Thursday, February 28, 2013

The inherent shallowness of "market-based" arguments against nuclear

In the middle of a lengthy takedown of Taxpayers for Common Sense's recent publicity stunt press release proclaiming their "Golden Fleece" award over the DOE's recent award of $452 million for NRC licensing assistance to B&W to construct a first-of-a-kind SMR at the Clinch River site, +Rod Adams brings up an extremely insightful point almost universally neglected in "market-based" critiques of described subsidies for nuclear energy. Specifically, Rod points out a perverse, unintended regulatory consequence brought on by anti-trust laws addressed by the Price-Anderson Act, which governs financial liability in the event of a nuclear accident. (The whole thing is of course well-worth reading.)

Rod points out:
The shared liability approach [inherent to Price-Anderson], if taken without permission, would violate the anti-trust laws that prevent competitors from cooperating. Price-Anderson’s system rewards the industry for sharing detailed technical information that would normally be carefully protected trade secrets. The nuclear industry’s habit of widely sharing important information and lessons learned from experience is one of the foundations on which its excellent safety record is built.
Price-Anderson liability structure
Image: NRC 
To those unfamiliar with how the Price-Anderson liability law works, the NRC has a helpful fact sheet which explains the basics. Contrary to common portrayal, Price-Anderson does not simply act as an "escape hatch" for financial liability for nuclear reactor operators. Each reactor operator is required to hold private insurance for $375 million per individual unit; after this limit is exceeded, a second tier of insurance from cross-pooling across each operating reactor kicks in - up to $11.6 billion. In other words, the liability structure of Price-Anderson explicitly makes it such that "an accident anywhere is an accident everywhere" - there is a shared financial liability across every operator.

The dispute arises of course as to what happens above the $11.975 billion liability threshold - yet this has never actually been tested. (In fact, after Three Mile Island, the worst nuclear accident in U.S. history, $175 million in funds came solely from the "first tier" - i.e., private insurance). Critics are of course free to make their case that the cap is too low - but it first involves an honest reckoning of what the actual liability structure actually is.

More important however, arguments like this tend to underscore a common problem with many of some of these so-called "market" critiques of nuclear energy - even cursory inspection tends to reveal how thin a paint job has been applied to what is primarily a vehicle for advancing a dogmatic anti-nuclear agenda. (I say this too as someone who is almost always first disposed toward market-based solutions.)

Such a harsh critique comes primarily from the shallowness of the arguments presented - which, like TCS's "Golden Fleece," focus primarily on the seen (i.e., the DOE's licensing assistance) and less so on the unseen (i.e., the flawed NRC licensing process which makes it incredibly difficult for new market entrants to feasibly seek design certification). In other words, the "market-based" aspect is simply invoked as a shallow pretext for one-sided arguments applied solely to nuclear energy, rather than across the entirety of the energy sector.

Thus why I highlight Rod's point: A fair free-market critique of the energy industry - nuclear included - would also look at the barriers erected by government regulation (which in turn are what spur the calls for so-called "subsidies" which free-market groups generally oppose). The perverse consequences of anti-trust regulation from information-sharing are an insightful example of this; likewise there is the issue of the regulatory standard for long-term disposal of nuclear waste. For example, a geologic repository for permanent disposal of nuclear waste is required to meet a standard of no more than 10 mrem/year exposure to the public over 10,000 years, followed by 100 mrem/year up to 1 million years. (How one evaluates these begins to leave the realm of engineering and move more into the realm of divination...) To give some perspective - this involves a protection standard equivalent to less than 5% of the average background dose one receives from natural sources over the initial post-closure period, and less than 30% in the million-year period. To put it in more familiar terms, this corresponds maximum exposure equivalent to 1 chest x-ray per year in the first 10,000 years, followed by half the dose from a head CT scan (and 1/10th the dose of a whole-body CT scan) over the next 990,000 years. (Discharges from nuclear plants are regulated still more strictly, at 0.3 mrem per year maximum - less than a standard dental x-ray.)

Ask yourself this - when is the last time you've heard of a coal or natural gas facility being required to sequester their toxic wastes from the public in near-perpetuity? (Likewise even with toxic heavy metal wastes incident to the production of solar panels). How many other facilities are required to pay hourly costs for regulators evaluating license applications (much less put in the encyclopedic licensing applications to begin with)?

The point here is not simply to complain or to justify any special treatment on the part of the nuclear industry - but it does provoke a question of why more so-called "market advocates" in energy only look at one side of the coin. A deeper (and more insightful) analysis would consider the inherent barriers erected as well - including the perverse consequences of features like anti-trust regulations and unequal applications of standards for risk exposure across different energy-producing industries - rather than  cherry-picking analysis we're typically treated to presently - thin gruel, indeed.

Wednesday, February 27, 2013

Serious climate advocates don't turn upon their vanguard

The easiest test of whether one is dealing with a serious environmentalist is quite simple: anyone claiming to be a friend to the environment who simultaneously makes it their priority to shut down the most abundant carbon-free energy source in present day is at best no serious friend to the environment, showing a ludicrous disregard for the most basic concept of triage.

In this case, the calculus of triage is quite simple, and quite brutal - taking Fukushima as an example of some of the very worst consequences of a potential nuclear accident in terms of modern nuclear reactors (insomuch as a 40-year old reactor design can be called "modern"), such consequences amount to a catastrophic loss of property and perhaps even livelihoods to a localized region - but it pales in comparison to the global and devastating consequences of unchecked climate change, and pales even in comparison to the premature deaths brought about from ordinary pollution from more polluting sources like coal.

Wimpy energy strategiesFew environmentalists are willing to take such a self-marginalizing position (although clearly that number is far from zero, if the ongoing campaigns against Vermont Yankee and Indian Point are any indication). Those that do inevitably fall into two categories - those that (disingenuously) assert that the gap can be filled nearly immediately with renewable sources (despite the mathematical difficulties of such a claim), falling back onto the idea of natural gas as a "bridge fuel" (again failing the basic arithmetic rule that half the carbon dioxide emission of coal, easily the dirtiest source available, is still far greater than zero, or close enough when all emissions are factored in over the entire lifecycle), or when pressed, falling back upon the idea of "energy austerity" - asserting (again, under highly questionable premises) that the energy deficit can simply be closed by using less - either by efficiency or simply by imposed austerity.

A natural experiment for this position is to look to Germany's Energiewende, which purports to do just that - trading carbon-free baseload from nuclear today for a promise of carbon-free intermittent electricity from renewables tomorrow. As to its efficacy, the evidence speaks for itself - Germany's carbon emissions increased last year by 1.2% - namely because the chief replacement for nuclear energy has come not from renewables but perversely from burning more brown coal and natural gas. Claiming that substituting definite and indisputable risks (if only from the environmental costs of coal burning alone) for an uncertain, possible (and by all accounts, remote) risk represents a positive environmental trade-off is laughably absurd.  Worse, it represents the very opposite of intelligent triage - again, taking for granted the idea that the risk of a nuclear catastrophe is non-negligible (debatable, but assumed for the sake of argument), basic logic dictates eliminating the worst and most certain environmental harms first - the very opposite of what is being done.

Inevitably then we come to the default position it seems of most "mainstream" environmentalists today, perhaps realizing the absurd parody of triage implied by prioritizing the closure of existing, operational plants which emit no carbon in their operations over the most significant environmental offenders, instead re-focus their message on opposing the development of new nuclear units (essentially hoping to simply run out the clock on the matter). The most curious arguments invoked inevitably come down to very selective applications of both arithmetic and economics - those being that nuclear takes too long to build compared to renewables (which causes one to question whether they've done the math at the time it would take to build out an equivalent capacity) or that it simply costs too much while in the same breath insisting that the federal government must provide financial support to their energy sources of choice. (As for the latter, there is yet another quick test of the seriousness of the convenient economic principle invoked - ask the proponent whether their argument applies equally when it is their own ox being gored. If the answer is "no," the argument about economics can be clearly dismissed as specious special pleading.)

Give the boosters of natural gas as an eponymous "bridge fuel" credit for one thing - at least their position doesn't rely upon logical gymnastics (although it does depend on where you call home in the wintertime).

US electricity graph
The argument is simply puzzling, to say the least. As of right now, nuclear energy forms the vanguard in the fight against climate change, making up about 60% of the U.S. carbon-free electricity portfolio. In what constitutes an existential fight for the simultaneous survival of the human race combined with an unparalleled drive to lift out billions from crushing poverty, what sane leader then treats the vanguard as disposable? Contrary to popular belief, we do not currently suffer from an embarrassment of riches when it comes to options for stabilizing carbon output, especially if economic considerations are factored in (as they should be).

The fact is, prioritizing carbon-emitting sources like natural gas over nuclear - be it for the present (if temporary) economic realities (again, where warm weather and plenty of pipeline capacity persists) or for more ideological reasons (i.e., avoiding nuclear energy at all costs) - poses a real and significant handicap in our ability to combat climate change.

Sane triage allows for the idea of swapping out the worst sources (like coal) for "better" sources (like natural gas) - but what serious advocate for action on climate change should advocate turning upon their own vanguard - especially when arguably the nuclear solution has the potential to cut across ideological boundaries, particularly to those who might otherwise be otherwise ill-disposed to work as allies (i.e., ideological conservatives)? One needn't even believe in the reality of climate change for solutions which mitigate carbon to have real consequences - something which itself ultimately demonstrates nuclear's cross-cutting value proposition as a key tool in climate change mitigation.

Monday, February 11, 2013

Chemophobia and radiophobia's shared cultural roots

Chemist Michelle Francl has a quite interesting critique of the all-too-common "bobo" conceit of chemophobia - in its distilled form, a variant of the "appeal to nature" fallacy (sometimes mistakenly referred to as the "naturalistic fallacy"). Faced with the unfamiliar (and sometimes unpronounceable) chemical names for even mundane medicines like naproxen (more commonly known under its trade name "Aleve"), they sound menacing and unfamiliar - despite the fact that naproxen is fundamentally similar to salicylic acid on a chemical level - an extract of willow bark (and a metabolite of the more common compound known by the humble name of "aspirin"). As a result, a booming cottage industry exists for peddlers of "natural" remedies - with the implication that "natural" means "safer." (In the end, chemistry doesn't really care whether it comes from a lab or nature - the laws of physics remain the same regardless).

An important consequence of chemophobia is that it trades established science for an unknown - "traditional" alternative remedies which may or may not be effective and which fall outside the rigorous quality, safety, and perhaps most important dose controls applied to pharmaceuticals. But the one thing that it doesn't escape from is chemistry itself - for these "natural" remedies to be effective, they rely upon the same chemical principles in modern medicines. Hence, the chemophobia fallacy.

Francl's discussion of chemophobia (of which the whole thing is very much worth reading) touches upon an important parallel common to discussions of nuclear technology - radiophobia:
We are a chemophobic culture. Chemical has become a synonym for something artificial, adulterated, hazardous, or toxic. Chemicals are bad—for you, for your children, for the environment. But whatever chemophobics would like to think, there is no avoiding chemicals, no way to create chemical-free zones. Absolutely everything is made of atoms and molecules; it’s all chemistry.
The problems of chemophobia and radiophobia share common cultural cognition roots - particularly a mistrust arising from the origin of perceived risks. Sources of risk from large, faceless corporations, from synthetic origins are unfamiliar or ill-understood conspire to increase perceived risk, particularly for more those who identify with more egalitarian / communitarian values. (By contrast, as Francl notes, more natural, friendly-sounding names - think extract of willow - by virtue of their familiarity sound less threatening - again, despite the fact that the chemistry is unchanged.)

US radon exposure map
The same is true for things like radon gas - despite frequent concerns about radiation exposure from nuclear power plants, individuals are far less likely to be concerned about far more common (and far larger) exposures from naturally-occurring radon gas in their own basements resulting from the decay of uranium byproducts found in uranium-rich soils. More importantly, the largest source of increasing radiation exposure in modern times has been due to medical imaging - the increasing proliferation of regular CT scans is far higher contributor to the average American's radiation exposure compared to nuclear energy facilities. (ANS has a very useful tool for estimating your average exposure based on these kinds of lifestyle factors.)

The consequences of irrational fear go beyond the consequences for the pharmaceutical and energy industries - the choice to eschew science-based medicine carries real risks for health and safety. Fear of radiation results in energy choices like coal (particularly in Germany, which has swapped coal for the nuclear plants which it has sought to shut down) which produce far more deaths per kilowatt-hour both by fine particulates and which incidentally release more radiation than the nuclear plants they seek to avoid. The desire for "natural," intermittent energy sources (like wind and solar) in turn lead to far higher consumption of natural gas to fill the gaps in their intermittency, again amplifying the far greater risks of global warming. (And, as +Rod Adams recently notes, overly conservative emergency evacuation protocols can in fact increase latent cancers in the event of a nuclear emergency - namely by contributing to increased traffic congestion, preventing the needed triage to evacuate those facing the greatest exposure).

Francl concludes with an astute observation of a common goal, which should not itself be to dictate choices concerning how risks of various alternatives (both in medicine and energy) are weighed, but to ensure that those risks are discussed and decided based upon sound information about those risks, rather than falling prey to cultural biases. Chemistry, like energy, is an indispensable component of the modern world, and both face the same communication challenge of fostering a science-based public discussion based on a rational evaluation of comparative risks and benefits. This in turn means understanding how cultural biases are formed - and ultimately developing science communication strategies to break through these biases. (In this regard, I once again point to folks like +Dan Kahan of the Yale Cultural Cognition project, who is doing the yeoman's work with this topic as well as David Ropeik, who writes about risk perception issues extensively in an approachable fashion.)

I will say as a postscript that I think all too often that there is a particular intellectual laziness which resists these kinds of strategies - which (at least in the case of nuclear energy) solely blames public (mis-)perception of risks on petroleum-fueled conspiracies. Aside from being devoid of evidence whenever challenged, such excuses (and they are excuses) unproductively halt any discussion of what to do about the issue (and further, fail to recognize the deeper cognitive science behind how risk perceptions are formed. For example, cultural polarization occurs even for novel technologies like nanotechnology after exposure to limited information about the technology.)

Obviously, there exists no doubt that there's money to be made preying on fear (both in the realm of alternative "energy" and "medicine"), but the fact is that these is more than sufficient evidence that how risk perceptions are formed has far more to do with our inherent values and cultural affiliations than the stock price of Exxon-Mobil. Thus, for these kinds of science-informed discussions to occur, it also requires nuclear professionals to stop hiding behind convenient, ephemeral excuses of conspiracies and actually begin understanding the science of how risks are perceived (and likewise, the science of risk communication).