Cost/Benefit Analyses of Nuclear Requirements

By Jim Hopf

DC PerspectivesIn this post I will expand on some of the themes I’ve been discussing in several previous posts—concerning what’s really needed to bring down nuclear’s costs, allow it to grow in the future, and contribute to reductions in CO2 emissions and air pollution.

In January, I discussed what’s driving escalating nuclear plant construction costs and what might be done to reduce those costs. In March, I discussed how some of those same themes may apply to small modular reactors (SMRs). In June, I discussed how the impacts of increased fossil fuel use are not considered when promulgating strict nuclear regulations, and when holding nuclear plants closed while all potential issues are resolved and corrected.

There have been some new developments that touch on those themes.

Questions about filtered vents and cost/benefit analysis

Recently, the Republican house committee chairs and senate committee ranking members were questioning the U.S. Nuclear Regulatory Commission about a (potential) requirement that some boiling water reactor plants install cesium vent filters. The legislators questioned whether or not the filter requirement passed cost/benefit analysis.

I haven’t been able to find conclusions of any such cost/benefit analyses for the filters (e.g., a cost in dollars per life saved, etc.). However, my reaction to the articles was that there are many NRC/industry policies and regulations that clearly would not pass any kind of cost/benefit analysis. I discuss several requirements and practices that I doubt are cost effective in the earlier posts linked above. My own back-of-the-envelope calculations suggest that many nuclear requirements amount to many billions of dollars per life saved; orders of magnitude higher than the standards applied to most industries.

What allows this? Here is the key point. The NRC only has to consider costs (i.e., do any kind of cost/benefit analysis) when it seeks to apply backfit requirements to existing, already-licensed plants. In all other cases, such as the establishment of requirements that will apply to new license applications, the NRC is free to use its judgment and does not have to perform any kind of cost/benefit analysis. The filters would be a backfit requirement, so cost/benefit analysis is being discussed.

This is in stark contrast to how things work on the fossil side, as I understand things. Whenever the U.S. Environmental Protection Agency proposes air pollution regulations, it always has to perform a cost/benefit analysis to justify it. Requirements that do not pass cost/benefit analysis (i.e., would cost more than a few million dollars per life saved, I believe), are not even considered. In many cases, even policies that do pass cost/benefit analysis (by a wide margin) are still politically blocked, and do not proceed.

Here’s an example of a proposed EPA soot rule that seems to pencil out to only on the order of ~$10,000 per life saved, but may still be delayed or even blocked due to political opposition. And, of course, even new EPA regulations that go through are not applied to the oldest, grossly-polluting coal plants because they operate under a grandfather clause to the (1970!) Clean Air Act. This clause almost seems like blanket immunity to any backfit requirements, regardless of what cost/benefit analyses say (if I understand it correctly).

Senate questions for MacFarlane’s confirmation

More recently, those same Republican congressional committee leaders submitted a long list of questions to NRC Chair Allison MacFarlane as part of her re-confirmation process. In the “Economic Consequences” section of the questions document (just before Question #27), reference was made to a recent NRC policy decision that states:

“The Commission finds that economic consequences should not be treated as equivalent in regulatory character to matters of adequate protection of public health and safety.”

In the answer to Question #31, MacFarlane states:

“If the NRC determines that regulatory action is necessary, it will then consider costs, unless the Commission has determined that the proposed changes are necessary for reasonable assurance of adequate protection of public health and safety and the common defense and security.”

and goes on to state:

“Where the proposed NRC regulatory action constitutes backfitting but is not needed for adequate protection, then the NRC first determines whether the proposed regulatory action provides a substantial increase in protection to the public health and safety or common defense and security. If there is a substantial increase, then the NRC evaluates whether the costs of the regulatory action are justified…”

In other words, as I said above, the NRC only considers cost (and performs any kind of cost/benefit analysis) if a backfit requirement is being proposed. For all other requirements, the NRC is free to apply its judgment, and can pass any regulations it likes, regardless of cost, if they deem them to be necessary for “adequate” public safety/protection.

Also of note is how the Republican ranking senate committee member said that he “applauded” the NRC’s ruling (that cost is no object) in the paragraph before Question #27—this being the same party that opposes EPA air pollution regulations no matter what cost/benefit analyses say (that is, no matter how large their benefit and how little the cost, with the soot case I gave earlier being but one example). Thus, it appears that both major political parties fully concur with the policy of cost being no object, and cost/benefit analysis not being necessary, for anything other than backfit rules. For the nuclear industry only, that is, in stark contrast to fossil fuels, and other industries in general.

Technical solutions to political/regulatory problems?

Many people are hopeful that advanced reactor technologies (e.g., SMRs, non-light water reactors, etc.) will result in lower nuclear plant costs, since they will be inherently safer and less complex, and will require less complicated safety systems. This has yet to be demonstrated (of course) and I’m not sure that it will be the case.

These plants will likely give up power density and economy of scale. What will they get in return, with respect to economics? Imagine that they designed a reactor that, due to fundamental geometry, size, materials and physics, could not melt down, or could not ever produce any significant release. Could you imagine the NRC classifying all the components of that reactor as “non-safety-related” with respect to fabrication QA requirements? My guess is that full NQA-1 fabrication QA requirements would still be applied for most components. There would also be little relief in operating or staffing requirements. The reason will simply be that “it’s nuclear” and that’s how things are done in our industry. Security and emergency planning requirements would also not be relaxed (much) despite the much smaller- to non-existent potential source term. Unless credit is given for these reactors’ inherent safety and much lower potential source terms (releases), in the form of reduced requirements, they may be even more expensive than large reactors.

I fear that unless there is significant regulatory and/or energy policy reform, advanced reactors or SMRs will fare little better than current reactors. The central fact is that if nuclear is held to a standard of near perfection, with even a small chance of the release of pollution being considered unacceptable, whereas the competition is allowed to pollute freely, no reactor design will really stand a chance of competing. If cost is no object for nuclear regulations, while even cost-effective requirements for competing (fossil) sources are rejected, how can nuclear compete? I believe, however, that a defensible case for (strategically) trimming nuclear regulations can be made.

In its testimony above, the NRC repeatedly refers to protection of “public health and safety”. As I’ve discussed in earlier posts, we learned at Fukushima that even the meltdown of several large reactors had no measurable impact on public health. And the maximum potential release from an SMR is far smaller than that (probably only a few percent of the Fukushima release, at most). Thus, for SMRs at least, it is absolutely clear that no significant threat to “public health and safety” is involved, or even possible. It seems pretty clear that the consequences of even severe accidents/releases would be purely economic. That should be sufficient to justify regulations being subject to cost/benefit analysis, since we’re really just talking about cost (of an accident) vs. cost (of requirements). Given this, one could even question NRC involvement at all, and argue that such decisions should be between the operators and their insurers.

Needed policies

It should go without saying that all nuclear regulations, requirements, and practices should be subject to full cost/benefit analyses, as are most other environmental regulations. Requirements that do not pass muster (i.e., involve costs per life saved far higher than those applied to most industries) should be eliminated. Of course, any highly cost-effective new requirements (e.g., lessons from Fukushima-like rapid response centers) should be fully considered. All requirements should be evaluated for cost-effectiveness. If they were, we could achieve similar (or perhaps even higher) levels of safety at far lower overall cost.

scale 201x201Requirements, and associated cost/benefit analyses, should fully consider the maximum potential release of the reactor in question. SMRs’ much lower potential release should be fully considered when setting all manner of requirements (operational, design, component fab QA, etc.).

Finally, the potential impacts of increased fossil fuel generation should be considered, when promulgating nuclear requirements that may price new nuclear out of the market, or when making a decision to keep a nuclear plant shut while some issue is being resolved or investigated. (This is something that should also be considered by Japan and Korea, which are burning massive amounts of expensive and harmful fossil fuels while nuclear “issues” are being investigated and resolved.)

An “R&D” program I’d like to see

My view is that the area of research that would be most helpful to the industry does not involve advanced reactors or fuel cycles. There should be a significant area of research devoted to what is making nuclear construction/capital costs so high and what can be done to reduce them. This, after all, is the biggest issue the industry faces. Technology advances would be considered, but more importantly, all current policies, practices, regulations and requirements would be put on the table and subject to a fresh, objective, bottoms-up review to determine their cost effectiveness. Non-cost-effective requirements would be discarded. New requirements would be considered, if cost-effective.

In the specific area of component fabrication QA requirements, the use of more typical industrial or commercial QA requirements (as opposed to the nuclear-unique NQA-1 program) would be thoroughly evaluated. Instead of just assuming that non-NQA-1 (e.g., commercial-grade) components WILL fail, the evaluation would study historical failure rates for components fabricated under different (more common) QA regimes. Also, the evaluation would fully consider the nature of the component failures, based (again) on historical records and statistics of how (non-nuclear-grade) components have failed. I’ve seen evaluations that not only assume that any component that is not verified (by nuclear QA program or dedication) will fail, but will fail completely in a totally non-realistic way (e.g., simply vanish). We must do better than this.

A detailed Probabilistic Risk Assessment evaluation would consider the use of non-NQA-1 or non-dedicated components, based on non-nuclear industry component failure rates and failure modes. The effects of such component failures on the magnitude and likelihood of releases would then be calculated, and those results would be plugged into a cost/benefit analysis. Such an evaluation may allow the use of more common industrial or commercial component fabrication QA requirements for some or most of the components of a reactor (perhaps SMRs in particular, given their very low potential releases). That, in turn, could result in significant cost reductions with little impact on public safety or the risk of financial losses from a release.




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.


35 thoughts on “Cost/Benefit Analyses of Nuclear Requirements

  1. Brian Mays

    Yes most studies found no consistent evidence simply because those covered relative few subjects compared to normal fluctuations (noise).

    That is simply a lie.

    That makes the study so rock-solid!

    Another lie. As I point out above, if it is so “rock-solid,” then why does nobody in the field take it seriously? Why didn’t the US National Academy of Sciences consider it? Please explain that.

    It was an International Atomic Energy Agency (IAEA) study that put up such restrictions that they wouldn’t find results. Not strange as it is the target of the IAEA to promote peaceful nuclear.

    No. See below. Most of the work was performed by other organizations. The parts on health effects primarily relied on the work of the World Health Organization and other prominent papers in the scientific literature.

    So also not strange it was criticized as having no value:

    Criticized? By whom?!! Who is making such criticisms? Greenpeace?!

    They excluded all (western) countries where serious research regarding the influence of Chernobyl’s fall-out was done and published in English scientific journals.

    No. They simply excluded junk science, such as the study that you keep pushing, because nobody takes it seriously.

    They ignored any influence of lower levels of extra radiation, while there is enough evidence that it harms (in line with LNT).

    Nonsense. The projections of eventual deaths due to radiation (approximately 9000, which is surely an over-projection) was a result of applying the LNT model.

    The press release states that 100 scientists validated the report but you can not find their names, associated to the fact that they validate the conclusion (4000 deaths).

    Ah … so it’s all a conspiracy.

    Nine UN organizations participated in the Chernobyl Forum:

    – The International Atomic Energy Agency

    – The Food and Agriculture Organization

    – The United Nations Office for the Coordination of Humanitarian Affairs

    – The United Nations Development Programme

    – The United Nations Environment Programme

    – The United Nations Scientific Committee on the Effects of Atomic Radiation

    – The World Health Organization

    – The World Bank

    In addition, the governments of Belarus, Ukraine, and Russia also participated.

  2. Bas

    Yes most studies found no consistent evidence simply because those covered relative few subjects compared to ‘normal’ fluctuations (noise).

    This study included enough subjects to make the differences visible. Furthermore it also could compare with adjacent area’s that did not get fall-out, which allows for minimizing the noise of ‘normal’ fluctuations (via well-known and respected statistical methods).
    That makes the study so rock-solid!

    The UN’s Chernobyl Forum looked at similar research in the three most contaminated regions
    It was an International Atomic Energy Agency (IAEA) study that put up such restrictions that they wouldn’t find results. Not strange as it is the target of the IAEA to promote peaceful nuclear.
    So also not strange it was criticized as having no value:

    – They excluded all (western) countries where serious research regarding the influence of Chernobyl’s fall-out was done and published in English scientific journals.

    – They ignored any influence of lower levels of extra radiation, while there is enough evidence that it harms (in line with LNT).

    – The press release states that “100 scientists validated the report” but you can not find their names, associated to the fact that they validate the conclusion (4000 deaths).

    – etc.

  3. Brian Mays

    Read the study and then you find references to many scientific studies with similar results including a few review studies.

    Bas – No, there are references to many scientific studies with very different results. Even the authors admit this in the very next sentence after the one you quoted: “In most studies aimed at measuring the differences in pregnancy outcomes between regions or time periods, the authors concluded that no consistent evidence of detrimental physical effects leading to congenital anomalies (or other abnormal outcomes of pregnancy) following the accident exists.”

    No criticism published as far as I know.

    No criticism? Seriously? The entire purpose of this paper that you have cited was to address criticism of an earlier paper written by the two authors, as they point out: “The result of this analysis has been criticized for being the product of a too-specific selection of European countries [4]. In this paper, we show that our initial approach can be extended to yield far more specific and clear-cut results.”

    What more can you wish regarding scientific results?

    How about wishing that the results are consistent with the vast amount of additional scientific data that has been published in the literature? How about wishing that the scientific community would take them seriously? In this case, they do not.

    The UN’s Chernobyl Forum looked at similar research in the three most contaminated regions which found no trends in congenital malformation and stillbirth.

    If Scherb’s work is so “rock solid,” why wasn’t it even considered or discussed by the US National Academy of Sciences in its BEIR VII report? This report covered congenital malformation and stillbirth in Chapter 9. They cite multiple studies as their basis — not weak ecological stuff like the German paper, but far more robust case-control studies — and come to very different conclusions. None of Scherb’s papers were considered worth discussing.

    The only people who take any of Scherb’s papers seriously are members of the lunatic anti-nuclear fringe. The rest of the scientific world recognizes that Scherb went on a statistical fishing trip to “prove” his preconceived notions about the aftermath of Chernobyl. That’s ideology, not science.

  4. Bas

    Read the study and then you find references to many scientific studies with similar results including a few review studies. I quote: “Reviews of the material from these investigations were compiled by Little [15] and by Bard et al. [2].“.

    The study is from the official German research institute for health and environment. It is done by two scientists (also Weigelt) and published in the peer reviewed appropriate scientific journal for that type of research.
    No criticism published as far as I know.
    Many of the results are at a significance level better than one/thousand.
    What more can you wish regarding scientific results?

    Not strange that the results of these studies lead to real action.
    Austrian government (adjacent to Bavaria) recently installed a law that forbids the import of any electricity that is generated by nuclear (not even a small part).
    This is put in action at 2015 (allowing their neighbors time to arrange the closure of NPP’s; Austria has pumped storage that Germany need)!

    Argument; If a disaster occurs in neighboring countries then Austria has major (health) damage and do not get compensation payments (compare Belarus regarding Chernobyl).

  5. Brian Mays

    Your quote cannot be in the abstract of the Bayern study …

    Bas – Yes, I’m familiar with the junk study by the crackpot Scherb that you have been spamming websites with in recent months. Far from being “rock solid,” it is a pathetic bit of pseudo-science that is not taken seriously by anyone credible in the scientific community.

    My original question was what other studies do who have that support that work. You followed with yet another Scherb et al. masterpiece in junk science. I quoted from this latter paper’s abstract.

  6. Bas

    You are reading another study/abstract!
    Your quote cannot be in the abstract of the Bayern study (that I linked first in this thread), as the studied group was the whole population!

    That Bayern study is also unique and rock solid as it showed with high levels of significance:
    – a sudden rise in stillbirth etc after Chernobyl in districts that got fall-out
    – no rise in nearby districts with same characteristics that didn’t get that fall-out.

    Here the link to the study:
    You can also find it in: Environmental Science and Pollution Research • Special Issue 1 (2003): page 117 – 125

  7. Brian Mays

    Fully disagree regarding Scherb etal. That Bayern study is unique and rock solid …

    Bas – Then you disagree with two-thirds of the conclusions in the abstract. This is a direct quote from the abstract of the Scherb et al. paper:

    As we are dealing with highly aggregated data, other causes or artefacts may explain the observed effects. Hence, the findings should be interpreted with caution and further independent evidence should be sought.

    That does not sound “rock solid” to me, and I doubt that it sounds “rock solid” to anyone else reading this.

  8. Bas

    In the Netherlands the grid (and other inherent monopolistic infra) is also owned by the state (or local governments as with water companies).

    Still we can chose our electricity company, e.g. one that only delivers ‘green’ electricity (In NL we have about 10 companies to choose).
    While in some states in US, no choice at all.

    I didn’t know about those critics regarding the Taiwan study. Good info.

    Fully disagree regarding Scherb etal. That Bayern study is unique and rock solid as it shows with high levels of significance:
    – a sudden rise in stillbirth etc after Chernobyl in districts that got fall-out
    – no rise in nearby districts with same characteristics that didn’t get that fall-out.
    And there was no selection of a study sample (source of error), the sample studied was the whole population.

  9. Brian Mays

    Bas – Once again, you demonstrate that you don’t know what you’re talking about.

    China’s “market economy” is completely driven by the government. It’s entirely socialist, it’s largest companies are state-owned enterprises, and these companies produce over half of all of China’s goods and services. Most importantly for this discussion, however, is that the State Grid Corporation of China, which runs the power grid, is owned by the state. Are you really naive enough to believe that the government and the huge companies it owns don’t have an extremely large influence of this so-called “market economy,” particularly when it comes to means of electricity production?!

    Yes, they do, and it’s controlled from top down. China’s Communist government still issues five-year plans, just like in the good old days (although they’ve taken to calling them “guidelines” now, which I suppose makes good propaganda sense). China’s twelfth plan covers 2011-2015.

    China’s glut of solar panels and the artificially low prices that resulted from it was a mistake in its central planning.

    (By the way, I agree with you that the EU is working hard to implement its own communist top-down planned economy.)

    The “study” you cite by the crackpot Alfred Körblein is almost embarrassingly amateurish. It’s clear that this guy simply doesn’t understand statistics or statistical analysis. I would say more, but the “study” speaks for itself.

    The paper by Scherb et al. is a little better, since it was published in a real journal, but its “evidence” is extremely weak. Even the authors are forced to admit (probably by a conscientious reviewer) that it’s results are insufficient to draw meaningful conclusions without additional, independent evidence. That is, there are plenty of “other causes or artefacts” that “may explain the observed effects,” so try not to read too much into it. In any case, your other link demonstrates that Scherb is a crackpot as well.

    Finally, it is difficult for me to fully evaluate the study on the residents of the Taiwanese Co-60 apartments without access to the full paper, but even the abstract provides clues for flaws in its design and methodology. This study appears to suffer from the same flaw that appeared in an early study on these residents, which claimed to show highly beneficial health effects from exposures.

    As other researchers have pointed out, the apartments with the Co-60 rebar apparently were rather upscale buildings in a rapidly developing economy, and the residents of these building tended to come from a higher-than-average socioeconomic level in Taiwanese society. Thus, this population tended to take better care of themselves and tended to have access to better levels of health care, which means that when their mortality or morbidity statistics are compared to the general population of Taiwan, they appear to be healthier.

    This effect is not limited simply to less death and disease. Successful, professional couples tend to put off starting a family until later in life, due to the needs of building a career and providing adequately for their offspring, and it is well known that fertility and the ability to become pregnant decrease with age. Thus, when I read the following line in the abstract, “The comparison population consisted of 612 pregnancies born to 225 couples randomly sampled from the Taiwan general population,” I become very worried.

    A responsible study would have paired off exposed couples with control couples to ensure that discrepancies such as age, education level, income, etc., were stratified comparably in both populations. Without access to the paper, I cannot check to see whether this was done, but if the researchers have taken care to do so, they almost always mention it in the abstract.

    So I’m quite skeptical of the conclusions of this paper. If it ended up being the case that they were comparing the fertility of a population of older, professional couples to a bunch of couples in their early twenties, then the results make perfect sense and have nothing to do with radiation exposure.

    Bas – You really should work on your critical thinking skills. You embarrass yourself by reading too much into these weak studies. I guess that’s what comes from visiting too many crackpot websites. Crackpottery is contagious, and you’ve caught the bug.

  10. Bas

    Since Deng Xiaoping, their leader after Mao, China is a market economy without central planning (2 yrs ago I spent weeks in Shanghai, Xi’an and Being). The China economy resembles more Mexico/Brazil.
    Netherlands is far more socialistic than China nowadays!

    I think solar became a hype, just as ‘new economy’ in ~2000 here. So everybody started a plant… Now local authorities try to save as much as possible (just as here)… It’s an example of the porg-cycle.

    The EU just gave a great help (if a factory produces quality), with the agreement that their export-price must be at least 50cent/watt for PV-panels until end next year (no import duties as that generated to much arousal here).

    So now the normal restructuring for a market that is growing beyond infancy is going on. Smaller producers cannot compete, development in USA/EU and production in China/Taiwan/etc. Just as the chips-/computer-/mobile-industry.

    Your question about the danger to the unborn
    Note that peaks found two and nine months after the accident imply enhanced vulnerability after the 7th months and after conception (so I did not remember well).

    The discussion chapter of this study gives good overview:

    Most experts that theorize think that vulnerability becomes less as the unborn growth (seems logical), but apparently things are more complicated.

    Some more info: The effect of the famous building in Taiwan with high background radiation:

    Easy to read:

  11. Brian Mays

    That raised vulnerability in those months was also shown in other studies.

    What studies?

    The slower decrease in the period before 2008/9 is followed by a much faster decrease thereafter.

    In a beautiful display of how central planning by a Communist government leads to waste and stupidity, China overproduced solar panels that they could not use and then dumped their excess on the international market at a loss. You don’t think that this had anything to do with the price decrease, do you?

    China is not going to keep selling its panels for a loss and bailing out its solar panel manufacturers forever, nor can the US and Europe afford to waste money subsidizing this junk forever. After these artificial influences are gone, the market will correct to the price that solar panels really cost.

  12. Bas

    One of the other effects of enhanced low level radiation is that it is less easy for women to become pregnant*).
    So women in Finland may take more care once they succeeded in becoming pregnant (as that is more difficult for them).
    Note that this effect is not relevant in the Bayern study.

    *) That effect is observed is Germany and many other EU countries after Chernobyl. Conclusion at least one million less babies in W-Europe through Chernobyl.
    You can discuss whether this is a beneficial effect of Chernobyl.

  13. Bas

    stillbirth rate was more precipitous in the most contaminated Bavarian than in the other German/Bavarian places, than you can prove the connection between the low level radiation and the stillbirth…

    That comparison was done.. It showed: “Rise of stillbirth rate in contaminated Bayern areas and no rise in not contaminated Bayern areas” and that rise was exactly after Chernobyl.

    Results show even that fetuses that were in second month and those in 7th month were harmed most. That raised vulnerability in those months was also shown in other studies. Japanese population administration now show the same regarding Fukushima, indicated by preliminary study.

    – Can you show the link with the Finnish stillbirth rates of 1986/1987??
    I couldn’t find those figures.

    – the 40% decrease/decade is shown in the Bayern study diagrams. So a 30% difference can only found if you correct for all confounding which is impossible if you compare between countries that are so different (climate, mood, etc).

    – development level, etc. doesn’t tell much. UK is also a well developed country with quality health care. Yet it has a very high stillbirth rate:

    – The journal is the right one considering the subject. Peer reviewed with a decent impact level.
    High impact level journals only accept studies with real news value (especially The Lancet). And the results of the Bayern study were in line with the knowledge of (medical) radiation experts. So little news, only a confirmation.

    PV panels
    I take the long term price development, especially since there is no reason to assume that the price decrease will slow down. The slower decrease in the period before 2008/9 is followed by a much faster decrease thereafter.
    Even so much that US has big import duties (sick)! And the EU made an agreement that until end next year import in EU won’t be below 50cent/watt (created anger because it is an high price; for big projects the price was in Jan. already 40cent/watt).
    Remember; in 1980 the price was ~$20/watt.
    Technically there are reasons to assume that the price will go down much further, with ~ same speed. There is now much more effort and progress regarding improved yields (those are now ~15-21%, theoretical max ~70%, labs produced already 44%, thin sheets that can be glued, etc.
    And automated production is ~same technology as chips.
    But we will see in 20years who was right!
    By then you buy panels for ~12cent/watt, with a 25year guarantee that those will produces 100% all the time.

    That is the environment a new NPP has to compete.
    That is also the reason that no commercial enterprise takes the risk to order one unless guaranteed prices for the current it produces.
    Hinckley Point in UK shows that those guarantees (~12cent/KWh) will become are exceptional expensive for the taxpayer.

  14. Henrik


    1) My comparison isn’t invalid. There was no big difference between the average German and average Finnish lifestyle, and the alcohol consumption was (and is) higher in Finland than Bayern, leads relatively higher stillbirth rate in Finland. Btw in the late eighties, West-Germany (and especially Bavaria) has higher GDP/capita and GNP/capita than Finland. That means probably better medical services in Bavaria.

    2) You said that the Bavarian stillbirth rate went 40% down in the last decade. That is maybe okey (I didn’t check the dates between 2003 and 2013), but it wasn’t because of the decay of Caesium-137. It is because of the progress of medical sciences, the better air quality, and the decreasing tobacco consumption.

    IF you can show, that the decline of stillbirth rate was more precipitous in the most contaminated Bavarian than in the other German/Bavarian places, than you can prove the connection between the low level radiation and the stillbirth.
    Good luck!

    3) In my first comment I compared the record high stillbirth rate (in 1987) of the most contaminated Bavarian districts with the stillbirth rate of Finland in 1987 and not in 2012!

    4) 0.5 mSv vs 1 mSv. You still didn’t get it. If we assume, that the additional dose rate in the most contaminated Bavarian districts is only 0.5 mSv/year (citing “your” study) and not 1 mSv/year (as I estimate), then the difference of radiation dose-rate between the most contaminated Bavarian districts and between Finland is even more: 3.5 mSv/year, and not 3 mSv/year (as I previously estimated).

    So if the “relatieve risk” of radiation is 1.33/mSv/year, and (now we know) the radiation dose rate in Finland was with 3.5 mSv/year more than in Germany, that means, the Finnish stillbirth rate were 1.33^3.5=2.71 times as high as the German rates. But it wasn’t! Just check the figures of “your” study.

    And if we take account, that the alcohol consumption is (and was) higher in Finland than Bavaria, and the fact that in the late eighties the Finnish medical services weren’t as good as the Bavarian, then the difference between Finnish and Bavarian stillbirth rate should be more higher than it was.

    5) I would like to point you, that 0.5 mSv/year dose rate is only 57 nanoSv/hour. I think you should check the rates of background radiation in your country…

    6) About the cost of PV panel: I will never take trouble to read any article from “Scientific” American, or any pseudo-scientific, creationist press.

    But I copy your sentence here literally:

    “Yes, but not with the ~20%/a of the last few years. Just with the ‘normal’ 7%/a as it did during last 30 years.”

    Now please download the first pdf from and go to the 72th site. As you can see in the 3.8. figure, the “normal” 7%/year decline was true between 1980 and 1998.

    Between 1998 and 2007 the annual decline was only 2.45%. If you are skeptical, then (4$/5$)^(1/9)= 0.97551 And 100-97,551=2.45 (rounded value).

  15. Brian Mays

    Impact factors:

    Lancet – 39.06 — Science – 31.03 — Nature – 36.28

  16. Bas

    … study wasn’t even published in any notable peer-reviewed journal …
    This also shows that you did not read the publication at all.
    If you did you would have seen that it was published in:
    Environmental Science and Pollution Research, Special Issue 1, 2003.
    Impact factor of this scientific journal: 2.65

    As you do not read the few publications I gave, it is useless to give the other publications you asked for.
    You won’t read those neither. Only use those to drop wildly unfunded critics, as you did with the Bayern study and the Scientific American article.
    So it makes no sense to list other pub

  17. Bas

    Please ignore the last sentence of my previous post (was not aware that it was there)

  18. Bas

    Your conclusions are based on a comparison that is simply invalid / makes no sense. Because they are based on two total different situations and you did nothing to compensate for the spoiling factors (alcohol, nicotine, lifestyle, etc.).

    And those factors are important as I showed. The publication shows stillbirth rate in Bayern went 40% down in 10years. What was the cause?
    So with same radiation levels stillbirth rates between countries may differ factors..

    Did you compare with the stillbirth rates of Finland now?
    Or with that of the eighties? Big difference as the stillbirth rate in Bayern is now also very much lower (all kinds of improvements such as better medical supervision, less alcohol, etc).

    …Price of PV…
    Just read the article and then you understand that you conclusion is wrong (unless you don’t want to understand).

    Your second post.
    This post makes it clear that you did not read the Bayern study at all.
    Only picked few figures and did some math in order to show that they are wrong.
    That explains also your wrong conclusion of 1mSv while you can read in the Bayern study 0.5mSv.

    It makes no sense to discuss about a study with a person that did not read it.

    Btw. If you read the study you will see that the sample size is huge (the whole population).

    Please do the same with the Bayern study

  19. Henrik


    If the size of sample is small and the variance is high, then it is so simple to make junk science. There is a good story about the depleted uranium.

    and an April 1 yoke:

  20. Henrik


    About the 1.33 times more vs 33% more problem.
    As I said, english is not my native language, so I was misunderstandable (with my incorrect grammar). I meant 1.33*x (or 33% more) means in english 1.3 times more.
    Btw my calculation wasn’t incorrect because my wrong phrasing. If the relative risk of 1 mSv/year additional dose rate is 1.33, that means, we must multiply the old stillbirth dates with 1.33 the get the new dates.

    About the Bq to Sv conversion. I said “about”, not “exactly”. I used 1mSv/year additional dose rate in Germany, because I would like to give a conservative approximation. But if we assume, that the additional dose rate was only 0.5mSv (as you said), then the difference between the dose rates in Germany and between the dose rates in Finland is more, than I expected. (Especially, if we take account the fallout of Chernobil in Finland to)

    And that is the point! If the German study had been correct, than the stillbirth rate (in Finland) should have been much-much higher. At least 0,01. ( But if we take account the fallout of Chernobil in Finland, then even more!) But it isn’t!

    And that means, the study is incorrect. Btw: as I see this study wasn’t even published in any notable peer-reviewed journal such as Lancet, Nature or Science. You have mentioned that similar results were reported in Sweden and in Finland. I would love to see peer-reviewed publications…

    Price of PV.
    As I see in the site (cited by you), the price of PV panels was 5 dollar per W in 1998. And around 4 dollar per W in 2007. So your 7%/year cost-drop is simply false.

  21. Bas

    My speculation in my previous post: “Fighting the higher chance on stillbirth (due to radiation) may be one of the reasons that maternity leave is so generous in Scandinavian countries. may sound strange.

    But realize that other studies showed that the slightly higher level of radiation due to Chernobyl, also created less pregnancy. Estimations are that Europe missed ~1 million birth.
    This would imply that there is less pregnancy in Finland. So logically pregnancy then is considered more precious. Hence the longer maternal leave, etc.
    Of course cultural reasons may be far more important.

    Finland got also significant Chernobyl radiation and published similar studies (raised level of stillbirth, etc).
    As the fall-out in Finland was not local, there is not such a nice research situation as in Bayern. So those studies are less solid (not possible to compare adjacent area’s with/without fall-out, as those do not exist in Finland and Sweden (that also reported similar results).

  22. Bas

    … price fall continue in future? …
    Yes, but not with the ~20%/a of the last few years. Just with the ‘normal’ 7%/a as it did during last 30 years. The reason: That price fall is driven by the same technical progress as the chips industry (about same technology).

    It will stop when we have panels wit a yield of ~50% (now ~15-21%) that are produced in almost fully automated factories.
    Factories automated because the market takes >100million/year.
    Of course, in the years before that price fall will slow down.
    Please read the link I posted in this thread.

    low level radiation
    Your calculation has 2 mistakes. But the end result correct!
    The German study used a conversion coefficient from kBq/m2 Cs to mSv/a
    of 0.0143 (theoretical value 0.0123, all stated below figure 3 including a reference). That delivers ~0.5mSv/a (not 1mSv/a).

    The Relative Risk of 1.33/(mSv/year) implies 33% more stillbirth per mSv (not 1.3times more).

    When you look in figure 1 (least contaminated) to the development of stillbirth figures over the 1981 – 1992 period, you see a decrease from 0.46% towards 0.29%. This imply that there are many other factors that have a significant influence on stillbirth chance, as we also know from other sources.
    More rest, alcohol, smoking are a few majors.
    And regarding those Finland does probably a lot better.
    Fighting the higher chance on stillbirth (due to radiation) may be one of the reasons that maternity leave is so generous in Scandinavian countries.

    Mistakes are made easy. I made a mistake at the Atomic Insight forum, wrongly stating that this 1.33 implies 66% more stillbirth per mSv.

  23. Joris van Dorp

    Bas: “That may be true for adults, especially for old people, but it is the opposite for the unborn. Due to their high rate of cell division.
    Medical research shows that children are also very sensitive.”

    Yawn. CT scans deliver multiple mSV of radiation per minute, which is a huge radiation dose rate. It makes no sense to compare this with the radiation dose rate from a nuclear accident such as Fukushima, which has a tiny, tiny dose rate, and therefore a tiny, tiny risk.

    So why are you injecting this story about the (extremely low) risk of CT-scans into this discussion about rational nuclear regulation?

    I think I know the answer. You are an anti-nuke propagandist who likes making use (cherry picking) of misleading information in order to cause irrational fear, uncertainty and doubt. Shame on you.

  24. Bas

    Exponential downward trends in cost NEVER continue forever. True. Only, solar-cells are ~same as chip technology, which generated per unit (transistor) ~30%/a price-fall during ~50years now.
    So during the past 30 years PV-panel ($/MWh) went down with ~7%/a, with all signs that it will continue (price-fall accelerated last 3 years).

    The, cost-price plus ~6% margin based, solar feed-in tariff in Germany went down to ~$13/MWh now. Going down each months. In south of Italy (more sun) grid parity is reached.
    Note: In USA this is not very visible, yet. Chinese PV-panels on your roof cost in USA almost the double (MIT studied and reported about this strange price difference).

    The present panels have a yield (=conversion efficiency) of ~16%. Cheap panels with ~30% are expected in a few years (building plants).
    Panels with >50% yield are in design phase (yield theoretical proven).
    Apart from the economy-of-scale benefits with installation costs (MIT: that covers ~40% of the price difference), a yield of 32% implies that only half of the panels have to be installed for the same production.

    Agree for wind. With wind, price goes mainly down because the turbines get bigger and economy-of-scale. Cost price now ~$10/MWh (~7MW turbine). EU study showed that 20MW turbine is feasible, but a 50MW wind turbine would be a real tough one.

    .renewables … not be … able to provide more than ~25% ..
    Only wind turbines generate already >30% of Denmark’s electricity (all renewable ~45%).
    According to the Danish energy plan, wind alone will deliver 50% in 2020 (little solar due to its northern latitude).
    Some other countries go similar route (e.g. Portugal)
    Germany plans 80% renewable before 2050 (now ~25%, in 2020 ~35%). Important political forces want >90% renewable in 2050… costs being anything less than prohibitive …
    Pumped storage is not expensive if you have mountains. The Norwegians earn money with electricity trading (e.g. Statkraft) using their pumped storage capacity (and huge potential) and the lines to Germany/NL/Denmark.

    …the fossil industry is quietly supporting the renewable push…
    Not in Germany. They continuously try to undermine the transition. Not strange as they are loosing position all the time (renewable in Germany produces now ~25% of all electricity, most by citizens (rooftop), farmers and small cooperations (Wind turbines). Even their cheap coal/lignite consumption goes down.

    Note that the Germans build new fluidized bed plants (that can burn waste, biomass, coal, lignite with low temperatures, which allows for thin steel pipes, allowing fast up-/down regulation) closing the less efficient and less flexible plants.

    …LNT is probably overly-conservative …
    That may be true for adults, especially for old people, but it is the opposite for the unborn. Due to their high rate of cell division.
    Medical research shows that children are also very sensitive.

  25. Henrik

    English is not my native language, so I’am sorry for grammar errors…

    Hi Bas,
    I have a few problems with you comment.

    1th topic, Cost of wind+solar:
    There was a great price drop at the PV-panels. That is right! But what is the reason behind this phenomenon?
    Technological breakthrough, or just the overproduction (+dumping price) of the state-financed chinese PV industry?

    And now, let’s see the annual reports of the biggest PVcell/PVmodul companies : 1Suntech declared bankrupt, 2First Solar (this one is not chinese) had negative operating income and negative net income in 2012, 3 JA Solar had negative operating income and net income in 2012, 4 Trina Solar negative operating income and negative net income in 2012, 5 the German Q-cells had negative operating income and negative net income in 2011 (i can’t find th 2012 report), 6 Yingli Solar had negative operative income and negative net income in 2012 and in 2011, 7 SunPower had negative operating income and negative net income in 2012, 8 Hanwha SolarOne had negative operating income and negative net income in 2012.

    So, do you really think, that the price fall will continue in the future??

    2nd topic, low level radiation:
    Just because somebody published something, it doesn’t mean, he is right. Especially if it was written and published in Germany, where the anti-nuclear lobby is very active.

    But let’s go searching for some information!
    According to “your” study the Caesium 137 activity of the soil (at the most contaminated Bavarian cities) is between 54 kBq/m^2 and 27 kBq/m^2. Such a contamination leads approximately 1 mSV/year additional whole body dose (internal+external of course). The average dose from ALL natural source in around 3-4 mSv/year in Germany.
    The average dose from natural sources in Finland is about 7-8 mSv/year.
    (Source: Natural radiation atlas of Europe)

    Now, we have a few information, let’s go thinking! FIRST, I assume, that the German study is correct, and we can trust its findings/numbers.
    According to the 2nd table of the German study the Relative Risk is 1.33/(mSv/year). That means: each 1 mSv/year dose rate leads to a 1.33 times higher stillbirth. According to the 2nd figure the stillbirth proportion was around 0.0046 at the most contaminated Bavarian districts in 1987. Don’t forget: The average dose was around 4-5mSV/year (3-4mSv natural + 1 mSv because of Chernobil) at there.
    As I have already written, the average radiation dose (from natural source) is around 7-8 mSv in Finland.
    So if the study is good, than the Finnish stillbirth proportion should be at least 0.0046*1.33^3=0.01 (I don’t know how high was the additional dosage in Finland because of Chernobil)
    Let’s see the 17th table, and compare the result of my calculation with the Finnish data! It won’t match…

    Is my calculation wrong, or the findings of the German study?

  26. Brian Mays

    This is why the fossil industry is quitely supporting the renewables push

    Jim – I don’t think that the “Beyond Petroleum” add campaign launched by BP (formally British Petroleum) was all that quiet.

    Any view that LNT under-estimates health impacts represents a small minority view (i.e., the lunatic, politically motivated fringe).

    You should know that Bas here is a fan of the unabashed crackpot Chris Busby, a member of the avant-garde of the lunatic fringe. Expect him to counter your comment with links to crackpot, discredited, or severely flawed articles about infant deaths or miscarriages in Germany caused by Chernobyl. His spiel plays like a broken record.

  27. JimHopf

    Very few serious people/experts believe your projections for renewables costs. Exponential downward trends in cost NEVER continue forever. That’s not the way the real world works. For residential systems, the costs other than the panels (structures, wiring, labor etc..) alone are enough to make the cost of electricity ~10 cents/kW-hr, and those (mature technology) costs are not going down. The EIA thinks that solar will still be double nuclear’s cost in 2016 (just for raw kW-hrs, w/o considering grid and fossil backup costs) and it will be a very long time before it falls below it.

    Finally, even if renewables costs get very low, there have been no signs of large scale energy storage costs being anything less than prohibitive (they are not going down much). Given this, renewables will not be practically able to provide more than ~25% of overall generation anyway. For the rest it’s nuclear vs. fossil. How much will be nuclear vs. fossil will depend largely on whether mankind will EVER start to take fossil fuels’ health and environmental impacts seriously (i.e., anywhere near as serious as they take the relatively minute nuclear impacts/risks).

    This is why the fossil industry is quitely supporting the renewables push (massive subsidies, govt. mandates, etc.). They know that a choice to go down the “renewable path” will actually ~permanently enshrine their role in power production, with fossil fuels providing ~1/2 to 2/3 of overall power (when renewables are not operating). That choice will also remove the real threat to their role in the power sector (which was demonstrated by France, which went from 0% to 80% nuclear in only ~15 years). Nowhere are non-hydro renewables providing more than ~20% (despite decades of massive effort).

    As for respectable/mainstream views on radiation effects, it’s basically between those who support LNT and those who think it should be abandoned, with even those who support it acknowledging that LNT is probably overly-conservative (but believing there is no better, workable policy option). Significant fractions of the experts adhere to each of the two above camps. Any view that LNT under-estimates health impacts represents a small minority view (i.e., the lunatic, politically motivated fringe).

    Even pessimistically assuming LNT, it’s hard to call even Fukushima and Chernobyl disasters, when comparing them to the effects of the fossil fuel (primary) alternative. Even under LNT, Chernobyl is projected to cause on the order of 10,000 total eventual deaths, and Fukushima on the order of ~100. By contrast, fossil-fueled generation causes ~1000 deaths every single day, along with global warming. Even w/ LNT, nuclear remains the safest major energy source.

    I completely dispute your economic consequence numbers for Fukushima and a theoretical US meltdown. Your estimate of $100 million per reactor year is about a factor of ten too high, but even if we take it at face value, dividing it by the ~8 billion kW-hrs each reactor produces each year, you get a cost of just over 1 cent/kW-hr. My view is that the removal of non-cost-effective regulations would probably cut the cost of nuclear power by about a factor of two, i.e., about five times that (even w/o accounting for the fact that your number is way too high).

  28. JimHopf


    My general feeling about your post is as follows. What I’m really proposing is radical change, and it seems that you’re having trouble “letting go” (of the way things have always been done in our industry). Your questions seem to be about trying to fit my suggestions within the existing system (philosophies, and way of doing things) whereas I’m questioning the whole system at a fundamental level. I’m not surprised by this. I fully expect a whole lot of people to be similarly reluctant. (If you think that my ideas are quixotic, you may very well be right, but I’m not sure I see any other way for the industry to be successful in the future, unless there is some fundamental change.)

    As for the pump’s bolt and impeller example, what I’m really suggesting is that the whole thing be non-NQA-1. I’ll accept a detailed PRA that proves me wrong, but my judgment right now is that using a more common industrial QA program for all of reactor construction (and eliminating NQA-1 entirely) would easily pass a cost/benefit analysis. This would be especially true for SMRs, with their much smaller potential releases (i.e., consequences of component failure). BTW, some SMRs don’t even need forced cooling to avoid meltdown. The others have much longer allowable response times (several days) to restore active cooling, and even if they didn’t, the maximum possible release would be very small.

    What’s so special about nuclear that it should require a unique (and uniquely onerous) QA program, which almost all suppliers (inlcuding the one’s creating modules for Vogtle) are having real trouble working and complying with? Especially given that worst-case meltdown don’t have anywhere near the consequences we thought they would (again, SMRs consequences being FAR lower still). It’s not like the failure of tall buildings, dams, bridges and chemical plants would not kill people or have any consequences (the consequences may, in fact, be greater), and yet they can, and are allowed to, get by with more common, more workable QA programs.

    In refernce to the end of your first paragraph, I believe that NRC should have to do cost/benefit analyses in order to justify any regulations in the first place (i.e., the burden of proof should be on them). After all, that’s the way it works with other regulations/industries, e.g., EPA air pollution regulations.

    As for your doubts about SMR economics, I basically concur, as I’ve discussed in this post and my March SMR post. Yes, things probably need to change, in terms of requirements, for SMRs to be competitive due to what they’ve given up in terms of power density and economy of scale (although the economy of volume production can’t be ignored). But, as I argue, things can and should change (i.e., requirements should be reduced) given SMRs inherent safety, longer response times (to restore colling, etc.) and their very small potential source term.

    Concerning the rapid Fukushima evacuation, first of all (given what we now know about consequences) the rapid evacuation probably was not warranted for some groups of people, at least. Sheltering in place plus iodine, followed by slow, orderly evacuation is probably the best policy. Also, with SMRs, such effects will be much smaller to non-existant. I’ve heard someone who works with SMRs say that their analysis yields a required short-term evacuation zone that is so small that virtually nobody lives (or would live) within it. Finally, I’m hearing references ranging from 25-600 deaths resulting from the Fukushima evacuation (one more example of the reaction to nuclear events being worse than the event itself.) This compares to ~1000 deaths caused every single day by fossil fuels. In any event, I would not object to having such factors included in any cost/benefit analyses.

  29. Rick Grantom


    Very good article and it hits several key points. The cumulative effects of regulation has had and will continue to place nuclear plants with difficult economics. Many times it is not the intent behind a regulatory initiative but it is the scope to which it will be applied (i.e., all safety-related components). This is where the concepts of “graded QA” can play a significant role. 10CFR50.69 was structured after pilot efforts relative to exempting components from special treatment requirements. This process was systematic and used insights/results from PRA in conjuction with deterministic insights through an experienced independent decision making panel. The results were a clear separation between high, low, and non-risk significant components for both safety related and non-safety related components (yes, there are a few high risk significant components that are non-safety related). One of the issues, as you indicate, is our own nuclear culture where safety-related is safety-related and “that’s just the way we do things”. In our zeal to hold nuclear to a higher standard we have left ourselves vulnerable to a perfectionist standard that is never fully achieved and always open to interpretation and debate.

    New plants did not take advantage of these risk informed approaches due to the belief that combined operating license applications would be delayed. Thus, essentially the same rules used for the previous generation of nuclear plants will apply to the next generation currently being constucted. How this will manifest itself for SMRs remains to be seen but the economics are still marginal for them and would preclude them if they are held to existing requirements.

    In my opinion, the industry needs to examine its own culture if it is to survive. Initiatives such as graded QA and current efforts relative to cumulative effects of regulation can play an important role in the economics of nuclear power plants. Research into construction costs would also be a significant improvement. These initiaves and others currently in progress or being developed, in conjunction with a level playing field with respect to the promulgation of new or revised requirements requiring real cost-benefit analysis, would change the economic climate significantly.

  30. Bas

    Good story!
    The problem is that it has some flaws:

    1- SMR’s, etc. will have to be competitive in the ~2025-2065 period. So consider the situation in ~2040.
    Then competition will be renewable, as those prices continue to fall according to all experts. Especially solar panels (~7%/a).
    Cost price in 2040: ~$20/MWh going further downwards (panel yields then raised from 16% now, to ~40%). Wind costs go down ~3%/a.
    As solar and wind have almost no operational costs (once installed) they will deliver even for $1/MWh.

    That implies no base load for the SMR. Only option is to fill the gaps that wind, solar, hydro, pumped storage, etc. leave.
    It would be better to consider that economic situation.

    Note: In Germany we see already the first signs that thermal PP’s and even existing NPP’s are gliding into an ever worse P&L situation.

    2. The health effects of low level radiation.
    There is a real huge difference between IAEA/WHO/NPP supporters and the real experts regarding its damaging effects (factor 100 -1000).

    The problem is that the pro-nuclear people have little research to support their point of view, while radiation experts (supported by similar medical radiation effect research) showed that even real low levels of radiation from NPP’s (<1mSv/a) create real serious damages. E.g: this study.

    Denying those doesn’t help. The radiation experts know all the studies.
    Worse, repudiation makes pro-nuclear folks in the opinion of experts not trustworthy.
    And you do not license a NPP to untrustworthy people.
    So it is better to take the view of the radiation experts into your considerations.

    3. Your proposal for more flexibility: “Non-cost-effective requirements would be discarded was followed more or less in several countries. That resulted in three disasters (Mayak, Chernobyl, Fukushima).

    We were lucky with Chernobyl as wind blew to the empty areas in the north (and not towards Kiev), as well as with Fukushima (97% went towards the ocean). Still the damage of each is ~$500billion.
    note: Such a disaster with e.g. SONGS would have created trillions of damage.

    So with ~12,000 reactor years worldwide, that implies an insurance premium of >$100million/year per reactor to cover the risks of those slightly more flexible regulations.
    I doubt whether that would be economic.
    Keeping the stronger regulations may be more economic.

  31. Edward Knuckles

    Jim: You’ve outlined some ambitious ideas that provide a good basis for discussion but I feel that some of them need to be approached cautiously. Cost-benefit analyses are based on assumptions and judgments and as decision making tools they can help to clarifiy uncertainty but they are not full proof. Requiring regulatory agencies to perform them is not necessarily going to be beneficial depending on the objectives of the parties concerned: the public, the regulator, and the licensee which are not necessarily the same. I believe that a more constructive process will result by keeping the burden on the licensee and his industry representatives to make cost-benefit cases that can affect the regulatory outcome.

    Large and complex capital construction projects contain inherent uncertainties that make them difficult to control and they are not immune to changing design requirements during lengthy construction schedules. I agree with you that nuclear R&D should be directed more towards having our feet on the ground rather than towards maintaining a questionable edge in some assumed future technology but I’m not sure that R&D in this area will bear the fruit that will result in a breakthrough. The benefits of incorporating streamlining and standardization into the licensing and construction of the reactors now being built remains to be demonstrated. I believe that is in the practice of these projects are where we will learn the most significant lessons rather than in abstract pencil and paper exercises. Unfortunately they can be very expensive lessons. The SMR proposes to be less immune to licensing and construction obstacles by scaling down and simplifying but there is nothing inherent in the concept to assure its benefits in practice. Success in constructing the four new US plants within reasonable budgets and schedules may work against the SMR concept if the economies of scale of the larger plants are achieved in practice. This cost disadvantage will only be further compounded without the regulatory reform that you allude to.

    My last two observations are that: (1) I believe that your example of Fukushima overlooks the impact on public health and nuclear accident response in general because you’ve considered only the radiological impact and not considered the impact of mass evacuation on thousands of individuals. The health and safety of those individuals will be impacted by an evacuation regardless of the radiological consequence. (2) Lastly, I’m not sure that the state of the art of PRA has reached the point where, as an example, a non-NQA-1 mounting bolt for a pump can be separated from the pump’s NQA-1 impeller and still maintain a causal relationship in the overall failure response.

  32. JimHopf


    I agree. I think your touching on the issues I talked about in my last post, about the EPA’s proposed new Protactive Action Guideline. Their proposed changes are a step in the right direction, but don’t go nearly far enough. You’re right about the political reaction, of course.

  33. Dave Rossin

    Jim – – Another essential requirement (though plants will likely have to go ahead without it) is a set of internationally adopted regulations for radiation level and actions in the event of a future emergency. [No explanation provided here.] Many people have been calling for this development, but opposition to it would be hysterical.

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