New Nuclear Build - Economic Regulation?

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New Nuclear Build - Economic Regulation?
Gregg Butler Director Integrated Decision
Management Ltd Professor of Science in
Sustainable Development, University of Manchester
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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

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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

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Tolerability of Risk
Risk cannot be justified save In extraordinary
circumstances
10-2
Unacceptable region
10-4
Effect on maximally exposed individual -
Tolerability of Risk
ALARP or Tolerability region
10-6
Necessary to maintain assurance that risk
remains at this level
Broadly acceptable region
10-8
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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

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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
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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 teams
  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

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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
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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