be shorten dramatically by reducing the search time needed to convince the regulator. I agree that consistency is deeply needed for business to thrive. The NRC CAN decide there are amounts of source material that are too small for it to regulate, or that the regulation can be simple and uniform for those small amounts regardless of the style of reactor being used and clear the way for micro-reactors. I like reading Jack Devanney and agree with many of his points. However, a wholesale change and fast change from the NRC to Insurance at this point would be destructive. When we have several companies already selling tens of reactors a year, that change could be considered as a means to speed an already moving industry. But it would take time for the insurance world to come up to speed enough to offer a suitable insurance, and the insurance regulators in each state would need to come up to speed enough to make sure that the reactor insurance being sold was not scammed. At the moment, I agree with you, we are seeing the NRC embrace AI in very healthy ways that will dramatically reduce the workload. Best to encourage the 5 commissioners to work quickly and effectively.

2. Your earlier article regarding Vogtle 3 and 4 / VC Summer indicates exactly how NRC impedes new builds in the US.
   A utility can start building, NRC decides Shield Building does not meet Aircraft Impact Standards, and the utility is forced to re-engineer from the basemat up.
   We saw both outcomes. > $30 B for two AP 1000s in Georgia . And a fine unused set of South Korean RPV / SG components in South Carolina.

   If this were a novel concept, it could be perhaps justified.

   I was licensed at Clinton, built over 12 years 1975-1987 at 10 x the initial price and 1 unit vice 2.
   NRC gifted NUREG 0737 at the time, the plant had to install “TMI / ATWS” instrumentation with substantial redesign.

   So there’s a 40 year trend here of NRC tossing regulatory monkey wrenches in nuclear new builds. So that’s all up front.

   Let’s talk back end.

   Nuclear fuel reprocessing doesn’t happen. Y 12 and nobody else reprocesses fuel in the US.
   This ain’t France.
   NWPA, taxed nuclear energy billions to site, license, and build a “repository”. 1982 to 2025, 43 years, we have an expensive hole in the ground at Yucca Mountain and an additional budget item called Independent Spent Fuel Storage Installation to host Dry Casks. We’ve created a subsidiary industry to mitigate NRC regulation.

   Rod, I don’t think rational investors with an understanding of actual regulatory history are going to buy into new builds of any type with the NRC we have.

3. The proof of the pudding is in the making and over the decades the NRC has proven to not deliver results (ie operating plants at reasonable cost and schedule). There was going to be regulator reform, with the combined operating licenses and such. Plant Vogtle is proof that that didn’t work. The NRC is still the devil it was, if anything it is far worse now. In addition, there is no proof of improved safety; indeed the TMI accident occurred during NRC style regulation, with the TMI units being the latest and most up to NRC standards as plants. Drowning everything in red tape does not improve safety, it leads to questionable design decisions, even more questionable management (-objectives) and a general diversion of real improvements.

   The simple truth staring that we must all be staring into the headlights is that regulatory reform is a sine qua non for a large scale nuclear buildout.

4. If the NRC must be kept for political reasons, drastic changes are needed. As in any risky endeavor with large societal benefits, a balance must be found between regulation and the benefits of the activity. The omnipotent regulator that not only can set standards thousands to tens of thousands of times more stringent than esteemed national labs have found to have no observable effect, but can even change the rules of the game when playing, is a death sentence to new nuclear.

   Licenses must be based on what is known to be safe, with a reasonable safety factor as we do in all engineering. A factor of 2 or 5 is reasonable. A factor of 50000 like the EPA standard for drinking water, is not. Speaking of reasonable, the ALARA has to go. It is not reasonable to have unclear regulations. No engineer can design to ALARA. No investor can invest in ALARA. This must go in favor of clear an unambiguous rules for releases.

   Even more important, no changes must be allowed once a license is given. That means a license means nothing. No investor can get on board with a regulatory system where a license means nothing. If new insights are gained such as during Fukushima, then the licensee must perform a stress test and if any issues are found, a plan must be drawn up to make amends during the next major outage. In no way should this impact construction.

5. The financial angle must change as well. The regulator provides a public service, it is totally wrong to require the regulator to hold up their own belts by means of fees. This creates a perverse incentive that leads to either endless milking of applicants, or corruption, and the only way to avoid the latter is more bureaucracy and further costs and thus milking of applicants. The USNRC must protect the environment and people, not make money by milking applicants by the hour. They provide a public service and therefore should be paid by public funds. If there is to be a financial tie it could be in the form of a surcharge per kWh for every nuclear kWh generated.

6. “Investors studiously seek to minimize or mitigate uncertainty.”

   Absolutely 100%. The present operational method of the NRC militates against this very desire for certainty. ALARA and LNT both destroy certainty, and as others have pointed out, recent builds have proven it, with the NRC changing the rules mid-build. At minimum, once a construction license is awarded, the NRC should not be allowed to change the rules that the license was awarded under.

7. Separately from my previous comment, the US NRC logo in the article says everything about the viewpoint of the NRC: “Protecting People and the Environment” — from nuclear power evidently.

   A better tagline would be “Clean & Safe Energy for All”. The NRC as presently constituted is not about promoting safe energy, its about promoting safety.

   An illustration: If the first rule of traffic safety is “safety first” then 35MPH would be the maximum speed limit. If the first rule of traffic safety is “keep the traffic moving” then speed limits and other rules take their rightful place — accidents impede the flow of traffic, so traffic rules should help prevent accidents, but the rules become subservient to the primary goal of keeping traffic flowing.

   The safety rules around Nuclear power should be subservient to the rule that nuclear power should be plentiful, cheap, and safe. Those are not unachievable goals. The failure of the NRC is to regard nuclear accidents as somehow more special than any other industrial accident, contributing to the culture of treating nuclear power as more dangerous than any other industry. As Petr Beckmann noted in the title of his book, “The Health Hazards of Not Going Nuclear”, depriving society of plentiful, cheap and safe energy is more hazardous.

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