ALARA's not so bad. What about Korea, China?

Figure 1. Already out of date (2022) map of Chinese NPP sites

ALARA is the regulatory philosophy which holds that no amount of radiation exposure is acceptable if further reduction is "reasonably achievable". If the extra cost of some measure leaves the plant competitive with other sources of electricity (including other nuclear designs), then that measure is manifestly "reasonably achievable". This criteria, if interpreted strictly, inexorably pushes the cost of any design up to the cost of the marginal source. If a new design is truly cheaper, that just leaves more room for the regulator to push up costs. He's not doing his job if he fails to do so. This in turn means there is no incentive for investor to invest in that improvement.

ALARA is a radical departure from standard regulatory policy which requires balancing the costs of a proposed requirement against its benefits. It was recognized as such in 1971, when it was first articulated; but nuclear was in the midst of a boom created by the Oil Crisis and there was only modest pushback. Now ALARA has gone viral and has infested not only all of nuclear, but other regulatory regimes as well. ALARA is irresistibly attractive to regulators, because it gives them essentially unlimited power.

ALARA is usually defended on grounds that the process I outlined above need not necessarily happen. Examples are put forward of situations in which ALARA has not stopped some progress. In nuclear, Korea and China are usually cited.

In practice ALARA is an incremental process. The regulator will propose some "tightening" of an existing reg. The applicant is not allowed to argue that the cost of the measure is more than the benefit. If that change does not chase away all his customers, that tightening will become the floor for the next applicant. So even if the regulator is unchecked, the process always takes time. Depending on the politics, the ratcheting can be slow, but ALARA is a one way process. This gradualism tends to obscure how crazy ALARA can get. Tritium is probably the extreme example. More to the point, we don't really know what Korean and Chinese costs would be if there were no ALARA.

The other issue for an ALARA based regulator is his boss. In places like the US, Congress has decided to hand over full responsibility for nuclear "safety" to the bureaucracy. This allows them to blame the NRC when anything goes wrong. But it also means an applicant has no one to appeal an NRC ruling to, no matter how nonsensical. The system is self-perpetuating. If you are asking the NRC to award you a license, the last thing you will do is gripe about the system, and get on the wrong side of an omnipotent regulator.

The Korean system is different. In Korea, the Nuclear Safety and Security Commission (NSSC) reports directly to the Prime Minister. The Prime Minister appoints the NSSC chair, who is essentially a cabinet member. The PM in turn is appointed by the President. He is basically the president's executive assistant. This is quite unlike other systems, where the President is a figurehead. The President controls the NSSC in the same manner as he controls any other portion of his administration.

If KEPCO or a nuclear vendor is unhappy with an NSSC action, the CEO goes to one of his fellow Seoul University graduates who is close to the President. If as a result the President becomes unhappy with an NSSC ruling, that unhappiness will quickly filter down to the bureaucrat who made that ruling. His career will be in jeopardy. Korean bureaucrats are exquisitely sensitive to all this. So we saw night and day changes when the anti-nuke Moon became President in 2017, following the pro-nuke Park; and then another reversal when Moon was replaced by Yoon in 2022. In such a system, ALARA can be partially controlled, if the President wants it controlled.

I know very little about the Chinese system; but I suspect the practicalities end up about the same. In China, it is not wise to go against CCP policy. If CCP policy is pro-nuclear, which it currently is because the CCP is worried about coal pollution, I'm guessing the National Nuclear Safety Administration will be very careful in bucking that policy.

But these partial restraints on ALARA are no defense of a regulatory policy that does not require a regulator to show that the benefits of any regulation are larger than the costs, including the harm caused by alternatives, much less a system in which the only rule is that the regulator can use ALARA to change the rule. I repeat

1) No engineer can design to ALARA.

2) No rational investor can allow herself to be exposed to ALARA.

3) ALARA proclaims to one and all that near background dose rates are perilous.

ALARA must go. Any Congressional legislation aimed at "reforming" the NRC that dose not proscribe ALARA is an exercise in political posturing.