Nordhaus's Jack's-a-Gnome Piece

Warning: the Flop book website links in this piece can be very slow. Give them time.

Ted Nordhaus of The Breakthrough Institute has replied to the Gordian Knot Group's calling out BTI and other pro-nuclear NGO's for failing to go after LNT. Ted argues that LNT is not a core problem, and the NRC is both necessary and reformable. The solution is new technology in the form of "advanced nuclear", combined with a France-like public monopoly of electricity generation backed with oodles of taxpayer money. The piece also involves some very selective reading of the Gordian Knot Group's argument for abolition of the NRC and its replacement with Underwriter Certification.¹

Here are a few examples.

Nuclear Economics

Ted starts out by pointing out that the GKG claim that nuclear could be really cheap is not original. The GKG never claimed it was. But to make his point, Ted cites an old BTI article on the wonders of advanced nuclear, as evidence that nuclear could be really cheap. The GKG claim is not only that nuclear could be cheap, but that it was cheap. The plants that started construction in the mid-late 1960's produced electricity at 3 cents/kWh in today's money. To support that claim, we have cited Lovering, Yip, and (yes) Nordhaus over and over again.\cite{lovering-2016}

The difference between "could be" and "was" is important. The late Sixties plants used conventional light water technology. Nordhaus chooses to ignore his own data, because that data strongly suggests nuclear's problem is not technical and cannot be solved by new technology. Ted fails to mention that ALARA condemns advanced nuclear to the same dismal fate as light water. Even if a new technology is inherently cheaper than light water, --- something that has yet to be proven --- that just gives the regulator more room to push costs up. ALARA mandates him to do just that. And as long as we have an omnipotent regulator whose job is to prevent releases, we will have ALARA whether it is codified or not.

Energy Poverty vs Global Warming

Ted takes a swipe at my claim that US progressives are far more concerned about global warming than energy poverty. He points to a BTI piece on nuclear in Africa as evidence that lefties care about the poor too.

What we are talking about here is emphasis. The GKG starts out from the premise that humanity needs cheap electricity, and we could certainly use some insurance against the uncertainties of global warming. Most nuclear converts from the left were not attracted to nuclear by its inherent cheapness, but by its very low CO2 emissions. In my experience, most of them believe nuclear is inherently expensive; but are willing to pay that price in order to decarbonize. This difference in world views points to very different solutions. But perhaps I did paint with too broad a brush.

LNT versus SNT

Here's where Nordhaus really goes astray. He sets up the LNT versus SNT debate as LNT versus hormesis. Ted does this by citing a piece I did on hormesis, which argues that hormesis should NOT be part of a regulatory harm model. Nordhaus implies just the opposite. I urge everybody to read A Letter to my Fellow Hormetians to find out what I really said.

Nordhaus than poo-poos the difference between LNT and SNT claiming:

a) both are unfalsifiable,

b) the difference is unimportant at the all important low dose rate end.

LNT is easily falsifiable. LNT denies our O2-metabolism based ability to repair DNA damage. This biology is indisputable and undisputed (except by LNT).

This is confirmed by the data. All we need to do is compare the cancer incidence in groups who have received large doses all at once, for example, the atom bomb survivors, with groups that have incurred the same or larger doses more or less evenly over years and decades.

As Feynman and others have pointed out, one ugly fact destroys the most beautiful of theories. The Green Table lists close to a dozen strong counter-examples to LNT, the most compelling of which is the radium dial painters. LNT claims that all the 215 dial painters, who received between 20,000 mSv and 200,000 mSv cumulative had a 100% chance of bone cancer. The actual number is zero.\cite{rowland-1996}[Fig 1] It's hard to imagine a worse prediction.

Both Linear No Threshold(LNT) and Sigmoid No Threshold(SNT) accept the No Threshold dogma. That should be pretty obvious from the names. But by recognizing our ability to repair radiation damage, SNT predicts cancer incidences that are many orders of magnitude less than LNT when the dose is received more or less evenly over a protracted period, as will be the case for the public in a nuclear power plant release. For example, the Union of Concerned Scientists using LNT predicts 3420 cancer deaths from the Chernobyl release in Other Northern Hemisphere (outside Europe). SNT using the UCS's numbers predicts 0.0002 deaths. A massive tragedy under LNT becomes a negligible risk under SNT.

The policy implications of replacing LNT with SNT would be transformative. An occasional release becomes tolerable, much like we tolerate aircraft crashes in return for the benefits of air travel. Nuclear plant liability would become commercially incurable; but only if we replace the American tort system with a fixed radiation exposure compensation plan based on the dose rate profile each individual suffers. SNT allows us to implement such a plan.

LNT was adopted by the AEC/NRC and EPA without congressional mandate. It could be replaced with SNT by an Executive Order. In short, under the Trump administration, replacing LNT with SNT is not only politically feasible, it should not be all that difficult. It's totally beyond my comprehension why outfits like the BTI would not get behind this all important first step to making nuclear cheap again.

NRC versus EPA

Ted also takes issue with the GKG's second step: replacing NRC with EPA as our nuclear regulator. He points out that EPA's current LNT based radiation limits are tighter and less flexible than NRC's. That's true.

But the important point is we will be moving from proactive to reactive regulation. Nuclear pollution would be regulated like other forms of pollution. ALARA and the whole federal licensing apparat would disappear. Competition would open up. And when EPA was forced to adopt SNT and recompute all the limits and triggers based on the existing MIR's, we would see entirely different numbers. The real regulatory burden would shift from the Feds to the underwriters. Underwriters do a pretty decent job of balancing benefit and harm. If they don't, they go broke.

Repower Coops or Public Monopoly

The BTI and GKG agree on one thing. The current form of "deregulated" electricity markets used in much of the US is an unmitigated disaster. It must be done away with. There are two possible ways we can take this, both of which would be an improvement:

a) A ratepayer based coop system.

b) A national, public monopoly.

I don't intend to argue for either here. But I do need to point out that to make (b) work, the monopoly must be responsible for both providing reliable electricity and nuclear safety. This was the original French model. The EDF self-regulated. This gradually changed as the regulator became more and more independent. In 2006, this independence was written into French law by creating the ASN. Now French nuclear is as expensive as US nuclear, maybe more so. If the BTI's vision of (b) includes an independent ASN or NRC like regulator, nuclear in the West will be condemned to a few atrociously expensive Vogtle's and Hinkley Point's. Under either (a) or (b), the NRC must go. SNT is the key to making this feasible.

Nobody enjoys being called an "underpants gnome", even if he has no idea what it means; but I'm actually encouraged by Ted's rebuttal. It just might lead to some real progress. We'll see.

1. If you want a full exposition of the argument, you will need the How We Can Make Nuclear Cheap Again book, which is available from Amazon and elsewhere.