I also like rules and regulations; I am, after all, a retired US Navy nuke who spent a portion of my career training prospective officers at the Naval Academy.
However, human imposed rules are subject to change. They should be changed when they are not based on correct science. The motivation to seek change comes when one realizes that the rules of the game have been purposely chosen to benefit the established players at the expense of all other potential participants.
Appropriate reviews of established regulations don't happen by magic, especially when there are people that like the way things are today. They start when people, some of whom may be outside of the industry, point out the fallacies and incorrect assumptions. The reviews continue when people who have struggled to implement the rules and recognize their extreme costs speak up. (That is not easy, by the way. One person's extreme cost is another person's generous revenue stream. Something tells me that you have spent your career on the revenue side of implementing regulations.)
I've been in the industry and struggled with the excessive costs. I've seen the size of the design teams, and the cost of the excessively redundant layers. I've seen the numbers associated with meeting dose rate limits in the case of the "worst case scenarios" that that include magical dispersal of the entire core volume and give little or no credit for physical boundaries like 7 inch thick pressure vessels installed inside containment buildings that have 1 inch thick steel walls surrounded by 3 foot thick concrete shield buildings. Ten mile emergency planning zones are part of that cost, even though the State of the Art Reactor Consequences Analysis (SOARCA) indicated that there was little to no possibility of any injury outside of the plant boundaries.
I've watched the situation in Japan, where tens of thousands of people have been forced to abandon their homes in order to protect them from minor contamination that would give them an annual dose rate that is less than half of what I was allowed to receive as an occupational worker when I first started my nuclear career - and the Navy has kept extremely careful records for more than 50 years that show those limits were quite conservative already. The cost of evacuating people from their homes is almost incalculable, but one indication of the cost is that somewhere close to 1,000 people suffered an early death as the result of the process and the stress involved.
Finally, I have done enough review of the projected design of waste repositories to know how much additional cost was added due to the EPA setting a limit of 15 mrem per year - which is about 1/20th of average background exposure in the US not including medical - and establishing a requirement that the designers seek to ensure that the repository meet that limit for a million years into the future.
We need to challenge the basis for the regulations so that we can make intelligent design choices that balance safety with cost. The alternative to addressing nuclear system cost is to keep pricing it out of the market and encouraging more fossil fuel consumption by default. That is not the safe path.
This is as good as any place to keep the discussion going and to increase the pressure for sensible change.
Rod Adams, Publisher, Atomic Insights
PS - I have no worries that sensible radiation dose rate regulations will change the economics of oil and gas production. That industry already has sensible limits because they have convinced their regulators that radiation from Naturally Occurring Radioactive Material (NORM) is somehow less damaging to human health than radiation associated with nuclear energy production. When doses are equal, human bodies cannot tell the difference between natural and "artificial" radiation.