Climate change

July 19, 2010

TCASE 11: Safety, cost and regulation in nuclear electricity generation

Guest post by DV82XLHe is a Canadian chemist and materials scientist. For his previous article on the 2010 Nuclear Security Summit, see here, and on why an informed public is key to acceptance of nuclear energy, see here.

Unless you intend to design a nuclear reactor from scratch, you are going to have to accept whatever level of safety is designed into the one you buy. No original equipment manufacturer (OEM) is going to derate their product to cut costs for you. And that will go for things you will have to build yourself, like the containment, and spent fuel facilities. No one is going to risk their brand letting you install their product on a substandard site. But this is not where costs get out of control anyway.

Nor is it in operating safety protocols, which at any rate are tied into general plant integrity routines that must be done anyway. Ultimately cutting back in this area runs the risk of some failure occurring that might stop the plant from producing power, (i.e. stop making money) or causing harm to an employee. In other words most of this falls under housekeeping anyway.

The only place where costs can be controlled which is often (erroneously) referred to as safety issues, is unreasonable procedural nonsense during the initial build. Even this is not the real expense in and of itself, but it is the delays that these can cause that push cost overruns into the stratosphere. It is seeing that these do not get out of hand that is the real way to keep costs down. In any sane world too, most of these procedural issues would be properly referred to as Quality Assurance, or Quality Control (QC), as they would have little to do with real safety issues, but in the politically charged world of nuclear power plant (NPP) builds, the antinuclear forces spin these to security and safety issues their own ends.

Okay, so how to avoid this sort of pitfall? First and foremost there must be only one government agency/department/ministry/whatever, in charge of oversight, and it needs to be at the national level, and it needs to exercise eminent domain. Once the project has broken ground, it cannot be delayed by politics, or by lower levels of government. Some local water commissioner up for re-election cannot be permitted to bring the project to a halt while he grandstands demanding a second opinion on groundwater contamination, two years after the first one was done and approved. Similarly, abuses of the legal system by non-government organisations (NGO’s) have to be made impossible as well. Many of these like Greenpeace, are well aware of the financial dynamics of these builds, and are past masters at using the courts to get injunctions for the sole purpose of running up the costs, in the hope of getting a project cancelled. In fact they have been successful more than once with this tactic.

Next, the agency that does have oversight must operate under a rational set of rules. This is not as hard as it may seem. Most national aviation authorities have a time-tested set of protocols with with they administer their bailiwick, and they seem to be able to do it without disrupting the civil air transportation system unless they have very good reason. Nuclear regulators should have a similar set of rules, legislated into the laws that created them, so some commonsense prevails.

One of the cornerstones of transportation regulation (at least on the technical side) is the emphasis placed on the chain of responsibility. It is inculcated into everyone, from the first day you start, that every action is traceable, and every individual accepts unlimited criminal liability every time they sign off a job. Furthermore. it is made clear that your job is not in danger if you refuse to sign. If your supervisor is comfortable that the job is done right, and feels that you are wrong suggesting it is not – then he signs it off – and so on up the chain, until someone decides to take responsibility, or the job gets done again. The situation that cannot be allowed to develop is one where the regulator has to be involved at every step, and at every minor deviation. Yes, they should have independent on-site QA people, overseeing the quality process, but under no circumstances should the regulator need to sign off at every step.

How does this work? More to the point why does it work? It works because everyone is made to understand that they can be traced and tracked down, and will face charges if they are found to be responsible for shoddy/illegal work, if necessary years latter. This creates a culture where caution and attention to quality comes from the bottom up, rather than enforced from the top down. Small deviations will still be made, and time will be saved, but these will not be anything outside the comfort zone of all involved, and reason will prevail.

[aside: To give an example, for awhile I had a job clearing deviations for a group of Canadian subcontractors to a U.S. bus manufacturing firm. The client firm required strict adherence to their standards, or the signature of someone certifying the change was equivalent. The sort of deviations I was signing off were for things like using a paint with the colour “009876” instead of the standard “009875” a difference almost indistinguishable to the naked eye, for a bracket that would never be seen by the public. If they had not employed me, every change would have to go to engineering for approval, wasting time and money. However they hired me because I was expected to know which changes to let through and which need higher approval.]

As it stands in most jurisdictions, nuclear builds do not allow for this sort of thing. Every change must go through the full process of being approved by all the stakeholders including the regulator, no matter how minor. Many of these are not safety issues, and if they are legitimate QC issues they shouldn’t need global approval. Worse, as can be seen in the trials Areva is enduring in Finland, a regulator with too much responsibility coupled with a lack of experienced people, does more harm than good.

If Australia wants to lower the cost of building NPPs to help make them cost competitive, the area to focus on is not lowering the safety threshold, (which at any rate is likely impossible) but by controlling runaway costs generated by counterproductive bureaucratic overhead, and closing the avenues that permit NGOs and others to practice barratry. At the same time the public needs to be constantly assured that quality and safety, while related, are not always codependent and must be managed separately to assure both objectives can be met.

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