The Yosemite Wildfires and Energy Supply:

Another Vulnerability

[There are multiple nuclear-related issues in the news this week.  While the announced closure of Vermont Yankee has been getting the most attention from the nuclear community in the past few days, there is at least one other issue that is timely, so I will turn my attention this week to the news from 3,000 miles away.]

Even as the flames around Rim Fire at Yosemite still blaze, we learn that they are bringing to light yet another concern about our energy supply--the potential susceptibility to wildfires.  A recent editorial in the Wall Street Times referred to the new "message" we are seeing from the inferno as "California's Smoke Signals."  (Note:  The WSJ is a subscription publication.  As of the date of this writing, the editorial was available via an Internet search on the title, but I can't vouch for its permanence.  However, I will cover the key points below.)

There seem to be two parts of the problem:  siting of facilities and transmission lines.  The WSJ puts most of its emphasis on transmission lines, but I will start with the siting problem.

The WSJ notes that most solar and wind projects are located in fire-prone areas--dry, sunny desert and valley regions in the case of large-scale solar plants (at least in California), and mountainous regions in the case of wind farms.  Both of these types of areas are inherently vulnerable to fires, and although the editorial doesn't say so, climatic changes could exacerbate the vulnerability of these areas in future years.

Other kinds of power facilities, such as nuclear and coal plants, tend to be sited along the coast or on large bodies of water.  While it is not impossible for them to be affected by an external fire, the probability of them being exposed to large, long-duration blazes is much lower.

The other, more general, problem is that of transmission lines.  In this case, ANY power plant that is sited far from populated areas requires miles of transmission lines, often through--you guessed it--fire-prone areas.  Thus, large-scale solar and wind power stations are doubly vulnerable--they can be shut down by fires either at their sites or anywhere along their transmission lines.

However, nuclear plants, hydropower plants, or large coal-fired plants that are sited far from population centers have the same vulnerability to the transmission problem.  Hydroelectric power plants obviously have to be sited at suitable bodies of water.  Large-scale solar and wind projects require places where large tracts of land are available.  Large nuclear plants need access to water.  Even if cooling towers are used, public concerns will prevent them from being sited near population centers (although nuclear plants, with or without cooling towers, can be sited a lot closer to population centers than the 120-mile and 150-mile transmission lines mentioned in the editorial).  

The editorial cites a 2008 draft Environmental Impact Report for the San Diego Gas and Electric area that indicated there had been 33 "reported power outages" from 16 different wildfire or lightning events occurring from 1986 to 2005.  While this is less than one causal event and less than two outages per year, these types of outages, occurring in remote areas and sometimes over a widespread area, are generally not fixed quickly.  (No data was reported in the editorial on lengths of these outages, number of people affected, or costs of repairs.)   

Although the WSJ paints this vulnerability as a problem of the "green political obsessions" of California, I see the issue as more complex.

The description of the problem leads me to think that more attention needs to be given to citing some fraction of our energy supply closer to population centers, especially in areas of the country prone to large-scale fires.  This can be done--to some extent--with almost every power source (except perhaps hydropower).  There are certainly smaller-scale applications of solar and wind energy.  There are also small, more passive, nuclear reactors under development that should be able to be sited closer to population centers.

These statements are, of course, easy to make but hard to implement.  The reactors are still under development.  There is still a NIMBY problem, both for nuclear plants and, increasingly, for windmills.  There is still the reliability problem for renewable energy sources.  (This is true regardless of scale, but the larger-scale projects often are combined with on-site storage systems.)  There is the cost of the loss of economies of scale.  Alternatively, there might be a possibility of rerouting some transmission lines to make them less vulnerable to fires, but that will also entail a substantial cost.

The point is that the wildfires are a graphic argument for diversity of supply.  I have always believed that diversity is important, but I must admit that, until this week, I thought of it primarily as an issue of mixing sources, such as nuclear, coal, gas, and renewables.  Now, however, I think the definition needs to be expanded to include diversity of size and location as well. 


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Post-Fukushima Japan:

Unseen Impacts

I am often struck by comments I hear that the shutdown of most of the nuclear power plants in Japan hasn't seemed to have much of an impact.  The country continues to function, after all, doesn't it?  People are not dying in masses on the streets because of lack of heat in the winter, are they?

True, a lot of conservation measures have been taken.  Building hallways are darker and offices are warmer in the summer, but on the surface, everything looks like it is perking along more or less as usual.

What people do not realize, of course, is that the most serious effects are basically invisible to most of the people most of the time.  A couple of weeks ago, a report came out that Japan's carbon dioxide intensity in FY2012 far exceeded the levels achieved in the past when all the nuclear power plants were in operation.  This put Japan far beyond the carbon reduction targets they'd previously targeted to achieve.

This finding should not be surprising, because what Japan has done to keep the country functioning is to ramp up the use of fossil fuels.  The public may feel that it is mainly their efforts to conserve energy, and the sacrifices of their comfort and convenience, that are allowing them to function without nuclear plants.  However, in reality, a far larger effect has been the replacement of nuclear power by fossil-fired power plants.

There are other impacts as well.  The higher costs of energy have had effects on the economy.  For example, jobs have moved overseas as the cost and availability of energy made it less economical to manufacture goods in Japan.  These causes and effects are also not readily visible to the average person.

Unfortunately, the fact that things look generally OK on the surface makes it easy for the Japanese public to believe that they can continue to function without returning their nuclear power plants to service.  As long as they think that just notching the thermostat up or down a little will do the job, it will be difficult to get people to understand the need for nuclear power. 

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Irradiated Food:

The Case for More

I was pleased to see a recent NRC blog that highlighted the value of irradiating food to eliminate the harmful pathogens in our food supply that all too regularly cause massive outbreaks of illness and even deaths.  They were responding to news of recent outbreaks of illness traced to lettuce from Mexico served at the major US restaurant chains of Olive Garden and Red Lobster--only the latest of many such outbreaks in many parts of the US over the years
.

I have been following this issue for a number of years, and even I was surprised at the statistics they cited--that, according to the Food and Drug Administration (FDA), 1 in 6 Americans falls ill each year from tainted food.  Most of these food-related illnesses, of course, prove to be minor, but 128,000 people are hospitalized each year and 3,000 die.

That is far too many, and it should be unnecessary.  While some say that the solution is higher standards of cleanliness in the food production chain--and I cannot disagree with that--I do not think that is a complete answer.  The food chain is too far-flung and too distributed for the traditional methods of oversight to work effectively all the time.

With food irradiation, we have an option to provide a much higher guarantee of safety than we can possibly achieve by rules and inspections alone.  It's been proven safe, and contrary to what many people think, it has been in use for a number of years for certain food products, such as spices.

It seems, however, that expanding the use of irradiation to other foods has run into repeated roadblocks due to misconceptions about what irradiation does to food.  The NRC blog tries to address that issue.  I am glad to see them weighing in on this issue, but I can say from personal experience that they have a steep climb ahead of them.

I have previously told the story of what might be termed my ANS irradiated cheese caper--how, in 2001-2, when I served as president of the American Nuclear Society (ANS), I thought I would bring to America the cheeses from France that we cannot import!  I would ask for only a one-time exemption, I offered to post signs at the reception to remind pregnant women and others with health concerns not to eat the irradiated cheese, and I would engage the help of Congressman Joe Barton.  Piece of cake, I thought (or perhaps I should say, piece of cheese).

As I reported, it was all to no avail.  The FDA would not budge.  In the end, we held the ANS reception sans les fromages de France.

I tell this cautionary tale because I know the challenges that are faced by the efforts to improve the safety of our food through irradiation.  I am hopeful that, over time, the opinion of the public will change, the voice of the NRC will be influential, and that the FDA will begin to approve the irradiation of more foods.  I only hope that it will not take more disease outbreaks and more deaths for this to happen.

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New Nukes:

The Next Generation

I was pleased to see an article in Time magazine called New Nukes, which provided a rather positive and optimistic view of the need for nuclear power and its future.  [Note:  On-line access by Time magazine is by subscription, so I'm not sure this link will provide the full article or be permanent.]

What proved most interesting to me about the article, however, was not so much the content of the article as the approach.  Rather than highlighting the "usual suspects" for the next generation of designs--that is the integral pressurized water reactors (iPWRs) that most people acknowledge have an edge right now in terms of the stage of development and the knowledge base of conventional PWRs on which they build--they take the leap of focusing on non-light water concepts.  And rather than drawing on the national laboratories and other places that have been exploring non-LWR technologies for decades, they focus mostly on young graduate students--the next generation of reactors from the next generation of reactor designers.

I want to make sure it is clear that the article did mention all the options.  It described the AP1000s and the EPRs currently under construction, it mentioned Babcock and Wilcox and the US Department of Energy (DOE) award as well as the Hyperion and NuScale contenders, and it discussed larger, more established efforts on non-LWRs, such as Terrapower's traveling-wave reactor.

But the article began and ended with a focus on two graduate students who have founded start-up companies in the hopes of promoting non-LWR technologies.  (One is a molten-salt design, and the other, although not stated in the article, seems to be a very small module.)  It almost glossed over the prospects for the iPWRs on the grounds that, "to really change the economics of nuclear...you need to fundamentally change how plants operate."

I was pleased to see such an optimistic article in a major publication like Time.  I am very pleased to see the enthusiasm and enterprise of the next generation of nuclear engineers--and I certainly wish these two young entrepreneurs the best of luck.  Yet, when I see stories like this, I worry about the next "too cheap to meter" criticism.  The article tries to say that there are hurdles ahead, and that it will take time--and lots of money--to bring new designs to market--but I am afraid those cautions are almost lost.  Furthermore, while I think it is important to pursue more advanced technologies, we do ourselves a disservice if we dismiss the near-term technologies. 

Therefore, I hope to see Time, or other publications, continue to cover new developments in nuclear technology.  Over time, I hope these will provide the general public a more complete picture of the iPWRs and their promise and prospects. 

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Nuclear Power and Regulation, Part 2:

Is Regulation Needed in the First Place?

A recent post of mine on a case of over-regulation that was making magicians develop emergency plans for their rabbits in case of natural disasters inspired a commenter to suggest that we should think twice about writing any new rules.  After all, he says, "we have had zoos for well over 100 years and somehow we survived."  He goes on to say that he doesn't think we need a "constant stream" of new rules.

Although I'm not an expert on zoos, I would guess that there probably have been natural disasters in the past that breached the security of zoo enclosures and allowed the release of dangerous animals, or that resulted in animals dying cruel and unnecessary deaths.  But that is only my guess, and I have no more concrete evidence for that than does my commenter in saying that zoos were fine without any such regulations. 

I was addressing only the magicians with rabbits, where the rule was clearly excessive.

But I will also say this:  If you go back in history, most regulations that we have today started out in response to a problem.  Contrary to what some believe, they didn't originate for no reason at all in the halls of Congress, or from the cubicles of government bureaucrats. 

They originated to solve a problem.  And in most cases, they originated because of the obvious damage that had been caused when there were no rules in place.  Think about banking.  Think about monopolies.  Think about contaminated food.  Think about discrimination.

In reality, most regulations were only put in place after people were injured or killed, or after they'd suffered financially, or after they'd been treated unfairly. 

I suspect that those early regulations engendered the same kinds of controversies that exist today.  The industries of the day probably thought that things were fine without any regulations at all.  That they could fix their own problems.

And just as surely, the regulations probably missed the mark in some way or another.  Perhaps they didn't address all the problems.  Or perhaps they went too far in some respects.  That gets us back to the case of the rabbit and the magician.

It would be nice if everyone was smarter and and we could avoid these kinds of errors in the first place.  But the solution is not to block regulation in the first place.

The first solution is to fix problems once they are identified, and hopefully, to fix them more expeditiously than has been the case in the past.

The second solution is to try to get smarter about developing regulations so we don't have as many problems.  This, of course, is easier said than done.  It requires the active involvement of regulators, industry, and other stakeholders.  It requires everyone to look outside the box to think about finding solutions that minimize impediments to operations but at the same time address legitimate health, safety or other concerns.  And it requires them to think about the magicians with rabbits.

It may actually be easier for this kind of interaction to take place in the nuclear area than in the case of caged animals, since magicians and rabbits don't usually participate in the regulatory process, but nuclear vendors, utilities, and public interest groups do.

But the more we try to think outside the box, the more issues there are to be considered, and that takes time, which is also a drawback.

So, yes, regulation is by its very nature an impediment to someone, some of the time.  There are usually good reasons for most of those impediments, but sometimes, there are impediments that are excessive, misdirected, outdated, or unnecessary.  Therefore, the solution to regulatory problems is not to "throw the baby out with the bathwater."  Rather, it is to try be as smart as we can in the first place, and to fix problems promptly as they are identified.

Taking a knee-jerk stance against regulation is really just as short-sighted as thinking that more regulation is always better.  The real point is that we need smart regulation.  It is not easy to attain smart regulation in a complex and changing world, but we will never achieve that goal if we draw lines against regulation altogether. 


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Energy and Climate Change:

A Two-Way Street

We have long been bombarded with stories about how our use of energy is affecting our environment and our climate.  The biggest concern has been that the carbon dioxide emissions from power production can lead to global warming, but particulate emissions may also have environmental and climate-related effects.  

Now, we are being told that climate changes may, in turn, affect our energy supplies.  The US Department of Energy (DOE) recently published a new report outlining a number of potential effects of climate change on energy sources.  In fact, they point out that we have already seen the beginnings of these effects.

The most troubling aspect of this report is that virtually all sources of our energy supply are vulnerable to some degree.  Furthermore, there are multiple and widespread phenomena that can affect the energy supply, from droughts to floods, and from storms to rising sea levels.

Power plants of all kinds depend on cooling water, so droughts can affect nuclear plants, fossil plants, hydroelectric plants, and even solar plants.  Barges carrying coal and oil can be delayed by low water levels in rivers, and shale oil and gas extraction sites that use water may have to reduce or cease operations. 

Conversely, floods and storms that are becoming more frequent or more severe due to changes in the climate can force power plants to shut down, and rising sea levels can ultimately affect many power stations and other energy-related facilities that are sited on coastlines.  Storms can also damage power lines.

The report notes that we need to begin to pay more attention to these potential problems.  In some cases, improvements to the infrastructure can help make our facilities more resilient to phenomena such as storms and floods.  In other cases, R&D may be able to develop ways to extract oil and gas, and to cool power plants, in ways that use less water.

In the nuclear field, it is noteworthy that some of the advanced reactor concepts are designed to use coolants other than water.  Although these designs are being developed because of other potential benefits, they should also be largely independent of most of these climate-related effects.  They would certainly be more resilient to droughts, and since they would not need to be sited near sources of water for cooling, they should be less vulnerable to flooding, storm surges, or rising sea levels as well. 

It is clear that much more will need to be done as we begin to understand all the interactions between our energy supply and climate change, both to harden and protect our existing energy infrastructure, and to design more robust systems for the future.  It is heartening to know that at least some of the advanced technology developments we have been pursuing in the nuclear field are already steps in the right direction.

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Nuclear Power and Regulation:

Pulling Rabbits out of Hats

This week, the news carried an item that must have amused most people.  A magician is being harassed by the US Department of Agriculture (USDA) for not having a disaster plan for what to do with his rabbit in case of a natural disaster such as a tornado or flood.

I can hear the groans.  Yet another case of "arbitrary and capricious Federal regulation."  The little guy being harassed by the big, bad government.

All true.  And I think Marty Hahne, the magician in question, could now successfully expand his repertoire, if he wants to, from pulling rabbits out of hats to doing stand-up comedy about magicians battling government agencies.

But if we peel back the layers a little, we can understand both sides of this story. 

The rule was designed to deal with zoos and other institutions that have large numbers of animals, and in some cases, dangerous animals.  And since Washington, DC was only recently stalked by a red panda that escaped from the Washington Zoo, there is ample evidence that plans do need to be in place for the unexpected when it comes to animals under institutional control.

Therefore, most people would likely agree that we need some sort of rule.  In that light, let's examine this rule.

Is the overall rule a "good" rule?  It probably is.  As noted above, we need institutions to do something.  The only way to guarantee that is with a rule.

Is the rule a bad rule for magicians with rabbits?  Absolutely.

Should the USDA officials have thought about the needs of magicians when they wrote the rule?  Ideally, yes, of course, but I'll answer that question with a question of my own:  Would you have thought about magicians?

Should they have thought about bunny rabbits?  Same comment, and same question as above.

Clearly, what this incident shows us is an inherent short-coming of rulemaking.  A rule is made to address a particular need (emergency plans for zoos and other such institutions), and, I might add, sometimes a need identified at a particular point in time.  (More on that later.)

The rulemaking process has a safety valve that is supposed to help the agencies involved identify unanticipated consequences.  One problem in this case:  magicians probably don't review the Federal Register every day!

When the safety valve doesn't work, or when it works imperfectly, rules get put in place that have unintended consequences.  In this case, they create an undue burden on a man who pulls rabbits out of hats.  What is particularly ironic in this case is that he could keep the rabbit without being burdened by the rules if the rabbit was just a pet and was not used in a commercial situation.  Or, as the article points out, he could kill the rabbit and eat it without being bound by any rules.

You might well ask:  What is the message here?  Is this a case where it was wrong to have a rule at all?  I don't think so.  I would think that it is important for zoos and other institutions to have emergency plans in place.

Likewise, most of the regulations in other areas have a fundamental purpose that is valid.  The problem is that the regulators don't think of all the ramifications.  Or, in the case of technology, they write a rule that doesn't anticipate a new development.  Or, the situation changes in some other way.

This is not intended to excuse poor regulation.  It is a reality.  It is not that different from the reality that faces individuals and families and businesses all the time, for reasons big and small.  You plan a dinner party for the maximum number of people you can seat at your dining table, then learn that one of your guests has a significant other you hadn't known about.  You buy a house convenient to your job and then get a better offer--but with a much longer commute.  Your company moves into new quarters with just the right amount of space for the staff, and then gets a big new contract that requires additional staffing.  Trivial examples, perhaps, but some of the same issues are at play. 

So, what is the solution?  Obviously, the solution is that shortcomings in the regulations should be fixed as they are identified.  Of course, that usually turns out to be "easier said than done."  The rulemaking process is slow and cumbersome (for reasons both good and bad).  In the case of the magician's rabbit, the USDA does recognize the problem and is going to look into it, but that is usually a slow process.  The problem will probably eventually be fixed, but no doubt, Marty the magician is going to be saddled with excessive paperwork for a long time.  That is, unless he decides to pull an iguana out of his hat instead (as this particular rule applies only to mammals)--or unless (hint, hint) he can pull a final revised rule out of his hat!

(There is one "magic trick" the government can use, and they possibly will in this case.  That is, they can use a blanket waiver or an exemption for magicians with rabbits.  However, such waivers need to be used judiciously, or else fixing one mistake in a regulation could well end up creating another.  And for readers outside the US, I should note that, while the US uses a common-law system that allows the use of waivers, countries that use a civil law system generally do not allow waivers.)

The real message of this story is that government rules are only as good as the information that informs them.  If the regulators did not think about magicians and rabbits and if no one brought that particular situation to their attention, it is not surprising that the rule missed the mark.  If new technologies emerge and if regulations had no way to anticipate those technologies, it is not surprising that those rules may be fine today, but inadequate a decade from now.

Given this reality, I do not fault the government for rules with flaws.  I must admit, I got a good laugh out of this one, but I can fully understand how it happened.  However, for the same reason, I do fault the government for the slow pace of fixing flawed regulations.  While there is a process that takes some time (for example, to obtain and assess stakeholder views), the total process of making or revising a rule usually takes far longer than the public comment portion requires.  That is an important concern.

The case of magicians and the government is, of course, a special one.  The regulators are clearly at fault, but in reality, one can't have expected them to think of this very special scenario.  For most areas, where the industry watches their regulators closely, it is harder to make this statement.  Certainly, the regulators miss things.  In some cases, and particularly in cases where technology changes over time, the industry may miss things as well.  In other cases, the industry may raise concerns, but the regulators may decide the concerns are not valid, or not important, or are trumped by other considerations.

One reason some rulemakings take a long time is to accommodate the continued dialogue needed to sort out these kinds of issues.  I really don't know how often regulatory changes are made to address issues that were identified during the initial rulemaking process, but clearly, every time this does happen, it represents a failure of the public comment provisions of the rulemaking process to operate as intended. 

All government agencies really need to find ways to improve their rulemaking and to streamline the rulemaking processes, particularly where changes are needed to address shortcomings in existing rules.   Unfortunately, in this era of government cutbacks, I can't see an easy path for such reform.  And there are no magicians in the government!

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