New Nuclear Build - Economic Regulation?

Gregg Butler

Director: Integrated Decision Management LtdProfessor of Science in Sustainable Development,

University of Manchester

Reactors in the UK – Experience to date

• Generation I Magnox: 10 stations – 9 different designs (plus another two exported!)

• Generation 2a AGR: 7 stations – 4 designs, 3 design and construction consortia

• Generation 2b PWR: 1 station, derived from US design but extensively modified – ends as very much a ‘one of a kind’

Comment: • 18 reactors, 14 designs• only the near-identical Heysham 2 and Torness

stations were built in parallel, and this proved very beneficial in minimising delays and improving construction efficiency

Licensing Regime

• Safety licensing regime therefore developed to ‘cope with anything’

• Permissioning regime based on Safety Assessment Principles (SAPs)

• Risk levels governed by Tolerability of Risk• Safety improvement driven by So Far As is

Reasonably Practicable (SFAIRP) within the framework of Tolerability of Risk

Tolerability of RiskE

ffect

on

max

ima

lly e

xpo

sed

in

div

idua

l - T

ole

rabi

lity

of R

isk

10-6

10-4

10-2

10-8

Unacceptable region Risk cannot be justified saveIn extraordinary circumstances

Broadly acceptable region

ALARP or Tolerability region

Tolerable only if risk reduction is impracticable or if its cost is grossly disproportionate to the improvement gained

Tolerable if cost of reduction would exceed the improvement gained

Workforce

Public

Necessary to maintain assurance that risk remains at this level

ToR – Gross Disproportionality – Where to Stop?

• If Gross Disproportionality is to be bounded then the ‘Tolerable’ and ‘Broadly Acceptable’ regions need to be stabilised

• All the current signs point to erosion– Nuclear site delicensing now relies on meeting

10-6 as a limit – In the environmental field, guidance on BPM

explicitly removes any thought of ‘valuing’ Gross Disproportionality

ToR – Gross Disproportionality – Where to Stop?

“A Review of the Application of ‘Best Practicable Means’ within a Regulatory Framework for Managing Radioactive Wastes - March 2005” : “As a matter of principle, the (Environment) Agencies define no lower threshold of dose or environmental contamination below which BPM does not apply ……Put simply, BPM requires site operators to ensure that the measures in place to manage radioactive wastes are not unreasonably costly.

In all cases, however, the onus is on the site operator to implement measures to the point where the costs of any further measures would be grossly disproportionate to the risks they would reduce or avert.”

…….a quantitative definition of ‘grossly disproportionate’ would be ‘difficult, if not impossible’

Licensing Regime and PWRs

• The UK licensing regime has only had one try at licensing an international design

• Sizewell B was an operating US design, and was examined ‘from the ground up’

• Time pressures were not on the project team’s side – they gave in a lot!

• Sizewell ended up much more complex and expensive than its mother station – with many developments during the late stages of design and even during the build

Licensing and Regulation – Sizewell B Took 14 Years to Plan and Build

From www.niauk.org

Sizewell B experience - 7 years from site selection to site license - Construction 6.5 years

Any risk of a repetition = ‘no chance’ for new build!

From www.niauk.org

Sizewell B experience - 7 years from site selection to site license - Construction 6.5 years