I am not sure that I agree that shifting nuclear regulation from the NRC to the EPA would be pro-nuclear. The EPA has done an awful lot to hamstring fossil fuels. They might do the same for nuclear.
It's a concern. For one thing, current EPA dose rate limits are more stringent than the NRC's. But I can't over-emphasize the importance of moving from proactive regulation to reactive. With that change, the whole licensing process disappears and with it the single most important barrier to entry. And ALARA vanishes. ALARA is a philosophy which holds the only limit is what the plant can afford to do. Nobody can predict what that means. Under NRC style regulation, the only rule is the rules are whatever we say they are. The NRC is the Queen of Hearts incarnate.
At least the EPA limits are limits. And if EPA is forced to recompute its limits using a reasonably realistic radiation harm model, all the EPA dose rate limits change by multiple orders of magnitude.
It is true that reactive regulation is more subject to political pressure than proactive. But that's not necessarily a bad thing. If reactive regulation gets too far out of step with societal welfare, e.g. the EPA attempt to cut fossil fuel CO2 emissions by 90%, the body politic can react. NRC bureaucrats have a level of insulation from public pressure that their EPA brothers don't.
I would remind you that fossil fuel is alive and well in the USA. Nuclear most certainly is not.
In 2014 or 2015, ThorCon asked for and received an invite to present its concept to the NRC. I gave the presentation to a fully packed classroom sized room. There were surprisingly few questions. The basic response was: we don't know anything about molten salt reactors, but we are willing to learn. You can teach us at $280/man-hour. Here's the charge code. Use it, the next time you give us a call.
If I were an NRC commissioner, with the support of 2 others and the Secretary of Energy, I would put together a team with all the right expertise to evaluate the new designs. The team could include current NRC staff or outsiders. Don't fire anyone. The chainsaw method will only lead to backlash. What would stop us from approving demo reactors in safe, low-population places?
The sentiment that someone could come and "flip the table" on NPP regulation to get to "should be costs and timetables" is strong and understandable. From the perspective of someone living less than 200km from "Putins paradise" true finesse in solving any issue is needed. This strongly biases my personal opinion, but most people in the EU think quite similarly(people with good sentiment for US leadership, also for nuclear matters). For example there used to be an workable "Iran nuclear deal" already(which should be base for being worked on further).Trashing it pushed Iran toward supporting Putin, and long story short, here we are- Iranian made drones are being used to commit war crimes on civilians in Ukraine(cause and effect, objective observations regardless of politics will be noted in history). Joining Paris accords, leaving the Paris accord, joining and leaving again kind of roller coaster is an example of not achieving anything stable. One example of backlash mentioned by David MacQuigg in response above(?) There needs to be some stability and a plan that survives change of government that will eventually happen-may be imperfect, just pushing things toward better direction. SNT kind of regulation may/should/must come for the future.
What if LNT doesn't have to be immediately abolished to change NPP realities? Could NRC change evacuation guidelines such that enforcement happens only for unforeseen releases when LNT cancer probability is actually expected to be measurable and significant after basic precautions are obeyed (staying indoors, masking, Iodine for fresh fuel release etc)? Same incidents, same LNT- different outcomes. LNT albeit faulty is not forcing irrational responses by itself. What if NRC will be a voice to cut potential litigation on health effects in case of a release to calm the US tort system(currently NRC supporting artificial 80miles evac radiuses is strongly encouraging it)? What would be a minimum attitude (statutory) change for maximum output positive for future NPPs(such that would survive eventual government change)? Change in the US would propagate to the EU- one reason why it is so important for us here. All the best for keeping the fight! Marcin [hope that direct political references are cut out enough to satisfy GKN reasonable policy, sad things that the cheap stable, emission free energy is part of any politics, not factual evaluation]
We have a very strong rule here against gratuitous political comments. There are plenty of places for that. You ask some good questions, but pls reword or I will have to take the whole comment down.
I'm going to let your reworded comment stand, but it's right on the line. This site can deteriorate very quickly and the whole conversation becomes dominated by the loudest, who are also usually the dumbest. Yes references to political figures are unavoidable but they must be directly related to solving the Gordian Knot and nothing else. And tone is extremely important. Your tone is over the line.
As to your questions, I see no way that we can get balanced regulation under anything like the current NRC system:
1) the incentives we have given the bureaucrats are antithetic to societal welfare. People respond to incentives, not platitudes.
2) LNT has to go, especially if we are going to stick withthe current system. LNT overstates cancer incidence by multiple orders of magnitude for the dose rate profiles experienced in a release. The NRC bureaucrats accept LNT. I suspect most of them sincerely believe in LNT. If you believe in LNT, you do have reason to think a big release is intolerable, If you want your bureaucrats to be more "reasonable", the last thing you do is tell them a release is thousands of times more harmful than it is.
And it just so happens that thanks to the quirky US political system, we have a once in a lifetime opportunity to get rid of LNT. All it takes is an EO. Who cares who signs it?
The EPA recommended that the tritium levels in drinking water be 740 Bq/l. The Brookhaven National Lab determined that the no observable effect level for tritium in drinking water be 37 MBq/l.
That's 50000 times more stringent than an esteemed national lab recommended as zero effect level.
Doesn't fill me with much confidence. There is perhaps some merit to the conspiracy theory that this was all just to keep CANDUs out.
The EPA has no business being in the licensing process of a nuclear plant. They should be the environment police, law enforcement type. Having them intimately involved in the nuclear licensing business is like having a squadron of policemen be present in the driving school and tell you whether or not you get your license. That's not their intended purpose.
The NRC licenses reactors, not the EPA. The NRC says the CANDU has a positive temperature coefficient (an increase in temp results in an increase in powewr) in certain situations, and that's why it won't license it.
Perhaps Trump is just using the tactics he knows. Hansen does appear to be a staunch proponent of the gold standard, and keeping the NRC as strong a NATA (not accountable to anyone) as possible. Of course, the political correct term - that Hansen uses - for this is 'independence'.
It certainly seems progress to me to fire anti-nuclear-progress advocates in the NRC. We can't have another Jaczko disaster.
Jack, the NRC requires an EIS. This is evaluated by the EPA. The EPA is filled with anti-nuclear people who will endlessly come up with requests for more information for the EIS. Great way to stall things.
I am not sure that I agree that shifting nuclear regulation from the NRC to the EPA would be pro-nuclear. The EPA has done an awful lot to hamstring fossil fuels. They might do the same for nuclear.
Michael,
It's a concern. For one thing, current EPA dose rate limits are more stringent than the NRC's. But I can't over-emphasize the importance of moving from proactive regulation to reactive. With that change, the whole licensing process disappears and with it the single most important barrier to entry. And ALARA vanishes. ALARA is a philosophy which holds the only limit is what the plant can afford to do. Nobody can predict what that means. Under NRC style regulation, the only rule is the rules are whatever we say they are. The NRC is the Queen of Hearts incarnate.
At least the EPA limits are limits. And if EPA is forced to recompute its limits using a reasonably realistic radiation harm model, all the EPA dose rate limits change by multiple orders of magnitude.
It is true that reactive regulation is more subject to political pressure than proactive. But that's not necessarily a bad thing. If reactive regulation gets too far out of step with societal welfare, e.g. the EPA attempt to cut fossil fuel CO2 emissions by 90%, the body politic can react. NRC bureaucrats have a level of insulation from public pressure that their EPA brothers don't.
I would remind you that fossil fuel is alive and well in the USA. Nuclear most certainly is not.
Jack - I am genuinely curious. How much direct interaction have you had with the NRC staff in recent years?
Recently, none. It's too expensive.
In 2014 or 2015, ThorCon asked for and received an invite to present its concept to the NRC. I gave the presentation to a fully packed classroom sized room. There were surprisingly few questions. The basic response was: we don't know anything about molten salt reactors, but we are willing to learn. You can teach us at $280/man-hour. Here's the charge code. Use it, the next time you give us a call.
If I were an NRC commissioner, with the support of 2 others and the Secretary of Energy, I would put together a team with all the right expertise to evaluate the new designs. The team could include current NRC staff or outsiders. Don't fire anyone. The chainsaw method will only lead to backlash. What would stop us from approving demo reactors in safe, low-population places?
The sentiment that someone could come and "flip the table" on NPP regulation to get to "should be costs and timetables" is strong and understandable. From the perspective of someone living less than 200km from "Putins paradise" true finesse in solving any issue is needed. This strongly biases my personal opinion, but most people in the EU think quite similarly(people with good sentiment for US leadership, also for nuclear matters). For example there used to be an workable "Iran nuclear deal" already(which should be base for being worked on further).Trashing it pushed Iran toward supporting Putin, and long story short, here we are- Iranian made drones are being used to commit war crimes on civilians in Ukraine(cause and effect, objective observations regardless of politics will be noted in history). Joining Paris accords, leaving the Paris accord, joining and leaving again kind of roller coaster is an example of not achieving anything stable. One example of backlash mentioned by David MacQuigg in response above(?) There needs to be some stability and a plan that survives change of government that will eventually happen-may be imperfect, just pushing things toward better direction. SNT kind of regulation may/should/must come for the future.
What if LNT doesn't have to be immediately abolished to change NPP realities? Could NRC change evacuation guidelines such that enforcement happens only for unforeseen releases when LNT cancer probability is actually expected to be measurable and significant after basic precautions are obeyed (staying indoors, masking, Iodine for fresh fuel release etc)? Same incidents, same LNT- different outcomes. LNT albeit faulty is not forcing irrational responses by itself. What if NRC will be a voice to cut potential litigation on health effects in case of a release to calm the US tort system(currently NRC supporting artificial 80miles evac radiuses is strongly encouraging it)? What would be a minimum attitude (statutory) change for maximum output positive for future NPPs(such that would survive eventual government change)? Change in the US would propagate to the EU- one reason why it is so important for us here. All the best for keeping the fight! Marcin [hope that direct political references are cut out enough to satisfy GKN reasonable policy, sad things that the cheap stable, emission free energy is part of any politics, not factual evaluation]
msxc
We have a very strong rule here against gratuitous political comments. There are plenty of places for that. You ask some good questions, but pls reword or I will have to take the whole comment down.
Marcin,
I'm going to let your reworded comment stand, but it's right on the line. This site can deteriorate very quickly and the whole conversation becomes dominated by the loudest, who are also usually the dumbest. Yes references to political figures are unavoidable but they must be directly related to solving the Gordian Knot and nothing else. And tone is extremely important. Your tone is over the line.
As to your questions, I see no way that we can get balanced regulation under anything like the current NRC system:
1) the incentives we have given the bureaucrats are antithetic to societal welfare. People respond to incentives, not platitudes.
2) LNT has to go, especially if we are going to stick withthe current system. LNT overstates cancer incidence by multiple orders of magnitude for the dose rate profiles experienced in a release. The NRC bureaucrats accept LNT. I suspect most of them sincerely believe in LNT. If you believe in LNT, you do have reason to think a big release is intolerable, If you want your bureaucrats to be more "reasonable", the last thing you do is tell them a release is thousands of times more harmful than it is.
And it just so happens that thanks to the quirky US political system, we have a once in a lifetime opportunity to get rid of LNT. All it takes is an EO. Who cares who signs it?
The EPA recommended that the tritium levels in drinking water be 740 Bq/l. The Brookhaven National Lab determined that the no observable effect level for tritium in drinking water be 37 MBq/l.
That's 50000 times more stringent than an esteemed national lab recommended as zero effect level.
Doesn't fill me with much confidence. There is perhaps some merit to the conspiracy theory that this was all just to keep CANDUs out.
The EPA has no business being in the licensing process of a nuclear plant. They should be the environment police, law enforcement type. Having them intimately involved in the nuclear licensing business is like having a squadron of policemen be present in the driving school and tell you whether or not you get your license. That's not their intended purpose.
AC
The NRC licenses reactors, not the EPA. The NRC says the CANDU has a positive temperature coefficient (an increase in temp results in an increase in powewr) in certain situations, and that's why it won't license it.
Perhaps Trump is just using the tactics he knows. Hansen does appear to be a staunch proponent of the gold standard, and keeping the NRC as strong a NATA (not accountable to anyone) as possible. Of course, the political correct term - that Hansen uses - for this is 'independence'.
It certainly seems progress to me to fire anti-nuclear-progress advocates in the NRC. We can't have another Jaczko disaster.
Jack, the NRC requires an EIS. This is evaluated by the EPA. The EPA is filled with anti-nuclear people who will endlessly come up with requests for more information for the EIS. Great way to stall things.