There's an article that is making the rounds of the rat blogosphere that I think is seriously wrong. You've probably seen it quoted. It blames the ALARA (as low as reasonably achievable) radiation protection standard for all the economic problems of US nuclear power. From https://worksinprogress.co/issue/taming-the-stars/:
"ALARA is defined as: "making every reasonable effort to maintain exposures to radiation as far below the dose limits in this part as is practical consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public interest." [footnote citing 10 CFR 20.1003]
As currently applied to nuclear power, ALARA literally means that every expense must be spent on eliminating every possible effect of nuclear power, at least until the resulting electricity is no cheaper than what the market pays for electricity generated from non-nuclear sources. Since standards cannot ratchet downwards, only up, safety standards that are just about affordable at the top of energy price spikes get entrenched, meaning that nuclear is made unaffordable until the next price hike – which makes it even more expensive, since it prevents learning and the economies of scale that a steady pipeline of projects can allow. ALARA, as currently applied in the US and much of the rest of the developed world, means that nuclear power is never allowed to be cheaper, no matter how much safer and cleaner it is than other sources of energy. It makes affordable, safe nuclear energy impossible, and forces us to rely on much less safe energy sources instead." End quote.
The first paragraph is a literal quote from the regulations. Everything after that? where the author tells you what ALARA "literally means"? is wrong. At least, I think so. To the extent I understand the claim being made here.
Is the author saying that nuclear regulations actually change in response to energy prices? This absolutely does not happen. Is he saying that inspection standards or radiation protection procedures change with energy prices? So that some regulator or energy company employee is actually making the decision to increase radiation protection standards when they observe nuclear becoming cheaper compared to non-nuclear energy? Highly implausible. Energy prices change all the time, and regulations/inspection procedures/radiation protection procedures are only changed in a slow and cumbersome way. Also, industry would have no incentive to make itself less competitive, and it is very much NRC culture to NOT pay attention to energy prices.*
Okay, maybe the author is making a more general claim that the level of safety/security regulation increases over time, it's a one-way ratchet and regulation prevents nuclear power from being as cheap as it arguably should be compared to other energy sources. A fair but unoriginal claim. But then why the talk about ALARA?
First of all, understand that ALARA is about radiation protection. It is not the be-all and end-all of nuclear regulation. The ALARA standard adds on to other radiation dose regulations. For example, a typical nuclear power plant worker can get a max of 5 rem per year of occupational radiation exposure (10 CFR 20.1201) AND their radiation dose must be ALARA. So if a worker gets more than 5 rem, it's a violation of both regulations. If a worker gets less than 5 rem but the plant does not make reasonable effort to make the dose ALARA, it could be a violation of the ALARA standard. Conclusion...even if the ALARA standard didn't exist, nuclear plants would have to put significant effort into radiation protection, albeit not quite so much.
I'm not gonna say ALARA is unimportant. But it's only one of a whole host of regulations that apply to nuclear power plant design, construction, operation, and decommissioning. There are regulations that apply to nuclear security, reducing and mitigating the risk of nuclear accidents, emergency planning, environmental protection, and I could go on. There would be a significant regulatory burden even without ALARA.
Maybe the author is using ALARA as shorthand for the entire group of US regulations and laws relevant to nuclear? Or the entire regulatory mindset? But, if your argument is that nuclear regulation should incorporate cost considerations, why pick on one of the regulations that explicitly incorporates consideration of cost, instead of the many that don't consider cost at all?
Another quote: "[T]he components that are not safety critical are still subject to a gold plated ALARA standard. This means the same component is regulated differently depending on whether it is in a coal plant or a nuclear plant, even if it is far away from the reactor and cannot affect it."
False. The reason that a component in a nuclear plant is regulated differently from a component in a coal plant is that different laws, regulations, and administrative agencies regulate nuclear plants from those that regulate coal plants. ALARA has absolutely nothing to do with that.
I hate to be all argument from authority, but I notice the author, John Myers, seems to be a UK YIMBY activist and if he has any experience in US nuclear, I'm not aware of it. Please understand that the statement "ALARA, as currently applied in the US and much of the rest of the developed world, means that nuclear power is never allowed to be cheaper, no matter how much safer and cleaner it is than other sources of energy" is false. That is not what ALARA means. ALARA is not that powerful. Please stop quoting this guy uncritically.
*Because NRC's mission is to ensure nuclear safety and security, not to ensure that the US nuclear power industry is economically viable. If you want something to complain about, ask Congress to change that.
On nuclear regulation:
There's an article that is making the rounds of the rat blogosphere that I think is seriously wrong. You've probably seen it quoted. It blames the ALARA (as low as reasonably achievable) radiation protection standard for all the economic problems of US nuclear power. From https://worksinprogress.co/issue/taming-the-stars/:
"ALARA is defined as: "making every reasonable effort to maintain exposures to radiation as far below the dose limits in this part as is practical consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public interest." [footnote citing 10 CFR 20.1003]
As currently applied to nuclear power, ALARA literally means that every expense must be spent on eliminating every possible effect of nuclear power, at least until the resulting electricity is no cheaper than what the market pays for electricity generated from non-nuclear sources. Since standards cannot ratchet downwards, only up, safety standards that are just about affordable at the top of energy price spikes get entrenched, meaning that nuclear is made unaffordable until the next price hike – which makes it even more expensive, since it prevents learning and the economies of scale that a steady pipeline of projects can allow. ALARA, as currently applied in the US and much of the rest of the developed world, means that nuclear power is never allowed to be cheaper, no matter how much safer and cleaner it is than other sources of energy. It makes affordable, safe nuclear energy impossible, and forces us to rely on much less safe energy sources instead." End quote.
The first paragraph is a literal quote from the regulations. Everything after that? where the author tells you what ALARA "literally means"? is wrong. At least, I think so. To the extent I understand the claim being made here.
Is the author saying that nuclear regulations actually change in response to energy prices? This absolutely does not happen. Is he saying that inspection standards or radiation protection procedures change with energy prices? So that some regulator or energy company employee is actually making the decision to increase radiation protection standards when they observe nuclear becoming cheaper compared to non-nuclear energy? Highly implausible. Energy prices change all the time, and regulations/inspection procedures/radiation protection procedures are only changed in a slow and cumbersome way. Also, industry would have no incentive to make itself less competitive, and it is very much NRC culture to NOT pay attention to energy prices.*
Okay, maybe the author is making a more general claim that the level of safety/security regulation increases over time, it's a one-way ratchet and regulation prevents nuclear power from being as cheap as it arguably should be compared to other energy sources. A fair but unoriginal claim. But then why the talk about ALARA?
First of all, understand that ALARA is about radiation protection. It is not the be-all and end-all of nuclear regulation. The ALARA standard adds on to other radiation dose regulations. For example, a typical nuclear power plant worker can get a max of 5 rem per year of occupational radiation exposure (10 CFR 20.1201) AND their radiation dose must be ALARA. So if a worker gets more than 5 rem, it's a violation of both regulations. If a worker gets less than 5 rem but the plant does not make reasonable effort to make the dose ALARA, it could be a violation of the ALARA standard. Conclusion...even if the ALARA standard didn't exist, nuclear plants would have to put significant effort into radiation protection, albeit not quite so much.
I'm not gonna say ALARA is unimportant. But it's only one of a whole host of regulations that apply to nuclear power plant design, construction, operation, and decommissioning. There are regulations that apply to nuclear security, reducing and mitigating the risk of nuclear accidents, emergency planning, environmental protection, and I could go on. There would be a significant regulatory burden even without ALARA.
Maybe the author is using ALARA as shorthand for the entire group of US regulations and laws relevant to nuclear? Or the entire regulatory mindset? But, if your argument is that nuclear regulation should incorporate cost considerations, why pick on one of the regulations that explicitly incorporates consideration of cost, instead of the many that don't consider cost at all?
Another quote: "[T]he components that are not safety critical are still subject to a gold plated ALARA standard. This means the same component is regulated differently depending on whether it is in a coal plant or a nuclear plant, even if it is far away from the reactor and cannot affect it."
False. The reason that a component in a nuclear plant is regulated differently from a component in a coal plant is that different laws, regulations, and administrative agencies regulate nuclear plants from those that regulate coal plants. ALARA has absolutely nothing to do with that.
I hate to be all argument from authority, but I notice the author, John Myers, seems to be a UK YIMBY activist and if he has any experience in US nuclear, I'm not aware of it. Please understand that the statement "ALARA, as currently applied in the US and much of the rest of the developed world, means that nuclear power is never allowed to be cheaper, no matter how much safer and cleaner it is than other sources of energy" is false. That is not what ALARA means. ALARA is not that powerful. Please stop quoting this guy uncritically.
*Because NRC's mission is to ensure nuclear safety and security, not to ensure that the US nuclear power industry is economically viable. If you want something to complain about, ask Congress to change that.