ALARA

In 1971, the AEC proposed a radically new regulatory philosophy requiring all nuclear plants be designed to hold all radioactive emissions to levels such that "exposures were as low as practicable". In other words, there is no limit. And the criteria is not whether the benefit of further reduction outweighs the cost. The criteria is: can you afford the reduction?

This was such a departure from standard regulation that, despite their desperation to get plants on line, it did produce push back from industry. But after considerable debate the policy was formally adopted in 1975 with the wording changed slightly to "as low as reasonably achievable" or ALARA.

In practice, As Low As Reasonably Achievable is interpreted by the regulators to mandate any regulation that allows nuclear to remain competitive with alternate sources of power. This is a perfectly reasonable interpretation of reasonably achievable. Any requirement that still leaves a design or a plant competitive with other sources of power is manifestly reasonably achievable.

But driving the cost of all nuclear power up to say the cost of coal has four effects:

1) Technology stagnates. There is no point in developing cheaper, safer designs if all that means is still more expensive regulation. If investors cannot benefit from taking a risk on a new technology, they will not invest. Even incremental improvements are pointless. The winners are the incumbents. They don't have to worry about some cheaper provider of nuclear power coming in and undercutting them. They become both comfortable and sloppy. Then they embrace the system because it protects them.

2) Under ALARA, nuclear power can never be cheaper than the competition from other sources. If the providers of nuclear power were forced to operate in a truly competitive market, competing with each other, the inherent cheapness of fission power combined with technological advances would push the real cost of nuclear power lower and lower. The real losers here are the poor and the planet.

But it's the longer term implications of ALARA that are the most tragic. Imagine a world in which nuclear power costs less than three cents real a kilowatt-hour as it did not so long ago. Not only would the poor be immensely richer, but the planet would be far better off. Electrification of transportation and industry would explode. Desal would take off. Synthetic fuels could become viable. Skies would be clean. All this electricity would require little land and produce almost no CO2.

2) But under ALARA we will never even get started. One problem with driving the cost of nuclear power up to the cost of other sources is the cost of other sources changes. In the 1970's, the cost of fossil fuel skyrocketed. Under ALARA, the cost of nuclear rose in lock step with the cost of coal. Then from 1980 on the real cost of coal power started declining and is now as low as it has ever been. But the regulatory ratchet only works one way. Nuclear was left high and dry. New plant construction abruptly halted.

ALARA was not through. Nuclear power is an inherently low marginal cost source. For ALARA that's just means here's an opportunity, nay, a requirement, for more regulation. ALARA now went after nuclear power's operating costs, driving them up toward the operating costs of coal, for which fuel alone is about 3 cents per kWh. The easiest way to do this is paperwork requirements that add people. In the US a typical 1 gigawatt nuclear plant will have a staff of 700 people or more. But such a plant can be operated by fewer than 20 people per shift.

This was recently demonstrated in Spain. Spain has three 1 GW nuclear plants on two sites near Barcelona. Normally the three plants employ 850 people, far less than USA practice. When COVID-19 came along, the plants were instructed to keep all non-essential employees home. Turns out only 120 people were needed to operate the three plants. Not surprising. The 450 MW Riverbend coal plant in North Carolina operated with a total of 14 people per shift. Coal plants are far more maintenance intensive than nuclear plants.

Nuclear survived these bloated operating costs for a while. But then fracking came along; and the real cost of gas dropped by a factor of three. We now have the nonsensical situation where a fully depreciated nuclear plant which should have a marginal cost of well below a penny a kWh cannot compete with natural gas, a high marginal cost source of electricity. That's the power of ALARA.

4) ALARA sends an important message. The message is we should spend substantial resources reducing radiation exposure, even if the exposure is already far below the dose rates which have resulted in detectable harm. There is no dose rate below which it does not make sense to reduce the dose rate further. ALARA says to one and all, any radiation is perilous.

ALARA is often defended by emphasizing the adverb ``reasonably". The assumption is that the regulator will be reasonable. But what is perfectly reasonable to a bureaucrat covering his rear can seem nonsensical to the rest of us. But it is the bureaucrat's opinion that counts.

Here's an example from Rockwell:

A forklift at the Idaho National Engineering Laboratory moved a small spent fuel cask from the storage pool to the hot cell. The cask had not been properly drained and some pool water was dribbled onto the blacktop along the way. Despite the fact that some characters had taken a midnight swim in such a pool in the days when I used to visit there and were none the worse for it, storage pool water is defined as a hazardous contaminant. It was deemed necessary therefore to dig up the entire path of the forklift, creating a trench two feet wide by a half mile long that was dubbed Toomer's Creek, after the unfortunate worker whose job it was to ensure that the cask was fully drained.

The Bannock Paving Company was hired to repave the entire road. Bannock used slag from the local phosphate plants as aggregate in the blacktop, which had proved to be highly satisfactory in many of the roads in the Pocatello, Idaho area. After the job was complete, it was learned that the aggregate was naturally high in thorium, and was more radioactive that the material that had been dug up, marked with the dreaded radiation symbol, and hauled away for expensive, long-term burial.

The bureaucrat is playing with other people's money. For him, the Toomer's Creek expenditure was quite reasonable. It cost him nothing while completely rectifying the mistake. Toomer's Creek is just a particularly silly example of a pervasive and totally debilitating doctrine. Unless ALARA is dispensed with, nuclear power is doomed.