More Trouble Than I Can Stand Thinking About: Balancing Risk, Safety and Cost in Regulating Nuclear Energy

Peter A. Bradford1

One of the most dangerous phrases that nuclear officials can utter is That accident cant happen in my country. After the Three Mile Island accident in the U.S., Soviet officials came to the site and held a press conference at which they pointed out that the Three Mile Island design was not used in the Soviet Union, so no similar accident would occur in their country. Of course, they were right. Instead, seven years later, they had Chernobyl. After Chernobyl, many countries including Japan made solemn statements pointing out that their countries did not use the Soviet RMBK design, that their reactors had better containments, that the Soviet safety culture was deficient. All these statements were true, and Japan did not have another Chernobyl. They had Fukushima. Nuclear accidents do not repeat themselves exactly from one country to the next. The industry does learn and improve. What does repeat itself is the human inability to foresee the worst that can happen. That and the reluctance to spend the money to guard against combinations of events that are extremely unlikely at any one reactor over its lifetime but almost inevitable over a large population of reactors operating for many decades. So regulators and plant designers compromise, sometimes for want of imagination, sometimes to avoid costs. In normal times, careers are advanced by shortening licensing and construction times, not by finding new safety concerns. In 1972, a U.S. safety reviewer recommended that the U.S. stop licensing the type of containment that we now believe failed at Fukushima, a type also in use at many U.S. reactors. The official to whom he made this recommendation passed it on to his superior with a note that did not challenge the technical points. Indeed, it called the idea of banning pressure suppression containments an attractive one in some ways but concluded, the acceptance of (these)
1

Adjunct Professor, Vermont Law School; Member, Senior Policy Advisory Council, China Sustainable Energy Project; former Commissioner, U.S. Nuclear Regulatory Commission

containment concepts by all elements of the nuclear field..is firmly established in the conventional wisdom. Reversal of this hallowed policy.could well be the end of nuclear power. It would throw into question the continued operation of licensed plants, would make unlicensable (many) plants now in review and would generally create more turmoil than I can stand thinking about.2 No further action was taken with regard to the memorandum, though some of the problems with that containment design were addressed in later years. A hydrogen explosion at Three Mile Island was contained by the different containment structure in use at that site, but explosions of hydrogen that escaped the pressure suppression containments in use at Fukushima destroyed four reactor buildings, exposing the spent fuel pools and permitting a great deal of radiation to escape. The official who made the U.S. recommendation to ban Fukushima type containments continued to work at in nuclear regulation, though in relative obscurity. The official who rejected the concerns later became the chairman of the Nuclear Regulatory Commission and served as a director of a utility that owned nuclear power plants. * * *

China has the worlds most ambitious nuclear construction program. Over the last decade, eleven new reactors have begun to operate. Another 27 are under construction. Current planning seems to contemplate nuclear capacity at least equal to the 100 gigawatts in the U.S. by 2030.3 The Chinese nuclear program includes several different designs. China has not followed the lead of France in choosing to standardize its program around a single design. As a result it will have the benefit of experience with many reactor types but also like the U.S. forty years ago - the regulatory and construction challenges of dealing simultaneously with several different reactor designs. By way of comparison, the U.S. put a total of 120 reactors into operation in the 39 years between 1957 and 1996, most of them before 1985. About the same number of plants were cancelled. At
2

Daniel Ford, The Cult of the Atom: The Secret Papers of the Atomic Energy Commission, Simon and Schuster, New York, 1982, pp. 193-4. 3 Businessweek, December 2, 2010. http://www.businessweek.com/magazine/content/10_50/b4207015606809.htm

its peak the U.S. program had more than 100 reactors under construction. Most were one of a kind. So the U.S. program was both larger and even more difficult to manage than the one now being undertaken by China. The U.S. experience in scaling up a major program involving several designs on a small base of experience led to an economic fiasco of cost overruns, plant cancellations and poor operation from which the industry has still not recovered. New nuclear reactors still cost far too much to compete effectively in U.S. power markets, and U.S. private investors want no part of the risks of new nuclear units. Even before the accident at Fukushima most of the 30 new reactors thought to be likely in the U.S. by 2020 had been cancelled or very substantially delayed. This experience need not be repeated in China, but it is cause for caution. China has even higher demand growth rates than the U.S. expected (but did not achieve) in the 1980s. In addition, the world now has far more experience with nuclear power construction and operation. Still, this additional experience is only helpful to a point. Rapid nuclear program growth still poses immense challenges in quality control, in training of qualified personnel, in creating effective regulatory institutions and in vigilantly analyzing both nuclear operating experience and natural disasters. It will always be easy to use hindsight to see how a catastrophe like Fukushima could have been avoided. A much harder task is to create and empower regulatory and quality control organizations with the strength wisdom and independence to take the necessary action before the accident happens. * * *

At the time that the Fukushima units were built, the U.S. Atomic Energy Commission did not consider accidents that overwhelmed all reactor cooling systems to be credible events. Consequently, nuclear plant owners were not required to guard against them. Here are some events that were once thought by regulators and by the nuclear industry in the United States and in Japan to be so unlikely that no precautionary action needed to be taken: An earthquake of level 9.0 on the Richter scale A tsunami exceeding 10 meters in height

Loss of all off-site power accompanied by failure of multiple diesel generators lasting more than eight hours. Uncovering and overheating of fuel rods to such an extent that large quantities of hydrogen were released by the interaction of zirconium with the cooling water

Failure of the containments to contain the hydrogen Multiple hydrogen explosions in the reactor buildings Loss of coolant and fuel failure in spent fuel pools Further uncovering and overheating of nuclear fuel to such an extent that the fuel melted and fell to the bottom of the pressure vessels Fuel melting through the pressure vessels and into the reactor containments Escape of a significant fraction of the radioisotopes from the containments into the reactor buildings and from there into the environment. Evacuation of large numbers of people from around a nuclear power plant site Evacuation of people from around a nuclear power plant site needing to be conducted in the immediate aftermath of a natural disaster

Each of these twelve impossible events occurred (some more than once) during the first few days of the accident at Fukushima. Because they did, about one percent of the worlds nuclear capacity was destroyed on worldwide television. Also destroyed was the credibility of a regulatory regime that had theretofore been considered one of the best in the world. To learn and apply the lessons of a nuclear accident several steps are necessary. The accident must first be brought under control. Then a chronology of how the accident actually unfolded must be prepared. Then that accident sequence must be carefully and rigorously analyzed to determine basic causes, as well as effects and consequences. Only then can one prepare conclusions with regard to necessary reforms. Finally, these conclusions must be translated into revised regulatory requirements, with a firm schedule for their implementation. Since the accident at Fukushima is not yet under control, even the first of these steps has not been accomplished. Of course, analysis based on what is known can go forward, but it cannot be

considered complete or definitive in the absence of a definitive accident sequence. We are years away from being able to say that we know all of the lessons of Fukushima. One lesson is clear now, however. All safety regulatory systems in countries willing to build nuclear reactors will need to distinguish events that must be defended against from those deemed so unlikely as to be beyond regulatory concern. This is a solemn and a critical process. It cannot be hampered by complacency, by corruption, by a mistaken sense that everything is so safe already that costly new safety measures justify a prohibitively heavy burden of proof on the person proposing them. No precautionary measure will approach the cost that the Fukushima accident is certain to impose on the nuclear industry, to say nothing of the people of Japan.