Dog Days of Summer

The phrase is used to describe those hot, sultry days in July and August. Here in the southeastern U.S., these days are typically almost unbearable with the heat and humidity. We welcome the break in weather that comes in the fall that allows us to open the windows to enjoy fresh air.

The Greeks and the Romans believed that the “Dog Days” were an evil time. Here’s how Brady’s Clavis Calendaria put it: “The Sea boiled, the Wine turned sour, Dogs grew mad, and all other creatures became languid; causing to man, among other diseases, burning fevers, hysterics, and phrensies,”

I made the mistake of traveling during this evil time over the past couple of weeks. My odyssey of weather, mechanical problems, delayed flights, missed connections and luggage was almost worthy of Homer.

I know that everyone reading this has experienced the same. I try to use these experiences as learning opportunities. While it is tempting to say “I learned never to travel again,” I know that I will be on planes and going places within a few weeks. So what were my lessons?
The airlines are using some kind of optimizer to minimize the number of planes and maximize their time in the air. Makes sense. They don’t make money if a plane is sitting on the ground.
The optimum the airlines are finding is a “brittle optimum.” If you think of optimums as either a peak or a valley, where a ball will sit still, the airlines have chosen a “peak” where once the ball shifts even SLIGHTLY off the optimum, it will roll further and further away.

A “valley” is a stability point; the ball moves away, but rolls back to the optimum with no external forcing mechanism.

They count on the overnight reset to bring the system back to “optimum.” In other words, they roll the ball back up the hill overnight, but that’s a different Greek myth (Sisyphus) for another day.

We passengers are at least partly to blame. Few travelers are willing to pay even a few dollars more for an improved on time rate. In the world of deregulated air travel, we’ve demonstrated to the airlines that the only thing that matters is the cheapest fare.
From now on, I will try to remember Harding’s First Principal of Travel: ALWAYS FLY IN THE MORNING.

Cheapist Aint Best. What does this have to do with nuclear energy? The electricity system in the U.S. is in real danger of doing EXACTLY the same thing. Ratepayers, public utility commissions and independent system operators are always looking for the cheapest electricity.
The fact that some of the players get outside subsidies, or that some players get state mandates to support their chosen form of generation, are inadequately considered in electricity markets. Also improperly considered is the need for capacity to be available whenever the demand is there.

The capacity issue is the one that haunts the nuclear industry the most. Flying a plane half full to get equipment to the right place, and to have some extra equipment in the system to allow for potential failures, is the right thing to do but it costs money.

If the airline cannot get compensated by the passengers for having extra planes available when and where they are needed, they eliminate those flights that don’t pay enough.

Base load plants operate best when they run flat out as much as possible. Having them on line and operating gives the system cushion for when other generation isn’t available or demand peaks high enough.

The problem is that the markets will not pay (reward) these plants for their capacity to generate electricity when demand is low or their ability to stabilize the grid, or they don’t pay enough to keep the plants running.

This is where the analogy ends. There is a profound difference between the airlines and electricity. If passengers decided that on time performance was worth paying for, airlines could quickly add planes to their fleets and improve that performance over a matter of a few months.

If nuclear plants are closed, and their licenses withdrawn, there is no way to bring that generation capacity back. New plants take time to build.
If we allow nuclear plants to continue to close for economic reasons alone, we’re going to wake up one day and realize that we allowed a terrible decision process to destroy our way of life.

We have to stop talking to ourselves and get out there and start shouting to the world about these issues. Too many people are asleep and dreaming of a make-believe world where windmills and solar panels will keep them warm and dry and well fed.

This article was originally published in Fuel Cycle Week Vol 13 #582, 08.28.2014 where Margaret is a regular columnist. To become a subscriber, go to www.FuelCycleWeek.com or contact the publication at info@fuelcycleweek.com.

Liar’s Poker and Other Games of Chance

According to the Urban Dictionary, Liar’s Poker is an American bar game played with one-dollar bills. Each player picks from a pile of face-down bills, and uses the eight-digit serial number on the face of the bill (kept private) to shape a playing strategy.

This is a consecutive bidding game where players “bet” on the total number of occurrences of digits on all bills involved in the hand. The winner of each hand is decided when a bid is challenged by all the other players. If the bid is successful the bidder wins all the one-dollar bills. If he loses the bid he pays everybody a dollar.

Why am I writing this month’s column on Liar’s Poker? Because it is (1) a game of statistics and combinations, and (2) makes a point about bluffing versus knowledge.

How this relates to the energy industry in general and nuclear industry in particular in this brave new “carbon free” world is very simple: regardless of generation type the cost of construction, operation, fuel and electricity produced is a game of Liar’s Poker.
With respect to nuclear, different reactors will cost different amounts in different countries with different economic and regulatory structures. In other words, the costs of building reactor X in China won’t be the costs of building it in the United States.

The capital costs of new nuclear power plants in the U.S. are far from well known.Large light water reactors have not been built for many decades, and the current Westinghouse designs under construction in Georgia and South Carolina haven’t been built more than a few times anywhere in the world.Frankly, anybody that claims to know is playing Liar’s Poker.

Predictions about the cost of building small modular reactors are clearly Liar’s Poker, and the way things are going lately some of the bids by the players in the SMR world might be challenged. How many 1’s are on your dollar bill?

Wind and solar installations are also beginning to run into a NIMBY enthralled public that wants energy, as well as goods and services, but doesn’t want any of the messy bits to be located too close to their homes. As the local populations become more sophisticated in how to use government red-tape against ANY industrial facility, the cost of electricity will continue to climb. How many 2’s on your dollar bill?

Throw renewable portfolio standards, production tax credits and increased environmental regulation into the mix, and the bluffing and betting that goes on begins to boggle the mind. How many 3’s on that dollar bill?
The coal industry is trying to bluff its way through the entire issue by convincing the world that their product is really clean, and that coal ash spills are not really their fault. Oh, and did we mention the number of jobs coal provides around the country? How many 4’s on that dollar bill?

Then methane comes riding in to the rescue with its claims of being a great back-up for renewables, how much lower carbon it is than coal, how low cost it is and how wonderfully safe it is— until a major winter storm smacks the Northeast or a pipeline blows up under a building.
Let’s not even talk about the international issues related to methane. Russia’s current stranglehold on some countries in Europe could be an entirely separate discussion. How many 5’s do you have?

On and on it goes. 6’s? 7’s? 8’s? 9’s?

All of these costs, risks, and benefits are almost impossible for the average citizen to comprehend. Is it any wonder that we have no well thought out long-term energy policy that might result in reliable energy available at reasonable costs both to the environment and to our economy?

We have to challenge the bid and start to move forward with the BEST options available to our country. The “all of the above” strategy we are currently playing is, in the end, NONE OF THE ABOVE.

What really matters is how many 0’s are on the bill. Too many of those and there will be no winner, only losers in this game of Energy Liar’s Poker. •

This article was originally published in Fuel Cycle Week Vol 13 #566, 04.24.2014 where Margaret is a regular columnist. To become a subscriber, go to FuelCycleWeek.com or contact the publication at info@fuelcycleweek.com.

Yucca Mountain Follies: Let’s Rewrite The Ending, Please

Another act in the long running farcical melodrama called Yucca Mountain is unfolding this month. We have such a cast of characters that Broadway, or perhaps Monty Python’s Flying Circus, would be envious.

The dastardly villain has been played well by Sen. Harry Reid (D-Nev.), who has managed to include henchmen that are then disposed of when their usefulness has ended.

His chief minion was Dr. Greg Jaczko, whom he manipulated onto the Nuclear Regulatory Commission’s five-person commission, then again into the chairmanship.

Dr. Jaczko proved himself more dastardly than even Harry could manage, what with his ill- timed outbursts at staff and overt manipulation of the other commissioners.

After banishing the good doctor into oblivion at the Department of Energy, Harry brought in a new minion, one with more charm, Dr. Allison Macfarlane.

Our hero in this story at the moment is the U.S. Court of Appeals in the District of Columbia, which finally issued a Writ of Mandamus against the NRC.

The judges waited for a year, in the hope that Congress would do something to make its intentions clear, but between the political stalemates in almost every aspect of government and Harry’s Machiavellian maneuvers in the Senate, no clear intention was forthcoming.

This Writ is historically significant as it represents the first time in U.S. history that the judicial branch has compelled the executive branch of government to complete an action.

The NRC seems to have chosen the role of well-meaning but ineffectual country bumpkin. The other commissioners are unable or unwilling to stand up to the machinations of Sen. Reid and his minions and, with their silence, have allowed an extreme miscarriage of justice—not to mention a blatant flouting of the laws passed by Congress and ratified by a sitting president.

Of course, the victim here is Yucca Mountain.

Sadly, the project is still on life support and the prognosis is not good. The hapless NRC has insufficient funds to bring it back to life, but only to complete the documentation of what kind of repository it could have been.

Dr. Macfarlane, Reid’s latest minion at NRC, has decided to ask the parties to the lawsuit to tell her what to do.

It would seem that her charm and her proclaimed desire for scientific truth does not permit her to find more devious and cut- throat methods to keep Yucca Mountain in a coma and waiting for death.

It appears that she is hoping that the wily Sen. Reid will get other henchmen to give her the air cover she needs to put Yucca Mountain back on ice.

To be a true melodrama, though, audience participation is required. We audience members must boo and hiss the villain, cheer the hero, and sigh for the victim.

We have a chance at participation, though it requires more effort than just loud applause. The NRC asked for the public to comment and suggest what the agency should do next.

They have about $11 million to spend, not enough to complete everything in their purview on Yucca and rescue it from certain death, but enough to tell us what it could have been. Flaws and

positive aspects of the facility. Lessons to be learned for the next time we perform this work.

Help the NRC step up to the hero’s role and stop being the stumbling, bumbling fool. Send an e-mail to the Secretary of the NRC: secy@nrc.gov.

Tell him that the NRC should issue the essentially complete volume 3 of the Safety Evaluation Report, then complete issue volumes 4 and 5.

Then demand that after that, the agency should lay before Congress and the nation what it will take to complete the work mandated in the Nuclear Waste Policy Act.

Let the next act begin.

By providing that statement, perhaps we can help the other commissioners decide that the courts should not be the only hero in this story and demand a different ending to this multi-act play.

Such an action would allow the NRC to resolve the Waste Confidence issue that has brought all licensing actions to a halt and allow the U.S. to move forward with nuclear energy.

Whether or not we ever bury a single fuel bundle underground at Yucca Mountain is not, in fact, the point.

But having the option available when we finally need to store fuel is—and all we are asking for.

After all, nuclear is the only energy capable of delivering the vast quantities of electricity to drive our country without polluting our air and our water. That’s pretty heroic.

This article was originally published in Fuel Cycle Week #5383, 09.26.2013. where Margaret is a regular columnist. To become a subscriber, go to FuelCycleWeek.com or contact the publication at info@fuelcycleweek.com.

Of Pandora and Prometheus

The myths of Pandora and Prometheus are some of the most interesting of the Greek myths.

What I didn’t realize until recently is that these two myths are related.

Prometheus—whose name means “forethought” or “forward thinker”—was a Titan who helped to create humans and stole fire from Zeus and the rest of his Olympus gang to help humans live a better life.

For his troubles, Zeus eventually chains him to a rock and has an eagle eat his liver each day. The liver grows back each night so that the punishment can be eternal.

Many know this myth and many nuclear projects use the word “Prometheus” in honor of his actions.

Certainly, given nuclear energy’s potential it feels a great deal like we’ve stolen the ultimate fire from the universe.

Pandora, though, I was less familiar with.

Like most folks, I knew that Pandora’s box was filled with evil things and that she loosed them on the world by unlocking a box she’d been told to keep shut.

We’ve all heard the phrase “opened

Pandora’s box” to connote something that someone had done that created all kinds of problems.

Anti-nuclear activists like to describe nuclear technology as an act of opening a Pandora’s box.

They almost gleefully describe a litany of ills and problems that the curious scientists that developed this technology have opened with their discovery.

When the documentary “Pandora’s Promise” was released this past summer, and director Robert Stone explained that Pandora’s myth ends with the revelation that hope for all mankind was at the bottom of the box, I decided to investigate a bit further the story of Pandora.

Who was this Pandora woman anyway?

Pandora—the name means “all gifts”—is the first human woman in Greek mythology. Before her, all females were either gods or Titans.

Zeus demanded that the other Olympian gods create her in order to play a trick on mankind as punishment. What transgression was Zeus so angry about? He was angry because Prometheus stole fire and gave it to mankind.

Depending on the version of the myth, the gods first tried to give her to Prometheus, who recognized the potential trick and refused her.

The gods then give her to Epimetheus, Prometheus’s brother. Epimetheus means “after thought” or “hindsight.” He’s less well known than Prometheus, mostly because he always failed to plan ahead.

These myths are compelling. Nuclear technology is indeed the fire we stole from the gods.

As mere mortals, it has taken thousands of competent and dedicated engineers and scientists to wrest this fire from Olympus and bring it to mankind.

Some days, it certainly feels like our livers are being pecked out by something—and that, like Prometheus, we are being punished.

However, the campaigns by anti-nuclear activists over the past several decades now appears to be Epimetheus-like.

Lacking any foresight, they’ve been seduced by a pretty vision of the future. The ills our continued reliance on fossil fuels has created certainly seems to be Pandora’s box.

Our air is dirtier, our energy more expensive and less reliable, and our future less certain because of the delays in getting nuclear energy used more widely, not just in the U.S, but globally.

But there is still hope at the bottom of that box.

Many environmentalists have rejected the traditional anti-nuclear stance. There has been quiet talk in the corners of the movement that perhaps that knee jerk stance was wrong.

The documentary “Pandora’s Promise” brings that discussion into the forefront and perhaps begins to get us to the bottom of that box and to the hope that it brings.

This article was originally published in Fuel Cycle Week #543, 10.31.2013. where Margaret is a regular columnist. To become a subscriber, go to fuelcycleweek.com or contact the publication at info@fuelcycleweek.com.

RIC NRC – Part 1

I was at the NRC’s Regulatory Information Conference in Washington, DC this week. Every March, a couple thousand nuclear industry professionals, journalists, and members of the public come to the conference center across the street from the NRC’s headquarters in Rockville to hear the NRC discuss issues that concern them.

Many, if not most, of the people come for the first two days to hear the commissioners speak. That is frequently the most interesting part of the week as they do not confer with one another, nor do the staff recommend specific topics. The Chairman always speaks first and many times, the other commissioners will respond, directly or indirectly to her comments. This wide-open format can provide significant insight into each commissioner’s agenda as well as where there is disagreement between them.

In years past, when Dr. Jaczko was still the chair, there were some direct and pointed comments from other commissioners. Funny, at times, but showed the clear schism between the commission and the chair. Dr. MacFarlane is not as controversial, nor has she been as aggressive, so comments from other commissioners have been more muted.

First up, as always, is the chair. Allison MacFarlane opened noting that the conference was opening on the third year anniversary of the Great Tohoku earthquake of Japan in 2011. I find Dr. MacFarlane’s speeches to be vague and with limited useful content. This year, she chose to use her knowledge of earth sciences to tell the nuclear industry that we should recognize that knowledge and understanding about science changes. What? Does she think we haven’t looked at and incorporated new science and technology in the last 40 years? Then she lectured us about the volcanic risks in the US. I am still trying to work out how any of that was relevant to our industry. Was she trying to say that we should account for the possibility of 200 million year events in the lifetime of nuclear facilities? She talked about all the NRC is doing internationally, but failed to provide any specifics. Frankly, as she said similar things at the Platts conference in early February, I stopped listening.

The one thing of note was a brief mention of the Yucca Mountain review process. Dr. MacFarlane has been careful to remain within the executive branch directives of not completing the Yucca Mountain review. Although directed by the courts to spend the remaining money, she made it clear that the NRC had insufficient funds to complete the process. The fact that she failed to asked congress for the needed funds to complete the work was not mentioned, nor did anyone bother to ask the question. We assume that she would claim that DOE has to ask for the funds for NRC to complete the review. The fact that the courts have also whipped DOE about this whole mess is apparently not her problem.

Next up was the new EDO of the NRC, Mark Satorius. He has been in the position less than a year as Bill Borchardt retired in 2013 after the RIC. Because he is relatively new, his speech was more about the changes he was or wasn’t making and the learning curve of issues and events he had to gain speed on. He did state that the NRC is on track to complete its revision to the Waste Confidence Decision by fall of this year.

Aside: Dr. Dale Klein, former chair of the NRC, gave a speech to the local ANS section on Wednesday night. He took the entire government to task for its failures in this area. His lucid and clear headed discussion of the issues was refreshing. I wish he was still in the chairman’s position. End aside

After the break, Christine Svinicki spoke. She is always interesting at the RIC. Major public speeches with little direction are not her favorite activity and her talks at the RIC are sometimes rambling. This time she was both amusing and poignant with her talk. Her description of procrastination activities to avoid writing the speech hit a nerve with me. Although I‘ve never stooped to doing my taxes to avoid doing something else. She then spoke eloquently about suffering and the harm done to the Japanese people by the earthquake and Tsunami. Not just about Fukushima, but the entire coastline. I have been frustrated by the continued drumbeat of Fukushima at the expense of the 18,000 people who lost their lives, the families with no one left to mourn them, or even bury them at some villages. The 170,000 people that remain homeless due to the tsunami who receive little or no help from anyone in the world.

The final speaker on Tuesday was Dr. Apostolakis. I appreciate his deep knowledge of and ability to explain how Probabilistic Risk Assessment to those of us who have a smattering of statistics and probability but only enough to get it wrong in the more complex analyses. He took apart a common statement from anti-nuclear folks about the probability of an accident being far greater than PRA calculates. Most of them have used a simple formula: the likelihood of an accident has to be determined by dividing the number of accidents into the number of reactor years. Dr. Apostolakis pointed out that this calculation assumes that all reactors are basically the same, operated under similar conditions, with similar regulation. Since this is clearly not true, the basic formula is false. His analogy was the calculation of riskiest professions. Under the same assumptions, being president of the United States was far riskier than being a police officer. Clearly circumstances and new measures put in place after each assassination or attempt have improved the safety of the president. Thus the simple calculation cannot be used to compare these issues.

Wednesday was “the two Bills”, William Magwood and William Ostendorff. They frequently present interesting and related views about the commission. That will be the subject of a blog early next week.

Letter to the Editor of the Wall Street Journal

Two weeks ago (Aug. 18), the WSJ published a Saturday essay from Dr. Richard Muller titled “The Panic Over Fukushima”. I submitted a letter to the editor. Sadly, the WSJ decided not to publish it. However, I wanted to share it with my readers. I might add that anti-nuclear people hate his essay, and a fair number of pro-nuclear people hate it as well. Both claim “bad science” as the enemy. While his science isn’t completely accurate, it does provide something a lay person can get their arms around and understand. And it makes clear how miniscule the risks really are. For that I was glad the essay was published.

I want to thank the Wall Street Journal for Dr. Muller’s Saturday Essay. He did an outstanding job in making clear how even using the most conservative limits and estimates, the radiation released during the accident at the Fukushima Daiichi nuclear facility will not have a measurable impact on the residents of the region. The FEAR that has been instilled by those with an agenda and the hopes of other economic gain has done far more harm to Japan and to the rest of the world by convincing people to abandon nuclear energy.

This reliable form of energy generation has few incidents, so each time anything goes wrong, it is news, even when no one gets hurt and the risks are minimal. Unfortunately, this “no news is good news” method of coverage has left many people under the impression that these plants are dangerous and difficult to operate. Dr. Muller’s article helps clarify the fact that one of the worst nuclear accidents in history has had a minimal environmental impact. I hope that this understanding will allow people in Japan to return to their homes and begin the difficult job of picking up the pieces after a devastating earthquake and tsunami ravaged their lives. Restarting their nuclear facilities will go a long way toward bring Japan back on track as one of the largest economies in the world.

The benefits of the high energy density of nuclear energy are enormous. A typical currently operating nuclear energy facility generates nearly 8000 GWH of electricity every year from a facility that takes less than 2 square miles of land. That’s enough electricity to power more than 650,000 households. It takes only 750-800 people to safely operate the plant. But the impact on the local economy of well-paying jobs and high tax base of these facilities makes most localities very supportive of the plants. The presence of these power plants can attract industry, interested in reliable, low cost electricity. Increasingly new industries are concerned about clean energy and nuclear fills the bill nicely with ZERO carbon emissions, low cost and reliable generation. Only hydro power can come close to nuclear energy’s ability to unleash an economy.

Nuclear Energy can continue to provide clean, low cost electricity to power America, allowing manufacturing and high-tech energy intensive industries to employ thousands and recharge the US economy along the way. Only if we don’t let scare tactics and fear mongers frighten us into the next dark age. Let’s keep the lights on!

Now, tell me what YOU think…

American Nuclear Society’s CNST

Yes, this is another post related to things I learned at the ANS-UWC. I don’t usually dwell so long on one conference, but there was so much interesting information that I wanted to pass along.

Dr. Corradini and the ANS’ CNST

Dr. Michael Corradini, president of ANS spoke about a new project ANS has undertaken – The Center of Nuclear Science & Technology (CNST). The project was started about six months before the earthquake and tsunami in Japan, when Fukushima dominated the news waves. The CNST was put on hold for a period while the ANS concentrated on responding to those events.

A president’s committee within ANS that Dr. Corradini co-chaired was formed a month after the earthquake to assess various aspects of the events at Fukushima, including the level of public knowledge and understanding. One sub-committee was dedicated to assessing the communication effectiveness, trying to understand some of the crisis and risk communication in Japan. There was a clear lack of knowledge in the general public, both in Japan and in the U.S., regarding nuclear technology. No surprise to anyone, we haven’t been communicating enough, we need to do better.

So, Dr. Corradini announced the CNST at this conference. Its primary objectives are to provide education for K-12, teachers, the general public, and policy-makers on nuclear technology. The CNST will be providing fact-based worksheets and websites to help with education. In fact, this year, the CNST has run five sessions in Washington, DC for legislative aides, to help these folks understand a little more about the technology and how it works.

Mr. Freebairn, a Journalist’s View

After Dr. Corradini, Bill Freebairn of Platts talked about the views of nuclear from a journalist’s perspective. Mr. Freebairn is an excellent journalist at Platts, which is a news service for the energy business. His “beat” is primarily nuclear. He opened with a discussion of one of those age-old arguments – Does the media reflect or shape public opinion? His answer “a little of both” – For what it’s worth, I agree.

Mr. Freebairn talked about media coverage prior to Fukushima was mostly local, nationally there was limited interest. After Fukushima, there has been significantly more national press and media attention on nuclear. He acknowledged the limited knowledge of most journalists. Many went into journalism to avoid science and math, they are generalists. This is good and bad. Such journalists ask questions that the general population also does not understand, forcing us technical types to clarify concepts we don’t realize are not well understood. However, they don’t know whose facts are real, making them more vulnerable to wild claims.

Putting it Together

Dr. Corradini’s speech was particularly important to me as I’m involved in many of these issues with ANS. I served as a key spokesman for the ANS in the weeks following Fukushima and worked hard to explain the technology to journalists and talk show hosts all over the world. In addition, I served on the risk communication sub-committee and spent many hours researching risk understanding and communication for that group. Finally, I serve on the Public Information Committee within ANS, which has prime responsibility for the CNST. We are actively working on a grants program to encourage local sections and individuals to develop and use materials to educate the public and local governments about nuclear technology.

After Mr. Freebairn’s talk, I was struck by the two speeches put together. The CNST that Dr. Corradini mentioned and the training sessions we put together for federal legislative aides needs to be rolled out for journalists and local and state government folks. Webinars would allow diverse attendance and teachers to bring some sound science to people that are in positions to make decisions and/or influence public knowledge.

What are YOU doing to help educate the people in YOUR community?

Report from ANS Utility Working Conference

I spent Sunday night through Wednesday noon at the 2012 American Nuclear Society Utility Working Conference. That’s a mouthful, so most people refer to it as the ANS-UWC. Marginally better to say, but a lot easier to type. The conference them this year was “Nuclear! Still the one! The right business, The right results, The right way forward”. I guess we like long titles in this business. T-Bow Thibault of TVA was the conference chair and told all speakers that we wanted to learn something new this year. I’d say they hit the mark! Attendance was about 750. Not a record, but a solid number of professionals gathered in one place.

To be honest, until last year, this conference wasn’t on my radar. I’d heard of it through colleagues at GE-Hitachi but mostly as a vendor conference/quality program kind of thing. As an engineering leader, it was simply not on my list of things to do. But it should have been. If prior conferences were anything like the two I’ve attended, there’s great information and really great people to meet and talk to. Describing the great information and people would take far more than a single blog, so I’m just going to hit highlights. If you want to know more, e-mail me with specific questions.

Vendor Technology Expo

Breaks, meals, and evening socials were all in the Vendor Technology Expo that accompanies this conference. The venue was great in that there was plenty of space for networking and talking with non-vendors, but also a number of interesting displays to see from companies all over the industry. I talked with several new folks and learned about some interesting new technologies.

I am particularly intrigued by a display (Bloxr) I saw with a new shielding material that is being used quite successfully in the area of nuclear medicine. The material is significantly lighter than a similar shield made from lead and reduces mixed waste in disposal, both excellent features. I’m looking forward to talking more with the company and getting this material out into the nuclear energy industry as well.

Also interesting to talk to some firms that are working in the Wilmington, NC area where I make my home. I tend to see business as a long ways from home, but there are a number in my own back yard as well.

Opening Plenary

Tom Kilgore, CEO of TVA

This year’s opening plenary speech was given by Tom Kilgore, CEO of TVA. His message was so important, he talked of the need to communicate about this industry clearly and widely. Nuclear energy is the only emission free baseload and we need to let the world know how important that is – not just greenhouse gasses, but particulates, mercury, and other emissions are also zero from nuclear energy facilities. To quote Mr. Kilgore: “Nuclear Energy is not always the easiest option, but jobs, economics, and environment make it the best option.” Change your words, change your worlds. He closed emphasizing that good, safe performance is not enough, we need to communicate, demonstrate, and deliver every day.

Kilgore then switched gears a bit and talked more specifically about TVA. TVA currently has a fairly balanced portfolio with about a fourth each nuclear, coal, and hydro, and a fourth the rest (gas and renewables, mostly). He sees a future that is about 40% nuclear and very little coal. Current growth rates indicate that TVA will need 22% more electricity in 22 years. That’s lower than the prediction of a few years ago, but still represents substantial increased needs. He sees very little coal making that electricity. Good news for the environment, I think.

Finally, he talked pretty frankly about some of the recent issues that TVA has had with their nuclear fleet. He stated quite clearly: Safety first, public and workers. Second, system reliability. After the tornadoes in 2011 shut down transmission lines for as much as month and affected Brown’s Ferry units, they’ve added backups and better transmission lines. 2012 was less severe, but they had no outages. As he spoke, they have some coal units down unexpectedly, but the nuclear stations are all running at 100%. Kilgore talked about the fact that it ultimately comes down to people, well trained, competent people. He’s been trying to drive collaborative improvements in TVA – all stakeholders, undustry, education, regulator.

He closed exhorting all of us to talk more about nuclear energy in clear, understandable terms. The more people know about nuclear energy, the more they support it. We need to keep talking, using simple language, stop hiding behind our jargon. Let employees talk to the public. They want safety as much as, maybe more, than the public does. We most definitely need to stop talking to ourselves and start telling the world!

Josh Bleill, Indianapolis Colts Speaker

After Tom, we were treated to an inspirational speech by Josh Bleill, Iraq war veteran who lost his legs in defense of this country. He talked about his experience and journey through 22 months, multiple surgeries and learning to walk again (two times!). The Colts hired him to be an inspirational speaker. He told us about practicing with 3rd graders. (I’ve talked to 3rd graders, they are a much tougher crowd that we adults.)

He reminded us about service AND having a sense of humor. Closing line:

Don’t do the same things because you always have. Do the right things!

That’s all I have time for today. I’ll be providing insight and comments about the rest of the conference all next week.

NRC and Regulatory Capture

My blog last week got some interesting reactions regarding the larger picture of regulatory issues. I chose to look at quality as it is an area where significant changes in the broader context of quality control have occurred since those regulations were written and an update is overdue. This is also completely within the control of the NRC.

However, it brings up another question. Many have looked at what happened at Fukushima and concluded that the regulator was “captured” by the industry and was no longer an effective independent regulator. Some have accused the NRC of the same problem. Regulatory capture is a real and legitimate concern for all regulators and industry. What are the causes of such “capture”?

Let’s look at each scenario and determine whether the NRC might be affected.

The regulator is also responsible for promotion.

That was the direct cause for demise of the Atomic Energy Commission in the 1970’s. In the original design of the Atomic Energy Act, the Atomic Energy Commission was responsible for both regulation of nuclear power and its promotion. Interestingly, that was the model for the regulation of oil drilling until after the Deepwater Horizon oil spill in 2010.

Today, the NRC has NO role in promoting nuclear power in anyway. They communicate about the technology and their role in oversight. They prefer to present themselves as a competent regulator, which has sometimes been interpreted as promoting the industry.

The regulator and industry are providing jobs for each other

In essence, the regulator is either from industry directly, or guaranteed a position within the industry after departing the regulator. In Japan, TEPCO and NISA, a position on TEPCO’s board of directors was known as “the chair of heaven” and was guaranteed to be given to departing senior members of NISA.

In general, the NRC rarely hires from industry in any place other than entry level review positions. Commissioners also very rarely come from industry. The current five commissioners have virtually NO experience in the nuclear industry. They come from government (DOE, military, or congressional aides) or academia. Former commissioners have frequently gone back to academia or retired. Occasionally, they have become consultants, but with rare exception, NRC commissioners, or other high level staff, have not ended up in high level industry positions. Those exceptions have been looked at quite carefully (Richard Meserve, for example) and, to date, allegations of inappropriate ties have not been borne out by the Justice Department.

Expertise in the regulation can be powerful in assuring compliance within the industry. Putting former regulators in positions of authority can be helpful in enforcing compliance. In reverse, industry expertise in how a technology really works in practice can allow more effective regulation. However, guaranteed positions of employment going either way is clearly problematic.

Payment by industry to Regulator

The industry pays fees and review costs and funds a large fraction of the NRC’s operating budget. From the NRC’s website in response to a question about the oversight of NFS:

Do NRC fees to the licensee create a conflict of interest in regards to fair regulation? Ninety percent of the NRC’s funding is recovered from the plants that it regulates

No. The NRC operates with funds approved by the U.S. Congress that come directly from the U.S. Treasury. The fees collected have no affect [sic] on the approved NRC budget. The fees paid by licensees go directly to the U.S. Treasury …

While the NRC does not benefit directly from the fees paid by industry, clearly its budget is tied to receiving those fees. The separation of fee payment and service rendered (license maintained, or inspections passed) does prevent the NRC from seeing any one licensee as more important or more valuable than another. In fact, some of the fees assessed are directly related to having issues with the licensees. The more issues a facility is having, the more hours of inspection the NRC requires, which results in more fees.

More problematic is the area of new technology. The NRC has so little funding from the government that isn’t tied to income from industry that the efforts to develop regulation for new technologies (like SMR, or Gen IV) will have to come from industry itself. This process is definitely fraught with risk that the NRC may be overly influenced by the industry itself. While the funds do not flow directly to the NRC, they are clearly aware of their own funding sources.

Fundamentally, the problem with this arrangement is the APPEARANCE of regulatory capture. The question is – Do other oversight agencies operate the same way? And do they have any issues?

Conclusion

There is no direct evidence of industry capture by the NRC. They consult with industry on new regulation, but they also encourage the public to weigh in on these regulations. However, inherently, the NRC is parasitic on the industry. If the nuclear industry were to be abandoned entirely, much of the purpose for the NRC would immediately end and the commission’s role would be significantly reduced.

Two areas that should be monitored and considered are the potential for cross hiring to contaminate the independence of the commission and the issue of funding for specific areas of responsibility within the NRC.

How do other agencies get funding and hire and maintained a qualified, yet independent staff?

Nuclear Quality Regulations – Time for a new look?

I’ve spent most of my career working with Nuclear Regulation. One of the most complex series of regulations you can imagine. The U.S. Internal Revenue Service probably sent people over to help the AEC/NRC develop these regulations. They cover a wide variety of issues all under the name of safety and security.

One of the smallest parts of the regulation is actually quality assurance. The majority of this regulation sits as an appendix to one of the largest chapters, Appendix B to 10CFR50. This little collection of requirements is a mere 3 pages long. It draws in 10CFR21 as a part of the regulation which is an additional 9 pages. These regulations were written in the 1970’s with few modifications to clarify and/or expand the application of these regulations.

A little History

Appendix B was written primarily to target plants under construction, whereas the NRC was concerned with control of the engineering, procurement, and construction of nuclear power plants. The original authors split into several teams and fairly quickly generated the text that now forms most of Appendix B. In total, the requirements of 10CFR50 Appendix B apply to designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying. They never imagined that it would become so permanent.

10CFR21 requires immediate notification to the NRC of any facility, activity, or basic component that either contains defects or fails to comply with requirements and creates a substantial safety hazard to the facility. In addition, it provides a means for accepting commercially manufactured items for nuclear safety-related applications. This process is referred to as commercial grade item (CGI) dedication.

Like other regulations, standards were developed by independent organizations. ANS developed the first set, sometimes referred to as ANSI N45.2 and daughter standards. However, ASME stepped in after a few years and created a standard that eventually became known as NQA-1.  The NQA-1 Committee, which consists of a collection of QA experts and managers from all facets of the industry, meets periodically to update the standard to current technology and known issues. Some of these areas include Software Controls, CGI Dedication, and Maintenance.

So what?

The problem is that the regulations were written when few quality standards existed in industry. The NRC’s Appendix B program was a pioneer in demanding quality control, record-keeping, and training of the people performing the work. However, the criteria as written is poorly organized with overlaps and gaps in the requirements. It fails to deal with modern technology in terms of software control, electronic record keeping and document control. These have been left to the cottage industry the has arisen around NQA-1.

ASME issues a new version of NQA-1 every 4 years or so. They are planning to issue a new version in the next few months. The problem is that the NRC just approved the last standard in 2010 and virtually no one has been able to update their programs to reflect that standard. The new standard may well address critical issues, but the ability of the NRC to review and approve and the industry to adopt to the newer standards is not adequate to this continuous modification.

In addition, many of the small suppliers are finding these regulations to be burdensome without actually improving the quality of their products. Many suppliers today comply with ISO-9001 which is an international quality standard. However, the NRC (and ASME) do not recognize that this program provides adequate quality for parts generated under the program. This has created an additional burden to the industry that increases costs without increase quality. For safety-related components, the industry either had to demand that a supplier develop an NQA-1 based program in addition to their ISO programs, or they have to go through a separate dedication process that required testing and more paperwork to validate the part.

It seems to me that it is time, past time in fact, for the NRC to step back and look at the quality requirements in context of international standards (that are used by other nuclear regulators to a high degree of effectiveness) and modify the regulations to reflect these standards. Look at what experts in relevant technologies have done and point to those standards appropriately, stop trying to create independent regulations that are simply increasing costs without improving quality or safety.

Tell me what YOU think is needed?