Category Archives: DC Perspective

Federal affairs from a nuclear mindset.

New EPA Guidelines for Response to Radioactivity Releases

Posted on April 23, 2013 by pbowersox| 31 Comments

By Jim Hopf

DC Perspective

The U.S. Environmental Protection Agency just released a draft Protective Action Guideline (PAG) that sets standards and makes recommendations for the response to a large release of radioactive material into the environment (e.g., from a nuclear plant accident or a dirty bomb attack, etc.). The draft report is now out for public comments (which are due by July 15).

PAG recommendations

The PAG sets a public dose threshold of 2,000 mrem in the first year and 500 mrem in subsequent years, above which the areas in question should be evacuated. (See Table 1-1 of the PAG.) The PAG is not clear as to whether or not those same limits apply to resettlement of areas previously evacuated (i.e., if people can resettle areas after their exposure levels drop back below 500 mrem/yr). Section 3.8 of the PAG suggests that “re-entry” is allowed if annual exposure is kept under 500 mrem, but appears to say that this is only for temporary stays (to accomplish specific tasks). It’s unclear why permanent residence (resettling) would not therefore be permitted if full (annual) occupancy would not yield a dose over 500 mrem.

Apparently, the above evacuation guidelines (thresholds) are no different from the current guidelines, which were based on a 1992 PAG. The differences lie in the area of long-term cleanup standards, and (perhaps) standards for resettlement or reuse. Currently, the only guidance or precedent for such standards are the extremely strict standards that apply for EPA Superfund sites and nuclear plant decommissioning, which are based on allowable lifetime cancer incidences (for a hypothetical, most exposed individual) ranging from 10-4 to 10-6. For radiation, these standards led to dose rate limits as low as 10–25 mrem/year (i.e., far below natural background levels).

The new PAG does not appear to give any specific, recommended dose thresholds for long-term cleanup. In Section 4.1.3, it makes reference to the old 10-4 to 10-6 acceptable lifetime risk criteria, but goes on to suggest that in the case of a large scale release of radioactivity (e.g., following a severe plant accident), attaining such cleanup goals may be impractical. It then states that cleanup level (and perhaps resettlement) decisions should be made on a case-by-case basis, with inputs from local authorities and various other stakeholders, based on the principle of “maximizing overall human welfare”. In Section 4.1.4, it suggests that resettlement may be possible before the long-term cleanup goals are met, due to the fact that those goals will be met in subsequent years, resulting in acceptable lifetime exposures.

Whereas the EPA PAG does not give specific dose numbers for cleanup standards/goals, a related National Council on Radiation Protection report does talk about such values. It discussed possibly raising the allowable dose rates (for resettlement, and possibly long-term cleanup goals) to anywhere from 100–2,000 mrem/yr. That is in contrast to the existing EPA standards for nuclear plant decommissioning, which are on the order of 10–25 mrem/yr (and are based on a constant lifetime dose at those levels, and an acceptable lifetime cancer risk of 10-4 to 10-6). It did, however, go on to recommend continued cleanup efforts, even after the attainment of the (100–2,000 mrem) annual dose goal, and subsequent resettlement.

Political reaction

The EPA PAG and NCRP report have provoked a strong reaction from anti-nuclear groups, who characterize them as an enormous relaxation of radiation standards (i.e., a huge increase in allowable dose rates). In a New York Times article, however, the authors of the PAG and NCRP report insisted that they are not changing the cleanup standards or allowable dose, but are just using more accurate estimates of lifetime doses that people will receive, based on the Fukushima experience, and expected cleanup activities that will continue to occur.

I’m not entirely sure what they mean by more accurately calculating doses, when the subject is the setting of dose limits. I think that the authors are referring to what was discussed in Section 4.1.4 of the EPA PAG, where people can resettle in areas with a somewhat higher annual dose rate, while still “meeting” the old lifetime cancer risk criteria, due to an assumption that dose rates will fall off, significantly, due to decay, natural dispersion, and ongoing cleanup efforts.

Changes do not go far enough

All of these (EPA/NRC) policies and supporting analyses are based on the linear no-threshold (LNT) assumption, i.e., that cancer risk is directly proportional to radiation dose, for doses all the way down to zero. Many scientists outright disagree with this, and even most of those who do support LNT don’t really believe that the risk is truly linear, all the way down to extremely low doses (that are a small fraction of natural background). They just believe that it is a practical and conservative radiation protection policy, and that there is no better practical alternative.

It’s obvious that anyone who does not believe the LNT assumption, and believes that dose rates within the range of natural background have no health impact, will find these EPA/NRC policies to be completely absurd. I will not question or debate LNT here, however. For the reasons I discuss below, current policies—and even those suggested by the PAG—are clearly unwise, indefensible, and utterly hypocritical, even if one completely accepts LNT.

Man-made vs. natural radiation dose

My position has always been that the issue is not LNT per se, but the fact that it is selectively applied/enforced. While LNT is debatable, there is no debate among experts that a given dose has the same health impact, whether it comes from a natural or man-made source (or isotope). And yet, there is a complete black-and-white distinction between naturally caused doses and man-made doses (specifically, those from the nuclear power or weapons industries), in terms of dose limits. Government agencies assume LNT, and then apply an extremely low (and arbitrary) allowable cancer risk criterion, to arrive at extremely low allowable radiation doses. They then apply those low limits ONLY to nuclear-industry-related activities (and isotopes). Doses from natural and other sources that are orders of magnitude larger are not regulated or responded to.

How could it be that government agencies are saying that “contaminated areas” should remain off limits, and require expensive cleanup efforts, even though the overall exposure levels in those areas are lower than the natural background exposure levels in many regions of the earth (where millions currently live, with no apparent health impacts)? Under that logic, we should be spending billions to reduce doses in high natural background dose areas (e.g., Denver), or permanently evacuate those areas.

Those natural sources are responsible for annual collective exposures that are thousands of times higher than those caused by even worst-case accidents like Fukushima, let alone the nuclear industry in general. Even the individual exposures are orders of magnitude larger than those that would be allowed by the 10-4 to 10-6 lifetime risk criterion (radon exposes hundreds of millions of Americans to a lifetime cancer risk on the order of ~1%). Many of those natural doses (such as radon) would also be orders of magnitude less expensive to reduce (in terms of dollars per man-Rem avoided).

For these reasons, annual dose limits that are a small fraction of natural background, which only apply to nuclear-industry-related sources, are clearly indefensible. The policy solution to this is obvious. Government agencies need to be told that they are no longer allowed to apply policies or regulations that distinguish in any way between different sources of radiation (e.g., natural vs. man-made, etc.). Dose is dose, period. They need to establish what safe dose levels are, regardless of source, for normal (long-term) and accident/event (short-term) conditions. The only possible exception to that may be medical exposures, under the argument that they have an offsetting health benefit.

I can possibly understand the desire to set very low exposure limits (far below the level that poses any significant health risk) for normal nuclear industry operations, based on a “good industrial practice” philosophy. Routine releases really are unnecessary and easy to avoid, and we may want to avoid long-term buildup of man-made isotopes in the environment. However, unless the above reasoning is not clearly explained to the public, such policies may be counter-productive. The public will (understandably) tend to think that doses above the limits represent a significant health threat. In the event of an accident, the government will have to apply much higher limits, and then will have to explain that those higher doses are not really a significant health threat. This will result in a loss of public trust. A better stance would be to establish higher “public health and safety” dose rate limits around the top of the natural range (i.e., on the order of a Rem/year), but then say that much lower limits will be applied for normal operations since there simply is no reason why any significant releases are necessary, or should be allowed.

Cost vs. benefit

These extremely strict dose limits are yet another example of society spending enormous sums of money to reduce or eliminate tiny risks in one area, while ignoring vastly larger, and cheaper to reduce, sources of risk in other areas. This may be true of the (chemical toxin) EPA Superfund cleanup requirements, as well as the nuclear-related requirements.

The PAG and NCRP reports, and their authors, discuss the 10-4 to 10-6 “acceptable” lifetime cancer risk criteria, and how they will be maintained. To me, something seems odd about such stringent requirements in a world where ~25 percent of the people die of cancer. Clearly, there are much larger sources of risk that these regulatory bodies are failing to protect us against. That is, there are many industries or aspects of life where these strict risk standards are clearly NOT being applied. (Automobile exhaust, coal plant emissions, and the fact that coal ash is still not classified as a toxic material comes to mind.) It seems clear that this is yet another case of selective application/enforcement of overly strict requirements; another double standard.

My understanding is that the government has general public safety policies (for industrial projects/activities, building codes, etc.) that require that ~5–10 million dollars be spent per (expected) life saved. These same policies should apply for the cleanup and resettlement of nuclear-contaminated areas. At some point (dose level), the cost of continued cleanup up effort will exceed $5–10 million per life saved (even assuming LNT). At that point, cleanup efforts should stop.

This is especially true given that there are many ways to save lives that cost far less than $5–10 million per life saved. According to this article, the EPA’s proposed soot rule would only cost ~$5,000 per life saved. Also, according to my calculations, radon abatement (in a large fraction of U.S. homes) would cost only ~$100,000 per life saved (again, if you believe LNT).

Collective exposure vs. maximum individual risk

If one believes that there is a dose threshold (below which no health impacts occur), it may be logical to establish limits on dose rate (or annual dose) for individuals that are near that threshold. However, if one truly believes in LNT, limits on individual exposure have no logical basis. A simple mathematical result of the assumption that health risk scales linearly with dose is that the total health impact (i.e., numbers of sicknesses or deaths) scales directly with the collective exposure (in man-Rem). At the end of the day, the number of cancers is all that matters. Individual risk, and whether or not it is “acceptable”, is almost meaningless. Each person either gets cancer or not, and only the number of cancers matters.

Current limits invoke LNT (as they are far below the levels at which any health impacts are seen), but then establish extremely low limits on maximum individual risk (i.e., 10-4 to 10-6), as opposed to limits on collective exposure (in man-Rem). The way these current limits work, spreading the risk (pollution) out (e.g., tall smoke stacks) helps one comply with the limits, even though LNT (the very basis of those low limits) holds that spreading the risk out does not reduce the impact at all. It’s fallacies like this that make it possible for extremely low dose limits to apply for localized decommissioning or Superfund sites, that are having negligible impact, while fossil fuel air pollution (cars and coal plants) are causing tens of thousands of deaths every single year.

If LNT is to be the basis, correct policy would be to place limits on collective exposure, for any given industrial activity. For cleanup operations (or pollution prevention for that matter), a certain amount of money per man-Rem avoided should be required. Such policies would direct attention away from localized sites and towards more widespread pollutants that are actually having far larger health impacts. One thing is clear; these extremely low (10-4 to 10-6) limits on maximally-exposed individual dose have no logical basis and are completely indefensible.

Call to action

protective action guide 2013 c 201x259The draft EPA PAG is open for public comment until July 15. I urge American Nuclear Society members to respond. My personal view is that expensive cleanup operations or not allowing resettlement in areas with annual doses within the natural range (i.e., under ~1,000 mrem/year) is neither rational nor defensible. It wastes limited resources on a small to negligible public health benefit, and it inflicts needless suffering on the local population.

________________________

Hopf

Hopf

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.

 

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Posted in DC Perspective, Radiation

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Update and Perspective on Small Modular Reactor Development

Posted on March 21, 2013 by pbowersox| 14 Comments

By Jim Hopf

The US Department of Energy has a $452 million program to share development and licensing costs for selected small modular reactor (SMR) designs. The DOE’s goal is to have an operating SMR by ~2022. Last November, the DOE awarded the first grant to the B&W mPowerTM reactor. In more recent news, the DOE has decided to issue a follow-on solicitation to enter a similar cost-sharing agreement with one or more other SMR vendors (and their SMR designs). The status of development and licensing for several SMR designs are summarized below.

mPower (B&W)

B&W mPower SMR

The mPower reactor is a 180-MW pressurized water reactor. B&W was awarded the first cost-sharing agreement under the DOE’s SMR development program in November 2012. B&W has teamed up with Bechtel and the Tennessee Valley Authority to design, license, and build a set of 2-6 mPower modules at TVA’s Clinch River site. B&W plans to submit its design certification application (DCA) to the Nuclear Regulatory Commission by the end of this year.

NuScale

The NuScale reactor is an even smaller, 45-MW PWR reactor module. NuScale Power will apply for the follow-on (second round) DOE program cost-sharing award that was just announced. It has partnered with Fluor to develop and build the SMR, and is considering building its first SMR modules at the DOE Savannah River Site (SRS). It expects to submit its DCA to the NRC some time in 2015.

Holtec

Holtec International, which is developing a 160-MW (light water) SMR, may also apply for the second DOE grant, and is also interested in constructing its SMR at the SRS site.

Westinghouse

Westinghouse is developing a 225-MW PWR that shares many design features of its larger AP1000 plant. It is partnering with Burns & McDonnell, Electric Boat, and the Ameren utility to design, license, and build its first SMR plant at Ameren’s existing Callaway plant site in Missouri. It is expected to also apply for the second round of cost-sharing grants under the DOE’s SMR program. Westinghouse is expected to submit its DCA to the NRC in 2014.

Non-LWR SMRs

The most advanced non-light water SMR project is the Gen4 Energy’s lead-bismuth-cooled 25-MW reactor module (formerly Hyperion). Given the DOE’s focus on near-term SMR deployment, however, and the NRC’s indication that licensing a non-LWR will take a much longer amount of time, it is unclear whether non-light water SMRs have much prospect for winning a cost-sharing award under the DOE’s current SMR development program. Gen4 Energy withdrew its application for the initial round of DOE grants and it is not clear if it will apply for the second round.

Key desirable SMR features

My personal view is that SMRs should (ideally) have the following three features, entirely or to the extent possible:

  • The entire nuclear steam supply system (NSSS) can be factory built and rail-shipped to site.
  • The reactor can go indefinitely without offsite power or forced (pumped) cooling.
  • No on-site construction subject to NQA-1 requirements.

In a recent ANS post, I discussed issues such as the basemat rebar (and other) problems at Vogtle, as an example of the problems that are likely to occur when there are a large number of construction activities that are subject to NQA-1 and NRC oversight being performed on site, often by local suppliers or craft labor that do not have extensive experience with nuclear-related construction. Processes are much more controlled in a factory setting, where one is simply making a large number of copies of the exact same product (reactor design). Also, the factory would have dedicated staff that is highly experienced in making copies of that one product, and is very experienced with the applicable nuclear-grade fabrication and quality assurance requirements (e.g., NQA-1). The result is much higher levels of quality and consistency, with much less in the way of cost overruns or schedule delays.

For these reasons, it is imperative to have as much of the safety/nuclear-related construction as possible be done at the factory, and to minimize assembly and construction activities at the plant site. Thus, it is very preferable to have the entire NSSS (reactor and steam supply system, e.g., steam generators) sealed inside a container that can be shipped by rail to the plant site, without any at-site assembly required. Ideally, all components necessary for safety would be inside the “box” that arrives on the rail car, resulting in only non-nuclear grade construction activities at the site.

In that recent ANS post, I suggested that due to spiraling nuclear plant construction costs, a bottoms-up review is in order, in which all regulations and requirements are put on the table and objectively evaluated (using detailed probabilistic risk analyses, etc.) in terms of how much “bang for the buck” we’re getting in terms of overall safety. I made the suggestion (provocative to many, I’m sure) that NQA-1, i.e., a unique and extremely strict set of fabrication/QA requirements that only applies to the nuclear industry, most likely does not produce much safety benefit relative to its associated cost. I suggested that more typical QA standards and procedures that are used in most other large construction projects (bridges, dams, etc.) be used instead.

Well, with SMRs a “compromise” may be possible. Based on recent experience with Areva’s EPR (at Olkiluoko) and now at Vogtle, I had come to doubt that it was possible or practical to comply with those NRC and NQA-1 requirements, with on-site plant construction anyway. It seemed to be too difficult to comply with such strict requirements under field conditions, especially given the use of local labor and suppliers that do not have extensive experience with those requirements. The factory assembly line setting, however, is one setting where I can imagine it being practical to comply with strict NRC/NQA-1 requirements (with highly experienced staff, a controlled process, and NRC inspectors permanently present at the factory site).

Thus, with SMRs, almost all important-to-safety fabrication is performed at the factory site, and it could still be held to NQA-1 standards. Onsite activities at the nuclear plant that are subject to NQA-1 requirements can be greatly reduced or perhaps (as part of a “compromise”) eliminated. In my view, not having onsite construction activities be subject to (nuclear-unique) NQA-1 requirements, and instead letting the local construction entities use more typical QA requirements that they are familiar with, would greatly reduce costs and the risks of schedule delays, rework, and cost overruns. On the other hand, having NQA-1 standards apply at the reactor module factory would deliver virtually all of NQA-1’s safety benefit, without significantly increasing costs.

Finally, it would be highly desirable for the plant to have the attribute of always remaining sufficiently cool to avoid meltdown for an indefinite period without any outside power or active cooling (pumps, etc.). Post-Fukushima, such a feature may greatly increase political and public support for the reactor design. Also, such a feature would greatly reduce the plausible conditions under which meltdown and release could possibly occur. This, in turn, could greatly reduce the number of components or systems that must be classified as “safety related”, which would result in significant cost reductions (as well as reductions in actual accident/release probability).

Features of SMR candidates

The main SMR candidates that meet the goals listed above are as follows, based on their publicly presented information:

The mPower and NuScale vendors state that their entire NSSS will be fabricated at the factory and shipped (whole) to the plant site. Westinghouse is less clear, referring to “rail shippable scale” (which could refer to the entire NSSS, or a small number of NSSS component modules, which would require a limited amount of on-site assembly).

Hauling the NuScale reactor

NuScale very clearly states that its SMR is entirely passively cooled, and can go indefinitely without outside power and active (pumped) cooling. B&W (mPower) is less clear on this point, stating that no AC power is required for design basis safety functions, that they have three-day batteries to support DC-powered accident mitigation, and that the station can go up to 14 days (under loss of power conditions) without outside intervention. Gen4 Energy also states that its (lead-bismuth) reactor can go 14 days without power. I could not find a statement from Westinghouse concerning how long its SMR can go without any external power. Westinghouse does make reference to the operator having to add water (to a large tank) after seven days.

As expected, none of the SMR vendors discuss fabrication QA requirements for at-plant-site construction and components, or how many such components would be classified as safety related. Some have, however, performed some PRA analyses and do discuss the very low probability of core damage and significant release for their reactors. B&W (mPower) and NuScale state that their core damage frequencies (CDFs) are 10-8 and 10-7 per reactor year, respectively. By comparison, currently operating plants generally have CDFs of ~10-4 per reactor year and more recent large plants (e.g., AP1000) have CDFs under 10-6.

Cost and safety tradeoffs

Due to their smaller size and lower power densities, SMRs offer inherent safety advantages, largely because smaller reactors are easier to keep cool. As shown above, their chances of core damage are far lower than those of large reactors. In addition to a lower probability of core damage, their much smaller fuel inventory greatly reduces the maximum possible release. In fact, since these reactors probably can’t get nearly as hot, even in a core damage scenario, I’m guessing that their maximum core inventory release fractions (e.g., for cesium) under even worst-case meltdown conditions are also significantly smaller than those that apply for larger reactors. Thus, the maximum possible release is probably even less than the ratio of reactor powers (MW) would imply.

In order to get these advantages (along with the advantages of assembly line construction), they have to give up on economy of scale and power density, which will tend to increase costs. Some SMR vendors claim that groups of their modules will produce less expensive power than large reactors (e.g., the AP1000), but this remains to be seen. It is also unclear whether these modular reactors will be less expensive than fossil fuels (particularly gas). As I’ve often stated, these reactors cannot provide any health, environmental, or global warming benefits if they are not deployed. Thus, some actions may need to be taken to reduce costs.

This leads me to ask what SMRs will “get in return” for what they are giving up in terms of scale, power density, and increased fundamental safety. We may have to ask if there are any measures that could be taken that would reduce costs but result in a release probability that is closer to that of, say, the AP1000, as opposed to being orders of magnitude lower. In these evaluations, the much lower potential release from these reactors should also be fully considered. I believe that thorough evaluations of all potential cost-saving measures, supported by detailed PRA evaluations, should be performed.

One idea I discussed earlier is to use ordinary construction QA requirements for all on-site construction activities (i.e., for everything outside the NSSS that arrives by rail car). Given the much lower likelihood of core damage/release, the much smaller potential releases, and the fact that components outside the NSSS have a relatively small impact on overall safety (especially for these reactors), such an approach would be justified. In evaluating such an approach, we need to make reasonable determinations of both the probability and possible nature of failures of non-nuclear-qualified components. For example, the NuScale reactors lay in a large pool of water inside a concrete-walled underground pit. We have to ask ourselves: Is there any way the concrete could fail that would result in the water disappearing (especially given that the pool is underground)?

Other issues are operator and security staffing levels. The simplicity and inherently better safety of these designs should reduce the number of required operators and staff (and some SMR vendors are claiming just that). Security costs could be greatly reduced (in my view) if SMRs are placed on existing sites where large reactors already exist. Little extra security should be required, since the site is already protected.

Also, as discussed in my earlier post, licensing review should be fairly limited if one is placing a certified SMR design on a site that already has reactors. Almost like spent fuel dry storage casks, a simple review of the existing site evaluations, to verify that external parameters such as maximum ground accelerations and other environmental factors are bounded by the SMR’s generic safety evaluations, should be sufficient. An evaluation of some bounding number of reactor modules would then be done to address any impacts of the reactors on the site (e.g., a site boundary dose evaluation). After that is done, modules could be added without further licensing activity.

The NRC’s general philosophies, however, as well as some of its recent actions, leads me to believe that any kind of compromise may be too much to expect. In response to Fukushima, the NRC is increasing nuclear regulations even further. While we all agree that some specific improvements can and should be made as a result of lessons learned from Fukushima, there has been absolutely no discussion at all about whether any requirements should be pared back. This, despite the fact that Fukushima showed that the consequences of a severe (almost worst-case) meltdown are FAR smaller than what we had thought (and far smaller than the assumed accident consequences that many if not most of those requirements were based upon). For this reason, I’m inclined to believe that the NRC will take all the benefits of SMRs (i.e., the great reduction in release probability due to fundamental features) and give absolutely nothing back. That, despite the fact that some economic sacrifices (on economy of scale) had to be made in order to get those fundamental increases in safety.

If SMRs are to be viable, and provide safety, health, environmental, and global warming benefits, the NRC is going to have to make some compromises. If they do, SMRs may be able to provide an option that is not only economically competitive (allowing it to displace harmful fossil fuels), but is also far safer than current US nuclear plants, and as safe or safer than new large plants such as the AP1000.

_______________________

Hopf

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.

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Potential nuclear plant closures and what could be done to stop them

Posted on February 21, 2013 by pbowersox| 19 Comments

By Jim Hopf

Owners of the (556 MW) Kewaunee nuclear plant in Wisconsin recently announced that they will be closing the plant, because it was losing money and they were unable to find another company willing to buy it.

The reason the plant is losing money is that it is in a “merchant” power market, in which the price of electricity is governed by the cost of electricity from natural gas plants (those plants being the last, highest-variable cost, incremental supplier). Due to the current very low cost of natural gas, as well as weak demand due to a sluggish economy, the market price for electricity in those regions is very low. On top of this is the fact that small, one-unit plants like Kewaunee have relatively high operating costs, since many costs (including many of those associated with regulatory compliance, site security, etc.) do not scale down with plant size.

Unfortunately, it is possible that Kewaunee may not be the last plant to close for purely economic reasons. Many experts are saying that several other small plants in merchant power markets (including Vermont Yankee, Fitzpatrick, Nine Mile Point, Cooper, Ginna, Indian Point, and Clinton) are at risk of closing, due to weak demand and continuing low natural gas prices.

In addition to plants that may close for economic reasons, a few other reactors will or may close due to equipment problems. Based on estimates of $2–$3 billion to repair the Crystal River plant’s containment dome, Duke decided to close the Florida plant. Low natural gas prices almost certainly factored into that decision.

Meanwhile, the San Onofre plant in California has been offline for over a year due to tube failures in recently-installed steam generators that were based on a new design (that turned out to be problematic). Apparently (and surprisingly) it will take 4-6 years for new stream generators “that could pass regulatory muster” to be fabricated and installed. The utility is seeking Nuclear Regulatory Commission permission to run one of the two idled reactors at 70% power, based on analyses that show additional tube wear will not occur under those conditions.

Low gas prices likely temporary

Although many voices are saying that low natural gas prices (not much higher than current levels of $3–$4 per million BTU) will last for a long time, there are many reasons why this is unlikely to be true. The four main reasons are summarized below:

  • The price of natural gas is 4-6 times lower than that of oil, on a per unit energy (BTU) basis. Given that oil and gas are interchangeable for many uses/applications, such a difference in energy-equivalent price is unsustainable. In fact, plans are underway, as we speak, to use natural gas in the transport sector, mainly for large trucks and fleet vehicles. There are also plans to build Gas-to-Liquids (GTL) refineries that convert natural gas into clean diesel fuel.

  • The price of US natural gas ($3-$4/MBTU) is a factor of 3 to 4 times lower than what gas (LNG) sells for abroad, with Europe paying over $12/MBTU and Japan/Asia currently paying over $16/MBTU for LNG imports. Plans to export US gas are being made as we speak.  Such exports will even out worldwide gas prices, and lead to significantly higher US prices.

  • The price of natural gas is very sensitive to the balance between supply and demand, and demand should increase measurably in the coming years as the economy recovers.

  • Finally, and perhaps most significantly, the current price of natural gas is actually much lower than the raw cost of gas production for most US shale fields. This is clearly unsustainable. In fact, there has recently been a major shift in drilling activity (and drilling equipment) from gas to oil, since oil production is so much more profitable, given the much higher price for oil. Given the high decline rates for shale gas wells, any let up in exploration or the drilling of new wells will soon lead to declining production.

In addition to the above four reasons is the likelihood that increased (tightened) requirements will be placed on shale drilling operations, either by the Environmental Protection Agency or the states themselves, in order to protect groundwater and reduce air pollution. Such requirements would also result in somewhat higher production costs. Of course, if a price or limit on CO2 emissions is ever imposed, it would make existing nuclear plants more competitive vs. gas plants. Finally, it must be noted that new EPA pollution regulations are leading to a significant number of coal plant closures. Most of this coal capacity will be replaced by gas generation. The resultant increase in US gas demand will also put upward pressure on gas prices.

Given this, it seems likely that the unprofitability of the nuclear plants in question will be temporary; probably only a few years. For this reason, many nuclear plant owners (e.g., Exelon) have stated that they are not currently planning to close any plants. Thus, some of the plants listed earlier may not close, despite a negative short term situation. Given the likely short term nature of the situation, any such closures would be very unfortunate, and shortsighted.

Can anything be done?

The closure of nuclear plants like Kewaunee and Crystal River will have a devastating effect on the local economy, due to lost local jobs and a greatly reduced local tax base. As a result, some political efforts are being made to avoid closure. In Kewaunee’s case, a local legislator is proposing that nuclear qualify under the state’s renewable (or clean energy) portfolio standard. Depending on the details, and their design, however, many such proposals may not provide the assistance that the plant needs to remain open. As stated by the Kewaunee utility, what the plant really needed was a long-term power purchase agreement at an adequate price.

It would seem that the best solution would be to develop a means to either support the price or reduce operating costs, over the next few years, or somehow arrange (or incentivise) a power purchase agreement that would last for at least a few years.

Power price supports

One option would be for the government (federal, state, or local) to provide a minor level of price support for the plant’s power, with the understanding that such support would be only temporary (i.e., a few years). Given the current financial state of the federal government, any such support may be unlikely. However, given the negative local impacts of the plants’ closures, it may be in lower-level governments’ interest to offer some limited support, if it were enough to keep the plants open. Such governments would have to weigh the cost of any support against the permanent loss of local employment and tax base. The situation is analogous to how local areas offer economic incentives to attract large employers in the first place.

As for how a “price support” would work, one could take a cue from the support given to renewable energy over the years. Such government support has often taken the form of above market prices paid to renewable suppliers, or using “renewable energy certificates” to attain a renewable generation goal, and allowing renewable generators to sell those certificates (at a price determined by the market). In one way or another, the (local) government would pay off the difference between the market price for power and an agreed-upon price that the plant needs.

Another option would be to arrange for some type of power purchase agreement. Either the government would add some type of incentive for a private power consumer to enter into such an agreement with the plant, at least for a few years, or the government itself could enter into such a power purchase agreement with the plant. If the government’s own power demand is not large enough to use all the plant’s output, it could sell off any remaining power to private consumers at market rates (presumably at some loss to the government, that is, until gas prices go back up).

Many may say that such measures would be too expensive, that governments can’t afford it, or that any such interventions in the free market are not justified. It seems to me that the support these plants need is smaller in both magnitude and duration than the support that has been given to many renewable energy projects, in the form of operating subsidies or mandates for their use, regardless of cost (with power consumers being forced to pay the higher costs).

In terms of securing cost-stable, reliable, domestic, pollution-free, CO2-free base load generation for the long term, these may be among the most cost effective measures ever taken. In addition to preserving local employment and tax base, they would reduce the region’s vulnerability to natural gas price swings/spikes in the future. Call it a (temporary) subsidy on all (new or existing) emissions-free generation. It should be easier to justify than much larger renewable generation subsidies.

Reducing costs

Another option for keeping plants in operation would be measures to reduce their operating costs (or at least prevent them from increasing) for at least the next few years. Such measures could be removed in a few years, after the market price for power has recovered, and the plants can afford higher costs.

One example would be to delay any expensive Fukushima-related upgrades for plants that are currently barely profitable or (temporarily) unprofitable. After a several-year grace period, the plant would be required to make the upgrades. If the market price for power has still not recovered (due to gas prices not going up), then the plant would close if the upgrades would render it unprofitable.

As I discussed in my last post, requirements that result in the closure of nuclear plants, and their replacement by fossil-fueled generation (even gas) does not reduce public health and environmental risks; it actually increases them. Also, it’s not as though there is no precedent for such policies. After the Clean Air Act passed in 1970, the coal industry managed to get many (if not most) of its existing plants exempted (grandfathered) from the new law’s much stricter requirements.  The argument was that it would not make economic sense to retrofit old plants that would only be operating for a few more years anyway. It turns out that they kept operating those older plants (whose emissions of various pollutants are many, many times that allowed by the 1970 Clean Air Act) for 40 more years, and counting….

Note how there is no such thing as a “grandfather clause” for the nuclear industry, with respect to Fukushima upgrades or requirements in general (anything that NRC thinks is important). At a minimum, backfits are required if justified by cost-benefit analysis (something that is not required for grandfathered coal plants, where the benefits of CAA-mandated pollution controls greatly exceed any costs). Another difference is the fact that the overall public health and environmental risk/harm from the grandfathered coal plants is orders of magnitude larger than any from a nuclear plant without Fukushima upgrades (especially given the lack of earthquake and tsunami potential at all the sites in question).

On a more general note, with respect to Fukushima, I definitely agree that many intelligent, cost-effective measures should be taken in response to the lessons learned from the event. However, we’ve also learned that even a worst-case plant accident event (with multiple meltdowns followed by essentially a failure of containment) caused no deaths and is projected to have no measurable health impact. In other words, the public health impacts are FAR smaller than what had been previously assumed, as the basis for current regulatory policy. Given this, while I agree that some specific upgrades should be made in response to Fukushima, I’m wondering what requirements we should also consider paring back, given the much smaller potential impacts. Are any new cost-benefit analyses being performed?

To my knowledge, the NRC isn’t considering taking any steps in that direction. This is unfortunate, since some carefully-considered, strategic paring of certain requirements could possibly prevent plant closures, and may make nuclear more competitive in general, resulting in reduced use of (harmful) fossil fuels in the future. (Note that this would not be analogous to EPA relaxing pollution requirements so that coal plants could remain open, in that any replacement generation for old coal plants would be environmentally superior, whereas when a nuclear plant closes, its [fossil] replacement is environmentally inferior.)

In a similar vein, aside from Fukushima upgrades, one could explore other ways to reduce operating costs at small, vulnerable plants. Apparently, the operating cost for some of these plants (e.g., Ginna) is $40/MWh; much higher than the under $20/MWh operating cost that I was always told applies to existing nuclear plants. This must be due, in part, to their small size and single-unit nature. That said, one still has to ask why their operating costs are so high. I’m guessing that their staffing, per MW, is extremely high; higher than most nuclear plants and much higher than that of fossil plants (the 556 MW Kewaunee plant employed 655 people). In my personal opinion, the industry (e.g., INPO), Kewaunee plant operators, and the NRC should sit down and figure out why the staffing (and operating costs) are so high, and try to figure out a responsible way to reduce them. At least that much effort should be made to keep these plants open, given the impacts on the local economy and the long-term impacts on the environment, energy costs, and energy security. The industry needs to make more of an effort on this.

The Kewaunee plant is only ~5 miles from the larger, two-unit Point Beach nuclear plant. Both are pressurized water reactors. One question I have is why the plants could not be effectively managed and operated like a three-unit site, given the proximity. Are there any jobs/tasks at Kewaunee that could be handled by Point Beach personnel, or vice versa? I realize that this would result in staff reductions and lost jobs, but losing some jobs is better than losing them all. I also wonder if Kewaunee plant staff considered any wage/benefits concessions, or if management considered offering them before closing the plant and laying everyone off.

Mothball option?

One other option for temporarily unprofitable plants would be to mothball them for a few years, then reopen them when the market price for power recovers. The problem is that, due to various requirements (regulatory, etc.), it’s expensive to maintain a shutdown nuclear plant. If the owners give up the operating license, and switch over to a (“possession only”) license that applies to a decommissioned reactor state, it would be very expensive to gain permission to restart the plant. As a result, no nuclear plant that has been formally shutdown has ever been restarted.

This is one more thing that seems to be unique to the nuclear industry. Restarting a coal plant is much easier. In fact, while coal’s percentage of US generation has fallen from ~50% to ~32% over the last year or so, due to very low gas prices, utilities (e.g., Southern) have stated that they will switch many of those coal plants right back on once natural gas prices recover (i.e., once it is even slightly less expensive to run the coal plant, regardless of the much greater level of pollution). Some disincentive to pollute, which would at least raise the natural gas price at which utilities would switch old, highly-polluting coal plants back on, is clearly needed.

This is another area where some review of current policies is in order, in my opinion. As things stand, it is far too difficult and expensive to pull a closed nuclear plant back out of mothballs, and/or to maintain a plant in a “mothballed” state. I don’t really understand why maintaining the option of restarting a nuclear plant should make it that much more expensive to maintain a plant in a shutdown state. It’s not as though the risks and potential for release (from stored spent fuel, etc..) are any greater. Reform/scrutiny in this area should be more palatable than my earlier suggestions about paring requirements for operating plants, given the lower potential risks present during the long-term shutdown state.

Anyway, mothballing the plant is another option that should be studied by the local governments, the utility, and the NRC. If local governments want to keep the option of restarting the plant, they should try to find a way to make it happen (i.e., make it worthwhile for the utility).

Crystal River and San Onofre

Unlike plants like Kewaunee, the Crystal River plant is probably a lost cause given the (inexplicably) huge cost of repairing its containment dome. I still have to ask why no cost-benefit analysis is being done on the option of operating the plant in its current state. (It’s likely that the costs of repair greatly exceed any public health or economic risk reduction benefits.) I also feel compelled to point out that even if the plant were operated in its current (unrepaired) state, its overall risk to public health and the environment in the local area would be much smaller than that posed by the four coal units at the same site, that are going to continue to operate.

As for San Onofre, I am not sure what “that pass regulatory muster” means. Does it refer to installing generators of the old design, or does it refer to years of analysis (paralysis)? I have to ask why it will take 4–6 years to replace the steam generators (a piece of industrial heat exchange equipment). Does the replacement of large heat exchangers in any other industry take anywhere near this long?

Also, news reports are saying that the NRC is having some problem allowing the plant (steam generator?) to run at 70% because 100% was the design basis. I’m having trouble understanding how legal (licensing) issues could be a significant impediment. The engineering issues, i.e., the assertion that the steam generators can operate at that power level without further tube degradation, clearly need to be analyzed, but they should (expeditiously) perform the necessary engineering evaluations and move on.

Whatever these issues are, the NRC (and the utility) need to do what it takes to resolve them, in months not years. This is especially true given that to make up for the loss of San Onofre’s generation, they are firing up two old, dirty fossil units in the area; units that had been retired due to the fact that they did not meet current air pollution requirements, among other factors. Thus, the longer they delay, the greater the (real) impacts on public health in the region (as well as CO2 emissions) from those fossil units.

Is this beginning to sound like a theme? Going to the ends of the earth to avoid/reduce small nuclear risks, and ignoring much larger risks from fossil generation; fossil generation that is often being used to replace nuclear generation that is closed due to the relentless quest to reduce nuclear risks to zero.

______________________

Hopf

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.

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Post-election outlook for nuclear energy

Posted on November 21, 2012 by pbowersox| Comments Off

By Jim Hopf

In my September post at the ANS Nuclear Cafe, I discussed the Democratic and Republican party platforms, along with their potential impacts on nuclear energy. With the 2012 U.S. elections now behind us, this post provides a post-election follow up, and discusses the impacts of the election results on nuclear’s prospects over the near- to mid-term.

With the reelection of Barrack Obama, and minor gains by Democrats in the House and Senate, the election results portend a continuation of the status quo, for the most part. Impacts of the election in various areas that may impact nuclear’s prospects are discussed in the sections below.

Yucca Mountain

I’ve always taken great issue with the Obama administration’s actions on Yucca mountain, and maintain that, at a minimum, the Nuclear Regulatory Commission licensing process should be finished, even if a political decision is made to not pursue the project. It is clear to most observers that the NRC technical staff (which had completed its review) was about to conclude that the repository met all the technical requirements, before the process was terminated near the finish line, for political reasons. The public has a right to know that Yucca would have met all the requirements, and that yes indeed there is a viable, acceptable technical solution to the nuclear waste problem.

With the reelection of Obama and with (Democrat) Harry Reid remaining as Senate majority leader, the current status quo on Yucca Mountain will remain. Reid will continue to block funding for completion of NRC licensing, and the (Obama/Reid-appointed) NRC chair will likely cooperate with the effort to stop the process. As was the case before the election, whether the NRC will complete the licensing process will be primarily determined by the courts.

Yucca Mountain is one area where a Romney administration may have been more helpful to nuclear, but it’s not clear whether there would have been any meaningful difference. Romney was also making anti-Yucca statements (such as “states should have the right to decide if they want the repository”) during the campaign. Republicans winning the Senate would have made a far larger difference, as Reid would have lost the Majority Leader position, which is essential to his ability to block Yucca. On the other hand, if the president is not interested in changing the situation, even that may have not made much difference.

It seems that completion of the licensing process (the best we can hope for in the near term) is up to the courts at this point, and would have remained so regardless of who won the election. Also unclear is whether the lack of progress on the waste issue is having a significant effect on how much nuclear power there will be over the near-to-mid term. I’ve grown to believe that it is not as critical an issue as I formerly thought.

Fukushima–related upgrades and regulations

Whereas the anticipated regulations and required plant upgrades that will result from NRC’s response to Fukushima will add costs for existing nuclear plants (and to a small extent, new plants), it is unlikely that the outcome of the election would have had any significant impacts on those regulations. No parties or candidates have made any significant statements on the NRC’s actions in this area.

Nuclear plant loan guarantees

The Obama administration had supported increasing the nuclear loan guarantee volume by a factor of several (to over $100 billion) but could not get it through Congress. On the other hand, the Obama administration has been dragging its feet in actually approving any loan guarantees, even for the Vogtle and Summer plants. With the current budget situation, any increase in loan volume is unlikely.

It is unlikely, however, that Romney or the Republicans would have been better in the area of nuclear loan guarantees. Although the Republicans are ostensibly pro-nuclear, many in the Republican party are opposed to loan guarantees for any energy projects.

Finally, the overall impact of the nuclear loan guarantees is no longer clear. Indications are that other factors such as lack of power demand and low natural gas prices, as opposed to the lack of loan guarantees, are the primary reason that no plants other than Vogtle and Summer (and Watts Bar) are going forward. As for the Vogtle and Summer projects themselves, they appear to be going forward even without the government loan guarantees.

Climate change policies

Although the Obama administration is not planning to propose a cap-and-trade system or a carbon tax in the near future, Obama has stated that the nation needs to have a “conversation” about climate change, implying a desire to develop some type of policy.

It seems clear that the chances of some type of policy or progress on climate change are far greater under Obama and the Democrats then they would have been under Romney and the Republicans, who had explicitly promised to block all such efforts. For example, the chances of the Clean Energy Standard policy (being debated and developed in Congress) moving forward would definitely be greater under the Democrats. Any type of climate change policy that creates a disincentive to emit CO2 would be tremendously beneficial to nuclear, particularly over the longer term.

Although climate change had fallen off the agenda in recent years, and in the last election, there are reasons to believe that it will (again) rise in importance. Increasing numbers of Americans believe that climate change is a serious issue. As the economy improves, issues like the environment are expected to become more important in voters’ minds. Also of note is the fact that even some conservative organizations are starting to consider a CO2 tax as a better approach than cap-and-trade, as well as a potential source of government revenue in lieu of increased income tax rates (as one example).

Election impacts on coal

It is clear that the reelection of Obama has hurt coal’s future prospects. The coal companies themselves, as well as the stock market, confirm this. Coal company stocks fell substantially after the election, and some coal companies have laid off workers.

Under Obama, the Environmental Protection Agency is in the process of significantly tightening up air pollution requirements, which would significantly impact the oldest (and dirtiest) coal facilities. To stay in operation, such plants would have to spend large amounts of money on air pollution controls. Given the current low cost of natural gas, these requirements will render those facilities uneconomic, and many are expected to close. With Obama’s reelection, the EPA is also expected to proceed with a rule that requires all new power plants to emit no more CO2 than a typical gas-fired plant; a requirement that essentially precludes the permitting of any new coal plants.

In contrast, Romney (and the Republicans) campaigned on the promise to stop any tightening of air pollution limits, and perhaps even rolling requirements back. Their message was that they would act not only to keep existing coal plants open (including the oldest ones), but to increase the use of coal in the future. They emphatically opposed any efforts to reduce power-sector CO2 emissions.
With respect to any impact on nuclear’s future prospects, policies that result in the closure of old coal plants would help, the only question being how much. Any retired coal-fired generation will be replaced by gas-fired generation (as opposed to nuclear), at least over the short to mid-term. Over the longer term, however, the resulting increase in gas demand will result in higher natural gas prices, which in turn would make nuclear more competitive.

Regardless of any impact they may eventually have on nuclear, these air pollution and global warming policies are the right thing to do, in my personal opinion. Nuclear professionals and advocates need to ask themselves why, specifically, they support nuclear, i.e., why it’s important. Given our abundant reserves of coal (let alone gas), coupled with coal generation’s low cost, the economic and energy security arguments for nuclear may appear relatively weak—if they come from someone who doesn’t care so much about the environment, and therefore would have no problem with expanded fossil fuel use. The most compelling argument for nuclear (for me, anyway) has always been its environmental benefits. By extension, if one cares about air pollution and global warming, these policies are something to be celebrated, whether or not it is nuclear that replaces the old, dirty coal plants.

Wind tax credit

The reelection of Obama, and the Democrats’ small gains in Congress, make it somewhat more likely that the (~2 cent/kW-hr) wind energy production tax credit will be extended, for at least some period of time. Romney had stated that he would seek to end the tax credit, whereas Obama supports it. Even now, however, it is not clear that it will be extended, given the great need to cut government spending. This is true despite the fact that many Republican lawmakers, from farm states mainly, support the tax credit.

The wind power tax credit has some degree of negative economic impact on both new nuclear plant projects and existing plants. Wind often produces surges of power at times of very low power demand, which can actually lead to a negative market price for power over some time periods. The tax credit makes it still profitable to run the windfarms even under such conditions. These situations have a significant negative economic impact on existing nuclear generators in the region, which cannot shut down over short time periods. These problems are particularly acute in Illinois, where wind is being introduced and there is a large amount of nuclear generation (without much fossil generation that can be cut back in times of low wind demand). As a result, Exelon (the regional utility) has changed its position and is now opposing the extension of the wind power tax credit.

One final potential impact of the wind tax credit is that since it will result in more wind power, gas demand will be somewhat lower in the future, which may result in lower natural gas prices that would in turn make nuclear somewhat less competitive.

A legitimate issue that nuclear supporters should have with the wind tax credit is the question of fairness, i.e., why one non-polluting form of energy should benefit from large subsidies and (often) outright government mandates, whereas another, nuclear, does not. Yes, new nuclear plants also get a tax credit, but unlike with wind, the credit is limited to just the first few plants. Another issue is whether wind is being sufficiently penalized for its intermittent nature (producing power when it is least needed). Perhaps having the tax credit not apply during periods of very low demand, or some type of mechanism to support the electricity price during such glut periods, should be in order.

Natural gas

I have saved the best for last. Most experts agree that the single most important factor that affects nuclear’s future prospects is the price of natural gas. If gas remains at current (very low) prices over the long term, not only will few, if any, new nuclear plants be built (beyond Vogtle and Summer), but even the continued operation of existing plants may be threatened.

A perfect example of this is the recently announced closure of the Kewaunee nuclear plant. The plant lies within a “merchant” market, where the price of electricity is determined by the “last” supplier (highest variable cost), which is usually a gas plant. With the low price of natural gas, market prices for power in the region are very low. At current prices, Kewaunee is losing money. (This came as a shock to me, as the whole idea with nuclear is that whereas the initial capital cost is high, the operating cost, once built, is extremely low, low enough to easily compete with anything—or so I thought.)

If anything, the reelection of Obama and the Democrats somewhat increases the chances that the price of natural gas will increase in the future. They are considering tightening regulations on the fracking process, to a greater extent than the Republicans would have (although neither party is showing a significant degree of interest). Also, as I discussed earlier, Obama’s policies concerning coal (and perhaps global warming in general) can only lead to higher demand for gas, which would act to increase prices.

It seems that the common wisdom today is that natural gas prices will remain low for a very long time. Others have a different view, although they seem to be in the minority, at present. To me, it seems clear that gas prices will increase significantly in the future, at least from today’s historic lows, for several reasons:

First, the cost of natural gas is extremely sensitive to the balance between supply and demand. As the economy improves, and gas demand increases (especially if large numbers of old coal plants are retired), gas prices will increase, a lot. Second, gas costs several times what oil does, on an energy equivalent (per BTU) basis. Given that these two fuels are supposed to be largely interchangeable, this situation cannot last. (Right now several proposals for using natural gas for transportation are being explored.) Third, natural gas costs 3–4 times as much (as current U.S. prices) in Europe and 5–6 times as much in Japan. This is also a situation that won’t last, and plans are being made right now to export U.S. gas to world markets. And finally, today’s natural gas prices are far lower than what it actually costs to extract the gas (about half, actually), and producers are losing money hand over fist. This, again, is a situation that cannot last.

Summary

The election results largely preserve the status quo concerning policies that affect nuclear and energy in general. So, as to whether or not Romney and the Republicans would have been better or worse for nuclear, it’s a mixed bag of offsetting effects. In any event, few new nuclear plant projects are expected over the short term due to the current low price of natural gas in the United States. Over the longer term, nuclear’s future looks significantly brighter, especially if a serious global warming policy is (eventually) implemented.

___________________________________

Hopf

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.

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Update on Nuclear Waste Confidence Court Ruling

Posted on October 22, 2012 by pbowersox| 5 Comments

By Jim Hopf

As I discussed in a June 20 ANS Nuclear Cafe post, a federal appeals court rejected the Nuclear Regulatory Commission’s new nuclear Waste Confidence rule, and ordered the NRC to perform a more thorough evaluation that addresses potential risks and health and environmental impacts of very long term storage of nuclear waste at nuclear sites (until a final disposal option is developed).

As discussed in that post, anti-nuclear organizations were hopeful that the court ruling would lead to a halt in NRC licenses for new plants and plant life extensions, while others believed that the impact would be minor, the main result simply being more work to be done by the NRC. Recent events have shown both sides to be right, to some degree.

NRC’s response to the court ruling

In September, the NRC instructed staff to develop an environmental impact statement (EIS) to evaluate very long term storage of used nuclear fuel, and a revised Waste Confidence ruling. The NRC expects to complete the work in ~24 months. The NRC’s analysis will address issues raised by the court, including the impact if a repository is never built, as well as risks to spent fuel pools from leaks or fires.

The upshot is that the NRC believes that it can address the issues raised by a court, within a reasonable time period.

Suspension of licensing activity

On the other hand, and to the delight of nuclear opponents, the NRC also announced that it will not issue any final licenses for new nuclear power plants or 20-year life extensions (for existing plants) until the revised EIS and Waste Confidence ruling are completed and the court’s issues are addressed.

The NRC’s decision appears to affirm the nuclear opponents’ position that new plants or extended operation of existing ones cannot be justified in the absence of a valid Waste Confidence determination. On the other hand, most experts (as well as the NRC) believe that the issue can be resolved with additional analysis and evaluation. At worst, some additional measures and costs may be involved, such as moving more fuel from spent fuel pools to dry storage casks, spent fuel pool modifications and upgrades, more rigorous long-term monitoring of dry storage casks, or the possibility of repackaging stored spent fuel, if necessary.

Limited impact

As serious as it sounds, the impacts of the suspension of licensing are minor to non-existent, at least over the short-to-mid term.

For both new plants and plant life extensions, the NRC has stated that it will continue with all on-going work on license applications. The NRC will simply not formally release any final licensing decisions. Thus, the NRC’s completion of work related to any license applications will not be delayed. The only parties that would be affected are those that were expecting final licensing decisions over the next ~two years.

With respect to new plants, both of the reactor projects at Vogtle, in Georgia, and Summer, in South Carolina, can still go forward, since they have already received their final construction and operating licenses (COLs). A few other plant projects (e.g., the Levy project in Florida) are in the licensing process, but most if not all of these other projects are currently planning to only obtain the license, and have not decided (yet) to proceed with construction. It is unlikely that any projects other than Vogtle and Summer would have decided to start construction over the next two years anyway (for several reasons, including lack of demand for new capacity and low natural gas prices). Thus, the two-year hiatus in (final) licensing decisions is not expected to have any impact on new plant projects.

With respect to existing plants, there are several plant life extension applications before the NRC. In theory, there are many such applications that would be affected by the two-year licensing freeze. However, plants are allowed to keep operating while life extension applications are in NRC review (and would only be required to shut down in the event of a formal rejection of a life extension application by the NRC). Thus, the freeze in final licensing decisions will not result in any plant shutdowns, or any other impacts on such plants.

For the above reasons, the two-year freeze in final licensing decisions by the NRC is not expected to have any impact on the industry. The only potential impact will come ~two years from now, after the completion of the revised EIS and Waste Confidence ruling, in the form of additional requirements related to used fuel storage.

My perspective

As I discussed in my earlier post, I find the court’s characterization of stored used nuclear fuel as a significant public health and environmental risk to be absurd, given the perfect, several-decade record of (dry and wet) fuel storage, and the lack of potential impact from dry fuel storage casks under any scenario. Unlike, say, fossil-fueled power generation, stored nuclear fuel has never had any impact at all on public health or the environment, and almost certainly never will.

As for the environmental impact analysis, I can sum it up in one sentence: “The public health risk and environmental impact from extended storage of used nuclear fuel is negligible compared to the impacts of the fossil-fueled power generation that would be otherwise used, in place of nuclear generation that was shut down or never built due to lack of ‘confidence’ in used fuel storage.”

I’m still waiting on a similar “waste confidence” evaluation for fossil-fueled plants, or a plan to capture, contain, and store all of their wastes/pollutants, for as long as they remain hazardous. How can our society get it so backwards in terms of which energy sources have a serious, intractable “waste problem”, and which source is the only one with a valid, acceptable long-term plan?

I work in the dry storage area, and I know that the maximum potential release from a dry storage cask that could result from any form or system degradation, any type of accident, or (even) any potential terrorist attack, would not have significant off-site consequences (certainly nothing that would approach even the daily impact from U.S. fossil-fueled generation).

We have already started detailed evaluations of the issues related to very long term dry fuel storage. Currently, opinion is that no significant degradation of the fuel assemblies is expected to occur, even over 100 years or more of dry storage. As the fuel decays, temperatures inside the cask will decrease (as will radiation levels). This reduces the driving force behind many potential fuel assembly degradation mechanisms. The metal components of dry storage systems, including the canisters that contain the assemblies, are expected to hold up well (and already have, over decades of storage). Whether the concrete vaults/silos (storage casks) that the canisters are placed in will be able to hold up over the very long term is somewhat less clear. That would be a problem that is easily solved, however, as the inner canister could simply be extracted and placed within a new concrete container.

Based on my dry storage experience, it seems to me that, along with (possibly) requiring some spent fuel pool upgrades, all the NRC should have to do to adequately resolve the court’s concerns is require some additional monitoring of dry storage casks, along with (perhaps) some additional money to be set aside by utilities to cover any potential issues that may occur down the road (including the possibility of some repackaging, decades from now).

One thing that should be obvious is that storage of used nuclear fuel is “acceptable”, even if it is assumed to remain on the nuclear plant site indefinitely, since any public health risks and environmental impacts are negligible compared to those associated with fossil-fueled power generation (gas as well as coal).

______________________________

Hopf

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.

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The party platforms on energy–and nuclear

Posted on September 18, 2012 by pbowersox| 9 Comments

By Jim Hopf

Both the Republicans and the Democrats have recently released their party platforms. Here’s a look at what each platform has to say about energy and environmental issues in general, and on nuclear specifically.

Republicans on energy

The Republican party platform favors an “all-of-the-above” energy strategy that involves responsible development of all our energy resources, and results in a domestic, secure energy supply that is stable, reliable, and affordable. Other general goals of the strategy include the creation of jobs, spurring economic growth, lower energy prices, and a strengthened domestic energy industry. The platform states that it does not support, however, policies that “pick winners and losers” through government intervention in the energy industry.

With respect to environmental regulations, the platform is generally opposed to federal environmental regulations and the Environmental Protection Agency, preferring regulation by the states as well as an approach to achieving environmental goals that is more cooperative (vs. punitive) with industry.

With respect to coal, the platform support the development of new “environmentally responsible” coal plants, as well as research and development into clean coal technology and technologies to convert coal into liquid fuel or gas (that can be cleanly burned). The platform states that it is opposed to President Obama’s “war on coal”, since there is no economic replacement for coal (the largest electricity source) and reductions in coal use will result in the loss of large amounts of jobs in that sector. It states that the GOP is opposed to any type of carbon dioxide–limiting legislation such as cap-and-trade. It also opposes the EPA’s regulation of greenhouse gases, and supports legislation that specifically bars the EPA from doing so. It also appears to be generally opposed to stricter limits on other coal pollutants as well.

With respect to oil and gas, the platform claims that the use of imported oil is undesirable in that some of the money sent overseas may wind up in the hands of nations, or other groups, that want to harm the United States. The main response, favored in the platform, is the opening up of offshore areas, federal lands, and the Arctic National Wildlife Refuge to oil and gas development. In addition to reducing oil imports and increasing energy security, the platform states that the resulting domestic oil and gas development will result in large numbers of new jobs. It also explicitly states its support for the Keystone XL oil pipeline (from Canada to refineries in the United States) for similar reasons, and it criticized Obama for opposing the pipeline. It also expressed support for natural gas fracking and opposed new federal regulations on the practice, saying that state regulations are sufficient.

The platform touched briefly on renewable energy, stating that it supports the development of renewable energy in general, but that it was opposed to government loan guarantees for renewable projects. It instead favors a “market based approach” to renewable energy development. (Not in the platform is that most Republicans also oppose extension of the wind energy tax credit, one of the most significant federal renewable energy subsidies.)

Democrats on energy

The Democratic party platform does not have a section on energy per se. Its policies related to energy can be found in the section on the environment. The discussion on energy is shorter in general than it is in the Republican platform, and it generally does not discuss specific energy sources.

The platform states that protecting the environment is a top priority for the party, and touts Obama’s investments in clean energy and the administration’s efforts to protect the environment. It states that Obama has made the most significant strides in decades to cut pollution, citing the increase in the fuel efficiency standard for vehicles as an example. It specifically talks about many of the pollutants that primarily arise from coal-fired power plants and states that they are a significant threat to health. It states that clean energy development will be a significant source of domestic jobs. It also highlights Obama’s (first time ever) proposed limits on CO2 for new power plants.

Much of the platform’s discussion relates to climate change (global warming). It affirms the party’s belief that global warming is a problem, calling it “one of the biggest threats of this generation–an economic, environmental and national security catastrophe in the making”. It says that the administration (and party) will combat global warming by exercising leadership on the issue abroad, while using “market and regulatory solutions” to reduce emissions at home. It argues that domestic reductions are necessary to show leadership on the issue, which is essential to getting a global agreement to reduce emissions.

Specifically, the platform states that the administration will continue diplomatic efforts to work toward an international agreement to limit/reduce emissions. At home, Obama and the Democrats will continue to invest in clean energy, and will take steps (both legislative and regulatory) to reduce domestic emissions. Regulatory measures include the (already passed) vehicle gas mileage standard and the (proposed) EPA regulations that limit CO2 from new power plants (effectively requiring CO2 sequestration for any new coal plant). Possible legislative efforts would include cap-and-trade, some kind of CO2 tax, or the proposed Clean Energy Standard for getting ~80 percent of electricity from “clean” sources by 2035. None of these legislative options are specifically mentioned in the platform, however, with discussion of specific CO2 limiting policies such as cap-and-trade being conspicuously absent.

In another section of the platform, it states that global warming also represents a “real, urgent and severe” national security risk, arguing that it will result in increased geopolitical conflicts over resources (e.g., water) and refugees, will result in suffering from drought and famine (creating potential instability in various regions), and increased frequency and severity of natural disasters.

Finally, the platform criticizes the Republican party (and candidate), stating that the GOP doubts the science of climate change and wants to roll back regulations protecting our air and water. It also states that the Republicans do not recognize the benefits of the Clean Air and Clean Water Acts, and do not recognize the jobs created by clean energy development.

Nuclear energy

In a relatively brief (two paragraph) discussion, the Republican platform expresses support for nuclear energy, saying that it “must be expanded”. It calls for timely review of new reactor license applications by the Nuclear Regulatory Commission. It also raises the waste issue, stating that federal government’s failure to address storage and disposal of spent fuel has cost “the States and taxpayers” a lot of money. It calls for a “more proactive” approach for managing spent fuel, which includes the development of advanced reprocessing technologies. Mention of Yucca Mountain is conspicuously absent.

The Democratic platform is completely silent on nuclear energy. Although the platform generally does not mention specific energy sources (as I said earlier), it also does not touch on any policies or proposals that would affect nuclear in any way.

Who’s better for nuclear?

While the Republicans have generally had kinder words for nuclear than the Democrats, it’s less clear whether or not Republican policies would be more helpful to the industry. In general, it appears that while Republicans may be more helpful in the area of waste, Democratic policies such as CO2 limits (and stricter limits on fossil fuel pollution in general) would do more to make nuclear more economically competitive with fossil fuels.

Waste issues

In the area of waste, it would be hard to do worse than the Obama administration, with the shameful termination of the Yucca Mountain licensing process, and the (political) suppression of the results of the NRC staff’s essentially finished licensing review (which virtually everyone knows was about to approve the repository). The administration also appointed not one but two NRC chairmen whose opposition to Yucca Mountain was clearly the primary basis for their selection. On the other hand, would the Republicans be much better? Given that Yucca is not mentioned at all in their platform, it appears that they are not willing to stand up for the repository (or the completion of the licensing process, at least) either.

My view is that the waste issue does not impact nuclear’s competitiveness, since the cost of storing the waste, even over a long time period, is very small—on the order of 0.1 cents/kW-hr. The primary impact of the continued delay in resolving the waste issue is that it strengthens and extends the false notion, held by much of the public, that nuclear waste disposal is an intractable problem with no technical solution. This, in turn, results in increased opposition to the construction or continued operation of nuclear plants. For this reason, I’ve advocated the completion of Yucca’s licensing process, even if the project itself is not continued, since it will show the public that we had a technically sound solution. I personally doubt that alternative solutions—such as the reprocessing discussed by the Republicans, which involves going back to the drawing board and pushing resolution of the issue decades into the future—will have much positive impact.

All that said, it’s not clear that public opposition to nuclear over the waste issue is all that big a factor, in the grand scheme of things. It has not led to much increased opposition to specific projects, especially in the Southeast, where most new plants are proposed. The biggest obstacle to new nuclear plants is clearly economic competitiveness (with fossil fuels, especially gas).

Economic competitiveness

The Republicans made a vague statement about expediting the NRC review of new reactor projects, but specifics, and any real impact, remains to be seen. One would hope that now that the initial license applications (e.g., Vogtle and Summer) have been approved, follow-on applications would go pretty quickly. In any event, a somewhat faster approval process will not help nuclear’s competitiveness that much. (The cost of the licensing process is more of an issue.)

On the other hand, policies that would significantly reign in fossil fuels’ privilege of just dumping massive amounts of pollution (including CO2) into the environment, for free, would significantly increase nuclear’s competitiveness in the future. I’ve always believed that nuclear will never stand much of a chance if it is required to completely contain all of its wastes/toxins (with even the small possibility of release being something that has to be avoided, almost regardless of cost), while its competitors have nowhere near the same requirements.

Policies that would aid nuclear’s competitiveness (in addition to being the right thing to do) would be taxing or limiting CO2 emissions, reducing allowable emissions levels for other toxic pollutants (e.g., particulates, mercury, etc.), classifying coal ash/sludge as a hazardous material, and doing something to more adequately regulate gas fracking, which currently enjoys an exemption from the Clean Water and Safe Drinking Water Acts (I believe).

The EPA’s proposed policy that effectively bans new coal plants that don’t employ CO2 sequestration would have a huge impact over the long term. Although it would mainly result in the replacement of coal with gas over the shorter term, it would greatly help nuclear over the long term, since it would increase gas demand (leading to higher natural gas prices). I (and many others) also believe that the current gas glut will not last forever, and that renewables will never be capable of providing most (let alone all) of our power generation.

It’s clear which party would be better in this regard. Many in the Republican party are actually calling for pollution regulations to be rolled back, let alone be improved. The GOP platform clearly states that it will block any attempts to tax or limit CO2, prevent or reverse the EPA’s proposed policy on new coal plants, and oppose any regulations on gas fracking. With fossil fuels getting such a (continued) free ride, and the regulatory playing field remaining so unlevel and unfair, it is hard to see nuclear being competitive in the future.

Some may argue that global warming policies will not happen anyway, so having more reasonable treatment of nuclear in the waste area, as well as (perhaps) better NRC appointments, would make the Republicans better for nuclear, over the next presidential term. My personal view is that the EPA’s new coal plant rule alone, not to mention not having air pollution regulations rolled back, is more than enough to offset those benefits, in terms of the overall climate for nuclear.

Nuclear’s influence?

My general view is that the Republicans primarily support fossil fuels while the Democrats primarily support renewables. Both are now supporting gas, to some degree. Neither party supports nuclear to any significant degree.

This is due to a profound lack of influence in Washington by the nuclear industry, compared to other energy industries. Recently, some have tried to suggest that the industry (Exelon Corp., specifically) has had significant influence with Obama, due to campaign contributions and its presence in Illinois. This view is absurd. Here’s a question: What is the ONLY major energy source that was NOT mentioned at all in Obama’s Democratic convention speech? He (the Democratic candidate) even made brief mention of “clean coal”, but didn’t mention nuclear at all.

Due in large part to this lack of influence, the current regulatory playing field is heavily slanted against nuclear, with nuclear’s requirements being orders of magnitude more strict than those applied to fossil fuels (as measured by dollars spent per unit of public health and safety benefit, etc.). Five years ago, it seemed like things were finally moving in a more fair, balanced direction, with the prospect of CO2 limits, etc., but now things seem set to get even worse.

We have the NRC considering adding even more regulation, and arguing that current regulations are insufficient since the Fukushima event inflicted significant economic costs, even though the public health impacts have been very small—much smaller than what NRC had always assumed the consequences of a severe meltdown would be (i.e, current regulations were always based on the assumption that such an event would be vastly more harmful). Meanwhile, we hear calls from the right side of the political spectrum, to reign in or even eliminate the EPA, with no similar calls for the NRC. Humble proposals to merely reduce the ~20,000 annual deaths, in the United States alone, from fossil plant pollution are loudly decried, while nuclear requirements are being increased even further, in a quest to reduce even the chance of the release of pollution to even more negligible levels, without any fanfare or political resistance (even from the industry itself).

Nuclear’s complete lack of political influence, and the overly powerful influence of other sources such as coal, is starting to be examined in some quarters—a recent article by William Tucker being one example.

If our industry does not find a voice, its future does not look bright. We will continue to have policies such as Renewable Portfolio Standards (that mandate the use of large amounts of renewable energy, regardless of cost or practically) on one side, while continuing to allow fossil fuel plants to freely pollute on the other. The tremendously unlevel regulatory playing field between nuclear and fossil sources will remain, or get even worse.

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Hopf

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.

 

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Posted in American Nuclear Society, DC Perspective, Fukushima, Nuclear Regulatory Commission, Yucca Mountain

Court upholds EPA greenhouse gas regulations

Posted on July 18, 2012 by pbowersox| 1 Comment

By Jim Hopf

In a strongly worded unanimous decision, a federal appeals court recently upheld the Environmental Protection Agency’s authority to regulate greenhouse gas emissions, as well as the EPA’s “endangerment finding” that holds that those gases present a threat to human health and welfare. The court also upheld the EPA’s authority to “tailor” such regulations as it sees fit, which will allow the EPA to exempt small sources of emissions and focus its regulations on large emitters (which would be more practical, and a less expensive way of reducing emissions). The court stated that the EPA’s interpretation of the Clean Air Act (CAA) requirements was “unambiguously correct” and that its proposed rules were neither capricious nor arbitrary.

Lawsuits had been filed by organizations including the U.S. Chamber of Commerce, the National Mining Association, and the National Association of Manufacturers, as well as the states of Texas and Virginia. The plaintiffs had argued that the proposed regulations would be “devastating,” and would result in substantial economic costs and job losses, which would be especially harmful in times of economic weakness and high unemployment. In response to the ruling, the plaintiffs have stated that all legal avenues are being considered, and that there is a good chance that they will appeal.

One of the first specific EPA greenhouse gas regulations is a proposed rule that concerns new power plants. The rule would require any new plant to have CO2 emissions equal to or less than that of a modern natural gas-fired plant. Thus, any new coal plants would have to rely on some form/degree of carbon sequestration in order to comply. Since large-scale, economic, commercially available sequestration technology does not yet exist, this is generally viewed as being a de-facto ban on new coal plant construction.

Political responses/ramifications

Legal

Although the current Supreme Court is generally considered “conservative,” it may be unlikely that any appeal of the appeals court ruling would be successful. After all, in 2007 the Supreme Court ruled that the EPA violated the CAA by NOT taking any action to address global warming emissions.

Essentially, the CAA simply requires that hazardous air pollution be adequately addressed, and it leaves the details (and specific cases) up to the EPA (and to science). Thus, unless the CAA is amended, it comes down to science, and the scientific case was (apparently) already successfully made to the Supreme Court. Thus, unless there is some major new scientific evidence to present (showing that global warming is not an issue), it is unlikely that the court will reverse itself, especially given that the EPA is now on the other side of the issue.

Legislative

In the legislative arena, Republicans have vowed to pass legislation that would specifically remove EPA’s authority to regulate greenhouse gas emissions. Mitt Romney has stated that he would support such legislation, as well as efforts to roll back other EPA requirements on other fossil plant pollutants.

While this legislative approach would pass constitutional muster, the effort is unlikely to succeed, given the current Democratic control of both the senate and the presidency. It’s doubtful such a law could pass even if Romney wins in November and the Republicans gain a majority in the senate. In present day Washington, 60 senate votes are necessary to pass any significant or controversial piece of legislation, and it is very unlikely that the Republicans (or those opposed to action on global warming) would ever get such a large senate majority.

Administrative

The final avenue for opposing EPA greenhouse gas rules is in the administrative arena (if Romney becomes president). Here, the situation is a little less clear.

The EPA is part of the administrative branch, and answers to the president. A new EPA head would be appointed by Romney, and would likely share his views on greenhouse gas regulations. Would a Romney EPA simply halt the development of any proposed rules? If the rules are formally established before he takes office, would his EPA actually rescind the rules? Could they simply choose not to enforce them?

I couldn’t find any references to Romney having plans to defeat greenhouse gas regulations administratively; only references to his support of legislative efforts. Perhaps the reason for this is the 2007 Supreme Court ruling. In that case, the Bush EPA was dragging its feet in terms of regulating greenhouse gases, and the court basically said that they had to do something. Thus, if a Romney EPA tries to rescind or not enforce greenhouse gas regulations, the agency will be sued, and it is likely that the courts will require the EPA to take action, given that the CAA has not been amended.

Economic cost of emissions controls

I don’t find opponents’ arguments about greenhouse gas regulations having a “devastating” economic impact at all compelling, especially given the current low cost of natural gas. These are largely the same people who are crowing the loudest about the “miracle” of low cost (shale) gas, and how much it will benefit the economy. But they then try to ignore the low gas cost when they make grim predictions about the effect of coal plant closures on electricity prices and the overall economy. They can’t have it both ways.

Currently, gas prices are so low that many utilities are voluntarily shutting down coal plants and firing up (or even building) gas generation to take its place. Note that they are making this decision despite the fact that there is absolutely no economic incentive being given to choose gas over coal (i.e., to reflect coal’s higher CO2 emissions and the enormous environmental/health impacts of its other pollutants).

For the first time ever, gas recently accounted for the same fraction of U.S. power generation (32 percent) as coal did. A dramatic example is Southern Company, a large, historically coal-dependent power utility. As recently as five years ago, Southern got 70 percent of its power from coal and only 16 percent from natural gas. Now they’re getting only 35 percent from coal and 47 percent from gas.

In general, utilities are planning on shutting many of their existing coal plants in a few years, rather than installing expensive retrofits that will be required by EPA rules already on the books. Instead, that generation will be replaced by gas (and a few new nuclear plants).

Again, these decisions were made in the absence of any economic disincentive (e.g., tax) for CO2 emissions or any other pollutants. Thus, we’re seeing a substantial reduction in CO2 emissions without any economic cost. As many experts have pointed out, EPA’s (de-facto) no-new-coal-plant rule is entirely moot, since no coal plants are (or will be) built anyway. As we’re seeing, even existing coal plants are finding it hard to compete with gas. Paying a high capital cost to build new coal plants is a non-starter (especially given that most utilities still expect some kind of CO2 limits or penalties, eventually).

The need for emissions reduction policies

Given how close gas and coal generation are right now in terms of operating cost, it seems clear that even a small economic disincentive to use coal would go a very long way, and result in a much larger reduction in coal use.

My belief is that given the low cost of natural gas, we’ve lost every last excuse for keeping very old, grossly-polluting coal plants open. There are no longer any valid economic arguments, given that the incremental cost of replacing those plants with gas generation would be minimal. I find the notion of using coal instead of gas (or nuclear, or renewables) just because the operating cost is slightly lower to be very disturbing. This shows why we must have policies that place at least some economic weight on health and environmental impacts. In an earlier post, I discussed the possibility of using the dispatch queue to give preference to cleaner generation.

Most experts agree that natural gas prices will go back up at some point, after the economy recovers. Will coal plants closed today remain closed in the future? In our (nuclear) industry they certainly do. On the other hand, many utility executives have said that they will go right back to coal (i.e., reopen old coal plants) once gas prices increase. Strict pollution regulations, or even a small price on CO2 emissions, would go a long way toward preventing coal plant restarts, and would significantly raise the gas price threshold at which such restarts would be considered.

The EPA’s proposed power plant rule would effectively rule out new coal plants. Stricter pollution controls, policies that tax or limit CO2 emissions, or the proposed Clean Energy Standard would all act to speed the retirement of old, heavily-polluting coal plants. Such policies that place a small economic penalty on CO2 emissions and/or other air pollutants will lead to significant reductions in emissions at a very modest cost to the overall economy.

Impact on nuclear

The above policies would increase gas demand in the short term, which will eventually result in higher gas costs. This will make nuclear more competitive. Without these rules/policies, nuclear’s future looks rather doubtful, frankly, as it will probably remain more expensive than coal, and continued coal use would act to keep gas prices low.

The basic fact is that if nuclear is required to completely contain all of its wastes/toxins, for as long as they remain hazardous, and competing sources are allowed to freely dump their toxins into the environment, at no cost, it’s hard to see how nuclear will ever have a chance. It’s a matter of fairness, if nothing else.

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Hopf

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.

 

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Posted in DC Perspective, Environmental Benefits of Nuclear

The NRC chair and Yucca Mountain

Posted on June 20, 2012 by pbowersox| 2 Comments

By Jim Hopf

Several important events have recently occurred involving the U.S. Nuclear Regulatory Commission, the Yucca Mountain nuclear waste repository, and the interactions between the two.

New NRC chairman

Last month, NRC Chairman Gregory Jaczko stated that he would resign as soon as his replacement was appointed. His resignation was likely the result of political pressure and questions raised regarding his management of the NRC (which I’ve discussed in an earlier post).

Soon afterward, the Obama administration nominated Allison Macfarlane as a replacement for Jaczko. Macfarlane has a PhD in geology from the Massachusetts Institute of Technology, and is an associate professor of environmental science and policy at George Mason University. She also served as a member of the Blue Ribbon Commission on America’s Nuclear Future.

Based on past statements she’s made and publications she’s authored, it is clear that Macfarlane is an opponent of the Yucca Mountain repository. She had referred to it as seismically and volcanically unstable, and said that its selection “broke the covenant with the states that the siting process would be fair and the best site would be selected.” Her views may be reflected in the conclusions of the Blue Ribbon Commission, which recommended the long-term dry storage of used nuclear fuel, and a new “consent-based” repository siting process. Macfarlane is also on record as supporting the idea of moving used fuel into dry storage as soon as possible to reduce fuel pool-related risks.

Nonetheless, it appears that opposition to Macfarlane’s appointment as chairman has been relatively muted. There appears to be a (political) understanding that Macfarlane would be accepted as chairman, as long as Kristine Svinicki is also reappointed to another term as a commissioner (Svinicki’s term expires on June 30). Republican (pro-Yucca) senators have stated that they will not block Macfarlane’s nomination, and their questioning during Senate confirmation hearings was relatively mild. The Nuclear Energy Institute (NEI) has also not opposed her nomination. On the flip side, Democratic senators have made it clear that they will, in turn, accept Svinicki’s reappointment.

Based on the above, it appears clear that Macfarlane will soon be appointed as NRC chairman and Svinicki will reappointed for another term as commissioner.

Court decisions on waste program

There have also been important recent court decisions pertaining to the U.S. nuclear waste program.

In a unanimous decision, a federal appeals court has given the US Department of Energy six months to explain/justify continuing to collect a 0.1 cent/kW-hr waste disposal fee from nuclear utilities, given that there is no plan on the table for permanent disposal (with the abandonment of Yucca Mountain). The plaintiffs were seeking a halt or suspension of the fee. In six months, the court will rule on whether the DOE has given sufficient justification for continued collection of the waste fee. The plaintiffs and other observers are confident that the DOE will not be able to come up with a sufficient justification at that time.

Another recent federal appeals court decision threw out the NRC’s waste confidence ruling, which had concluded that waste could be safely stored on (plant) site for as long as 60 years after plant closure, and that a repository would become available when necessary. The court said that the NRC’s evaluation failed to consider the impact if a repository doesn’t become available, and did not adequately assess the risks of long term on-site storage. The chief judge wrote that “the commission’s evaluation of the risks of spent nuclear fuel is deficient,” and that spent fuel “poses a dangerous long-term health and environmental risk.”

Opinion on the impact of this second ruling varied widely. Anti-nuclear groups (including some of the plaintiffs) hailed the decision and hoped that it would eventually block the NRC from granting new reactor licenses or reactor life extensions.

Klein

Others—including former NRC Chairman Dale Klein—believe that the impact will be relatively small, and that it will simply be a matter of the NRC doing additional work, such as allowing more public comment (some of the court decision text appears to support this view as well.) The NRC could also perform site specific (as opposed to generic) evaluations of long-term fuel storage risks. Others in the industry actually view the ruling in a positive light, thinking that it will put pressure on the government to move forward with solutions to the waste problem, such as centralized storage or licensing a repository (e.g., Yucca). NEI disagreed with the ruling, and urged the NRC to quickly address the court’s concerns.

Finally, there is a federal appeals court decision due sometime this summer as to whether the NRC is legally required to finish the Yucca Mountain license application. While the Nuclear Waste Policy Act requires the NRC to evaluate the application, the NRC is arguing that since Congress has not appropriated any more money to the NRC to complete the task, it “cannot” do so. Yucca supporters have pointed to $10 million that the NRC has at its disposal for the task, but the NRC maintains that $10 million is not nearly enough money to finish the task. Meanwhile, the House recently approved an additional $10 million for the NRC to complete the licensing review. The fate of this funding in the Senate is unclear (of course).

In addition to disagreeing with the lack of funding argument in general, Yucca supporters point out that while $10 million may not be enough to get through the legal hearings phase of the process, the NRC could certainly release the safety evaluation reports (SERs), which give the scientific/technical conclusions of NRC staff (which almost everyone believes concluded that Yucca Mountain met the requirements).

Perspective on Macfarlane’s appointment

Macfarlane

As for the NRC chairman position, the selection of Macfarlane was clearly political, as was the selection of her predecessor. It is clear that one of the primary, if not the primary, basis for her selection was her opposition to Yucca Mountain. It’s clear that opposition to Yucca was a requirement (i.e., a litmus test) for being considered for NRC chairman; a testament to the power of Senate Majority Leader Reid. Macfarlane’s background is in geology and public policy, with some experience in nuclear waste issues. She has very little background or experience in the area of nuclear power or nuclear reactor technology. (Then again, neither did her predecessor.)

NEI’s acquiescence to Macfarlane’s selection as chairman is either a sign that they know that they won’t be able to get anything better, or that they are more focused on reactor issues and are willing to let Yucca go by the wayside. (It is true that, frankly, long term on-site storage of used fuel does not represent a significant cost, in the grand scheme of things.)

Jaczko’s conditioning his leaving on the appointment of a successor was politically shrewd, in that it gave the advantage to Reid and Obama. Refusal to accept anti-Yucca nominees by Yucca supporters in Congress would have simply led to Jaczko staying on indefinitely. Thus, the choice was clearly between Jaczko or another Yucca opponent. My only question is, couldn’t NEI, and other industry supporters (in Congress, etc..), have held out for a Yucca opponent who also knows a thing or two about nuclear power/reactors?

Macfarlane may be right that Yucca may not be the very best repository site anywhere in the country, and yes it would be ideal to have both local and state consent for a repository (note that Yucca DOES have local consent). But that’s not the point, at least as far as the Yucca license application is concerned. The question is whether Yucca is good enough to meet the requirements (impeccable requirements that far exceed those applied to any other waste stream). After spending billions on Yucca analysis, the American public deserves to at least know if Yucca would have met the requirements, and if it remains a viable disposal option (if we ever decided to use it).

All indications are, however, that Macfarlane will continue to do what Jaczko has done, which is to use administrative tricks and the lack of funding excuse to effectively halt the licensing process. She will probably also try to prevent the release of the SERs (which show that the repository passed the NRC staff’s objective, scientific evaluations). Whatever you believe about policy, whether or not Yucca passed the specified technical requirements is a matter of simple fact/truth. How can anyone in good conscience favor the suppression of the truth? I find the actions of Jaczko (along with Reid, possibly Obama, and soon to be Macfarlane) in this specific area to be unconscionable.

Yucca Mountain's north crest

I’ve always believed that the release of the SERs, or having Yucca pass the NRC licensing review, would be of significant value even if a political/policy decision were made to not proceed with the repository. A significant fraction of the public is laboring under the false notion that there is no practical or technical solution to the waste problem (i.e., they don’t understand that it is purely a political problem that has been technically solved). This is a significant source of opposition to nuclear. If we go back to the drawing board (in a quest to find a “consent-based” repository), without getting it on record that Yucca passed the (impeccable) technical requirements and is a technically viable solution, the public will go on believing the false premise that there is not (and may never be) an acceptable technical solution to the waste problem. This will have a negative impact on public support for new reactors going forward.

With Macfarlane at the helm, and any funding for completing the licensing review likely to be blocked by Reid, the only hope for completing the licensing review may be in the courts. Let’s hope that the courts understand that the political will of one man (Reid) does NOT represent the will of Congress. Many votes have already made clear that large bipartisan majorities in both houses support Yucca, and that it is only the power of one man, over both legislation and appropriations, that is causing the current situation. Given that the Nuclear Waste Policy Act was passed into law (making Congress’ intent at that time clear), and that finishing the application still reflects the will of the great majority of legislators, the court should see that finishing the application is the clear “will of Congress”, one senator’s undue influence over the budget and appropriations process notwithstanding.

Perspective on court decision

As for the court decision throwing out the NRC’s waste confidence ruling, all I can say is that I hope the optimists are right (i.e., that it’s just a matter of doing some more work or that the ruling is a means by which the government will be pressured to move a waste solution forward). Personally, the decision makes me a bit nervous. The anti-nukes seem to believe that it will lead to blockage or shutdown of reactors.

Can we be sure that the government (or courts) will not take such a (drastic) step? What will be sufficient to satisfy the court? Will centralized long-term storage facilities be enough, or will we need a repository (or at least tangible progress in that regard)? Or will further analysis into technical issues of very-long-term dry storage be sufficient? Again, this is an area where having a licensed repository would be of value, even if the political/policy decision (at present) is not to pursue it.

I personally take issue with the court’s characterization of stored nuclear fuel as “a dangerous long-term health and environmental risk”. As someone who works in the dry used fuel storage field, I’m confident that the risks of long-term storage are negligible. The issue of whether fuel is stored in pools or in dry storage casks is independent of the issue of how long it takes to establish a repository. The result of a lack of (or delay in) a repository is increased dry fuel storage (not pool storage) especially given that confidence ruling considered the period after the plants are closed/decommissioned (where all fuel is in dry storage). There are few, if any, conceivable mechanisms that would cause a significant release from dry storage casks. Tangible or significant public health impacts are all but inconceivable. Also, inspections of casks, which have been loaded for ~20 years, are not showing significant degradation of the cask materials.

In addition, one must ask the question, “dangerous compared to what”? The (obvious) fact is that the risks associated with long-term dry fuel storage are negligible compared to the public health and environmental risks associated with the fossil fuel plants that would be used in lieu of nuclear plants, if nuclear plants were closed (or not built) over the lack of a waste confidence rule. One would hope that the NRC would mention such issues (risk comparisons that look at the bigger picture) in the revised waste confidence evaluations required by the court. But alas, I wouldn’t hold my breath . . .

I’ve been advocating looking at the bigger picture (i.e., the risks of nuclear compared to the fossil fuel alternatives) for some time now, with respect to a lot of things, such as deciding nuclear regulations and how strict they should be. I’d love to see a cost vs. public health risk benefit analysis for the Vogtle basemat rebar issue. Any remotely reasonable evaluation would conclude: “use as is”. But, of course, no such evaluation will be done (“verbatim compliance!”).

There’s one positive development in this area, however. The American Nuclear Sociery has taken a courageous stand in its Fukushima Committee Report, where it suggests that the federal government quantitatively assess the relative risks/impacts between nuclear and other energy sources. Hopefully, the conclusions of such an evaluation would be considered when making decisions on future requirements for nuclear plants. It may perhaps lead to recognition that if such requirements were to result in nuclear plant closures, public health risks and environmental impacts would increase due to the use of fossil fuels instead.

_____________________________________

Hopf

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.

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Posted in DC Perspective, Department of Energy, licensing, Nuclear Regulatory Commission, Yucca Mountain

ANS Friday Nuclear Matinee: The Basics of Nuclear Energy

Posted on May 11, 2012 by pbowersox| 1 Comment

Today’s matinee is a foreign film feature: an excellent overview of the very basics of nuclear energy.

The video is courtesy of Emirates Nuclear Energy Corporation. The United Arab Emirates is embarking on an ambitious nuclear energy program, having signed a nuclear cooperation agreement in 2009 with the United States, and construction of the UAE’s first reactor is scheduled to begin later this year (for background and details see this ANS Nuclear Cafe interview with the UAE Ambassador to the IAEA).  Whether or not the agreement should serve as a model for all future nuclear cooperation agreements between the United States and other countries was the basis of this week’s ANS Nuclear Cafe DC Perspective article by Jim Hopf.

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Posted in DC Perspective, Education

Congressional debate over terms of future 123 agreements

Posted on May 7, 2012 by pbowersox| Comments Off

By Jim Hopf

In 2009, the United States and the United Arab Emirates (UAE) signed a “123” agreement, which allowed the transfer of US nuclear technology (e.g., reactors, etc.) to the UAE. As a condition of the agreement, the UAE gave up all rights to enrich uranium or reprocess spent nuclear fuel, now and at any point in the future. Thus, the UAE agreed to give up significant rights that are granted to it as a signee of the nuclear Non-Proliferation Treaty (NPT).

The UAE agreement is now fueling a debate in Washington as to whether or not similar conditions should apply to all future US 123 agreements with nations that want to start nuclear programs.

The debate has significance since several more 123 agreements will be considered in the near future, with nations such as Vietnam, Jordan, and possibly Saudi Arabia. Some of these nations (e.g., Jordan) have significant uranium reserves that they may desire to exploit someday, which may make them reluctant to give away any future enrichment rights.

Pros and Cons

The arguments for requiring new nuclear nations to give up rights to enrichment and reprocessing, as a condition of any 123 agreement with the US, are as follows:

  • Unlike power reactors, enrichment and reprocessing facilities can potentially give those nations access to weapons-useable nuclear materials, and could greatly shorten the time required to develop a weapon, if they ever chose to do so.
  • Given the mature, well-established, competitive world industry for uranium enrichment services (with multiple enrichment facilities in several developed nations), there will not be a need for developing countries to establish enrichment or reprocessing facilities.
  • It would not make economic (or practical) sense for a new nuclear nation with a small number of power reactors to develop enrichment or reprocessing capability and construct those expensive facilities. Thus, any desire to do so would be suspect.
  • Holding all nuclear entrants to such high standards would strengthen the international community’s arguments against less cooperative nations such as Iran.

There are, however, many arguments against requiring terms similar to the UAE agreement for all future 123 agreements. These include:

  • Such a (US) policy would have little effect since there are several developed nuclear nations, including France, Russia, China, and South Korea, competing in the world nuclear market that will not make such demands on potential customers.
  • Few new (developing) nations would be willing to surrender rights granted to them under the NPT, especially given that most nuclear supplier nations will make no such demands.
  • If (as a result) few such nations enter into 123 agreements with the US, the US will lose influence over those nations’ nuclear power programs, which would stem from their dependence on US technologies, and our involvement with their reactor operations.
  • It is possible that such nations would instead turn to suppliers with less safe reactor designs, and a lower level of experience and/or excellence in reactor operations.
  • Without an absolute no-enrichment requirement, the US may (on a case-by-case basis) be able to successfully negotiate 123 agreements that are stronger (stricter) than agreements offered by other nuclear supplier nations. With an absolute no future enrichment requirement, most nations will almost certainly instead enter into agreements with other supplier nations, which may make few if any demands.
  • If a 123 agreement with the US is in place, and the US therefore has influence and involvement with a country’s nuclear program, the US may be better able to convince that nation to not engage in fuel cycle activities in the future.
  • There are other ways to limit enrichment activities, including actions by the Nuclear Suppliers Group and ensuring that a reliable and adequate supply of enrichment services exists in the world market.
  • Finally, requirements for entering into an agreement with the US that are much stricter than those required by other suppliers will likely result in US reactor and nuclear technology companies being shut out of much, if not most, of the market in the developing world. In addition to any negative safety or proliferation impacts, this will have a significant negative economic and employment impact in the US.

House Bill

A bill, H.R. 1280, which essentially requires the same terms as the UAE agreement for all future 123 agreements, has been introduced in the House. It has passed the Foreign Affairs committee and is now being debated in the Rules committee. It may soon be voted on by the full House.

In addition to prohibiting enrichment or reprocessing facilities at any point in the future, the bill requires:

  • Limited access to facilities, equipment or materials by 3rd country nationals (personnel of a separate nationality to both the US and the developing nuclear nation).
  • Implementation of chemical and biological (weapon) production and stockpiling conventions.
  • Implementation of an export control system.
  • Cooperation with the US in preventing state sponsors of terrorism gaining access to weapons of mass destruction (WMDs).
  • A ban on (non-humanitarian) assistance to nations that have not signed the NPT.
  • Joint congressional approval for any changes or additions to the terms of new 123 agreements.
  • Liability protections for US nuclear suppliers similar to those given under the Convention on Supplementary Compensation for Nuclear Damage (i.e., more protection than India is offering).

Tauscher – Poneman Letter

On January 10 of this year, Undersecretary of State for arms control and international security Ellen Tauscher and Deputy Secretary of Energy Daniel Poneman wrote a letter to key congressional committee leaders. The letter stated that an administration internal policy review has concluded that future 123 agreements should be made on a case-by-case basis, and that the administration would not seek the same requirements agreed to by the UAE for all future agreements.

The letter gave many of the reasons listed above (and argued elsewhere) as to why an absolute no-enrichment-requirement for all 123 agreements would not be good policy. The letter also discussed other actions that may or are being taken, including strengthened enrichment activity guidelines agreed to by the Nuclear Suppliers Group, nuclear fuel reserves, fuel leasing arrangements, and progress towards establishing a Nuclear Fuel Bank.

On the basis of the above-referenced letter, it appears that the administration will not be in favor of the House bill. The bill also faces a very uncertain future in the US Senate.

Additional Thoughts

I find some encouragement in the fact that even the non-proliferation side now appears to have accepted that power reactors in developing countries do not present a significant proliferation risk, and that the focus should be on enrichment and/or reprocessing facilities. I’ve always believed this, since spent power reactor fuel is at least as hard to convert into weapons material as raw uranium ore. The widely held belief that Iran’s enrichment activities (independent of nuclear power plants) constitute a proliferation risk further supports this principle.

Now, the debate seems to have shifted to what is the best way to prevent such fuel cycle facilities from popping up in more countries. Given that there is ample enrichment capability in the (developed) world, any such limitations should not significantly hold back the deployment of nuclear power.

The administration and others have argued that new nuclear states are likely to be reluctant to give up enrichment rights granted to them under the NPT, since they have uranium reserves and may want to complete the supply chain, or they don’t fully trust the current supplier nations to reliably supply the needed enrichment services. I would add a psychological/political reason. Policies that restrict fuel cycle facilities (or nuclear technology in general, or even nuclear weapons) to a set of existing “advanced” nations implies a notion that “we are civilized enough to responsibly handle this technology, but you are not.” Such notions tend to produce negative or contrary responses from most people (or nations). They will be very inclined to opt for the suppliers who do not make such (condescending?) demands, especially given that the right to fuel cycle technology is enshrined in the NPT, which they willingly signed.

Also of note is the fact that natural gas prices in the U.S. are currently very low (~$2/MBTU) and may stay relatively low for some time. This may limit the prospects for new nuclear here in the U.S. This makes access to international markets—where natural gas prices are much higher—even more important to the U.S. nuclear industry. Small modular reactors (SMRs) in particular, are an area where the U.S. may be able to take the technological lead and reestablish leadership in the world nuclear industry. A healthy market for those SMRs, however, would be necessary.

Conclusion

It seems to me that policies like those outlined in H.R. 1280 would not provide any of their intended benefits unless there was an agreement between all nuclear supplier states to follow those policies. Without such an international agreement, all H.R. 1280 will do is harm the US nuclear industry, and have significant negative economic and employment impacts here at home.

H.R. 1280 may even have negative worldwide impacts in terms of nuclear safety as well as nuclear proliferation, since it will result in most, if not all, nuclear entrant states forging agreements with other nuclear supplier states instead. Those other states are likely to be willing to enter into nuclear supply agreements that have less stringent requirements than what the US would be likely to negotiate, on a case-by-case basis, in the absence of H.R. 1280.

__________________________

Hopf

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.

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Posted in DC Perspective, Export Control, Nonproliferation, Nuclear Fuel Cycle, nuclear technology, U.S. Congress

Good and bad news stories for nuclear 2011/2012

Posted on March 22, 2012 by pbowersox| 8 Comments

By Jim Hopf

After giving a brief update on recent Fukushima-related events in the United States, I’d like to talk about some good (but relatively unpublicized) things that have happened during what has otherwise been a very challenging year for the nuclear industry. Then I’ll discuss what, to me, was the most disconcerting story in the past year.

NRC response to Fukushima

The Nuclear Regulatory Commission published a series of new requirements for U.S. nuclear plants, as a result of its evaluation of the Fukushima event. Requirements include seismic evaluations and upgrades (if necessary), the addition of portable pumps and generators (sited at multiple, protected locations), and enhanced monitoring capability for spent fuel pools. For many older boiling water reactors, hardened vents may be required (if not already in place). Another requirement being discussed is the ability to maintain operations (and cooling) without off-site power indefinitely (as opposed to the current requirement of 4–8 hours).

During Senate testimony, NRC Chairman Jaczko and other commissioners appeared to disagree over the amount of time that will be required for plants to make the proposed changes. Jaczko stated that some of the changes are likely to take until 2017–2019 (something that he said he was “concerned” about), whereas other commissioners thought that the changes will be in place by 2016.

Good news in 2011/2012

We’re all aware of the fact that the final NRC licenses were finally granted for construction of the new Vogtle reactors. It is also true that the project is within budget and schedule so far. Some lesser-known bits of good news are discussed below.

NRC Accident Consequence Statement

This is one potentially very positive thing that happened for the industry recently, without much publicity or fanfare. In part as a result of its evaluation of Fukushima, the NRC released a position statement concerning the potential consequences of (even worst case) nuclear plant accidents. The NRC (finally) acknowledged what many of us have known for a long time. It stated that the risk to public health, even from a severe accident, is “very small”. It also stated that the risk of short-term fatalities from acute exposure was “essentially zero,” and that the scenario of a large amount of radiation being released very quickly
(thus requiring a rapid evacuation) was unrealistic.

This is probably as close as we’re going to get to a formal retraction of the earlier analyses/assumptions that formed the basis of emergency response planning over previous decades. These grossly unrealistic analyses predicted thousands of immediate deaths from acute exposure, followed by tens of thousands of long-term cancers. Chernobyl had already shown those analyses to be completely unrealistic, and (I suppose) Fukushima, with its complete lack of health impacts, was the final nail in the coffin.

But, alas, I suppose I’m being unrealistic in hoping that this could lead to some relief with respect to emergency planning requirements. Indeed, many seem to be drawing precisely the reverse conclusion, asking whether evacuation zones should be increased (never mind that many other facilities that are actually more dangerous, such as chemical plants, oil refineries, etc., do not have similar evacuation zones).

This is a shame, given that these evacuation zones/plans have always been an albatross around the industry’s neck that has been used relentlessly by nuclear opponents (e.g., the Shoreham plant). They always argue about how rapid evacuation may not be practical. Well, we’ve just (finally) realized that it’s not necessary!

Fukushima also showed that, even with respect to longer-term impacts, significant effects of even a worst-case meltdown do not extend beyond ~20–25 miles of the plant (in any direction). And yet we still hear people talking about populations as far as 50 miles from plants (e.g., New York City from the Indian Point plant).

Clean Energy Standard Legislation

The Senate Energy Committee finally released a detailed legislative proposal for a Clean Energy Standard. The final proposal is the result of many years of analysis and negotiation. While it is unlikely to pass (or be considered) this year, it is considered more likely to pass than other options such as comprehensive global warming legislation. It has the potential support of several moderate Republicans.

The good news is that the final details of the legislation appear to be rational and even-handed, and fairly good for the nuclear industry. The Standard requires that 85 percent of U.S. electricity generation be from “clean” sources by 2035. While the final version does allow partial credit for fossil sources like gas, the amount of partial credit scales (inversely) with the level of CO2 emissions (relative to a coal plant). Thus, non-emitting sources like nuclear would retain a significant advantage over gas, particularly in the later phases of the program (when an all-gas generation profile would no longer be able to meet the requirements).

SMRs Move Forward

The U.S. Department of Energy recently decided to provide $452 million in funding for licensing of small modular reactors (SMRs), over the next five years. The DOE is also making plans to host three SMR demonstration projects on the Savannah River Site. The three selected reactors are the 45-megawatt (MW) NuScale Pressurized Water Reactor (PWR), the 25-MW Gen4 Energy fast reactor, and a 140-MW PWR reactor from Holtec.

Hopefully, construction of the prototypes will speed the technological development of these reactors, although NRC licensing should occur in parallel. Use of the Savannah River complex may make siting these prototype reactors easier, which could speed licensing and deployment.

A New Low Level Waste Site (at last)

The Waste Control Specialists’ low level waste (LLW) site in Texas (near the New Mexico border) will soon begin operation. The site will take waste from 38 states. It will handle all types of LLW, including Class A, B, and C. Given the closure of the Barnwell site to out-of-compact waste, the Texas site is now the only site that accepts all classes of LLW from most states.

This represents a significant victory, given the level of difficulty the nation has had in siting new LLW disposal facilities, anywhere, for many decades. This is the first site to open in 30 years. For some time, the political task of opening new LLW sites was thought to be intractable.

It should also be noted that within the same general area (in southeast New Mexico), the local communities around the DOE’s WIPP repository are actively seeking to host the nation’s spent fuel and high-level waste as well. There is some indication that the state government is willing to consider the option.

Sanity Prevails in France

The French government recently released a new long-term energy options evaluation that concludes that the most economical and practical option is to extend the operating life of its existing reactor fleet from 40 years to 60 years.

In the past, French policy had always appeared to be to replace its reactors with new ones after ~40 years of life.  Given the long-standing position in the United States that light water reactors (LWRs) could be run safely for 60 or more years, I’ve always found the (old) French position to be puzzling. I wondered if it was, in part, just a means of creating extra work to keep its domestic industry employed and on top of its game, similar to U.S. Depression-era make-work programs.

In any event, it seems like they’ve finally come to their senses. Any new nukes should be used to increase, not maintain, capacity (i.e., be used to replace fossil fuels). The cost savings will be enormous. Perhaps this new position is partly a result of Fukushima. With political support for new reactor construction much lower, perhaps the French government concluded that the only way their nuclear capacity would be maintained would be through extended operation.

The biggest bad news story of 2011/2012

Despite the positive news stories discussed above, my level of optimism for nuclear’s future was deeply shaken last year, not by the Fukushima event itself, but by the public/media/political reaction to it, particularly in Japan.

Here in the United States, Fukushima is somewhat less significant. Polls show only small reductions in public support. New nukes remain highly popular in most regions/locations where new reactors are being considered. Also, in the United States, several other factors, including the lack of any global warming policies on the horizon, the fact that the economic downturn suppressed future power demand growth, and low natural gas costs due to the shale gas “miracle,” loom larger over nuclear’s future.

In the rest of the world, however, Fukushima has had a surprisingly large impact on public opinion in many, if not most nations. In addition to Japan and Germany, anti-nuclear opinion has surged in other nations with strong nuclear programs, such as France and South Korea. The reaction in Germany does not surprise or upset me much. They are merely returning to their usual long-standing anti-nuclear position (with the 2022 nuclear phase-out date actually being two years later than a long-standing 2020 phase-out date). I was (and am) utterly dismayed, however, by the public/political reaction in Japan.

Japanese Reaction

If one asks the question of how big a natural disaster (e.g., earthquake) a nuclear plant should be able to take, the rational answer is clearly not “infinite.” One quite reasonable answer given by many people is that the disaster should be sufficiently large that if it did occur, a meltdown would be the least of their problems. One would think that Fukushima would be a textbook case of this, with ~20,000 deaths from the earthquake and tsunami, no immediate deaths from the meltdown, and few if any projected future deaths. It is also true that the number of evacuees and lost homes due to the earthquake and tsunami is larger than that from the radiation release.

But then, we watched in horror as the world’s attention (media, etc.) focused mostly on the plant meltdown, as opposed to the earthquake and tsunami. Not only were the enormous impacts of the earthquake and tsunami (deaths, etc.) deemed less newsworthy than the plant meltdowns, but so were the vastly larger ongoing health and environmental impacts of fossil fuel generation. Apparently, such logical thinking on our part does not adequately consider various psychological and political factors.

According to the World Health Organization, fossil-fueled power generation causes hundreds of thousands of deaths, worldwide, every single year (i.e., on the order of 1000 deaths every single day). Even conservative estimates, based on the pessimistic linear-no-threshold assumption, predict less than ~1000 eventual deaths from Fukushima. Thus, in terms of health impacts, worldwide fossil fuel power generation is having an impact equal to (or worse than) having a Fukushima event occur every single day. And that’s before considering global warming.

Despite these facts, the people of Japan, and their political leaders, are apparently ready to shut down their nuclear plants and replace them with vastly more dangerous and harmful fossil fuel generation. They are willing to do this even through it will mean greatly increased air pollution and CO2 emissions, and will have a devastating effect on their economy. Japan has always had an export-driven industrial economy with large trade surpluses. For the first time in memory, however, Japan will be running a trade deficit, primarily due to the increased fossil fuel imports that are necessary to replace their nuclear generation. In addition to horrendous health and environmental impacts, the fossil generation will result in markedly higher power costs. Many of Japan’s heavy industries have threatened to move off-shore.

Double standard forever?

These reactions, in Japan and elsewhere, are leading me to believe that there is a deeply-ingrained prejudice against nuclear power as a means of power production; one that may never disappear. Whether it is the legacy of the bomb, or is due to enormous media/political influence of the world fossil fuel industry (who knows?), the fact is that minor impacts from nuclear are given far more attention, and are far less tolerated, than far larger impacts from fossil fuels and other technologies.

The double standard is also alive and well in the United States. Not only has the U.S. nuclear industry accepted the NRC’s new requirements without significant resistance, but they’ve even proactively pursued improvements on their own, without being legally required to do so. And yet, in congressional hearings
and elsewhere, many are not satisfied with the rate or amount of improvement,
saying that having to wait over five years is an unacceptable risk. Meanwhile, old “grandfathered” coal plants in the United States are still not meeting the requirements of the 1970 Clean Air Act, the result being tens of thousands of annual deaths. Despite the fact that the public health risks in question are orders of magnitude larger in the coal plants’ case, apparently taking over 40 years is okay for them, whereas five years is too long for nuclear’s Fukushima upgrades.

Nuclear has always been held to standards thousands of times as strict (in terms of dollars spent per life saved, etc.) than fossil fuels. Before Fuksushima, with all the attention being paid to global warming, I had thought that the playing field might start to become somewhat more balanced. Now, after Fukushima, nuclear requirements are becoming even more strict (with any notions of regulatory relief being put to bed), whereas attempts are now being made (in the United States, anyway) to reduce regulations/requirements on fossil fuels even further. Humble requests to reduce air pollution and/or CO2 emissions are met with calls to eliminate the Environmental Protection Agency.

Thus, the spectacularly unlevel playing field will likely get even more unlevel. The Clean Energy Standard is the only hope left out there.

Our industry seems all too eager to accept unprecedentedly stringent requirements, for love of the engineering challenge, apparently. The most pertinent example is the acceptance of radiation dose rate limits (e.g., 100 mrem/yr) that are orders of magnitude lower than the levels for which any significant health impacts are seen. The fact is, in my view, that NO technology can survive (over the long term) while being on the receiving end of an enormous double standard (i.e., under a tremendously non-level playing field). Better technology (e.g., SMRs, etc.) is not the answer. We must ask ourselves what we can do to get policies enacted that will level the regulatory playing field, and how we can reduce the tremendous prejudice that society has against our technology. I have several thoughts on those issues, but I’ve run out of space for this column…

____________________

Hopf

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.

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Posted in DC Perspective, Department of Energy, Fukushima, Nuclear Regulatory Commission, Small modular reactors, South Korea, U.S. Congress

Jaczko fiasco in Congress

Posted on December 21, 2011 by lscheele| 3 Comments

By Jim Hopf

Seems to be the season of controversy in Washington concerning nuclear issues and energy issues in general. First we had the whole Solyndra affair (discussed in my Nov. 28 post), and now we have an unprecedented—and highly politicized situation—concerning the U.S. Nuclear Regulatory Commission.

Jaczko

On October 13, the four NRC commissioners wrote a letter to White House Chief of Staff Bill Daley, voicing “grave concerns” about NRC Chairman Gregory Jaczko. They stated that his actions and behavior are damaging the NRC as an institution and creating a work environment that does not promote the independence and scientific objectivity that is essential to being an effective regulator. It should be noted that two of the four commissioners are Democratic appointees, and two are Republican appointees.

Charges against Jaczko

Specific issues raised by the four commissioners, in the letter to Daley and in congressional testimony, include:

  • Jaczko has ignored the will of his fellow commissioners on several issues and has treated them with disrespect.
  • Jaczko has attempted to designate significant issues as “administrative” matters (over which the chairman has control) as opposed to “policy” matters (on which the other commissioners also have authority).
  • Jaczko inappropriately exercised emergency authority in the wake of the Fukushima event, which gave him more decision making power with respect to the NRC’s response to the event.
  • Jaczko has engaged in abusive and bullying behavior toward NRC staff.
  • Jaczko has suppressed independence and scientific objectivity among NRC staff, essentially telling them that the objective is to advance his agenda as opposed to conducting independent assessments, and that “wrong answers” would have consequence.
  • Jaczko has been abusive and intimidating toward female NRC staff.

As a backdrop to the specific issues raised above, there have been some disagreements between Jaczko and the other commissioners.

Fukushima Daiichi during the event

One issue concerns the response (such as plant improvements) that the NRC will recommend or require for U.S. nuclear plants, in response to the Fukushima event. The primary disagreement is not over what the requirements will be, but over the length of time that will be allowed for the NRC to develop and promulgate the requirements, and how much time the plants will have to implement them. The other commissioners believe that the NRC should take more time to “get it right”, whereas the chairman believes that the situation is urgent, and that the requirements should be instituted much more quickly.

Yucca Mountain's north crest

Another issue concerns the Yucca Mountain repository, and how Jaczko essentially terminated the review/licensing process, using the administrative powers of his position, just before NRC staff was about to rule on whether or not the repository met all the technical requirements. This was done despite the fact that there was not a majority commission vote, which was necessary to overrule the Atomic Safety and Licensing Board’s decision that the Department of Energy and the NRC did not have the authority to terminate the licensing process.

Given the history of Jaczko’s (political) appointment, many believe that his actions with respect to Yucca Mountain are one example of a political agenda taking priority over scientific and technical merits.

Political reactions

The political reaction to these events has been swift, and surprisingly partisan given the bipartisan background of the four commissioners.

Issa

House Oversight and Government Reform Committee Chair Darrell Issa ( R., Calif.) stated that Jaczko was driving the NRC toward “catastrophe.” Republican House Energy and Commerce Committee Reps. John Shimkus (Ill.) and Ed Whitfield (Ky.) called on President Obama to replace Jaczko. Ranking Senate Environment and Public Works Committee Republican James Inhofe (Okla.) praised the four NRC commissioners for their “courage.” There is also an effort to pass a law that would only allow the NRC chairman to invoke emergency powers if there is an imminent safety threat at an NRC-licensed facility.

Boxer

Democrats, primarily Sens. Harry Reid (Nev.) and Barbara Boxer (Calif.) and Rep. Ed Markey (Mass.), have called the four commissioners testimony a “politically motivated witch hunt”, and have essentially accused them of serving the interests of the nuclear industry, at the expense of public safety, and trying “stage a coup” over Jaczko, whom they praised for putting safety first and trying to improve things at the NRC. In particular, they’ve suggested that the other commissioners were trying to water down the new post-Fukushima plant requirements and slow their implementation.

What to make of all this

Having not worked at the NRC, or with Jaczko, I don’t know enough to judge the extent to which the accusations about his management style and treatment of NRC employees are true. That will have to be left to the upcoming investigations.

Markey

I find the accusations of the four commissioners by Jaczko’s Democratic political patrons (Reid, Markey, and Boxer) to be pretty implausible, as well as offensive, especially given the bipartisan background of the four commissioners. The two Democratic commissioners were nominated by the (anti-Yucca Mountain) Obama administration. Everyone who works in the nuclear industry is well aware of just how safety focused and strict the NRC is, and the four commissioners have worked in the industry (and on nuclear safety) far longer than Jaczko has. It’s also a lot harder to believe that the problem is with all four commissioners (as well as NRC staff) and not with Jaczko.

With respect to possible motives among the four commissioners, the issue that I find most plausible is the one about how Jaczko was trying to concentrate more power and authority into the hands of the chairman, and reduce the authority of the other commissioners. This is one area where one could imagine all the other commissioners having a problem with Jaczko, regardless of their backgrounds or political affiliations. In general, I don’t have a strong opinion on how powerful the chairman should be relative to the other commissioners. I do, however, believe that a powerful chairman could be problematic if he/she has a political agenda. I also think that Jaczko’s decision to exercise emergency authority in the wake of Fukushima was unjustified.

Reid

As to whether or not he is competent as NRC chair, and whether he has political agendas (as opposed to being objective), one cannot ignore the fact that his primary work experience before becoming an NRC commissioner was working as a congressional staffer for Rep. Markey and for Sen. Reid. Markey has always been an outspoken critic/opponent of nuclear power, perhaps to a greater extent than any other representative. Reid, while not a nuclear power opponent per se, is the primary congressional opponent of the Yucca Mountain repository. Reid used his position as Senate Majority Leader as leverage to get Jaczko appointed as an NRC commissioner. Many believe that the sole purpose of this was to prevent the Yucca Mountain project from going forward.

This leads us to what is probably the most serious of the issues that were raised. In their testimony the commissioners suggested that Jaczko had clear agendas and had pressured staff to work toward advancing those agendas, as opposed to being objective and scientific in their evaluations, and openly asking questions. Such behavior would clearly reduce the NRC’s effectiveness as an objective regulator, and could even end up reducing safety. If these criticisms are shown to be true, then something tangible would need to be done to rectify the situation.

Is Jaczko a serious problem?

I personally do not have a strong opinion on the speed at which the Fukushima reforms should be implemented. I have also not found Jaczko to be particularly antagonistic to the industry on issues other than Yucca Mountain (including plant life extensions, Fukushima requirements for U.S. plants, or the new plant licenses). I find that his actions on the Yucca Mountain front to be objectionable, however.

Jaczko effectively suppressed the release of the NRC staff’s findings on the technical adequacy of the repository, even though they had completed their work (and as almost everyone believes, found that the repository met the technical requirements). Whether or not we decide to proceed with Yucca Mountain, the fact that it met the requirements, and was a technically viable solution to the nuclear waste problem, should have been documented. He also accomplished this using the (administrative) powers of his office, despite the fact that the commission’s votes to stop the licensing process were not there.  Hopefully, this will be resolved in court.

Jaczko’s actions on Yucca Mountain are clearly at least one example of him pursuing a political agenda, as opposed to being objective or scientific. This is especially clear given his political and professional background. As discussed above, coercion of the NRC staff by an agenda-driven chairman would clearly be a problem, especially if most of the power is concentrated in the hands of the NRC chair, as opposed to the four commissioners. This suggests that the issues raised by the commissioners are significant, and require some tangible action in response.

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Hopf

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.

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Posted in DC Perspective, Nuclear Regulatory Commission, U.S. Congress

Solyndra, and its possible impacts on nuclear

Posted on November 29, 2011 by lscheele| 15 Comments

By Jim Hopf

I’m sure everyone has heard all about the Solyndra “scandal” by now. There have been too many news stories to count on this subject (no need to provide links). So, instead of delving into the details, or giving a blow by blow account of all the events and the hearings in Congress, I will focus on the impacts this whole affair may have on government support for nuclear, and for clean energy in general.

A brief summary of the issue

As part of a general program to support clean/renewable energy sources, the federal government provided Solyndra, the maker of a certain type of solar panel, a $535 million loan guarantee in 2009. Soon after the loan guarantee was awarded, however, market conditions for the company deteriorated, rendering it unprofitable.

The price for solar panels has dropped significantly in the past year or two, primarily due to cheap solar panels produced in China, which heavily subsidizes its solar producers, in addition to having cheap labor. Also, China (and the world in general) appears to have ramped up solar cell production capacity too rapidly, resulting in a supply glut that has, at least temporarily, resulted in a dramatic price drop. It is unclear if most or all solar producers are currently selling at a loss (i.e., not recouping their investment in production capacity), but relatively high-cost producers like Solyndra are clearly being priced out of the market.

As a result, Solyndra recently shut down all operations and filed for bankruptcy. This in turn has resulted in the government losing the $535 million dollars it loaned the company.

The failure of the Solyndra loan has been highly publicized, and has led to congressional investigations and a significant amount of political controversy. Many have accused the Obama administration of incompetence, arguing that the company’s deteriorating prospects should have already been apparent when the loan guarantee was awarded. Others are using this issue to question the general idea of government providing assistance to specific energy sources or companies (i.e., government support of “clean” energy sources).

Nuclear loan guarantees questioned

New nuclear projects, such as at Vogtle, are also receiving federal loan guarantees. Some policymakers, including the Obama administration, would like to increase the nuclear loan guarantee volume.

Markey

Perhaps predictably, nuclear opponents such as Rep. Ed Markey (D., Mass.), have suggested that nuclear loan guarantees should also be scrutinized, or perhaps eliminated, in light of Solyndra. That is, they should be given the same scrutiny/treatment as loan guarantees for renewables. There are significant flaws in this reasoning, however, given the substantial differences in terms between loans given to nuclear projects, and those given to renewable energy projects.

For nuclear project loan guarantees, the government requires that the utility pay a large sum of cash, up front, to the government. This cash payment (the “credit subsidy fee”) is essentially an insurance premium, which compensates the government for the risk of loan default. It is somewhat analogous to mortgage insurance that some homeowners pay. The amount of the cash payment is determined, on a project-specific basis, by the federal Office of Management and Budget (OMB). The required amount can vary significantly for different projects, based on various market factors like whether they are in a merchant or regulated market, if they have a long term power purchase agreement, etc.

The amount of the insurance payment is significant. It can be as much as $1 billion, i.e., a significant fraction of overall project cost; enough to significantly impact the project’s overall economics.

In fact, the cash payments that the OMB has requested have been enough to make a loan guarantee not worthwhile in some cases. Constellation Energy rejected the federal loan guarantee for the Calvert Cliffs-3 project. The government wanted a cash payment of $880 million, equal to 11.6 percent of the total loan amount. Constellation said that not only would those terms render the project non-viable, but that it could probably get better terms on the open market, with no government help. (Some “subsidy”, eh?) In other cases, such as for Vogtle, the calculated fee is much less, and the loan guarantee remains worthwhile.

With renewable project loan guarantees, the OMB also determines the “credit subsidy fee” that would be required to adequately compensate the government for the risk of loan default. As with nuclear loans, the amount of this fee can be very significant, enough to greatly impact the economics of the overall project. (In other words, the OMB has found renewable project risks to be similar to nuclear project risks.)

There is an enormous difference, however. As part of the stimulus package, the federal government has been paying the credit subsidy fees for renewable projects. The fee was determined by the OMB, but then the government appropriated funds to pay that cost. (At least the subsidy is quantified and documented.)

Not only does this difference in terms have a huge impact on project economics, but it also probably has a significant impact on project risk. A nuclear project has to pay the (huge) credit subsidy fee, along with ~$100 million in licensing costs, before it can even start construction. Thus, it has a large investment at stake. With the government paying the credit subsidy fee, renewable projects have much less at stake financially. They don’t have to invest anything up front (or perhaps ever), and the government pays off the loan if the project fails. This, in theory, results in riskier, less viable renewable projects going forward, whereas nuclear companies will do much more in the way of “due diligence.”

Another reason why nuclear loan guarantees may be more justifiable than renewable loan guarantees is the issue of “sovereign risk.” That is, nuclear projects have a significant need to be protected FROM the government. Many in the nuclear industry, who remember the Shoreham debacle, view this as the main reason why government loan guarantees are necessary for new nuclear.

With a government loan guarantee, the government has “skin in the game” financially (even with a credit subsidy fee payment). As a result, it is much less likely that the government will act to kill a project just because it thinks that it may provide some short-term political benefit. For (motherhood and apple pie) renewables, this is not a significant issue.

To summarize all the above, renewable project loan guarantees are very clearly a subsidy, which (as currently structured) may encourage risky loans. It is much less clear whether nuclear project loan guarantees are a subsidy at all, and their current terms, which require large amount of money to be put at risk by the builder, are much less likely to encourage risky projects. Perhaps instead of calling for an end to loan guarantees, Congress should just require that all projects pay the credit subsidy fee determined by the OMB.

Let the “market” decide?

Attacks on the nuclear loan guarantee program, as a result of Solyndra, are not only coming from the (anti-nuclear) Left. They are also coming from the right side of the political spectrum. Many of the Republican presidential candidates were previously supportive of nuclear project loan guarantees, particularly if the project was in their state or district. Now, virtually all of them have come out in opposition to all energy project loan guarantees, including nuclear. Texas Gov. Rick Perry is one notable example.

The argument being presented by most (if not all) Republican candidates is that the government should not “pick winners and losers” in the energy industry (given how Solyndra went), and more generally that the government should not interfere with energy markets, to promote one form of energy over others. Instead, the “market should decide” what energy sources get used.

I have several problems with this line of reasoning. First of all, the notion of a “free” market with no government intervention is a complete myth. There has never been such a free and fair market. Not only is the market rife with subsidies of all kinds, given to all energy sources, but there are also huge differences in the level of regulatory requirements applied to various energy sources. The most notable example are the rigorous regulatory requirements that are applied to nuclear, which are orders of magnitude more strict than those applied to other (notably fossil) energy sources.

The second issue is that, under current policy and regulations, the enormous external (i.e., public health and environmental) costs associated with fossil fuels, particularly coal and oil, are not accounted for by the market, or reflected in their price. This represents a colossal market failure. Scientific studies estimate that accounting for external costs would roughly double the price of coal and oil derived energy.

Spending hundreds of billions of dollars annually to patrol the Persian Gulf (and fight wars in the Middle East) in order to secure oil supplies, but not having that cost paid for by a tax on oil or gasoline, represents an enormous government market intervention. Allowing coal plants to dump massive amounts of pollution into the atmosphere for free (resulting in ~20,000 deaths annually in the United States, along with global warming), is a massive market intervention. Giving shale gas drillers a blanket exemption from the Clean Water Act (while holding anything nuclear to impeccable standards) represents a huge market intervention.

In my September. 28 post, I discussed external costs, and the various options we have for addressing them. One can issue regulations that require reductions in air pollution, CO2 emissions, or oil imports. Alternatively, one can reflect these external costs in the market by imposing taxes on those things. Barring either of those (more enlightened) policies, one can support or subsidize clean energy sources that do not have the above negative impacts.

Conservatives have always been dead set against either the regulatory or financial disincentive (i.e., taxation) approaches, and now, after Solyndra, they are coming out against any type of support for clean, domestic energy sources. Thus, they are against any policies that would correct the enormous market failures discussed above. When they say that the market should decide, they really mean that the current (regulatory and policy) status quo should remain intact. These policies represent an enormously slanted playing field, with what effectively amounts to a large amount of government intervention on behalf of fossil fuels.

Renewable energy sources are also the beneficiary of huge government market interventions, mainly at the state level. In addition to very large subsidies, renewables benefit from portfolio standards that require a large market share for renewables, regardless of their cost or practicality. This is a huge (essentially infinite) subsidy.

Future slanted against nuclear?

As retiring Exelon chairman John Rowe recently pointed out, in the current political climate, renewable portfolio standards are probably going to be the only policies out there to support clean energy, in lieu of more intelligent policies that tax or limit pollution and let the market decide how to respond. That will be a shame, because (as he points out) such policies will result in emissions reductions being achieved in a more expensive way.

Such (renewable portfolio standards only) policies are bad news for nuclear. Under such a scenario, fossil fuels continue to benefit from having their huge external costs not counted, whereas renewables benefit from outright government mandates for their use. Nuclear is left out in the cold.

Nuclear’s external costs are tiny compared to fossil fuels and similar to renewables. It is more economical and practical than (intermittent) renewables in many if not most cases. Thus, it would do very well under any objective playing field where external costs are accounted for but the market is then left to decide.

Just a few years ago, it appeared that such enlightened policies, such as cap-and-trade and significantly more stringent air pollution requirements, were on the horizon. Now, cap-and-trade appears dead and there is enormous pressure to back down on air pollution rules. The possibility of passing (badly needed) limits on air pollution has even resulted in calls by some to eliminate or emasculate the Environmental Protection Agency. No such pressure on the Nuclear Regulatory Commission.

We’ve all been hearing about how the nuclear renaissance is diminished or dead, and how the reason is because (new) nuclear is no longer economical (due to the “shale gas miracle”, or whatever). My view is that much of this is due to government policies, and a market/regulatory playing field that is very slanted against nuclear. I hope the discussions above have illustrated some of the basis for this view.

In any event, the industry needs to aggressively defend the preservation/expansion of nuclear loan guarantees, as well as the formation of a Clean Energy Bank, and a CO2 tax or cap-and-trade system over the longer term. In terms of policy, things have gotten much worse for nuclear over just the last few years, with no CO2 limits, possibly no more loan guarantees, and possibly less strict air pollution requirements. The economic downturn and the gas glut aren’t helping either. Our current (political) course won’t cut it, if nuclear is to have much of a future.

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Hopf

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.

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Posted in DC Perspective, financing, Renewable Energy

Roadblock in Congress for SMR Development

Posted on October 25, 2011 by lscheele| 6 Comments

By Jim Hopf

As discussed in my June 20 post, small modular reactors (SMRs) have many potential advantages, and could very well represent nuclear’s best prospect for the future. The industry has run into trouble, however, in getting government support for getting SMRs off the ground.

The Obama administration has made a multi-year, $450 million request for SMR development, including $67 million this year to support SMR licensing. The U.S. House of Representatives has included the $67 million in its 2012 budget bill. That funding got removed from the U.S. Senate budget bill, however, by the Senate Energy and Water Development Appropriations Subcommittee, due primarily to opposition from Chairwoman Dianne Feinstein (D., Cal.).

Feinstein cited the fact that SMRs would create additional nuclear waste, for which there is still no permanent disposal site, as a reason for her opposition. She also said that federal nuclear R&D money should be spent on safety, as opposed to new reactor development, in light of the Fukushima disaster.

Improving Safety

I don’t agree with the Senator’s logic on the safety issue that she raised. I, for one, think that one of the best ways to improve nuclear safety is to develop and deploy much safer reactor designs, which are not vulnerable to the issues that caused the meltdowns at Fukushima. In turn, one of the best ways for the federal government to help improve nuclear safety is to support the development and deployment of such designs.

SMRs (such as designs from NuScale and Hyperion) are passively cooled, and are more able to reject heat to the environment (due to their small size). Large reactors, like Fukushima, require active cooling at all times, and fuel damage would occur almost immediately after the loss of all power. In stark contrast, the Hyperion module can go two weeks without any power (i.e., active cooling), and the NuScale module can go indefinitely without power (or active cooling). This is a critical difference, given that the Fukushima release occurred as a result of the loss of power, which was needed to provide continuous active cooling.

It’s true that SMR development does nothing to improve safety at existing reactors, and perhaps that’s where Feinstein is coming from. But the issue of implementing needed safety upgrades at existing reactors is being addressed by the Nuclear Regulatory Commission, and will be implemented by the industry itself, on its own dime. It’s not clear how much government research would help, in terms of improving existing reactor safety, and it’s not clear that the government should be paying (directly or indirectly) for necessary safety upgrades at existing plants.

Waste

As for the nuclear waste argument, well, that’s an old, familiar issue. The fact is that most experts, and scientific studies, have concluded that the public health risks and environmental impacts associated with nuclear power are much lower than those associated with fossil fuels, despite the nuclear waste issue.

Unlike fossil fuels, nuclear’s wastes are safely stored and are not released into the environment. And we are confident that a final solution to the nuclear waste problem will be developed and/or agreed upon at some point, with the final result being no release of wastes into the environment, ever. Given this, opposing increased use of nuclear power because it generates nuclear waste is hard to justify, since the result of not using more nuclear is (still) primarily the use of more fossil fuels, which have an infinitely worse “waste problem”.

Finally, it’s difficult to argue that we have not found a solution to the nuclear waste problem, at least from a technical perspective. It seems clear, at this point, that Yucca Mountain was a valid permanent solution to the nuclear waste problem, from a scientific and technical perspective. NRC staff had completed its review of the Yucca Mountain repository, and most observers believe that the repository would have passed the review, and been licensed, had the review not been halted for political reasons.

It is also true that some of the SMR designs are fast reactors, which have the potential to be part of a closed fuel cycle that would reduce the volume and longevity of our nuclear waste stockpile.

One Bright Spot

If there’s a bright spot in all this, it could be that some or all of the SMR developers may proceed without such R&D aid from the federal government. Both NuScale and B&W (with its mPower module) say that they are proceeding with license applications to the NRC. And the Tennessee Valley Authority is making plans to deploy mPower modules at its Clinch River site.

NRC Issues More Important?

As many have observed, the main barrier to the deployment of SMRs may not be a lack of government financial or R&D support, but instead the enormous amount of time and money required to get new reactor designs licensed by the NRC. Reactor licensing processes have been taking many years and costing more than a $100 million dollars. Even approving an exact copy of an already-licensed reactor design (for a new site) is projected to take more than two years.

Even SMRs that deploy conventional light-water technology (such as NuScale or mPower) can expect a long (~ 5 year) licensing process (starting in late 2012 or 2013). For non-conventional technologies like Hyperion, who knows how long it will take? The NRC has stated that non-conventional SMRs like Hyperion are not on its priority list right now, and that it will only consider such an application when a serious customer has been found (thus setting up a chicken-egg problem).

Other issues that may hold back SMRs include security and emergency planning/evacuation requirements, and per-reactor NRC fees. If the NRC is not willing to consider the SMRs’ lower potential radioactivity release, as well as the lower probability of such release, in setting these requirements, as well as scaling fees with reactor capacity, it may destroy SMRs’ economic viability.

Perhaps a more effective way for the government to support SMRs is for it to do something to reduce the licensing-related barriers discussed above, as opposed to outright financial support of SMR development. Possible options include making sure the NRC has sufficient resources to handle the entire volume of incoming license applications, somehow limiting the scope of review, or requiring the NRC to complete reviews within some fixed, reasonable time period.

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Hopf

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.

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Posted in accident, DC Perspective, Environmental Benefits of Nuclear, Fukushima, nuclear opponents, Nuclear Regulatory Commission, reactor designs, Small modular reactors, spent fuel, U.S. Congress, Yucca Mountain

The Dispatch Queue – An Alternative Means of Accounting for External Costs?

Posted on September 28, 2011 by pbowersox| 1 Comment

by Jim Hopf

Without much going on recently that hasn’t been covered by other blog posts, I’d like to explore a topic not specifically tied to nuclear power or to activities currently going on in Washington, D.C. It involves an idea I have about a possible alternative means of having the electricity market account for the public health and environmental costs of various energy sources, and encouraging the development and use of cleaner sources (including nuclear) without requiring legislation. Given the failure of Congress to take action on global warming, as well as environmental issues in general, non-legislative approaches to accomplishing environmental goals may be necessary.

The Problem

While most people express a desire to use cleaner, lower-CO2-emitting power generation sources, there is still no tangible mechanism in the electricity market that encourages their use over dirtier, highly-emitting sources. There are regulations and requirements for pollution controls, but once these minimum requirements are met, there is no incentive to use a cleaner source over a dirtier one.

The external (public health and environmental) costs of generation sources such as coal and oil are very significant, and if they were fully accounted for by the market, it would almost double their price. Some have called the fact that external costs are not accounted for the largest “market failure” within our energy economy. Given that these external costs are as real as the “normal” economic (or internal) ones, the current market is warped, in that it effectively subsidizes dirty sources by having a significant fraction of their real overall cost not be reflected in the market price.

One may say that the best response would be to significantly tighten pollution regulations, perhaps to the point where no sources have significant external costs. There are problems with this approach, however, above and beyond the fact that the energy industry has (and will?) successfully blocked the legislation that would be required. Significant tightening of regulations raises issues such as how expensive compliance will be, and whether or not viable alternative (cleaner) sources would be available. The beauty of simply placing a cost (or tax) on pollution that reflects its costs to public health and the environment is that those issues need not be addressed. The market just decides between sources based on the true, overall cost of each, resulting in the minimum overall (economic + environmental) cost-generation portfolio.

The above reasoning is what led to policies like cap-and-trade or a CO2 emissions tax being proposed as a solution for the global warming problem. This has not flown politically, however. Policies that attempt to have external costs included in the market cost of energy have been labeled a “tax increase.” This is particularly true given that the associated pollution taxes (or emissions credit costs) would have largely gone to the government.

Well, if we can’t tax pollution, how about encouraging the use of clean sources by giving them subsidies? This has proved to be more popular so far, but this idea has also recently run into trouble, given the current situation with the budget deficit and national debt. Events like the Solyndra bankruptcy have put government clean energy subsidies even more on the defensive. Thus, it seems that neither policies involving money flowing to the government nor policies involving money flowing from the government are politically viable at this point.

One final idea, which does not involve money going to or from government, is simply requiring that cleaner sources provide a certain fraction of our overall power generation. The many state Renewable Portfolio Standards (that do not include nuclear) and the Clean Energy Standard being considered by Congress and the Obama administration (which does include nuclear) are examples of this policy. While better than nothing, such policies are not ideal in that they are crude, and don’t involve a quantitative incentive based on real external costs. An energy source is either defined as “clean,” or it is not. Note that the definition of “clean” would be decided politically, as opposed to objectively based on tangible external costs determined by scientific studies (nuclear’s exclusion from state Renewable Portfolio Standards policies being one outrageous example). Finally, there is the fact that any such policy would require legislation.

All of the above begs the question whether there is a policy available that will encourage the use of cleaner energy sources that is revenue-neutral (i.e., does not involve money flowing to or from the government), does not involve the outright (political) selection of certain energy sources over others, and does not require legislation.

Enter the Dispatch Queue

There must be enough power plants in a given region to meet the maximum load (or demand) expected to occur. In fact, total generation capacity must exceed maximum demand by a specified “reserve margin,” to address the possibility of a plant going offline, or other possible considerations. Due to the fact that demand varies significantly with time, a significant fraction of the generation capacity remains offline, some or most of the time.

The dispatch queue is a means by which utilities, or independent regional grid operators, decide which power plants will operate in order to meet demand at any given instant. A good discussion of dispatch queues and how they operate can be found in this Department of Energy report.

The general goal of the methodology used to set the dispatch queue order is to minimize overall generation cost, while staying in compliance with all federal or state laws (environmental rules, etc.). This is done by placing the power plants with the lowest “variable” cost first in the queue. Plants with the highest “variable” cost are placed last. The “variable” cost of a plant represents how much more it costs to operate the plant than it costs to leave it idle (i.e., it includes the fuel cost and maintenance costs that arise from operation, but does not include the plant capital cost, personnel costs, or any fixed maintenance costs). Thus, one starts with the least expensive plants, and moves up (in cost) until generation meets demand. The remaining, more expensive plants are not fired up. This ensures that the lowest-operating-cost set of plants is used to meet demand at any given time.

As far as who makes the decisions is concerned, in many cases the local utility itself runs the dispatch for its own service territory. In most of the United States, however, there is a large regional grid (covering several utilities) that is operated by an Independent System Operator (ISO) or Regional Transmission Organization (RTO), and those organizations, which are independent of the utilities, set the dispatch queue for the region.

The Idea

As discussed above, a plant’s place in the dispatch queue is based upon variable cost, with the lowest variable cost plants being first in the queue. As discussed in the DOE report, all the dispatch queues in the country base the dispatch order almost entirely on variable cost, with the only possible exceptions being issues related to maximizing grid reliability. What if the plant dispatch methodology were revised so that environmental costs were also considered?

Ideally, the public health and environmental costs would be objectively and scientifically determined and cast in terms of an equivalent economic cost (as has been done in many scientific studies such as the ExternE study referenced earlier). The calculated external cost would be added to a plant’s variable cost, and its place in the dispatch queue would be adjusted accordingly. The net effect would be that dirtier plants would be run much less often, resulting in greatly reduced pollution.

This could have a huge impact in the United States, especially at the current time. Currently, natural gas prices are so low that the variable costs of combine-cycle natural gas plants are not much higher than those of coal plants, even without considering environmental impacts. Also, there is a large amount of natural gas generation capacity sitting idle. The current situation is almost tragic, where we could replace a huge amount of old, dirty coal-fired capacity with modern gas-fired capacity, which would result in a huge reduction in both air pollution and CO2 emissions, and could do so at little cost. This would, in fact, occur if the electricity market put even a small weight on environmental considerations, but alas it places none.

More specifically, if dispatch queue ordering methods were revised to even place a small (economic) weight on environmental costs, there would be a large switch from coal to gas generation, with coal plants (especially the older, dirtier ones) moving to the back of the dispatch queue, and only running very rarely (at times of very high demand). The specific idea of putting gas plants ahead of coal plants in the dispatch queue is being discussed by others.

The beauty of this idea is that it does not involve any type of tax or government subsidy. It is revenue neutral. Also, depending on the specifics of how it’s implemented, it can be quantitative in nature, with environmental costs of various power plants being objectively weighed, as opposed certain sources simply being chosen, by government/political fiat, over others. It also may not require legislation (see below). Finally, dispatch queues and their policies and methods are a rather arcane subject and are generally below the political radar (many folks haven’t even heard of them). Thus, this approach may allow the nation’s environmental goals to be (quietly) met without causing a political uproar. It could allow policy makers to do the right thing without paying too high of a political cost.

Questions/Issues

The DOE report does mention some examples of dispatch queue methods factoring in issues other than just the variable cost. It is fairly common for issues of grid reliability to be considered. Also, compliance with federal or state environmental requirements can have some impacts. Examples of such laws include limits on the hours of operation for certain polluting facilities, or state requirements that a “renewable” facility generate a certain amount of power over the year. The report also discusses the possibility of favoring more fuel efficient gas plants over less efficient ones in the queue, even if using the less efficient plants at that moment would have cost less, in order to save natural gas. Thus, the report does discuss deviations from the pure cost model, to consider things like environmental impact and resource conservation.

I could not ascertain from the DOE report, however, what legal authorities govern the entities that make the plant dispatch decisions (i.e., the ISOs and RTOs), and what types of action would be required in order to change the dispatch methodology (e.g., whether legislation would be required). The DOE report was a study that was called for by the Energy Policy Act of 2005, which implies that its conclusions would be considered in future congressional legislation. I could not tell from reading the report if the lowest cost (only) method of dispatch is actually enshrined somewhere in state or federal law. If so, the changes I’m proposing would require legislation, of course.

The DOE report states that in some regions the local utility runs the dispatch queue itself. In the case of the larger grids run by the ISOs and RTOs (which cover most of the country), the report implies that those entities are heavily influenced, if not governed, by the Federal Energy Regulatory Commission (FERC), which is part of the executive branch of the federal government.

In the case of utility-run dispatch queues, it seems that nothing short of new regulations (on pollution limits, or direct guidance on dispatch queue ordering) would result in a change in dispatch policy. Whereas reducing cost and maximizing grid reliability would be directly in the utility’s interest, favoring cleaner generation sources in the queue would not, unless it is driven by regulations. Thus, in this case, legislation would probably be necessary, although it’s conceivable that the EPA could act (like it’s about to on CO2).

In the case of the large grids run by ISOs and RTOs, it’s possible that such a change in dispatch methodology could be made by the federal executive branch, if indeed the FERC has the power to mandate such a change. In the current political situation, where the executive branch favors market-based mechanisms for reducing emissions (e.g., CO2) but doesn’t have sufficient support in Congress, this approach could be an alternative means for the administration to meet its objectives, without legislation being required. It must be noted, however, that although legislation would not be required, it is not clear how much direct influence the administration has over the FERC, which is an independent regulatory body. It may not be in FERC’s nature to initiate such a significant policy change by itself.

Effect on Nuclear

With respect to the impacts of including environmental costs in plant dispatch order determination, I’ve mainly discussed the effects on gas vs. coal. Indeed, a switch from coal to gas would be the main impact of such a policy change.

As for nuclear, as well as renewables, the direct/immediate impact would be minimal. That is because both nuclear and renewable sources have high capital costs but very low variable costs. They also have very low environmental impacts; much lower than those of coal or gas. Thus, they will remain at the front of the dispatch queue, ahead of both coal and gas. Nuclear and renewable generation sources will be put into service whenever they are available, and this proposed policy change would do nothing to change that. It is likely, however, that such a change in dispatch policy would have indirect impacts, further down the road, that would benefit nuclear as well as renewables.

Given the political opposition to new coal plants, as well as looming air pollution (and perhaps CO2) reduction requirements, most observers believe that there will be few, if any, new coal plants built in the United States. Meanwhile, renewables will provide a specified fraction of overall generation in the future, mostly based on state or federal government mandates. For most of the rest of our new generation needs, many expect nuclear and gas to be the primary competitors.

Given the future competition between nuclear and gas for bulk baseload power generation in the future, the future price of natural gas is one of the primary factors that will affect nuclear’s future growth. In addition to reducing air pollution and CO2 emissions (which would result in tremendous environmental and public health benefits), a change in dispatch policy that results in a shift from coal to gas will help correct the current imbalance between natural gas supply and demand (i.e., alleviate the current gas glut) and firm up natural gas prices. This in turn would result in at least some increase in nuclear generation.

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Hopf

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.

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Posted in DC Perspective, Department of Energy, Economic benefits of nuclear, Electricity generating capacity, Environmental Benefits of Nuclear, financing, News