Comment by epistasis

9 hours ago

Which are the fake costs from regulation?

We have new builds in Europe of the EPR, in France and Finland, and it has had disastrous costs. China has built some too, presumably cheaper, since they keep on building more. What is the regulatory difference there?

I have yet to find any concrete defense of the idea that costs are coming from regulation, rather than the costs of construction in advanced economies.

If regulations are the cost, name them and a solution. Otherwise it seems like we are wasting efforts in optimizing the wrong thing for nuclear.

> I have yet to find any concrete defense of the idea that costs are coming from regulation, rather than the costs of construction in advanced economies.

One of the main drivers of excessive costs of construction in advanced economies are from excessive regulations, so it's really one in the same. Nuclear is obviously more regulated than other industries, and it routinely faces more frequent, longer delays and higher cost overruns than projects of comparable scale and complexity. This study [1] goes into a lot more detail.

Digging more into the details, it's all linked. The lack of regulatory clarity means that designs have to be changed more after construction starts, requirements for redundancy increase complexity, changing regulations prevents standardization, etc. Prescriptive regulations which were created decades ago limit the cost savings possible with newer technologies, like improved reinforced concrete. This study [1] goes into a lot more detail.

> Our retrospective and prospective analyses together provide insights on the past shortcomings of engineering cost models and possible solutions for the future. Nuclear reactor costs exceeded estimates in engineering models because cost variables related to labor productivity and safety regulations were underestimated. These discrepancies between estimated and realized costs increased with time, with changing regulations and variable construction site-specific characteristics.

[1] https://www.sciencedirect.com/science/article/pii/S254243512...

  • > The lack of regulatory clarity

    Oddly enough, that sounds like a request for more regulation. And I have heard many people say that if the regulators had made sure that if approval had gone beyond mere safety, into constructibility and other areas, that Vogtle would have been closer to the initial budget, and that Summer might have completed.

    Thank you for the link, and I will read it in detail later, but at a high level, I think it's great support for my point that it's construction productivity that's the key driver of cost, not regulation (emphasis mine):

    > Relatedly, containment building costs more than doubled from 1976 to 2017, due only in part to safety regulations. Costs of the reactor containment building more than doubled, primarily due to declining on-site labor productivity. Productivity in recent US plants is up to 13 times lower than industry expectations. A prospective analysis of the containment building suggests that improved materials and automation could increase the resilience of nuclear construction costs to variable conditions.

Its multifold.

1. Regulations are a big asterisk to any project. If you don't think you will get licensed or your project will get axed halfway through or there is a risk (Which has been very high in the past). Investors who would put money up for the project won't do it OR they require a significantly higher cost of capital. 2. There is very little muscle memory in the fabrication of reactors and reactor components in north America because we de facto shut down the industry from 80s until 20s. Therefore the first projects will cost more money as we recover our abilities to fab. 3. The licensing and regulatory costs are also incredibly high - and you cant make any adjustments if you kick off the project or you restart the process. This leads to massive cost over runs.

China and Korea are currently building reactors about 1/6 the costs of the US I believe.

  • China is building US and EU designs of reactors at a fraction of the costs in the US and Europe.

    Your examples of regulatory asterisks are on the design side of things. I don't think that the cost of capital for Vogtle & Summer in the US, or Flamanville and Olkiluoto in the EU, were excessively high. As for your 3rd point, there were tons of adjustments during the build of Vogtle, which is a big reason for its large cost overruns. Regulation didn't necessitate those changes, they were all construction bungles.

    Which I think leads to your point 2, construction competence, being the primary cause, which aligns with everything else I have read on the subject. For example, another poster pointed to this paper:

    > We observe that nth-of-a-kind plants have been more, not less, expensive than first-of-a-kind plants. “Soft” factors external to standardized reactor hardware, such as labor supervision, contributed over half of the cost rise from 1976 to 1987. Relatedly, containment building costs more than doubled from 1976 to 2017, due only in part to safety regulations.

> If regulations are the cost, name them and a solution.

That is a funny ask. Regulation doesnt have to be a single thing. It can very well be cost-overrun by a thousand paper cut. You can drown any project in endless paperwork, environmental and national security reviews. In fact unclear and contradictory requirements are much more conductive to drive costs up than a single Lets-make-nuclear-expensive-Act.

That being said if you need to pick a single thing (which is silly) then the “As Low As Reasonably Achievable” principle of radiation protection is a prime candidate. When you have a safety limit you can design a system to remain under it. When you are designing a sytem for the ALARA principle that in itself will blow your costs up.

  • You're getting downvoted, but you're correct. It's death by a thousand cuts, because ALARA forces radiation exposure-reduction expenditures to scale upward forever, despite the fact that radiation exposure from plants long ago reached levels far below those that result in any risk. There is no lower bound, so the regulators never stop reducing exposure further, raising costs further and further over time.

    Under ALARA, nuclear literally isn't allowed to reduce market electric costs, because the requirements for reducing exposure scale to what keeps it competitive with other forms of production! If all other electric costs doubled tomorrow, the NRC would respond by raising the requirements for plants to reduce radiation exposure.

    If that sounds insane, it's because it's insane. Our nuclear regulations are insane.

    • ALARA would indicate that the increased costs from regulation are due to the design of the reactor.

      However, my example is of reactors that China can build cost effectively, but which Europe can not. (And the AP1000 is an example where China can build the design cost effectively, but the US can not.)

      That would indicate that nuclear reactors could be built cost effectively, with the same design, and without changing ALARA.

      Removing ALARA may provide some sort of cost savings, but without some concrete and specific indication of how that would change the design, and to what savings during construction, it's hard to agree that ALARA is at fault.

All the safety and countermeasure costs here ultimately stem from regulation. If we allowed less safe power plants, they would likely be cheaper to build and operate.

However, I’m not sure I want private for profits actor deciding the level of safety of such projects.

  • We have one model for cheaper construction of nuclear, using exactly the same designs as in the US (AP1000) or EU (EPR), and that example is China.

    I don't think China is building them any less safe. I don't think the regulations are significantly different.

    I don't think any of the designers of the nuclear reactors want to build them any less safely, either, because they are not asking for that.

    Many of the "safety" stuff is also about prolonging longevity of the reactor as long as possible. Like really inspecting the welds on tubing, etc. Any reduction in safety there also ultimately increases costs by reducing the lifetime of the plant or heavily increasing maintenance costs.

    That's why I don't think this is a tradeoff between safety and cost. I think it's a tradeoff between construction/design competence and cost.

It takes 15 years to build a nuclear power plant. It shouldn't take this long at all and it's strictly because of regulations. If we cut down the time it takes to build a plant the cost plummets.

  • Which regulations?

    What would change in the construction process?

    China builds the same designs as the EU and US, yet faster. What is different?

    I saw toooooooons of reports of construction mishaps in the US at Vogtle and Summer. I didn't see anything about "oh if we changed this sort of regulation it would have saved us money."

    It's a very worthwhile to read the retrospectives on these builds. There are lots of plans of future builds of the AP1000 that would be cheaper, but none of the plans even indicate that a regulation change would help.

    I beg of people who say regulations are in the way: which regulations? Concretely, what should change to make construction cheaper? Pun intended.

    • > What is different?

      All of the NIMBY roadblocks that ties up U.S. projects in court, that China doesn't give a F about considering they'll displace 1.3 million people to build a damn.

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    • Perhaps the are talking about Unions and the regulations around minimum pay and working conditions.

      I don't know about big construction projects, but the costs to get an extension approved on my house is a drop in the ocean compared to paying tradies. (contractors in us speak.)

  • Nuclear regulations are no worse than aviation regulation. Yet planes manage to be cost competitive.

    Cutting regulations isn't necessary the win people think. If safety regulations are cut, it risks accidents in future.

    Nuclear needs to move from bespoke builds to serial production.

    • Thats not the full picture. Aviation exploded in growth -- you can easily expand operations and work to smaller margins. The US shut down the nuclear industry intentionally from the 80s until the last 5 years from regulations.

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  • But what are the specific regulations you would cut, dude?

    • I have heard it claimed, at least for US construction, that a nuclear plant under construction has to implement new safety measures even if those measures were adopted after the design approval or construction start date.

      This means that the design can change multiple times during construction, which both slows construction and exposes the project to even more safety design changes.

      Ironically, the creaky old plants that were built long ago don't need to adopt such new safety requirements. They are grandfathered in, but can't be economically replaced because the costs of a replacement are artificially inflated.

      A car analogy would be that we continue driving 1955 Chevy Bel-Airs with no seat belts since an up-to-date car is too expensive to develop, since we can't start production until the latest LIDAR and AI has been added. Once the LIDAR is in, pray that there's no new self-driving hardware released before full production, or we'll have to include that too.

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Shouldn't the burden of proof belong to those that claim that regulation isn't the cost, when it is so extremely obvious to anybody who has ever had to build anything that it is?

Just look at building costs in California vs Texas. Both are nominally constituents of the same "advanced economy".

  • If you're proposing a change, shouldn't the change be specifiable? Why is the burden of proof on those asking "what change?" to demonstrate that no change is possible? That's a complete inversion of responsibility.

    I have a whole host of clearly specifiable changes to California building law that will make it cheaper, and am actively working on them both locally and at the state level! This is clear!

    As somebody who is very interested in making Calforina housing cheaper, and in particular housing construction cheaper, it is my duty to say what should change, why, and convince others of it.

    If I go out and advocate for "change" without being able to specify a single change, I would get jack shit done. It doesn't work that way.

    Every single nuclear advocate that I have ever met that says "regulations should change" can still not yet specify how those regulations should change. That's the minimal bar for holding an opinion.

    Reading the DoE LPO report on how nuclear can scale up and get cheaper, it wasn't regulations doing the work. It was learning how to build.