True, but the idea behind the combined operation license was to allow construction and operation to continue while license issues are litigated. The delays in plant Vogtle and in SC are from the challenges with actually building the plant since much of the equipment has never been built before so they must building, testing, and constructing while they are trying to create a commercial plant on a tight schedule.
While there are very real concerns about the lack of construction experience as well as longer term engineering and operational support, these delays seem to be self inflicted, from issues with concrete pours to assuming brand new designs can be built on a very tight schedule where many of the components have never been built or used before.
Read more about the the Vogtle rebar issue. It is not fair to dismiss it as self-inflicted, when the regulator insists upon perfection and is unresponsive to circumstances. The rebar was installed to current building standards, rather than those in place when the design was approved. It was a small deviation and eventually the NRC allowed it with minor modifications. The problem is that such a minor issue can introduce a 6+ month delay when interaction with the NRC are required.
While all I know about the bear issue is from the news I'd still lay most of the responsibility on the licensee and architect engineer. The regulator is not insisting on perfection but rather on the licensee complying with the COL. The COL was intended to limit delays through litigation so it is important to ensure you meet all the requirements to the letter lest you get sued later on the grounds you are not compliant with the COL. While many deviations truly are trivial, the NRC still must ensure it follows the law to avoid problems later. As a result, engineering analysis is needed to ensure the design provides the same level of safety as the original. Since the licensee failed to meet the COL or take actions to amend it prior to pouring concrete then it is pretty much, IMHO, a self inflicted wound.
Regulations should be focused on safe designs, not on libraries of paperwork certifying safety. It is silly to require an N-stamp on every last nut and bolt (even in non-safety related systems) rather than using off the shelf parts where suitable. Certificates can be forged, and even if they are genuine, nothing is perfect. Safe designs make allowances for imperfect materials. Such a “cost is no object” approach is not useful in the real world, The oppressive regulatory regime only mires any progress and ensure that we are burdened with ancient, yet "approved" designs.
The question then becomes, what is a safety related system and at what level of defense in depth do you switch to commercial grade components? I can see an argument being made for systems on the secondary loop but not on the primary side. Of course, many secondary systems do not need an N-stamp anyway under current regulations.
Concurrent with that is what level of testing is sufficient to ensure a safety system will respond when needed?You can test so much the testing degrades reliability and drives up maintenance costs as a result. Since AP-1000 is designed for passive cooling in the event of an accident are annual DG tests appropriate, for example.