How Can Nuclear Construction Costs Be Reduced?

by Jim Hopf

This month’s post discusses my ideas on an issue I’ve been thinking about for awhile.  Although we have four new reactors under construction in the United States (at Vogtle and Summer), the nuclear “renaissance” has so far not been nearly as strong as many had hoped. This begs the question as to what is holding nuclear back.

Impediments to nuclear growth

Some have suggested the need for even safer reactors, despite the fact that overall nuclear is already among the safest, if not the safest of all energy sources.  The fact that any direct health consequences of Fukushima, which was essentially a worst-case nuclear accident, have been essentially non-existent further suggests that insufficient safety is not the primary area needing improvement (or factor limiting nuclear’s growth).

Others believe that the nuclear waste issue is the main reason holding nuclear back, and that “solving” it (by closing the fuel cycle and through other advances in fuel cycle technology) would “unleash” nuclear to grow and solve our energy problems.  The truth, however, is that indefinite on-site storage of all of a plant’s waste (in the pool and in dry casks), versus having the Department of Energy take it away after a few decades, increases the cost of nuclear power by only ~0.1 cents/kW-hr.  Waste management activities will never be a significant fraction of nuclear power’s total cost, regardless of what waste policy is adopted, or what fuel cycle we develop.  I had thought that the perceived lack of a waste solution would significantly reduce support for nuclear, but it appears that, at least where almost all new US nuclear projects are proposed (in the Southeast), there is an ample degree of public/political support for new reactors.

No, it’s pretty clear that the primary factor holding nuclear back is economics, particularly the high upfront capital cost of new reactors.  The current low price of natural gas, coupled with a weak economy (and associated lack of power demand growth), and the lack of taxes or limits on CO2 emissions does not help, but it is also true that the costs of reactor construction have increased substantially over the past ~8 years (and increases in labor or raw materials costs do not come close to explaining this).  In addition to escalating initial cost estimates, many if not most current reactor projects have been experiencing fabrication issues and cost overruns.

How can we reduce costs?

Based on the above, it seems clear that nuclear research and development should focus primarily on ways to reduce nuclear plant construction costs, and less on fuel cycle or even safer reactor technology.  Even the safest conceivable reactors and fuel cycle will do nothing to help overall public health and safety and reduce environmental impacts if nuclear is not deployed – due to high capital cost – while fossil fuels (which are vastly worse than current reactor technology in terms of public health and safety) are used instead.  Ideally, this is something the Nuclear Regulatory Commission would keep in mind as well.

What is really needed, however, is to have all the experts sit down and perform a thorough, objective evaluation to figure out what is driving nuclear construction costs, and what needs to change to reduce those costs.  In this analysis, everything needs to be on the table—all regulations, policies, and practices. Nothing can be viewed as sacred or unchangeable (i.e., “that’s just the way things are in the nuclear business”).  We need to fundamentally reexamine all of our current policies and requirements, to determine which ones produce the most bang for the buck in terms of public health and safety benefit.

Not only should nuclear requirements be compared to each other (for benefit vs. cost), but nuclear requirements should be objectively compared to the requirements placed on other energy sources and industries.  One mindset that simply must disappear is that of “nuclear exceptionalism”, which views nuclear’s potential impacts/accidents to be uniquely unacceptable (i.e., that radio-isotope pollution is a uniquely unacceptable form of pollution), and that therefore, unlike other industries, no expense should be spared to remove even the tiniest chance of release.  By extension, we should ask why non-nuclear power plants are so much cheaper to build.  Is it that nuclear plants are more complex, or have more safety features, or is it the unique quality assurance requirements that only apply to nuclear?

My personal view is that the main factor leading to high plant construction costs is not the design of the reactors, or various safety features that they employ, but the uniquely strict QA requirements that apply (only) for the fabrication of safety-related nuclear plant components (i.e., “nuclear grade” components). Conversely, I believe that in terms of safety, fundamental reactor design, employed safety features, intelligent operation/training, and maintenance are much more significant (effective) than the application of extremely stringent fabrication quality control requirements.  This is a personal opinion that I welcome comments on—the purpose of this article being to start a discussion.

The costs of nuclear’s unique QA requirements

Having supplier qualifications and requirements for component fabrication that far exceed those applied to any other industry can lead to dramatically higher costs, for multiple reasons.  In addition to the increased costs of compliance, the number of qualified suppliers is much smaller, which in turn results in supply bottlenecks, not enough fabrication capacity to meet demand, and (essentially) a bidding war for components.  This seems to be a far more plausible explanation for the observed increase in reactor construction cost (vs. that initially estimated) than any shortages of labor or raw material.  Conversely, if the nuclear industry could use a more typical set of industrial quality requirements (e.g., ISO-9000), the number of suppliers would increase dramatically, there would be ample supply and significant competition, and costs for nuclear components could drop substantially.

It seems clear that problems complying with fabrication QA requirements, as opposed to reactor design features, are primarily responsible for reactor project cost overruns, since the reactor design was fully understood at the time of the initial cost estimate.  Also, meeting “nuclear grade” fabrication requirements is the reason most often cited in the numerous articles discussing cost overruns at nuclear projects.

At Vogtle, they are having significant problems, and cost overruns, due to the construction of something as simple as the concrete pad that the reactor will sit on.  This comment from an article on the Vogtle difficulties is typical:  The fabricator was “not accustomed to the requirements to document every step in the fabrication process. Correcting the mistakes took eight months for one of its modules….”  In addition to problems such as this, the Vogtle project is literally spending billions of dollars on quality control programs.

Similar problems are occurring for the nuclear projects in Finland and France, QA/fabrication issues being the primary reason for cost overruns.  And yet, those same reactor designs, with all the same safety features, are being built at a fraction of the cost in China.  Why the difference?  I believe that lower labor costs are only part of it.

I’ve also, anecdotally, heard many stories about how the nuclear-grade version of a component often costs several times that of the commercial/industrial-grade version of the same thing.  This is not due to any material difference in the component; just the QA paperwork cost and the (severe) lack of nuclear-qualified suppliers.  I have significant doubts as to whether the safety benefits are worth the additional cost.

Potential negative impacts on safety?

Due to onerous QA requirements, as well as the nuclear industry practice of taking a great deal of time in analyzing everything (“analysis paralysis”), there can be significant reluctance to make changes, including adding safety features or improvements.  In addition to making it more difficult to change, or even fix things, these practices also act to stifle innovation and technological progress in our industry.  The NRC “review barrier” to new, innovative, safer reactor designs is but one example.

Consider the following example: the NRC is debating whether or not to require filters on reactor vents that would remove most of the cesium from any vented air stream that may be necessary to control containment interior pressure in the case of a severe accident.  (Failure to vent was a major factor in the Fukushima event, resulting in a much larger release.)  In my opinion, such a design feature seems to be extremely worthwhile, since it greatly reduces potential cesium releases, and the long-term consequences of severe nuclear accidents pretty much scale (specifically) with the amount of cesium released.  The filters would cost ~$16 million per reactor.

Meanwhile, the Vogtle project was significantly delayed (several months) due to minor, inconsequential variations (from the specified design) in the rebar within the concrete pad that the reactor will sit on. Eventually, the NRC agreed that the alternate configuration was fine, but it took an inordinate amount of time (and money) to reach that conclusion. Under current practices and procedures, addressing any changes or deviations from an approved design is extremely difficult and time-consuming. Did this base pad rebar issue cost the Vogtle project more than $16 million? I’m pretty sure it’s much more than that.

So the question is, which is better bang for the buck in terms of safety: installing cesium filters on containment vents for $16 million, or spending a much larger sum to address (or correct) a small/inconsequential change to the rebar configuration in the plant foundation?  To me the answer is obvious.  Would dramatically reducing the cesium release in the event of a severe accident result in a significant reduction in nuclear’s overall risk?  Absolutely!  A small change in the configuration of the rebar in the (passive) concrete pad that the reactor sits on?  I cannot, for the life of me, imagine how that would have any significant impact on the likelihood or severity of a significant accident/release.

Despite this, whereas the cesium filters may end up not being required, the fact that Vogtle had to do what it did to resolve a minor deviation from licensed design (any deviation from licensed design), is not even questioned.  It’s just “the way things are in our industry”.

There have been some allegations made that the nuclear industry is not doing enough in terms of flood protection or component maintenance at some sites. Improvements in these areas may very well result in measurable reductions in risk, but, in my opinion, excessive (and unique to nuclear) QA requirements make any such responses or improvements so difficult and expensive that the industry is sometimes reluctant to implement them.  That’s both in terms of component fabrication QA requirements and the amount of analysis and review that is required for any actions or changes.  The end result could actually be a net increase in overall risk.

In my view, risks from component fabrication defects are not a significant fraction of overall nuclear risk.  No serious accident has ever resulted from a fabrication defect.  Instead, the rare instances that have occurred resulted from poor reactor design, operator error, or from things the industry just hadn’t thought of.  Fukushima is probably an excellent example of the latter.  They simply didn’t anticipate (or view as credible) a tsunami of that height.  Seawall fabrication defects were not the issue.

In other words, let’s put cesium filters on reactor vents, but pay, say, ~$4 million for them, instead of $16 million, by foregoing the impeccable fabrication and paperwork requirements required for “nuclear grade”, “safety related” components.  Let’s apply the QA requirements/standards that generally apply for other industries, or perhaps even use “commercial grade” filters.  It would surely be better than doing nothing.

Lazy thinking?

I’ve been in the industry long enough to know how most will respond to the above (rash) proposal.  Industry thinking tends to be that if full, nuclear-grade QA requirements are not applied to a component, it’s the same as it simply not being there.  Probability of function is 0%, regardless of the fact that such a failure type (or mode) is completely impossible.

Given the huge costs of nuclear-grade QA requirements, the industry has not put nearly enough time and effort into evaluating the probability of failure of non-nuclear grade/qualified components, and what the nature of any failures would be.  Such evaluations should be followed by detailed probabalistic risk assessment (PRA) analyses to determine what the effect on accident/release frequency (and severity) would be of having various components not be nuclear-grade.  These effects, on risk, should then be objectively compared to other options for reducing risk, such as fundamentally safer reactor designs, or the employment of various safety features (e.g., vent filters).

Such an effort has not been made, however (the NRC’s new “risk-informed” philosophy is a far cry from what I’m talking about).  It’s easy to follow up any analysis or evaluation with the statement: “and it shall be a perfectly constructed component, with zero defects”, without any regard for how much it will cost to make such a guarantee.  That way, one doesn’t need to do the hard task of evaluating the likelihood and consequences of (realistic) component failure.  Also easy is the notion that zero changes or deviations from the approved design are allowed, and that any change at all (no matter how small) requires re-performing and re-reviewing all the associated licensing analyses/evaluations.  How about exercising a little engineering judgment?

One has to ask how other industries handle fabrication defects or deviations. It seems clear it’s not the way the nuclear industry does, given their lower construction costs, shorter schedules, and fewer cost overruns.  It’s not like construction projects such as bridges, tall buildings, oil refineries, chemical plants, or non-nuclear power plants, etc., are not “important to safety”.  In many cases, their potential consequences (of component failure, etc.) are actually just as great.  Yet under nuclear QA logic, all these structures are repeatedly vanishing, crumbling into dust, or simply not performing their design functions, given that they were not built to nuclear-grade standards.  The real truth, of course, is that all these structures have been performing just fine, with acceptable levels of safety.

This is all just an example of the “nuclear exceptionalism” discussed earlier, where nuclear risks (or potential consequences) are treated as being infinitely greater than that of any other endeavor, while the facts clearly show otherwise.  For this reason, uniquely strict QA requirements, unlike those used in any other industry, may be hard to justify.


My personal view is that the low risk of significant release primarily comes from fundamental reactor design, safety features, and operational practices (e.g., operator training).  The onerous, uniquely strict component fabrication QA requirements and procedures that are applied only to the nuclear industry provide relatively little risk reduction relative to how much they are costing.

Thus, my primary recommendation is that while the NRC should definitely thoroughly review new reactor designs, once a reactor design is certified, normal industrial QA requirements should apply to reactor (and reactor component) construction.  That is, the same fabrication/construction requirements and practices that apply to non-nuclear power plants.  This would not only greatly reduce costs directly, but it would result in an enormous increase in the number of suppliers that can participate in nuclear plant construction, which would further greatly reduce costs.

At a minimum, the detailed component failure evaluation I described earlier should be performed, and specific relaxations to fabrication QA requirements should be evaluated and possibly traded for other, more cost-effective measures to reduce risk.  One example of a cost-effective measure, in my view, is the rapid emergency response capability that the industry is now developing.  One lesson learned from Fukushima is that flexibility, and the ability to respond (quickly), is imperative since one can never really predict the sort of events and disasters that potentially may happen in the future.  Another example would be that if one developed a smaller, lower power density reactor that was fundamentally safer (perhaps even unable to meltdown, due to basic size and geometry) but was somewhat more expensive, the QA requirements on at least some components should be relaxed, since the consequences of component failure would be far lower.

One thing seems clear to me.  Given how things are going with current (large) reactor projects, in the developed world anyway, the industry does not appear to be on a success path.  It was given a second chance to show that it could build new reactors at a reasonable cost, and on time and on budget, and it appears to be failing (although things don’t appear to be too bad yet at Vogtle and Summer).  Barring a large increase in natural gas prices AND the enactment of hard, declining limits on CO2 emissions (that would force a phaseout of coal), it appears that few new nuclear plants will be built in the future in the developed world.  Something has to change; something that will significantly reduce plant construction costs.

Small modular reactors, built in an assembly-line-like fashion, may offer a way forward; a development that I will discuss in a later post.  As for large reactors, the ideas presented in this article are my best attempt to figure out what could be done to change an otherwise fairly bleak picture.  I again remind everyone (and the NRC) that the environmental and public health benefits of nuclear (which are huge) will not be realized if nuclear is not deployed and fossil fuels are used instead.  We need to make a concerted effort to do what’s necessary to reduce nuclear plant construction costs, not only in the area of technology development and deployment, but in the areas of regulations and QA requirements as well.

I hope to start an active discussion on this topic, and hear other people’s ideas on what could be done to reduce nuclear plant construction costs.



Jim Hopf is a senior nuclear engineer with more than 20 years of experience in shielding and criticality analysis and design for spent fuel dry storage and transportation systems. He has been involved in nuclear advocacy for 10+ years, and is a member of the ANS Public Information Committee. He is a regular contributor to the ANS Nuclear Cafe.

47 thoughts on “How Can Nuclear Construction Costs Be Reduced?

  1. Roger Blomquist

    Now is a great time to be talking to members of the public. A few are anti-nuclear zealots, some have their minds made up and only follow conventional wisdom, but most of them are genuinely interested, and want to get information from a technically-trained person instead of a journalist. They hear that nuclear has gotten a bum rap, and they hear that nuclear is not a greenhouse-gas emitter. My experience in talking to civic groups, churches, etc., has been entirely positive. Staged anti-nuclear events are another story. So let’s undermine the support of the zealous antis by giving the public the facts.

  2. Robert Margolis

    Perhaps we all need to be more activist in our pro-nuclear activities. I try to get out and talk to the public, but it is not always easy. Still, we can help win the public imagination and not leave the discussion to the antis.

  3. Engineer-Poet

    Yes, we are very much aware of this.  The inexpensive natural gas is a temporary condition; production from most of the shales costs $7/mmBTU or more, and what we have right now is a combination of a production bubble caused by “drill it or lose it” contracts signed several years ago, a rush into gas companies pushed by cheap debt, and gas being dumped because the profitable product is the natural-gas liquids associated with it.  3 years from now, nobody would consider closing Kewaunee for economic reasons.

    The real irony is that cheap natural gas could be substituted for gasoline to cut the cost of running our cars, and that demand would increase the wholesale NG price to where gas-fired base load wouldn’t be economic any more (and Kewaunee would be a money-maker).  It’s not happening because the oil companies have bought most of the players in natural gas, and they like things just the way they are.  The only change happening is the opening of liquid natural gas terminals at truck stops nation-wide.  Truckers will get cheaper fuel, the average American will not.

  4. Rick Maltese

    Has anybody followed that, in Wisconsin, Dominion is closing their only nuclear plant. Some say due to natural gas outselling them. Have heard predictions of eight more plants in US considering the same path. Too hard to make profits? Backroom deals? There is a Bill up for Wisconsin to make nuclear energy to be treated like renewable energy so that they can remain competitive. I speculate that higher gasoline prices can be explained because natural gas prices are being kept low to push nuclear out of business. That is probably hard to prove but if the public suspected this they might consider supporting nuclear energy.

  5. Gale

    I understand the difference, the point is that each drives the requirements for compliance and specifications that end up in the purchase order for an SSC. Blaming the resultant quality program is an easy answer to the fact that quality only verifies and requires what engineering specified.

  6. Cal Abel


    There are two issues here that are similar, but quite distinct. They are reliability and regulatory requirements. Conflation of the two as the historic historic norm is what has lead to the cost increases. Internal QA requirements hold much different requirements and burden of proof than do proof and control of design considerations b the regulator.

    Vogtle and VC Sumner are a prime example of this. Regulators like any bureaucracy tend to “no” as the default answer as it shows strong oversight and control of the situation, its what justifies their existence. Unfortunately this removes much of the responsibility from the operator as the regulator is there for safety. This fallacy is perhaps the most pernicious. In my short career in plant operations and maintenance, I found that safety fundamentally comes down to ownership, in the literal and figurative sense. Without this responsibility no amount of bureaucracy will provide any improvement, just added and unnecessary cost.

    Let’s take the example of Fukushima to illustrate this point. The plant suffered a tidal wave that overwhelmed a sea wall that was designed for the intent of protecting the population, safety, just not focused on equipment reliability and survivability. As a result TEPCO relied upon the regulator to keep them safe. Even with this fundamental failure, the reactors have yet to kill a soul. The needless and draconian evacuations on the other hand are the real tragedy and have caused a measurable loss of life.

    While at first glance this is obvious it is not sufficient to prove my point. I want to go back to the 1960’s when the AEC and designers settled on the inferior isolated containment. Much of this decision was based on preventing any radiological release to appease fears that any dose of radiation is unsafe, LNT. Interestingly, Rickover even held such misconceptions and let that steer many of the design and operational considerations as he developed the Nuclear Navy.

    Here is why I say an isolated containment is an inferior design.readidng through the INPO time line the operators were conferences about the political implications of venting the primary containments even though they clearly knew that procedures required them to do so. Because they didn’t vent the containment and accept the realize of some fission products they allowed the containments to become compromised limiting their ability to access equipment and control the plants. The concern is to reduce the pressure inside the containments to prevent containment failure. Any steam release acts to dilute existing oxygen and hydrogen in the containment atmosphere and venting acts as an air ejector removing the non condensible gases. What would have happened is a short release of fission products early in the casualty and would have preserved the secondary containments and access to vital plant equipment. These two things would have changed the course of the entire casualty. They would not have saved their fuel, TEPCO’s failure to implement reasonable equipment hardening and an adequate sea wall doomed units 1-3. They would have saved unit 4 and cut the total radiological release to a trivial fraction of what was ultimately released. Here too, a filtered vent is not necessary to ensure public safety, the total activity released is inconsequential if the containment is allowed to maintain its integrity.

    So now let’s examine the impact of excessive design criteria on plant modernization. The spa and scope of the control of the NRC precludes modernization of safety related equipment. For the simple fact of the hassle and cost to implement design changes that end up improving overall plant reliability and safety. Japan also suffers from this paralysis. The act of having to satisfy a regulator increases burden of proof of the owner of the plant, they have to take into consideration the total cost of a resin change before making a design change.

    Also the probabilistic level to prevent damage to the society has a faulty risk assessment model that provides warrant to the regulator to further “ensure public safety” and regulate down into the minutia, increasing the cost of the plant for what amounts to a degraded safety and reliability posture.

    By restricting the role of the regulator wih a radiation threshold, the warrant they can assume is limited and quantifiable. This effectively contains the cost regulatory compliance allowing owners to focus on reliability. The more anti-fragile the plants become the better it is for the bottom line of the utility. Tis approach uses the inherent self interest of humanity to achieve a desirable outcome. Please do not conflate safety with reliability they are two fundamentally different topics and need to be treated as such.

  7. Gale

    Nuclear Program Requirements

    It is interesting to note that individuals that are outside the nuclear QA function look at the issues and onerous or overly restrictive quality requirements as the cause of cost increases. One has to look at the basis of the quality programs provided for the nuclear industry and it would be difficult to identify a single technical equipment detail in the quality program. The QA program requirements of NQA-1 and other nuclear quality programs identify the processes to be used to provide a level of assurance that systems, structures and components specified in the technical requirements, engineering specifications and drawings of nuclear facilities will perform in the manner described in the requirements for the item. Thus the “onerous or restrictive” technical or engineering details provide the requirements for the items, not the quality requirements.

    The quality requirements identify the necessary attributes that must be controlled – to meet technical and engineering requirements. Failure rates, ALARA, reliability and risk analysis are not detailed in the AA programs. What is detailed is the methods and management processes required to provide assurance that an item or component will perform to the specified data in the engineering documents.

    Quality assurance does not specify the engineering, technical or scientific data used to establish the nuclear facility design basis. The reliability and failure data is a product of the regulations and requirements such as one in a million or other specific data. The quality program provides tools for requisite level of assurance that the structure, system or component will meet the regulations and facility reliability requirements.

    In many of the generation four reactors, the reliability requirements as stringent for many of the non-safety items as the quality requirements for the safety related items. At over 1 million dollars a day expected gross revenue, having a system off line due to failure is costly. Having a shutdown reactor for safety reasons is also costly, but in some cases removes some of the motive forces identified in the safety analysis, i.e. operational case to shutdown decay heat loads. The newer designs have are providing a list components that reduces the number of components in the safety and safety related item categories. The current Westinghouse, General Electric and other designs have shown the reduction in the safety related items in the facility.

    Working at a metal processing facility, much of the concrete work specifies the same American Concrete Institute standards and codes, why? The effect of a chemical reaction of caustic material in the process with the ground will cause a process failure in that area. Again at a figure of above two million dollars a day loss of revenue, the criteria in the specification drives the quality requirement for rebar, strength of concrete, rebar placement and testing requirement. In fact, we use the same forms for civil and structure work here as we did previously for nuclear facilities in the past. Material certifications are required for all metals used; in all cases the interaction of the chemicals in the process with much of the systems and component must be controlled. In the non-safety commercial buy in the United States, material certifications were not required. You need to look further into the chemical, pharmaceutical, and aviation industry for comparative technical and regulatory requirements.

    One issue that is critical is the concentration of safety and non-safety items in a nuclear facility in a relative small and compact unit. Individual aircraft and other facilities are smaller individual units that may or may not have similar safety related specifications. A commercial aircraft failure and cost of perhaps 20 to 600 lives with the current aircraft and with a cost of the aircraft at 10 to 300 million. As others have stated, the risk is low, airline travel remains one of the safest forms of transport. The nuclear risk measured in x to the tenth power (1 in a million or less). The quality program does not state or identify the required safety criterium, the safety analysis that is translated into an engineered facility does specify the values necessary to assure safety.

    While many will repeatedly say it is the quality requirements that drive the cost, as a nuclear quality professional I have never found any safety criteria in the quality program. The components are fabricated and facilities are built to engineered specifications, drawings and procedures derived from the safety analysis and facility reliability requirements. The procurement of the materials are written based on the engineering specification and drawings. The codes specified in the specification detail the required level of assurance for the items. Quality then verifies the equipment meets the specified requirement. Non-conformances require engineering resolution, not quality. Corrective actions on the process and management methods employed are the quality program specifics.

    So as a designer, when you tell the procurement engineer to obtain a part with the following specifications, please work with the quality to verify you get the part you ordered, to the requirements specified, with the assurance it was designed, fabricated and tested to meet the procurement order. When a part or item does not meet specification – it is the engineering specification or drawing that is to be resolved, repair, rework or reject.

  8. seth

    I would think you could consider natural gas generators as SMR’s. Factory built, delivered to sit by rail and bolted to a concrete pad. Basically a nuke without a pressure dome.

    No wonder they are so cheap.

  9. Engineer-Poet

    You know, there’s at least one way to set a floor on the target for reducing per-kWh radiation exposure:  if a coal or gas plant would expose the public to more radiation per kWh, further effort to reduce emissions from nuclear plants isn’t just pointless but counteproductive.

    One executive order to the NRC to balance their priorities against carbon fuel-related emissions would fix a whole lot.

  10. Robert Steinhaus

    The choke point in current new nuclear construction is not the cost of new reactors but rather the availability of new licenses.
    Only 4 new licenses for constructing new nuclear reactors have been granted by NRC in the last 30 years. Without a license to build from NRC, it does not matter what reactors cost, you will not get a chance to build any.
    We should reform NRC by bringing back balanced nuclear regulation such as was practiced in the first two decades after the dawn of the nuclear age when over 300 commercial, military, and research reactors were built. Without reforming NRC, the nuclear chokepoint stays in place, and none of the engineering or financial efforts we make to revive the technology will then make any difference.
    For more on reducing the construction costs of nuclear reactors .
    Dr. Bernard Cohen, “Cost of Nuclear Power Plants – What went wrong?” –
    (Regulatory ratcheting, quite aside from the effects of inflation, quadrupled the cost of a nuclear power plant).

  11. James Greenidge

    What I’d like to know is where is this written exemption of the EPA for the oil and gas and coal industries to produce health degrading emissions whose overt effects and consequences are hundreds of times the legislated tolerances of the minimum nuclear rad exposure in a local community? Why aren’t nuclear legal eagles hopping on this hypocrisy? Aside, I see no sin in creating dirt-cheap reactors if they pass safety specs muster. Though it’d be nice comfort, I don’t need an Abrams to cruise the Interstate. An Impala is safe enough. Antis just want to gold-plate safety enough to kill the build incentive. Lastly, the nuclear industry shouldn’t ever be mute about Fukushima; the silver lining in this dark cloud is brilliant! The antis worst nightmare didn’t happen three chances over in the rare worst nature can throw a set of old plants outside an asteroid strike! Not ONE death! Hey, try that on, Gulf oil rigs! Shot down the biggest boogeyman hovering over nuclear energy — and biggest excuse NOT to go nuke! This should be strutted out front like gangbusters on the PSA front! More nuclear education on TV and PSAs!!

    James Greenidge
    Queens NY

  12. Geoff Russell

    Thanks for a fascinating article and comments.

    Is the LNT standing in the way? I don’t think so. It’s just that nuclear authorities are sitting back and allowing the LNT to be taken far too literally. The regulatory authorities need to need to get out more. Consider. Alcohol causes cancer and the Australian Cancer Council (and others) quite clearly backs an LNT model: “Any level of alcohol consumption increases the risk of developing an alcohol-related cancer; the level of risk increases in line with the level of consumption.”

    But if somebody tipped a tanker load of alcohol into a city water supply, nobody would demand an evacuation on the basis of the number of cancers that would be caused if that amount of alcohol was consumed in normal ways. But this silliness is what the anti-nuclear movement does and keeps doing. I wouldn’t call this LNT, I’d call it LNT-silly.

    The Hoeve-Jacobson paper was admirably clear … LNT-silly predicts ~180 cancers in a vast population. But 150,000 people, destined for 50,000-60,000 cancers anyway had their lives torn apart in an evacuation which caused some 600 deaths. To the extent that regulatory authorities have a hand in evacuation decisions and standards then they are culpable for this suffering.

    Working backwards, once evacuation decisions are rationally made using comparative risk assessment, then the whole chain of risks can be reassessed.

    So the nuclear industry needs to be more up-front about comparative risks. And it needs to learn more about other cancer causes. e.g., The introduction of red and processed meat into the Japanese diet in the second half of last century has lead to about 80,000 extra bowel cancers EVERY SINGLE YEAR.
    How much radiation would it take to match that impact?

  13. Jim Hopf

    True, one thing we learned from Fukushima is that *rapid* evacuation is not necessary. Only I-131 is a potential problem over the short term, and that is controlled by short-term food restrictions, and shelter in place (perhaps with KI pills) at the very most.

    We should push hard on this, since rapid evacuation (and the possible impracticality thereof) is one of the major tools the antis are beating nuclear over the head with (e.g., talk of having to rapidly evacuate NYC as an argument against Indian Point).

  14. Robert Margolis

    True. It will be a challenge to convince the public as we will look like the proverbial barber recommending a haircut to the bald man ;-) I think that the best persuasion will be based on benefits rather than lwoer expected risks (though this will play a role).

  15. Robert Margolis

    South Korea has the misfortune of scarce fuel resources. LNG is expensive, so nuclear is more of a straight-forward solution.

  16. Cal Abel

    That is quite true that some level may be needed, but not a 10 mile EPZ. Additionally the evacuation can be done over the period of days, much like a hurricane and not require large infrastructure investments. Additionally it would allow people to return to their homes much earlier.

  17. Robert Margolis

    Nuclear costs in staff have gone down over the years as personnel needs have shrank. Plants requiring 1000 in the 80s now get by with 600-700.

    I can also understand local concerns. Even with better application of LNT, large reactors can still need SOME evacuation in a large accident.

  18. Jim Hopf

    One more thing going against nuclear, that is not fab QA, per se, is that strict (verbatim) compliance with requirements, as well as the setting of the requirements themselves, are not subject to (or tempered by) any sort of cost benefit analysis. In an earlier response (to Damon), I gave an example of how the fossil industry often avoids requirements even if cost/benefit analysis shows that the requirements is justified by leaps and bounds. With nuclear, the opposite is usually true, with many requirements being imposed reagrdless of cost (i.e., even though the costs are orders of magnitude larger than the benefits).

    I’ll illustrate this with a rather provocative example. I’ve inquired what the cost vs. benefit tradeoff would be of running the Crystal River plant *in its current state*, versus the other two options of repairing the shield (containment) building or closing the plant and replacing it with fossil generation. Since nobody (e.g., NRC or the utility) have shown any interest in performing such an evaluation, I will do so below. Note that this is a rough (order of magnitude) estimate, based on rough guesses for various inputs, and is not extremely accurate.

    The current goal, of current regulatory policy for currently-operating reactors, is a significant release probability of on the order of 1.0E-5 per reactor year. Let’s assume that if the plant were repaired, that’s what its release frequency would be. I will also assume that, in the un-repaired condition, the release probability increases by an entire factor of 10, to 1.0E-4 per year (probably a conservative assumption – it would be nice if someone bothered to do the actual PRA, the fact that nobody has being my main point).

    For the impact of a major release, I will conservatively assume ~100 eventual deaths, based on conservative, LNT-based estimates from Fukushima (despite the fact that three cores, vs. one, melted down there). I will also conservatively assume an economic cost of ~$100 billion. The costs estimates for repairing the Crystal River plant have ranged up to $3 billion (for reasons I can’t fathom, don’t get me started….) I’ll assume $2 billion for the analysis. The plant would have ~20 years of operation left, in an extended license (I think).

    Now let’s do the math. Let’s conservatively neglect the probability of release for the repaired condition. In the unrepaired condition, we have 20 years of operation with a 1.0E-4 per year chance of significant release, resulting in a total chance of release (over the remaining ~20 years of operation) of ~2.0E-3.

    In terms of pure economics, repairing the plant would spend ~$2 billion to avoid a 1 in 500 chance of a cost of ~$100 billion. Thus, it appears that the economic costs (of repairing the plant) exceed the economic benefits by a factor of ~10.

    Note that this does not even touch on the argument/fact that a lot of the “costs” (for Fukushima, etc..) are due to LNT assumptions and radiophobic reactions/policies. More rational policies would result in much lower costs (smaller to non-existant evacuation/non-use areas, much less thrown out food and restrictions on farming/fishing, etc…).

    Finally, in terms of public health/mortality, repairing the plant would spend ~$2 billion to avoid a 1 in 500 chance of a release that may cause ~100 eventual deaths (the estimate of 100 most likely being significantly high). That amounts to ~$10 billion per life saved. That’s right, ~$10 billion per life saved, orders of magnitude more than what is being asked for other industries. In the example I gave ealier, the soot (particulates) rule being considered by EPA is asking the (largely coal) industry to spend ~$5,000 per life saved. It’s encountering significant political resistance…..

    As for the 3rd option of closing the plant and using fossil fuels instead, not only would it involve greater economic costs, than operating the plant in its current, unrepaired condition, but it would also pose greater public health risks (than even a reactor whose large release risk has increased to 1.0E-4).

    I realize that my analysis is extremely rough and may be in (some degree of) error. I am not taking the position that, based on the above analysis, the Crystal River plant should clearly be operated w/o repair. What I’m suggesting is that it warrants looking into. A PRA analysis should be done. And yes, I’m suggesting that, if a detailed, accurate and objective analysis shows that the costs of repairing the plant exceed the benefits, the repair should not be required. No requirements should be above the perview of cost/benefit analysis.

  19. Robert Margolis

    ACI 319 is for nuclear safety grade concrete structures, so fossil plants are unaffected. The question is whether is arose from regulatory ratcheting, the loss of skills from lack of construction, or some of both.

  20. Jim Hopf

    It turns out that they’re having the very same problems with the (simple, passive) basemat at the Summer project as well (see below):

    Much like Vogtle, it involves non-compliant rebar. Thus, it doesn’t appear to be an isolated incident; more of a pattern, with local contruction companies having a real hard time with compliance.

    Is it an NQA-1 thing? The article refers to non-compliance with American Concrete Institute Code 319. I actually thought that the ACI codes were not nuclear specific, but applied to all construction projects. Is that the case? And again, I must ask, if they had a similar issue occur at a non-nuclear plant construction site, how would they respond? Would it be any different?

  21. Gunnar Littmarck

    Thanks for a thoughtful post.

    This is true for the U.S. in terms of policy, but for Sweden it is politically difficult to build new GenIII + with cheap and effective regulatory frameworks, perhaps GenIV can pave the way for a policy change?

    I think mass production of smr get started in the next 10 years, humanity in the new fast-growing countries have such a desperate need for energy, then countries like U.S. and Sweden can buy complete reactors where production takes place under as good control as significantly more complex aircraft.

    To sad that Sweden get more or less out of nuclear industry after Chernobyl, the nuclear industry was too poor rhetoric, a good public education would instead put Sweden today as a leading nuclear power developer.

    Therefore, it is important to reach the voters, not the reactor physicist.

    It is much easier to scare people and paint threats, than to create confidence and hope for the future.

    This uses organizations such as Greenpeace, WWF with more.

    Reactor Design with extreme security MSR in enhanced stable bedrock should certainly not get tougher requirements than aluminum industry, chemical industry, etc. with large potential risks.

    “Walk Away Safety” 4S should not have harder requirements than the risk potential.

    South Korea is a good study example because they have copied the U.S. regulatory but since last summer they build APR 1400 pairs cheaper than coal, so even if coal were free, it would be more expensive for Korea due to expensive logistics.

    My best//gunnar

  22. Robert Margolis

    Have the French performed a similar number of power uprates and SG replacements as the US? Perhaps this work and the navy nuclear construction has helped the US keep some of its skills. As for gas, even accounting for QA differences it is still relatively simple. Nuclear fuel does require a little more “gussy up” than gas or even coal…

  23. Jim Hopf


    I concur about SMR factories, and will discuss that point in a later post on SMRs. Bottom line is that I think an SMR factory, with an assembly line that is just making copies of the exact same thing in a controlled environment, and has a set of permanent employees that specialize in that task, is one place where impeccibly strict (e.g., NQA-1) fabrication QA requirements can be (practically) complied with. Hopefully, this approach would result in the dramatic reduction (or elimination) of “nuclear grade” activities on site. Again, our experience seems to be showing that NQA-1 requirements and field work (construction) do not mix. (Since local suppliers can not get their arms around the requirements.)

    You raise an interesting point about the possible lack of large construction expertise in the US (vs. China, etc..). Marty alluded to the same thing earlier, suggesting that large non-nuclear projects don’t have it much better. I suppose the question is how much of nuclear’s cost problems are due to this, and how much is due to unique (and unprecedentedly strict) nuclear QA requirements? I would like to hear people’s opinions on that point.

    I will offer two observations. One, the French appear to be having even worse construction problems/overruns (with their EPR) than the US is (with the AP-1000s in the South). Is this because the French have also forgotton how to build anything?

    Two, US lack of large construction expertise does not seem to be affecting our ability to build natural gas power plants (at a cost of only ~$1,000/kW, vs. ~$5,000 for nuclear). This is despite the fact that the AP-1000 was supposed to be simpler and cheaper than the last generation (you know, “way fewer pumps and valves…”) This is of critical importance, gas being nuclear’s main competitor in the future, and THE source of it’s current lack of success/prospects.

    The question bears repeating. Why are gas plants so much less expensive to build than nuclear plants (in the US)? It’s that basic question that I’m seeking answers for. Is it a fundamentally expensive design? Is it a plethora of expensive safety systems? Is it a lack of construction expertise that somehow affects nuclear but affects gas plants to a much smaller extent (if at all)? Or is it nuclear’s unique QA requirements?

    A related question is how could price estimates from just a few years ago be so much lower (more than a factor of two). How could they have gotten it so wrong? (Were they being dishonest?)

    One final “poll” question for everyone. If it was declared, right now, that Ap-1000 plants (which are already designed and licensed) will be built using the same construction/fabrication QA requirements that apply for US natural gas plant construction, how much less expensive would the plant (construction) be? I’d like to hear some opinions.

  24. George Carlin

    The refurbs that have proceeded so far in Canada have been first of a kind using workers with little to no experience. But the fact that these major refurbishments are required after such a small number of operating years is troublesome. This is probably why OPG is looking into building an AP1000 instead of a CANDU EC6 for the new reactors that will be built at Darlington.

    If OPG chooses the AP1000, does that spell the end for CANDU reactors?

  25. Jim Hopf


    Either that or SMRs, perhaps… Personally, I’m a fan of NuScale. The core has only 12 half-height PWR assemblies!! This is smaller than the dry storage canisters/casks that we make. US industry should be more than able to do that.

    I must say, though, that my impression CANDU operating experience is not that high. Unlike PWRs, which can operate 60-100 years with only some relatively straightforward component replacements (steam generators and vessel heads), CANDU’s apparently require a major refurbishment after only 25-30 years. And the experience with refurbishments hasn’t been that great, with large cost overruns and overall refurbishment costs that exceed what one would think would be a reasonable cost for a whole new reactor.

    As with PWRs, though, in other parts of the world (as opposed to Canada), everything just goes a lot smoother and is a whole lot cheaper, for some reason.

  26. Jim Hopf


    I understand that design, analysis and licensing costs are also a major factor (the “analysis paralysis” I referred to in the post). Indeed, it has struck me how the mere recovery of planning and licensing expenses have become important enough to be a major political/legislative issue in some states (e.g., Missouri and Florida). We’re talking about over $100 million dollars, and years of effort, for a mere S-COL application in some cases! I could get behind legislation telling NRC that they’ve got ~$50 million and 1 year to approve S-COL applications (set the scope of review accordingly….).

    I also agree that perspective on radiation risks and impacts would, theoretically, allow less expensive reactor designs.

    But I’m not sure I get how the analysis/licensing rigor (or LNT for that matter) as opposed to NQA-1 fab requirements, would affect the cost of a given component or the number of willing suppliers. Are you saying that nuclear plant designs require *types* of components that industry does not usually make, and that that is the cause of the extra difficulty and expense? Furthermore, are you saying that the only reason nuclear plant designs have such components is due to the excessive effort to avoid/limit any releases (due to LNT and radiophobia)?

    My impression has been that, due to unique fab QA requirements, even the same thing (component) costs several times what the commercial (or non-nuclear-industry) grade version of the exact same thing. I recall you giving one example of this awhile back (involving a component with a “phonographic surface”).

    Also, as I state in the article, it seems to me that all the cost overruns we’re seeing are specifically due to difficulties meeting fab QA requirements. As you were saying, if the plant designs require a unique type of “special” component that would hard to make, you’d think that the fabricators would say so up front, (or decline to bid) and the cost would show up in a high initial cost estimate, as opposed to an “unexpected” overrun. Instead, the suppliers thought that they could make the components for a reasonable cost, but had no idea what they were getting into with respect to fab QA (paperwork) requirements (as shown by the example article I linked).

    Consider the AP-1000. It probably took altogether too much effort and analysis, but it has been licensed and certified. All that’s left to be done is build copies at various sites. At this point, how would the requirements for excessive analysis and overly-safe design affect things moving forward (and cause project cost overruns)?

    My proposal is that once a reactor design is certified, its construction should be governed by the same fab QA requirements that apply for non-nuclear plants. Isn’t it true that this is the primary thing that can be done, at this point, to reduce AP-1000 construction costs?

    As for reducing nuclear requirements overall, based on the fact that radiation (and meltdown events) are not nearly as seriously as people think (or thought) they are, that’s going to be a much more difficult political accomplishment. The concept that meltdowns are simply “unacceptable” is pretty deeply enshrined. Note how NRC is using Fukushima as an excuse to tighten regulations EVEN further, arguing that large scale land contamination is “unacceptable”, despite their own acknowledgement that this worst-case event had essentially no public health consequences. I think an argument that fab QA requirements aren’t yielding much bang for the buck in terms of safety (i.e., *avoiding* large releases) may be a much easier sell, politically.

  27. Josh

    USS Thresher’s physical defect was only one part of the picture: procedure at that time dictated that steam valves be shut, essentially disabling the propulsion plant from pushing the ship. The solution was also twofold: SUBSAFE, which improved QA in Submarine components, and a new recovery procedure which allows the propulsion plant to answer demands with residual steam after a reactor SCRAM.

  28. George Carlin

    Robert, I am currently attending the Royal Military College of Canada where one of the remaining SLOWPOKE’s is located. It is quite a neat little reactor, it is almost completely automated, it just sits at the bottom of the pool and runs. I fear with Defense budget cuts in Canada, leading to big research cuts at RMC, that the RMC SLOWPOKE may be on its last fuel load. I do not see the school spending the money to refuel it. It is a tragedy since it is quite useful for neutron activation analysis research etc..

    I have been working on a project for the past 18 months to develop an aqueous homogeneous reactor with the relative dimensions of the SLOWPOKE, as a possible replacement. The main feature of switching to the liquid fuel would be relatively easy isotope separation using LEU (meaning revenue for the reactor program). The idea is similar to what it was for the SLOWPOKE: install it in a number of schools and hospitals except instead of providing heat it would provide molybdenum.

    It is a neat concept!

  29. Engineer-Poet

    We have lost our manufacturing edge in the U.S. No longer do we get large forgings, steam generators or turbines on shore.

    This is a very big deal, and I’m glad someone mentioned it.  Having to go to Japan or S. Korea to have RPVs forged is not something that ever should have happened.

    This is also why I think any rapid expansion of nuclear in the USA in the near future should use CANDU, because forging pressure tubes is not as demanding as a much larger pressure vessel.  Compared to that savings, the work for chemical engineers building D2O plants is small potatoes.

  30. Robert Margolis

    Lead is also an LNT material, yet it is ubiquitous globally in car batteries. Nuclear had the unfortunate circumstance of having LNT imposed PRIOR to its expansion. Lead is accepted precisely because it is familiar (I drive a car with a lead battery, so lead must be safe). I once interviewed for AECL trying to get involved with the Slowpoke reactor precisely because the plan was to deploy them in neighborhoods or large buildings for hot water (elections killed the project, so I went to Korea instead…).

    If reactor physics would allow for even smaller reactors using low-enriched fuel, we could have better deployed nuclear energy so that it would have the familiarity with the public. The current large reactors run by large fleet utilities does not help to change the public perception that nuclear reactors are dangerous exotic machines that require vast regulation and tons of overpaid experts JUST to make electricity. We need to bring nuclear power to the public (and convince them that electricity is not something that merely comes out of the wall socket…).

  31. seth

    China of course is having no problem building its nukes on time and on budget even after the year long FUKU stoppage. I’m sure ISO9000 is just fine over there.

    Fact is the Chinese are doing far more concrete and steel construction than in the US, and are skilled in modern technique not the last century stuff done in the US. A 30 story hotel that takes years to build in the US, can be build prefabbed in China in 2 weeks .

    China’s leaders are engineers, ours are attorney’s skilled at one thing – stuffing their pockets with campaign donations. Nary a one could change a tire to save their own lives.

    Nukers should be happy the Chinese are around to shame us.

    That said we are still very skilled at high tech manufacturing airplanes/autos/military equipment – same sort of tasks needed in a SMR factory. Even if we required mil spec for the SMR’s we should be competitive

    Be nice if the Obama could be persuaded to spend a tiny fraction of the R&D and subsidy on advanced nuclear that is wasted by the DOE on nuke weapons, and wacky tech like wind/solar/carbon capture.

  32. bill eaton

    Thanks for the insightful article, Jim. I think you hit one mark with respect to QA requirements and the related costs of fabricating and supplying components. The overly broad application of “pedigree” does add considerable cost, and a lack of alternatives, to the supply chain. I think some of the previous responders are off the mark in their implied arguments that we should abandon some aspects of redundancy or safety system complexity because the cost of fatality or injury is skewed with nuclear being penalized. That is a no-win argument in my opinion. And, to add to the debate perhaps, I would like to put a slightly different spin on the issue of construction cost.
    As we blame the NRC for slowing things down, the use of LNT methodology to define radaiation risk, or the several other “targets” that nukes like to put on the debate table, including the unfair emissions playing field that fossil enjoys, let’s look at the reality of the investment/build process. The fact that nuclear has always been more expensive to build than coal or gas did not stifle the industry way back in the 60’s and 70’s. Even though we were much more expensive to build, the economics were overwhelmingly favorable because the assumptions of market and pay back were favorable. I would hazard a guess that almost half of the nukes in operation today are merchant plants with no regulated cost recovery that started out as rate recovery plants. For a merchant plant the capital costs are just as important as operating costs.Most of the remaining PUC regulated cost recovery plants are in the South, where you see new construction. Had the original industry faced an open market- merchant fleet economic model I doubt several would have been built. So, investors today are faced with significantly different risk decisions. The other factor, which is a Catch 22, is that when fewer plants are being built the capability and efficiency of construction forces are lacking. This is further complicated by a general lack of skilled workers in the U.S. Most nuclear maintenance and construction firms have difficulty mustering even a 50% repeat or return ratio for construction or maintenance and refueling work. The new plants are literally being built with first generation nuclear workers. I am not surprised by slow pace and cost escalation in that environment. Added cost is also related to cost of components and competition from non-U.S. projects. We have lost our manufacturing edge in the U.S. No longer do we get large forgings, steam generators or turbines on shore. Only now is the glimmer of retooling and heavy manufacturing coming back into the U.S. It’s easy to blame design concepts and regulation, but unless we somehow educate the public, all is moot. The design and regulatory requirements are truly symptomatic of our collective fear of nuclear technology. Why does it always come back to education?

  33. Cal Abel

    Navy nuclear power has several different levels of quality control. They are entirely dictated by NAVSEA 08 (Naval Reactors). NAVSEA 08 has complete autonomy under the auspices of the DOE and is not required to comply with 10CFR50. Although 10CFR20 is still applicable. Basically, you can do whatever you want as long as you don’t mess up. Navy requirements are actually more stringent than commercial standards especially when coming to ALARA.

    Nuclear QA is a little moire complex. We have four levels of non-nuclear QA, Level 1 (high press/temp/compressed air), oxygen (oxygen systems preventing hydrogen explosions and oxygen fires), Scope of Certification (for protection of divers), and SUBSAFE (dealing with safety and recovery of submarines). Then you add nuclear on top of it. We have nuclear level 1 systems, nuclear SUBSAFE, and nuclear level 4 (non-level). Looking at a 700# air cartridge valve, the difference in cost between the nuclear level 1 and the plain Jane level 1 was a factor of 2 in cost. Additionally we were restricted even further with the lubricants that we could use while installing these valves increasing the risk of galling and requiring more frequent replacement because the o-rings would embrittle faster in the nuclear component. The entire system (ship/submarine) was made less reliable requiring more frequent repair with a lower OPTEMPO all in the name of ostensibly saving a few mrem at much greater cost.

    I want to stress again, the constraint that is forcing this ridiculous level of QA and obtuse maintenance practices, is as Rod says, nuclear exceptionalism. What makes nuclear exceptional is the radiation. What makes the radiation so bad is LNT. LNT is the sole justification of ever increasing regulatory burden inside the military and outside. IT is what makes nuclear cost so much. If you try and tackle the costs without first addressing LNT then all of your actions will fail and you will be denigrated a hater of human life because you are not tackling that last marginal mrem regardless of the cost. LNT allows the actual risk of radiation to be removed from being in context of other risks. Risk has costs.

    LNT hampers the use of nuclear energy in more surface combatants because of the O&M and personnel costs. This limits our ability to deploy combatants as they are needed and are often tied to vulnerable supply chains including fleet oilers and frequent underway replenishments which are a very high risk evolution, ships frequently collide. I had to place people under disciplinary review because they could not read TLD’s as effectively as the procedure dictated. I had my ORSE grades negatively impacted because somebody had trouble reading a worthless and obtuse procedure on how to read a TLD, or that we didn’t put enough administrative oversight into tracking every last damn mrem. That my guys didn’t minimize their exposure during maintenance evolutions that would result in a 1/2 mrem of total dose savings. I refused to drink the koolaid and took those comments so I wouldn’t beat my guys up, instead I made them fix things and get what little precious sleep they could. That was hard enough.

    By continually focusing on what is not important we loose sight of what is important. If we want to make a change we have to push back at the faulty/bad/deceptive science that allows the justification of ALARA below some threshold. Without doing this the insanity will continue. Our actions as an industry civilian and military are based on the wrong foundation, because of this we are exhibiting the wrong action. If we presume to affect the right action we first have to establish the right basis.

  34. Rod Adams

    Jim – speaking strictly for myself and not my employer, I can testify that you are on the right track, but your focus on the way that QA affects fabrication expenses is too limited. The prevailing nuclear exceptionalism attitude that you identified adds tremendous costs to the task of designing and licensing, even before you think about fabricating components.

    As just one tiny example of the way that nuclear QA wastes my rather well paid time, I once spent close to an hour trying to convince a room full of other similarly well paid people that the word “accept” is simply another form of the word “acceptance”. I wanted to drop the effort after 5 minutes, but I realized what it would mean to the cost of reading and following procedures if I could not ensure that my basic point was understood.

    One of the reasons we have such a limited base of suppliers is that most successful manufacturers refuse to do business in special ways for individual customers, especially those who want to purchase a small number of units. I used to be a manufacturer; I fired a number of potential customers who could not seem to get that being treated special added substantial costs and that we could not make any money if they did not want a reasonable sized production run. It wasn’t worth the effort. The customer is not always right.

    Cal is correct that one of the major issues we have to address to get rid of the especially high cost of nuclear is the notion that radiation is so hazardous that it requires extraordinary efforts. We also have to recognize human nature, however, and understand that there is a lot of opposition associated with any effort that might reduce cost.

    As I try to remind people on a regular basis, accounting is a double entry discipline. For every customer that has to pay a higher COST, there is a supplier who receives higher REVENUE. On Atomic Insights, I have a regular commenter named Bob Applebaum who shows up every time I publish an article about the absurdity of the Linear No Threshold dose response assumption.

    Applebaum was the founder of a Memphis-based radioactive waste handling company called RACE. He sold that company to Studsvik in 2006 for $36 million. The company’s revenue of about $40 million per year was almost completely dependent on providing services that would not have been required if a more reasonable regulatory model than the LNT was in use. This link to Bloomberg BusinessWeek indicates that he is still involved in RACE and still has a strong financial motive for defending the LNT.

  35. Jim Hopf


    Thanks for your excellent example that illustrates the point I was trying to make.

    I had no idea that the price industry is willing to pay for ALARA has increased so much. Pretty disturbing. Even LNT predicts about one death per ~2500 man-Rem. Thus, spending $25,000 per man-Rem amounts to $62.5 million per life saved (if you believe LNT!), which is far more than what other industries are asked to spend on safety.

    Meanwhile, on the fossil side, an EPA proposal to limit soot (fine particulates), which is estimated to save 40,000 lives and $9 billion annually in health care costs, while only costing indsutry $53-350 million, has drawn massive political opposition and may not even be implemented. (NRC regulations never spark any significant political opposition.) Astonishingly, this works out to only ~$5,000 per life saved!!!

    And we’re only talking about what our industry spends on ALARA. Given the very low probability of severe nuclear accidents, and the low public health consequences, I’m pretty sure that what the industry spends on nuclear safety (nuclear-grade QA, in particular) runs well into the billions of dollars per life saved. Meanwhile, $5,000 is too much to ask of the coal industry.

  36. Jim Hopf


    Given the lack of deaths and public health impacts of even the worst-conceivable meltdown event, the consequences of nuclear accidents are essentially purely economical. On top of this is the fact that in the case of a nuclear accident, the utility will be asked to pay massive compensation to local people, as well as paying for cleanup and plant decommissioning. Thus, it is not like the fossil power generation industry, which gets to routinely emit massive amounts of pollution that causes tens of thousands of annual deaths in the US alone along with global warming, without paying any compensation to anyone, ever.

    Based on the above, I almost wonder why prescriptive govt. (NRC) regulation is even necessary. You would think such decisions could be left to the nuclear industry and its insurers, since (after all) they will be paying the entire sum required to make the public fully “whole” in the event of even the most serious accident.

    Just to clarify, imagine a case where the nuclear industry would have to not only clean up and decommission the plant, but it would have to buy all the land that is rendered unuseable and compensate anyone who has to move. In such a case, they will have made the public “whole” and will have fulfilled all their responsibilities. Given this, decisions about how far to go (how much to spend) in the persuit of safety would be up to the industry and its insurers. Hopefully, it would lead to a more lvel-headed approach that does not waste money on things that do not provide a significant, tangible safety benefit.

    In other words, I (personally) would be willing to consider trading the Price-Anderson Act for significant reductions in prescriptive regulations/requirements by NRC. Such a proposal is not “outrageous”, given the lack of public health consequences, and the fact that the consequences (costs) are essentially all economic.

  37. Jim Hopf


    I’m planning on a later post that specifically deals with SMRs, including some of their advantages and some of the issues they face. One of the key issues will be O&M costs, including staffing requirements. If NRC imposes all the requirements they do for large reactors, then SMRs will be killed by economy of scale.

    One would like to think that they would give credit for the fact that (many) SMRs are almost meltdown proof due to fundamental features such as small size, geometry and materials. That along with the fact that due to their much smaller core inventory, and the fact that the fuel would not get nearly as hot even in a meltdown scenario, the potential release (i.e., the “source term”) would be orders of magnitude smaller than that of a large LWR.

    The (whistful) notion would be that due to relative lack of risk (both probability and potential consequence), many of those requirements, including staffing, would be greatly reduced. I could see a site with a large cluster of SMRs, having one central office with a total staff perhaps equal to that of one large plant. But how would you get started (i.e., avoid needing that huge staff before even the 1st module is placed).

    As for non-nuclear plants, your experiences are just what I’m hoping to learn about. I acknowledge that I may be wrong about how much “easier” things are on the non-nuclear side.

    With respect to my policy position/suggestion, all I’m asking is that nuclear be held to similar construction QA requirements that non-nuclear plants are (once the design is thoroughly reviewed). I’m not suggesting we totally blow off fabrication QA, or (necessarily) that we just use commercial grade (off the shelf) components w/o dedication. I’m just suggesting that we do what everyone else does (in the contruction of important, non-nuclear industrial projects). For me it’s almost simply a matter of fairness, especially given that I reject the notion that nuclear is uniquely hazardous, or that there are no other industries where the consequences of component/construction failure are as serious.

  38. Jim Hopf

    Well, that was back in 1963. I’m sure that QA requirements/standards are nothing like they are now. Also, I should probably know this, but are military nuclear components/activities (such as subs) under the juristiction of NRC, or does the military itself call all the shots? Was it then? Is it now? Of course, back then it would have been the AEC.

  39. Damon Bryson

    As a 20-year nuclear industry veteran, I have not doubt that your hypothesis is essentially correct. The QA requirements which were properly interpreted back in the 1970s have been increasingly narrowly interpreted in recent years, to the detriment of the nuclear industry. I am not just referring to the economics of nuclear, but the safety as well.

    As an example, consider the Keowee Hydro Station, which provides emergency power to the Oconee Nuclear Station. Back in the 1990s, when cheap and reliable computer control systems became available, Duke retrofitted their fleet of about 25 hydro stations with remote computer control systems. Of course, these control systems did not meet nuclear QA requirements, so Keowee was the only hydro station which was not upgraded. Within a few years, it became obvious that Keowee was not only the highest cost hydro station, it was also the LEAST reliable. The QA system of good intentions had unintended consequences that actually reduced the safety of a nuclear plant. This is a good example of the drawbacks of the nuclear QA system.

    I do agree with some other commenters that the LNT approach to ALARA is also a major impediment. In the 1980s, we were willing to spend $2500 per person-rem to prevent radiation dose. In the 1990s, that figure went up to $25000. I have not seen a more recent figure, but I suspect it is approaching $1 million in some cases. Certainly our society has become more risk-averse over the years, but clearly this is overkill when any dose under 50 rem/year has an insignificant health impact.

  40. Cal Abel


    I want to push a little farther as to why the “nuclear way” is the way it is. There is something that nuclear possess that other industries do not. That is radiation as all regulations are based on LNT there is no safe level, so there is no end to the justification of additional cost, the additional documentation, etc. Without first addressing this issue there can be no headway in making nuclear construction and design standards more rational and consistent with other industries.

    If you want to reduce costs of new nuclear, then we need to address LNT. Radiation is no different than other industrial hazards once we accept that there is a safe level then we can limit the regulatory overreach.

    It will not be fast going and utilities and vendors are going to have to “man-up” and start filing lawsuits against the frivolous regulation. It will take time and a lot of capital but is not impossible. It has to begin with removing LNT.

  41. Joffan

    The NRC is no doubt a body filled with many dedicated and professional people, but their mandate is totally lopsided. They have no interest in better reactors or cheaper reactors (or how the two combined make for safer reactors in future). They have no interest even in the benefits of existing reactors compared to other power sources.

    The NRC document I think should be a touchstone for future regulation is SOARCA, the study of the public consequences of a reactor accident. They are essentially nil. NRC should acknowledge this reality and stop imposing ever-stricter requirements on reactors – like the extreme obstacles to restarting San Onofre, for example – and start enabling enhancements of the sort that Jim suggests – investigating the safety implications of using more standard components, and allowing it if they are still within that consequence envelope. The use of standard components does NOT have to be as safe or safer than specialist components – it only has to be safe enough.

    Put the “Reasonably” back into ALARA.

  42. Marty Kwitek

    This is the kind of article I like to see, because at the end of the day, assuming safety and environmental compliance, it’s about money. I am glad you referenced the SMR initiative, because since leaving the nuclear plant world, I have come to understand that the marketers of our product want:
    • On/Off Capability
    • Infinite Ramp Rates
    • Zero Firing Costs
    The large core reactors do not do this well – the renewables and gas fired units are the most maneuverable and they are the competition of the future, with or without a carbon tax.
    Second and equally critical are the O&M costs – capital can be recovered and passed along to the ratepayers, but variable O&M can take a plant out of the market as rate backpressure builds in the state public service commissions. Myriad program additions continue to build staff sizes and embedded contractor ranks. Even as U costs fall, eventually the breakpoint is reached and licensed plants cannot compete outside of the regulated world and will shut down under their own weight. Those of us who weathered the TMI, Chernobyl, and now Fukashima changes understand the value of most new programs, but the overhead is becoming excessive.
    My final comment gets right back to your thesis of QA/QC. Anyone with recent fossil construction experience will tell you that domestic suppliers are few and far between. Quality of production and fidelity of pedigree are challenging at best. Working in the international market for warranty and technical support can be an exercise in diplomacy. Parts lead times are ridiculous, and a solid commercial grade dedication staff is vital. The supply side of the equation will continue to be an anchor unless and until the proposed renaissance becomes reality and there is a strong incentive for quality Appendix B commitment.

  43. John S. Frick

    Until last year, with the licensing of 4 reactors, all 104 reactors were in essence licensed by the AEC. The NRC was formed to slow the nuclear expansion to a halt through regulation. The path forward is not with light water reactors. As Alvin Weinberg so aptly stated, “If your reactor needs an Emergency Core Cooling System, then it is not safe enough”. The Prisim reactor and Molten Salt reactors have been proven to not need an Emergency core cooling system. In case of an accident, each of these reactors directly cool to the ultimate heat sink, the atmosphere. However, this obvious solution is lost on the NRC. They state that they will not seriously consider any reactor design that is not water cooled and moderated for the next 10 years. The regulator themselves block the path toward truley safe designs.
    Still don’t believe me, then consider that very little progress has been made since the early 70’s. Weinberg’s Molten Salt Reactor and EBR -1 and 2 were established designs before the NRC was formed in 1975. So was the NERVA rocket engine and the Molten Salt reactor powering a Strategic Bomber. How much inovation has occured since then? How many reactors have been decommissioned verses new reactors built. Now we are focusing on High Temperature Gas Cooled Reactors. Because of their very low power density the reactors are large in comparison to their MWe. Since costs scale to the 3rd power of volume, these reacotrs are going to be very expensive due to size.They will also consume much of the Strategic Stockpile of Helium. Leaks in the recuperators and reactors will make long term operability a serious concern. Obviously this is not the right direction!! Molten lead and molten salt reactors incorporate both high power density and intrinsic safety. This is the true direction toward lower cost and justifiably lower QA costs!
    There is only one obstacle preventing the implementation of this solution. As a result, further development of Nuclear Power may have to occur off-shore.


    In 1963, USS Thresher sank in a flooding accident that in no way was caused by the reactor. It was, however caused by inattention (lack of QA, or at least quality control) to the quality of silver-brazed seawater piping systems. As you suggest, the question “How safe is safe enough” has a component question, “How high does quality need to be?”

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