Carnival of Nuclear Energy 166 – US energy regulations are not designed to efficiently save lives or the environment

The Carnival of Nuclear Energy 166 is up at the Hiroshima Syndrome

If US energy policy was looking for the most cost effective clean energy to help the environment and prevent climate change risks for the next ten years then the 30MW restriction would be removed from new hydroelectric power.

If US energy policy was looking for cost effective ways to save lives lost to energy then soot control measures that would save lives at $10,000 per life saved would be applied to coal, natural gas and oil and the same cost/benefit regulations would be applied to nuclear power. Forcing nuclear energy to pay billions of dollars per life saved is a waste when tens of thousands of more lives can be saved by making fossil fuels safer.

An energy professional who has worked with nuclear power and hydro power describes why “energy policy experts” like Sovocol and Amory Lovins are wrong

Without the 30MW restriction on new subsidized hydro there would be no need for any new wind, solar, geothermal or biomass facilities for 7-10 years in the western USA

Often, those who claim such expertise have little education, experience or training in technical topics and have vested interests in promoting competitive technologies.

My cynicism of solar and wind advocates is best addressed by discussing the RPS issues regarding hydro generation. RPS legal limits for hydro facilities are set at 30 MW in every state in the US that has an RPS enacted. Anything below counts towards a utility’s renewable portfolio, anything above does not – even 1MW above is not allowed a waiver. There have been attempts to remove this restriction in California and Washington but some of the most vocal groups who oppose changing this restriction are the solar and wind advocacy groups. So is this debate about climate change or their preferred energy generation source?

Additionally at the utility I worked, the State RPS allowed a natural gas co-gen plant that was rated below 30MW’s to meet the renewable portfolio formula. So we were asked to begin to prepare a cost estimate about mothballing a perfectly good hydro facility that was slightly over 30MW’s and install a co-gen plant run by natural gas just to meet an arbitrary legal requirement. Thankfully for the rate payers, the management decided to begin to educate the politicians about how there were other solutions that could achieve the same goals without decommissioning hydro facilities before we spent too much time preparing the estimate.

Based on some initial assessments I was able to review before I moved to my new position, if the 30MW restriction was removed from all hydro facilities in the Western US there potentially wouldn’t be a need for any new wind, solar, geothermal or biomass facilities for about the next 7-10 years in the Western states. The near-term estimates for future electricity demand indicates those “renewable” facilities are under consideration primarily to meet the 20-30% RPS goal of the respective states, not because they are needed to meet expected power demands. So what may happen is a situation where functional non-nuclear facilities may be mothballed strictly to meet legal RPS requirements with the added complication of more natural gas being burned in peaking plants to maintain grid stability. These points were raised this past year when California began to reconsider the 30 MW hydro restriction. Hence there is a significant financial motivation for the solar and wind groups to resist the removal of this legal definition from the RPS statutes.

Whenever the U.S. Environmental Protection Agency proposes air pollution regulations, it always has to perform a cost/benefit analysis to justify it. Requirements that do not pass cost/benefit analysis (i.e., would cost more than a few million dollars per life saved), are not even considered. In many cases, even policies that do pass cost/benefit analysis (by a wide margin) are still politically blocked, and do not proceed.

The NRC (Nuclear Regulatory Commission) only has to consider costs (i.e., do any kind of cost/benefit analysis) when it seeks to apply backfit requirements to existing, already-licensed plants. In all other cases, such as the establishment of requirements that will apply to new license applications, the NRC is free to use its judgment and does not have to perform any kind of cost/benefit analysis.

Many nuclear requirements amount to many billions of dollars per life saved; orders of magnitude higher than the standards applied to most industries.

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

Small Modular Reactors with NRC regulation will not be allowed to be cost effective

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

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

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

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