Monday, August 20, 2012

Cultural signaling and energy

An image that struck me recently and has stayed with me since was a license plate. Specifically, a jet-black Kentucky license plate, emblazoned "Friends of Coal."

KY friends of coal license plate
The first thing that ran through my mind was, "Who in their right mind proudly trumpets supporting that?" It struck me as about the same contrarian attitude as waving around a Confederate flag (or its more common contemporary, sporting a Confederate flag bumper sticker; which again, some people actually do that). These are things that, to an uninitiated Midwestern exile like myself, should seem embarrassing to display, to say the least.

Yet, oddly enough, much like the confederate flag paraphernalia one encounters with depressing frequency south of the Mason-Dixon line, Kentucky's "Friends of Coal" license plate is the state's most popular custom license plate design - more popular than veteran's plates and those supporting the University of Kentucky. As it turns out, several other states in the area have their own variations, including Virginia and West Virginia.

Obviously, coal is a major economic player in Appalachia, so strong support is to be expected. But the image in my mind started making me think about a broader issue in energy politics, and perhaps why it seems why so often it seems like there are two sides talking past one another (where, incidentally, nuclear tends to be neglected in the crossfire). Specifically, a part of me wonders if what one sees in trends of public support for various energy sources has to do with the economic phenomenon of "signaling" behavior.

I've of course speculated about how cultural perceptions might play a role in public opinion over energy sources numerous times before, but what struck me here was whether support for energy sources - and specifically, some of the most stark divides that manifest - are perhaps deeper expressions of the cultural and aspirational values of the proponents, trumping factors including economics and environmental considerations (as well as basic issues of numeracy).

To back up a bit - in economics parlance, "signaling" is usually used as a way which people convey information which can't always be directly inferred or observed. Signaling can exist both in the banal, uncontroversial sense - wearing a suit and tie signals conformity, particular conformity to societal expectations of professional behavior - to somewhat more contested areas (such as whether higher education acts as a signal to employers as to characteristics including intelligence, diligence, or again, conformity).

Thus, my hypothesis - I am left to wonder if strong, highly polarized opinions on energy sources - particularly on divides such as coal (and to a lesser degree, natural gas) as well as wind and solar don't perhaps serve as signaling "stand-ins" for statements of individual values and cultural affinity.

In particular, the coal industry has capitalized on this in a particularly effective way, with their "America's power" re-branding, and in particular attempting to link coal exclusively to the idea of low-cost, reliable energy generation (again, despite the fact that the levelized costs of nuclear, with its capital costs folded in, are not wildly out of line with coal, particularly if carbon capture and sequestration is a mandated component.) Coal is, in effect, a signal of working-class values, and in particular an expression of solidarity with the working-class communities typically associated with coal-mining.

In a less regionally confined sense, one has to wonder whether some of the pushback from the right over President Obama's "War on Fossil Fuels" also has more to do with outward expressions of cultural affiliation than it does practical concerns over energy. (Nevermind that favoring one fossil source over another hardly consistutes a "war" on fossil fuels). Consider if you will how often right-wing pundits complain about how curtailing fossil fuel use for electricity would spike energy prices - again, as if nuclear energy weren't supplying a fifth of our electricity at the lowest marginal cost of baseload production next to hydro.

I can't help but feel like the effect is intentional - although perhaps not for the reasons folks like Rod Adams might assert (i.e., no, this is not a fossil-fueled conspiracy). Instead, look to the numbers - while support for nuclear energy is strong among self-identified Republicans, it trails far behind support for exploration of new fossil sources. Ultimately, one has to wonder if such public rending of garments pertains more to a cultural push-back response - rallying around fossil sources because of perceptions of the other - and less about actual, considered evaluation of economic and environmental trade-offs of different energy sources.

Contrast this with renewables - support for renewables is much like recycling - a token expression of environmental concern which can be done for minimal required effort. It is, in essence, expressing support for the environment without actually requiring any kind of substantial commitment from the individual. Considerations such as reliability of supply, economics, or even sheer scale are immaterial - support for renewables is, in essence, "green cred." Among the more radicalized, the inherent limitations of renewables are even considered a feature, not a bug - the limited capacity and availability of renewables are an exhortation to consume less, and ultimately to de-industrialize. In either case, support for renewables is less about the practical reality of the enormous challenge in powering an industrial society at the whims of nature and more about the value expression (or, as it were, aspiration) that it entails.

This process playing out prominently on the campaign trail right now. In Iowa, President Obama blasted Mitt Romney for his support of allowing a wind power production tax credit to expire. Meanwhile, Mitt Romney and his supporters have been slugging back, contending that Obama has been waging a "war on coal." (Note as well the targeted blue-collar audience.)

One can easily see where this one is going. Orphaned from any such discussions is nuclear; something at least now (mercifully) given tepid support by both sides, if only because excluding nuclear from energy discussions on the grounds of both environmental and economics grounds is inherently a politically self-marginalizing position, even if it doesn't seem to command strong feelings among most.

So what does support for nuclear energy signal, if you will (and likewise, its opposition)? I would hypothesize that the dividing line for nuclear turns on issues of technological optimism and energy abundance. A common thread I have observed among many nuclear professionals and advocates is a belief that the technology can consistently be made cheaper, more abundant, and ever safer. In particular among these people - myself included - is a belief in the imperative of energy abundance (this in fact was part of the reason I became a nuclear engineer). By contrast, nuclear opponents are frequently (although not always) in the opposite role - sometimes technological pessimists and with a shocking frequency advocates of energy austerity - believing that the answer always is to consume less (despite the unmistakable positive correlations between prosperity and energy consumption, namely due to what energy enables us to do in modern society).

I remark that nuclear opponents are not always technological pessimists, namely because one occasionally encounters the odd nuclear opponent with delusional beliefs about the capability of renewables - although almost universally they fall back to the position of energy austerity when the limitations of renewable sources are brought up.

What do you think? Is energy advocacy a marker for more deeply-held cultural values? And if so, what does a strong preference for nuclear indicate?

Aside: On a personal note, I hope to be back to more regular blogging soon; this month I started out as a new faculty in the Nuclear Engineering department at the University of Tennessee, and suffice to say, the life of a new faculty can at times be... overwhelming.

Tuesday, June 26, 2012

Deconstructing anti-nuclear economic myths - a response to Veronique de Rugy

Let me start things off with a disclaimer - I am not an economist. I don't even pretend to be an economist; I'm a nuclear engineer by training (I hold Ph.D. in Nuclear Engineering). That notwithstanding, economics (and specifically, the economics of energy) are a side interest of mine. So it was with mixed interest and trepidation when I read a recent piece by libertarian economist Veronique de Rugy from the upcoming July issue of Reason, entitled "No to Nukes."

Plausibly, de Rugy's animating complaint (given Reason's market-oriented focus) is in the subsidies for new nuclear (specifically, when I followed up with de Rugy on Twitter, she pointed out the issue of loan guarantees, although nowhere does this specifically appear in her piece). The piece itself is nothing new, however - the bulk of it is in fact a retread of a suspiciously-timed nuclear hit piece which appeared literally two weeks after the Fukushima disaster. (One gets the distinct impression that, despite her protestations to the contrary, de Rugy is more than happy to dance on what she perceives to be nuclear's grave, particularly given her timing and choice of targets.) In reality, the piece seems to follow on to a frustrating trend of pro-fossil contrarianism as of late, particularly in libertarian circles (contrarian in the sense of singling out the most economical, carbon-free competitor to fossil fuels for special scorn on economic grounds); although perhaps this contrarian turn owes to the fact that conservative heavyweight think tank Heritage has cornered the market in advocating nuclear energy as a free-market energy source. (Who said hipsterism is limited to fashion and terrible beer?)

de Rugy's piece begins with an overly long introduction detailing to the reader why nuclear power was destined to fail to live up to its promises, including citing public opinion which she describes as having " remained steadfast against the technology ever since [Three Mile Island]" (although someone may want to refer de Rugy to the latest polling data on the subject), along with other issues, such as "[d]isputes over waste disposal [which] have never been resolved" (once again however, these are political rather than technical matters).

Finally we get to the meat of the matter - it would appear that a restart of the nuclear industry is, "[...]not just bad politics. It’s awful economics." Well.


To this end, de Rugy characterizes the recent decision by the NRC to grant Southern Nuclear company a license to build two new AP1000 units at the Vogtle site - the first new units in 30 years, as "[...]an act of desperation by a president who has realized he is running out of other options." Fortunately, contrary to the opinions of a economists with a particular axe to grind, the decision to award Southern Company is not in fact in the hands of the president, nor are operating licenses granted upon individual opinions about economic viability of the project - they are voted on by the commissioners of the NRC on the basis of safety alone. This fundamental misunderstanding of the process is pervasive throughout the rest of the piece.


Levelized cost of electricityMuch of the piece is particularly scarce on actual sources and utterly devoid of hyperlinks (however, given the fact that the piece is a re-tread of her prior post-Fukushima piece, most of her sources appear to be taken from there). de Rugy cites a 2009 MIT study by Ernest J. Moniz and Mujid S. Kazim as evidence of nuclear's uncompetitive costs; one assumes she is referring to MIT's "Future of Nuclear Power" project which includes cost projects of nuclear compared to other conventional fossil sources under a variety of circumstances. In the 2009 update, it reports the following cost comparison: assuming current cost of capital, coal clocks in at 8.4 ¢/kWh, natural gas at 6.5 ¢/kWh, and nuclear at 8.4 $/kWh. The authors specifically note however that this includes a current "risk premium" to capital costs for nuclear - recalculating capital costs at comparative market rates (absent the "risk premium"), they come up with a number far closer to gas and coal: 6.6 ¢/kWh. Even assuming the risk premium stays, with a carbon capture and storage the cost for coal and gas quickly reaches near-parity with nuclear once more. Such an analysis is also borne out in applying levelized cost of electricity estimates to EIA data, resulting in similar conclusions.

Taking up the example of the French (with their nuclear-heavy energy portfolio), de Rugy asserts that because of the France's (state-subsidized) industry, French consumers pay more for electricity. Specifically, she writes:
But producing nuclear energy in France is not magically cheaper than elsewhere. French citizens are forced to pay inflated costs to support grand government schemes, such as the decision made 30 years ago to go nuclear at any cost after the first oil shock in 1974. 
EU electricity prices
Really? Going to the data, the opposite is in fact true: France has one of the lowest retail electricity prices (the 7th lowest in the E.U.); compare this to Germany, which has recently phased out nuclear entirely, which pays the second-highest rate. (Again, these are not hard things to find, but something de Rugy asserts with no evidence and in clear contradiction of the data.) She might try to argue that consumers pay indirectly, but nowhere has evidence been presented to support this, nor is it supported by retail electricity price data.

de Rugy's main thrust here of course is that capital costs for nuclear in the U.S. are little different than those than in nuclear-friendly France, relying on the analysis of the Vermont Law School's Mark Cooper, an individual who isn't exactly private about his own agenda when it comes to nuclear. (Hint: he's not a fan.) Again, one gets the impression the data is being cherry-picked to fit the desired conclusion. de Rugy makes an incomplete comparison here, citing the high "overnight cost" estimates for nuclear capital costs compared to coal and natural gas, while neglecting to inform her readers that this alone is a highly misleading comparison. (To see how this process is properly unpacked, even with natural gas still coming out favorably compared to nuclear, I invite you to see how Dr. James Conca unfolds the data).

To wit: "overnight" cost is a rough estimate of total capital cost (i.e., total money which must be invested to build the plant), assuming the plant "overnight" - i.e., without the borrowing costs (in other words, interest on loans which continues to pile up while plants are being built and not generating revenue), something which particularly dominates nuclear costs. However, a more accurate comparison is the levelized cost of electricity  (LCOE)- something which calculates both the capital cost and operations & maintenance costs (which include fuel - a cost which dominates natural gas economics). The LCOE calculates the "break-even" cost of electricity from a plant given the projected costs over the plant's lifetime, with a reasonable discount rate (for example, the expected return of ~3% on treasury bonds) over the life of the facility. Given that the expected lifetimes of different facilities can vary widely by type (i.e., the current fleet of nuclear plants will almost all be relicensed to operate for a total of 60 years, with some potentially operating up to 80 with facility improvements and upgrades), this makes for a more useful comparison of the actual cost of electricity. Once again, something absent from de Rugy's analysis.

Indeed, taking this out to the logical extension - if nuclear plants were wholly unprofitable to build and operate, why in the world then would operators of the existing fleet of 104 reactors not simply turn each one off tomorrow, much less put a dime into maintenance outages which run up into the millions of dollars? The answer of course is because this is not true; nuclear plants are indeed expensive to build (due to capital costs, including the borrowing costs associated with construction times), but the marginal cost of power from a nuclear unit is tiny - namely because most of the cost is in the cost of capital itself. Nuclear in this sense represents the opposite economics of natural gas, which has a low front-end cost but whose costs are generally dominated by fuel price. (Thus, the levelized cost - something de Rugy does not look at - is extremely dependent upon assumptions of future fuel prices - hence why nuclear is often seen as a hedge against future fossil fuel price increases.)

However, de Rugy comes back with the follow-up that such estimates of nuclear cost come "after taking into account a baked-in taxpayer subsidy that artificially lowers nuclear plants’ operating costs." Looking at the broader picture of historical energy subsidies however, this point doesn't seem to carry the impact de Rugy seems to think it does - from the period of 1950-2010, nuclear has been the recipient of about 9% of total federal energy subsidies, compared to a shocking 44% for oil. (For those following at home, the rest include: Natural gas - 14%, Coal - 12%, Hydro - 11%, Renewables - 9%, Geothermal - 1%). Most of nuclear's subsidy has, contra de Rugy, not been focused on the regulatory side (although the study does point to an approximate regulatory subsidy of $16 billion over the total time period) but R&D, which should surprise few who are conversant with the history of nuclear. (Oil, by contrast, receives the whopping share of its calculated subsidies from tax policy and regulation, while natural gas has almost exclusively benefited from tax policy).


Claymore mine
Image: Wikipedia
Notably absent from de Rugy's analysis is how the most important subsidy fossil fuels (especially coal) have come to rely upon, which is treating the atmosphere like an open cesspool. Indeed, looking to the above costs from the MIT study, were we truly dealing with a "level playing field" in the sense that carbon-intensive industries were required to give their waste products the same degree of scrutiny that nuclear already does, the much-ballyhooed "cost difference" largely vanishes. (Again however, discussions of energy subsidies invariably seem to only go one way: like a claymore.)


No doubt though de Rugy is invoking the issue of nuclear liability insurance of course (known under the moniker of the "Price-Anderson Act", passed in 1957). What is not noted is the exact taxpayer liability to date under Price-Anderson - which is exactly $0. Again, contrary to the claims of nuclear opponents like de Rugy who dress up their objections in economist's language, nuclear is not "uninsurable" on the private market - in fact, each nuclear unit is required to carry an individual liability of $375 million; following the exhaustion of the individual commercial policy, each operator-licensee is required to kick in up to another $111.9 million (pro-rated), producing what amounts to a collective cross-insurance arrangement of $11.975 billion. One can dispute whether such a sum is "sufficient," but the idea that the industry is utterly absolved of tort liability is clearly at odds with the the current reality.

When I pressed de Rugy over what particular subsidies she was complaining about and why her complaint so specifically singled out nuclear (looking at her publication history, there is nary an article devoted to the issue of energy subsidies for other sectors), she responded by pointing me to an analysis she did on the market-distorting effects of loan guarantees. (This after I pointed out that I was in favor of removing all subsidies - but it would seem, like many in the punditry business, the conclusion comes first).

Frankly, I won't get into all of the analysis - because once again, I am not out to defend loan guarantees or any other form of energy subsidy. However, one thing that did jump out at me once more was the use of extremely cherry-picked data in her report - the few items that do mention nuclear (most of the piece pertained to loan guarantees for solar - which incidentally, was not required to pay the credit subsidy fee which nuclear was) are, shall we say, "factually challenged." de Rugy rolls out the several-times-over debunked trope of the 50 percent default rate with nuclear loan guarantees - based on poorly-documented projections over a program which was never passed. While de Rugy immediately pointing out that the CBO revised this number (without specifying how much), the supporting evidence she gives to this revision doesn't even pertain to civilian nuclear power - rather, the study she points to is a comparative economic analysis of nuclear power for naval propulsion.

The only other nuclear-specific studies de Rugy cites in this study come from Peter Bradford - a well-known anti-nuclear activist with the Nonproliferation Policy Education Center (simply google "Bradford" and "nuclear" if you don't believe me) - along with Henry Sokolski (also affiliated with the same). The extremely selective use of sources known to have a hostile agenda to nuclear (that is, when the sources even accurately refer to de Rugy's claims) again strongly implies a rushed, cherry-picking approach that implies a "conclusion-first, evidence later" approach that is all too familiar with established punditry. Indeed, it might make for impressive-looking studies (and good sound bites), but it hardly suffices for serious scholarly work. Indeed, if the evidence is as strong as she claims it to be, it would behoove her case greatly to find such evidence from more objective and less clearly agenda-driven sources.

Of course, all of this is the problem: even rather sloppy studies like this, particularly when attached to someone with a Ph.D. in economics, sound plausible and require the time and energy to deconstructing their myriad of errors and misplaced assumptions - something which amounts to a non-trivial task for one when most of their day is typically occupied by honest employment, alas.

Tuesday, June 12, 2012

Questions for MacFarlane

Allison MacFarlane
Dr. MacFarlane (Image: George Mason University)
The nomination of Allison MacFarlane has drawn a considerably mixed reaction among the nuclear community, ranging from NEI's rather speedy endorsement and Rod Adams' similarly rapid denouncement. Others (including myself) have chosen to withhold judgment for the time being, although I do recomend Margaret Harding's list of desirable qualities in a potential NRC chair.

Given that MacFarlane's hearing before the Senate Environment and Public Works committee is scheduled for tomorrow, here are some questions which I believe would better inform the discussion both of whether MacFarlane is a good candidate to lead the NRC and what her leadership might entail.

NRC & Leadership

  1. Given the size and relative impact of the NRC, it is not an agency known for its amenability to on-the-job leadership training. A particular concern is in your lack of organizational leadership experience on your resume. Why do you believe you are qualified to lead the NRC, and what leadership qualities do you believe you bring to the table?
  2. Describe what you feel are the key challenges currently facing the NRC. What areas would you focus on as chair, and how would you work to overcome them?
  3. Your attitudes appear to have evolved from being a self-described "nuclear agnostic" to indicating that "we absolutely need" nuclear energy with respect to climate change. What provoked this evolution?
  4. A prominent concern regarding your appointment to the chairmanship of the NRC is that your background has generally not focused on nuclear fuel cycle technology per se. How do you believe you can overcome this experience gap?
  5. Much of the NRC's policy comes down to producing an appropriate balance of safety with economic considerations in regulation. Please describe your thinking on what constitutes socially acceptable risks. Should the safety threshold for nuclear energy systems be higher than other commonly accepted risks, such as air travel? What about in comparison to other energy sources?
  6. A decision which has been roundly criticized by many nuclear experts was outgoing Chairman Jazcko's unilateral decision to establish a 50-mile evacuation zone for U.S. residents in Japan, contrary to both existing U.S. evacuation guidelines and the Japanese evacuation guidelines. Do you agree with this decision? If so, upon what basis? If not, where did the Chairman err and how would you handle the situation differently?

Nuclear Waste Management

  1. As an outspoken critic of Yucca Mountain, both on technical and procedural grounds, how do you view the decision by your predecessor Gregory Jazcko, along with President Obama and Secretary Chu to terminate the licensing review process in light of amendments to the 1982 Nuclear Waste Policy Act which legally mandate Yucca Mountain as the nation's sole geologic repository? Would you allow the licensing process to move forward? If not, how then do you square this under existing federal law?
  2. One of your significant contributions to the Blue Ribbon Commission was a strong focus upon a more consent-based process of involving communities in the repository licesing process. What do you view as the NRC's role the siting process for a potential repository (if any)?
  3. What immediate actions (if any) do you believe the federal government should take with respect to spent fuel management?

Nonproliferation

  1. Your academic background includes several publications on the topic of nuclear nonproliferation policy. In particular, you have publicly stated your opposition to spent fuel reprocessing on nonproliferation grounds. Do you believe President Carter's decision to suspend civil reprocessing in the United States was ultimately effective in achieving its stated nonproliferation goals?
  2. How do these nonproliferation concerns relate to the NRC's recent license to GE to construct a laser enrichment test facility, given similar nonproliferation concerns?
  3. Please describe why you believe reprocessing of reactor-grade plutonium to be a viable proliferation concern, particularly in nuclear weapons states.
  4. What role (if any) do you see for the NRC in establishing U.S. nonproliferation policy?

Licensing and new construction

  1. A particular challenge to the development of novel reactor concepts such as small modular reactors as well as entirely new reactor concepts such as TerraPower's traveling wave reactor has been the difficulty in getting such designs through the NRC licesning process. In particular, this has been described as a "chicken-and-egg" problem, with the NRC refusing to prioritize designs with no present commercial interest, while utilities are generally only interested in designs that are expected to receive NRC review. As a result, some designers - such as TerraPower - plan on circumventing the U.S. market entirely. What do you believe the NRC should do to address this issue?
  2. Nuclear experts such as Rod Adams have pointed out that the existing COL process relies on the assumption that no amendments to the design will need to be made after construction begins. Does this process need to be improved? If so, how would you propose improving it?
  3. Departing chairman Jazcko was frequently the lone dissenter on several recent votes for involving reactor licensing and construction, including the construction licenses for Vogtle and VC Sumner reactors as well as the recent 20-year license extension for the Pilgrim nuclear facility. Do you believe Jazcko's dissenting votes were justified? If so, on what grounds? If not, how would you approach the situation differently?

What questions would you ask MacFarlane, given the chance?

Update: Margaret Harding presents her own list of questions, and Rod Adams posts a transcript of his 2007 interview with Dr. MacFarlane in which she declares herself as an "atomic agnostic."

Update II: Jack Spencer at Heritage's blog similarly poses his questions. Some substantial overlap in themes arises - particularly over issues such as Yucca Mountain and new reactor licensing.

Monday, May 28, 2012

Checking out the competition

In a bit of a change of pace from the normal fare, I thought I'd post some pictures from a visit today to TVA's Norris Dam. At 130 MW peak generating capacity, it is perhaps the one source out there that can truly compete with nuclear in terms of marginal unit cost as well as dispatchability: hydro.

Norris Dam panorama

Norris reservoir
Norris Dam from the western overlook
Norris Dam serves a dual purpose, being designed both to provide large amounts of reliable electricity as well as providing flood control along the Clinch River (which winds through east Tennessee, eventually joining with the Tennessee river).

Norris Dam western overlook
Norris Dam and power station
Hydro represents one of the most interesting sources of electric power, in terms of its flexibility - its economics are similar to nuclear in certain respects (in that it is capital-intensive yet very low marginal unit cost, meaning it is the first energy source to be dispatched for demand), yet by its nature it is easily suited to baseload generation (low marginal cost), as well as load following and peak generation (i.e., given the ease at which floodgates can be opened or closed). Nuclear is also capable of load-following, which is commonly done in France, although much less so in the United States (due to economics) save for where nuclear exists is high concentrations; typically load-following is accomplished through fast-response natural gas turbines.

In other respects, hydro shares some similarities with other renewables - the energy output of a hydroelectric plant is fundamentally tied to nature - namely by the reservoir level (which in turn is influenced by rainfall levels). Unlike wind and solar however, hydro represents relatively "smooth" and predictable power output - while meteorology is far from a perfect science, rainfall patterns are generally quite predictable, meaning output levels from hydroelectric dams can also be readily planned for in advance.

Looking down from Norris Dam
The view from the top of Norris Dam

Clinch river valley
Clinch River valley, past the impoundment
More photos here.

Unfortunately, at least as far as the U.S. goes, most of the "prime" hydroelectric capacity has already been tapped - meaning we've got about as much as we're going to get from this source.

Happy Memorial Day to our U.S. readers - we'll be back to our regular scheduled programming later this week.

Thursday, May 24, 2012

A closer look at Jazcko's replacement

Dr. MacFarlane
Earlier this week, embattled NRC Chairman Gregory Jaczko announced he would be stepping down from his position contingent upon the confirmation of his replacement. Wasting no time, the Obama administration announced their nominee today, a mere three days after Jaczko's announcement. Their candidate? Dr. Allison MacFarlane, an associate professor of Environmental Science and Policy at George Mason University.

MacFarlane is not without technical credentials - she holds a Ph.D. in geology from MIT and has written extensively on nuclear waste management issues - in particular, serving on the recent Blue Ribbon Commission. And, unlike the departing Chairman, MacFarlane at least has an academic career to point to, rather than solely being employed as a political aide for entire career. Ideologically however, she is relatively aligned with the departing Chariman however - thus, while not quite Gregory Jaczko II: Electric Boogaloo, she is likely close enough for government work.

A mixed bag

Suffice it to say, MacFarlane's ideological interests represent a mixed bag, to say the least. In many of her writings concerning the siting process for a nuclear waste repository, MacFarlane has repeatedly pointed to the need for a consent-based process (like that used for the Waste Isolation Pilot Plant [WIPP] in New Mexico) for locating a disposal facility, something which has been repeatedly stressed by other nuclear professionals (including myself). Thus, her influence over the Blue Ribbon Commission's final report is quite obvious.

On the other hand, MacFarlane has been extremely critical of spent fuel reprocessing along with being a tenacious opponent of Yucca Mountain itself; she, along with Frank Von Hippel of Princeton have repeatedly advocated plutonium immobilization of surplus stocks of reactor-grade plutonium from civil reprocessing programs, as well as for weapons-grade plutonium from dismantled nuclear warheads. Needless to say, this is an incredibly wasteful and inefficient waste management solution. (It is thus perhaps unsurprising then, given her influence, that the BRC final report also declined to endorse reprocessing as a policy solution for spent nuclear fuel.)

MacFarlane couches her objections chiefly in terms of nonproliferation concerns (something which I have an academic specialty in); what is not clearly demonstrated in any of her analysis is how reactor-grade plutonium (itself not suitable for direct use in weapons, due to heat-producing impurities such as Pu-240 and Pu-242 which make for sub-optimal weapons materials - more on this in a moment) represents a viable proliferation concern, particularly in nuclear weapons states such as the United Kingdom, France, Russia, and the United States.

The exception here to this trend is of course Japan, which currently reprocesses fuel and ultimately aspires to achieve a fully "closed" fuel cycle for reasons of resource independence. However, even absent a reprocessing program, their world-class leadership in nuclear technology means that they are hardly constrained on a technical basis from developing a weapons program. (Japan is quintessentially a "screwdriver's turn" from nuclear weapons capability.) Yet given their deep cultural aversion to nuclear weapons, Japan is in fact a leading figure in the international nonproliferation community.

All of this said, MacFarlane herself has gone on the record of indicating the she personally does not oppose nuclear energy itself, arguing that in the face of climate change, we "absolutely need nuclear power." Again, very much a mixed bag, so to speak.

The two faces of the nonproliferation community

Much of MacFarlane's background has been associated with what I term the "political" wing of the nonproliferation community - the other being the "technical" side (where my background is from). Her affiliations include the Belfer Center for Science and International Affairs at Harvard (not exactly a hotbed of pro-nuclear activity or solid technical analysis at that), home of well-known academic nuclear critic Matthew Bunn, as well as being a regular co-author with Frank Von Hippel (someone also not known for his warm feelings for nuclear energy - although a perfectly pleasant person in real life.)

Nonproliferation tends to get a poor reputation among nuclear professionals and advocates, precisely due to the "political" wing, who tend to focus on opposing any nuclear technology seen as "proliferant," which in turn lends itself to the anti-nuclear strategy of "bottle-necking" - in other words, "constipate" the nuclear fuel cycle and then complain loudly of the "lack of solutions" for nuclear waste (despite the plethora of available technical options).

Conversely, the "technical" nonproliferation community tends to focus on aspects such as how to improve aspects of verification and measurement within fuel cycle facilities - in other words, ensuring that declarations of sensitive facilities are complete and accurate and that material is fully accounted for. An example of this includes projects like those I am currently working on, which seek to use radiation detectors to better characterize the isotopic contents of spent nuclear fuel in order to provide for a superior accounting of materials such as plutonium. The difference in focus thus could not be more stark - one side complaining of the potential problems and the other seeking solutions to improve facilities such to eliminate said problems.

Ultimately, these kinds of debates come back to the question I frequently ask: "So what's your alternative?" To her credit, MacFarlane at least does offer an alternative solution - one I find to be highly flawed, but it is nonetheless out there. And again, likewise to her credit, MacFarlane does not declare herself to be outright opposed to nuclear energy. Thus, the problem is simply a matter of coming to an agreement on a better solution for nuclear waste management.

A small background on "weapons-usable"

So-called "weapons-grade" plutonium contains more than 90% Pu-239 - the isotope most suitable for weapons use (given its low spontaneous fission rate and low heat generation rate). Even-numbered plutonium isotopes - Pu-238, Pu-240, and Pu-242 - tend to have a high heat generation rate (Pu-238 has such a high heat generation rate from alpha decay that it is frequently used as a power source for space missions such as the Cassini-Hugyens probe which took spectacular images of Saturn and the New Horizons probe currently en route to Pluto). Pu-240 and Pu-242 also have a high level of spontaneous fission, which means in addition to producing large amounts of heat they produce high levels of neutrons - in a weapon, this leads to unpredictable yield, or "fizzle." Thus, generally speaking, "reactor grade" plutonium, while usable in the strictest sense (i.e., one can construct a fission chain reaction using the materials), they are far from optimal for a national weapons effort - any nation with the capability of reprocessing would easily choose a more dedicated route (i.e., with separate plutonium-production reactors to produce high-purity Pu-239 and separate reprocessing facilities) before resorting to diverting civilian stocks.

Political calculations - the "twofer"

So why did Obama tap MacFarlane? Two reasons are likely in play. The first of course is that given her prior criticisms of Yucca Mountain, her nomination has been bolstered by the support of Senate Majority Leader and infamous Yucca Mountain opponent Senator Harry Reid (D-NV). Second, her nomination comes on the heels of President Obama's renomination of current Commissioner Kristine Svinicki. Thus it is likely the Obama Administration is seeking a "twofer," seeking to align the confirmation of Svinicki with that of MacFarlane as a "package deal." Senate Republicans are unlikely to object to Svinicki, who has enjoyed the support of the nuclear community given her extensive expertise in nuclear issues. (And indeed, even NEI has been pushing this strategy of jointly confirming the two nominees.)

The nomination of MacFarlane as chair may also be a concession to Reid and other anti-nuclear Senate Democrats in another sense - Senator Reid has complained (without substantial basis) of Svinicki's record on the NRC - a rather questionable position, given Svinicki has generally voted with her three other commissioners on many important issues (in other words, it would seem that Reid's criticism, and in particular singling out Svinicki, is mostly upon the grounds of several prominent 4-1 votes in which Chairman Jaczko stood alone).

However, his grumbling appears to be muted in a press release similar to that of NEI, stating:
I continue to have grave concerns about Kristine Svinicki’s record on the Commission. But I believe the best interests of the public would be served by moving the nominations of Dr. Macfarlane and Ms. Svinicki together before Ms. Svinicki’s term expires at the end of June, to ensure that we have a fully functioning NRC. Republicans claim to share that goal, and I hope they will work with us to make it a reality.
The smart money will thus likely be on a joint appointment deal hammered out sometime this summer.

And as for Yucca Mountain? I still wouldn't bet on it.

Thursday, May 17, 2012

TECPO's triage at Unit 4

My prior post debunking some of the more outrageous myths circulating the internet as to the state of the Fukushima Daiichi Unit 4 spent fuel pools generated some considerable amount of heat, particularly over at its syndicated location at The Energy Collective. Much of this discussion has focused upon the physical state of the Unit 4 reactor building itself (at the top of which the Unit 4 spent fuel pool resides). Yet contrary to popular belief in particular circles, TEPCO has certainly not left the spent fuel pool at Unit 4 to the vagaries of nature, nor have they failed to produce a credible, long-term plan for stabilizing and containing the remaining spent fuel at the reactor units.

Before getting too far into the topic, it's useful to point to a comprehensive companion piece to the prior discussion by Will Davis (of Atomic Power Review) over at the ANS Nuclear Cafe, entitled "Spent Fuel at Fukushima Daiichi Safer than Asserted." (Along with several other nuclear bloggers, I offered a moderate amount of technical consultation for this topic.)

TEPCO's remediation strategy for the Fukushima Daiichi site (original)
Given the concern over the structural state of the reactor building, it is thus useful to look at what TEPCO is actually doing to address the issue. Much of TEPCO's strategy is oriented around immediately stabilizing the site with a focus upon long-term remediation; in a word, triage.

In order to stabilize the earthquake-damaged reactor building, TEPCO has already conducted an evaluation of the structural integrity of the Unit 4 reactor building, deciding to reinforce the foundation of the building with a steel-beamed outer support structure, work which was completed last summer. In this sense then, the immediate concern over the stability of the reactor building (and spent fuel pool) has already been addressed.

However, there remains the issue of the fuel itself in the Unit 4 spent fuel pool. TEPCO has already put measures into place to ensure adequate cooling in the event of a sudden loss of water (i.e., from another large earthquake), including the deployment of concrete pumper trucks (referred to as "giraffes," which were used to originally restore the water levels at the Unit 4 pools). To emphasize - the concern here is not from a loss of water due to evaporation (again, spent fuel pools are kept at atmospheric temperature and pressure under normal conditions; meanwhile, the youngest fuel within the pool is now well over a year old, meaning it is cool enough where sudden evaporation is not a concern). Rather, the planning is again one of being able to respond to issues such as future earthquakes.

Despite the fact that the situation is as stable as can be expected presently at Unit 4, there is a legitimate concern about the impact of future earthquakes. Again, to emphasize - the chief concern over a (rather unlikely) collapse of the spent fuel pool is not the global catastrophe flogged by certain activists lacking in technical credentials (both my prior post and Will Davis' post adequately address why this is so), but rather a mechanical failure of the fuel (which would release local contamination - in particular, radioactive cesium and strontium) and force a local evacuation from the site, thus greatly complicating the cleanup response. (Thus, while far from catastrophic, such a collapse would greatly hinder the ability of TEPCO to clean up the site and add considerable expense to an already vastly expensive project.)

Thus, the medium-term strategy is to relocate the fuel out of the Unit 4 spent fuel pool into the common pool, thus obviating the risk from further damage to the Unit 4 reactor building; current plans call for the fuel from Unit 4 to be fully removed by mid-2013 (and from Unit 3 by the end of 2014). Again, in contrast to the opinions of certain press-seeking political office-holders and activists, this is not a process accomplished with the wave of a wand.

According to TEPCO's mid-to-long term roadmap, this will roughly consist of the following:

  • Clear debris from the spent fuel pool which was dropped into the pool due to the hydrogen explosion
  • Install a cover over the damaged building to shield heavy equipment from the environment (e.g., wind and rain). Following this, heavy fuel handling equipment (e.g., heavy cranes) will be installed in the reactor buildings in order to begin the process of moving undamaged fuel rods.
  • Relocate undamaged, older fuel from the common fuel pool into dry cask storage to make room for newer, hotter fuel from the spent fuel pools at each reactor building. 
  • Begin removing spent fuel from the reactor buildings; this will involve placing the fuel from the reactor buildings in temporary transportation canisters and lowering the canisters to ground level, where they can then be relocated to the common fuel pool.
Ultimately, this is not a quick process; nor is it clear how, despite the best intentions of "concerned outsiders" how this could reasonably be expedited beyond the current schedule, as several tasks are contingent upon one another. (i.e., spent fuel pools must be cleared of debris and a temporary cover must be installed before heavy equipment can be installed, and subsequently fuel can be relocated). Yet it is also clear from both current triage efforts as well as long-term recovery plans that the situation is far the looming disaster it is being sold as.

Update: Via TEPCO's English-language Twitter feed comes this presentation specifically addressing their analysis of the structural soundness of the Unit 4 reactor building.

Sunday, May 6, 2012

Overheated rods & rhetoric

A little knowledge is sometimes a dangerous thing - particularly when fundamentally incomplete technical knowledge is used to make sweeping engineering recommendations. The latest example of this is the concern over the spent fuel storage pools at Fukushima Daiichi Unit 4, which has been getting attention from several corners. First, there was U.S. Senator Ron Wyden (D-OR), a ranking member of the Senate Energy and Natural Resources committee, who recently toured the stricken Fukushima site and released a very widely reported statement that, "things were worse than reported." In particular, Wyden has singled out the spent fuel pools at Unit 4 for unique concern, calling on both the Japanese and U.S. governments to see to it that the rods are safely relocated elsewhere, citing their storage in unsound structures close to the ocean. Wyden has pushed the NRC and others to relocate these spent fuel rods to dry cask storage elsewhere.

As for Wyden's technical credentials for making this assessment? A J.D. in law and his self-assurance in a Senator's unerring technical omniscience.

I suppose it probably doesn't occur to the Senator that relocating spent fuel rods out of the damaged building is no mean feat, given that the rods which will be relocated need to maintained underwater while they are transferred into concrete casks (in this case, mostly for radiation shielding purposes) using heavy cranes. Meanwhile, TEPCO has already reinforced the damaged building, addressing the concern he has over future tsunamis further damaging the weakened building and leading to a release into the environment. Its current plans call to begin removing spent fuel for relocation within the next two years. To emphasize - this is not a problem that relevant technical experts were ignorant of until one brave Senator stepped in and decided to lead.

Of course, to be fair to Wyden, as Dan Yurman points out Wyden is clearly not the only politician suffering from an acute hubris on technical matters.

Overheated rods & rhetoric


spent fuel pool
A spent fuel pool (Image: IEEE spectrum)
At least the good Senator can be forgiven for his enthusiasm however, as it's not nearly as obnoxiously hyperbolic as certain other accounts going around the internet. Anti-nuclear activist and self-described nuclear "expert" (to use the term rather loosely) Robert Alvarez has been shopping around the dangers of spent fuel pools for some time, specifically focusing his ire upon the rods contained in the spent fuel pool at Unit 4. This of course is not a new topic for Alvarez, who has gone so far as to argue that such pools are "a ticking time bomb" and that the U.S. needs to move toward dry cask storage of all spent fuel as soon as possible. (More on why this is silly at best and potentially a dangerous misplacement of priorities in a moment.)

unit 4 spent fuel pool
Spent fuel rods at Unit 4 (Image: IAEA)
Alvarez's latest work, "Why Fukushima Is a Greater Disaster than Chernobyl and a Warning Sign for the U.S.", hits a new low in terms of outrageous hyperbole. Let's start with the headline premise - Alvarez asserts that the potential danger - a release of radioactivity from the spent fuel rods at Unit 4 - is already worse than something which actually happened - i.e., the Chernobyl disaster. (Perhaps aware of this seeming logical contradiction, Alvarez walks this back to "may be worse" in the first sentence.)

The basis of his reasoning? 1) Spent fuel contains very large amounts of radioactivity, 2) The spent fuel pools have been exposed to air (due to the hydrogen explosion at Unit 4), 3) A collapse of building containing the spent fuel pool would lead to an overheating of the rods contained at Unit 4, 4) Somehow, this would lead to a zirconium fire and release all of the radioactivity present in the rods.

Alvarez' blog post is a perfect example of the trouble one can get into when one extrapolates from a small bit of knowledge to a larger technical issue.

Taking it point-by-point - first we have this:
Several pools are now completely open to the atmosphere because the reactor buildings were demolished by explosions;
First of all, it should be noted that spent fuel pools are generally kept at room temperature and atmospheric pressure to begin with. A spent fuel pool, at its core, is essentially a very deep, very large swimming pool (which is also very radioactive as you reach the bottom). At the top, radiation levels are low enough to safely work without problems - you can even look down inside and see the eerily beautiful blue Cerenkov glow if the lights are dark enough. As for containment? The explosion at Unit 4 was in the secondary containment, which is essentially a thin* metal reinforced concrete shell - again, namely because spent fuel rods are un-pressurized and not at the kinds of temperatures found in the reactor. (In other words, the same kinds of phenomena involved in a core melt aren't relevant here.) The primary containment in any spent fuel pool is the water itself, which isn't hot enough to be going anywhere.

*(Edit: "Thin" being relative to the primary containment, which is 4-8 feet thick; most of my understanding of the secondary containment comes from diagrams such as this one, or this one via TheEngineer which bears much greater detail)

Moving on:
As more information is made available, we now know that the Fukushima Dai-Ichi site is storing 10,833 spent fuel assemblies (SNF) containing roughly 327 million curies of long-lived radioactivity About 132 million curies is cesium-137 or nearly  85 times the amount estimated to have been released at Chernobyl. 
So what does this mean? Without context - absolutely nothing. What Alvarez is trying to imply is that in the circumstance that these materials were released into the environment, the consequences would be far worse than Chernobyl. The problem? Alvarez presents no credible physical mechanism for this to happen.

Then there's this:
Also, it is not safe to keep 1,882 spent fuel assemblies containing ~57 million curies of long-lived radioactivity, including nearly 15 times more cs-137 than released at Chernobyl in the elevated pools at reactors 5, 6, and 7, which did not experience melt-downs and explosions.
Why is it not safe? Well, other than the fact that spent fuel is radioactive, Mr. Alvarez doesn't say. An industrial blast furnace is also not a safe place to be, but that certainly doesn't prevent their use. Instead, we actually take precautions to use them safely - the same way spent fuel pools use deep levels of water to both cool the fuel and shield the high levels of radioactivity.

To wit: certainly no one would want to be next to a spent fuel assembly without the shielding provided by the deep pool of water. (With this shielding, the levels of radiation are low enough where it is quite safe to stand above the pool and look down inside - something I have had the opportunity to do before). But for this radioactivity to be truly disastrous (rather than simply being a dangerous but extremely localized nuisance), something has to cause the radioactive materials in the fuel to change state - i.e., to either melt or be carried away ("lofted") by a fire.

In the beginning of his article, Alvarez eludes to the possibility of a zirconium fire, which he asserts could happen if the rods grew too hot. (Alvarez provides no further explanation or reference to credible technical resources beyond this.) Yet there are several significant problems with this theory. First, this would require the rods growing hot enough to ignite (if this is even possible - zirconium in solid form will not ignite, and its melting point is 1852° C). It second assumes that all of the radioactivity is uniformly lofted into the atmosphere; one of the main reasons for the magnitude of the Chernobyl disaster had to do with the fires in the reactor building which lofted radionuclides high into the atmosphere, where they spread across Europe. (Incidentally, this fire was also not from zirconium - it was a graphite fire from the reactor and control rod design being used.)

(Alvarez also rides his hobby-horse in inveighing against spent fuel reprocessing - a topic beyond the scope of this post but one which we've covered previously.)

A background on spent fuel

Spent fuel heat (click for larger)
Meanwhile, let's back up for a moment such that everyone understands what's going on. As we've covered on this blog before, spent fuel does still produce heat after the fission reaction shuts off. The remaining radioactive materials in the fuel, created both by fission and absorbing neutrons - are decaying. The quickest-decaying materials produce very high levels of radioactivity, and much of this energy is trapped in the fuel itself, heating it. Thus why spent fuel needs to be cooled following the reactor shutdown (which was the resulting source of problems at Units 1, 2, and 3).


Both this radioactivity and decay heat fall off dramatically with time, as the shortest-lived fission products decay away. Within 100 days, the heating rate and the radioactivity in spent fuel have dropped by a factor of 10; within 10 years, this drops to 1/100th of the original values.


Spent fuel radioactivity (click for larger)
Doing my own calculations using ORIGEN-S (a tool for nuclear licensing evaluation which is used to simulate spent fuel inventories), a typical assembly of the type found in the spent fuel pool would produce about 3-4 kW of heat after being stored around 1.5 years (and even less as it grows older) - or about 17-20 watts per pin (which themselves are over a meter long). In other words, while fuel which has just been ejected from a reactor poses a challenge in terms of cooling, it is difficult to conceive of how one gets the type of scenario Mr. Alvarez describes, in which something producing so little heat manages to cause these assemblies to melt or spontaneously catch fire.

A solution in search of a problem

Dry storage casks
Dry storage casks for spent fuel
Getting back to the main thread now - let's assume for a moment that this scenario, one already demonstrated to be of extremely questionable plausibility, is true - i.e., that there remains a real threat spent fuel pools, in which the cooling water is lost and the rods subsequently overheat and either catch fire or otherwise change state. So Alvarez's solution, to prevent these rods from overheating? Put them into thick concrete casks cooled by circulating air. Apparently, the same rods at risk of spontaneous combustion when exposed to air are fine if put into thick concrete casks. The logical inconsistency beggars belief.

Note that I am most explicitly not criticizing dry storage - in fact, dry storage casks have been demonstrated to be an effective, medium-term solution for isolating spent fuel from the environment. But to simultaneously assert a danger of spent fuel rods melting when exposed to air while simultaneously advocating to put them in thick concrete casks exposes a basic failure of physics reasoning, one which both Mr. Alvarez's employer and the ever-reliable science reporting of the Huffington Post are happy to embrace.

Alvarez and his sponsors at the liberal think tank Institute for Policy Studies are of course using this reasoning to go a step further, arguing that all spent fuel pools at U.S. reactors are at risk and thus need to be moved to dry storage. Let's just watch the errors compound...

First, let's go back to the decay heat issue. Generally speaking, spent fuel isn't suitable for moving into dry storage until it has cooled for a few years in a spent fuel pool - a general rule of thumb for dry storage is 5-10 years cooling time, although less is possible. The heat generated by 10-year old spent fuel assemblies are a hundredth of that generated by recently-ejected assemblies - in other words it would take one hundred assemblies stored for ten years to equal the contribution of one "fresh" ejected assembly.

If the reasoning here is to give greater safety margins for spent fuel pools in the event of a loss of cooling, dry storage is an extremely inefficient mechanism for doing so - namely because of the fact that the assemblies which are eligible to be moved into dry storage casks make at best a marginal contribution to the spent fuel pool heating. In other words, a large expense for very marginal gains in safety.

So here's how it breaks down: "newer" spent fuel rods are too hot to go into dry storage casks, and thus must be kept in the spent fuel pool to cool. Therefore, the integrity of the spent fuel pool must be maintained. Yet if the integrity of the spent fuel pool is maintained, there is no real safety reason (at least in terms of heat or radioactivity) to move older rods, which can be moved into dry storage. (Note: there are other reasons one may choose to do so - spent fuel pools are limited in terms of total capacity, based on a number of safety-related factors, including total heat as well as how closely the assemblies can be placed together in order to prevent assemblies from going "critical" and restarting the fission chain reaction. However, these are far less limiting circumstances.)

What we have is thus a classic case of a solution in search of a problem. Alvarez (and others, for that matter) have found a solution they like - dry storage - and have (by process of scientifically incomplete reasoning) connected this with a problem they see - the vulnerability of spent fuel in wet storage pools - and naturally put the two together. Regardless, that is, of whether that square peg will actually fit in said roundish hole - the solution is, apparently, to just keep pounding.

When well-meaning ignorance actually becomes dangerous


This is where I think Alvarez's (possibly well-meaning) concern actually becomes dangerous. Maintaining the integrity of spent fuel pools for "younger" fuel is vitally important - which is why some of the most recent changes recommended by the NRC as well as industry call for improvements such as better monitoring and instrumentation at spent fuel pools, along with other kinds of contingency plans to ensure water can be delivered to the pool in the case of a loss of coolant. Likewise, ensuring the integrity in the design of spent fuel pools indeed should be a priority.

But herein lies the problem with "experts" like Mr. Alvarez, who has no actually technical background to speak of - starting with the faulty premise that "wet storage" (i.e., spent fuel pools) can be eliminated entirely (they can't), we are then assaulted with faulty recommendations to move fuel out of these spent fuel pools at large expense and very marginal contributions to safety. Yet arguably these are resources that could be better spent on improvements to the safety of spent fuel pools - things like better instrumentation to know what is going on in said pools and improved emergency response capabilities (such as designing easier means of supplying auxiliary water to the pools). The focus on dry storage as a safety measure thus makes for a dangerous distraction which commits attention and resources away from more productive ends, thus potentially compromising safety as a whole.

Alvarez isn't the only one guilty of a single-minded focus on dry storage as a "solution" to spent fuel storage pools - all kinds of individuals (such as Senator Wyden above, and even some people I know of in real life who should know better...) have jumped all over this. The problem comes down to a simple failure to think things through - again, if spent fuel is too hot to be exposed to air, it's too hot to go inside a thick (thermally insulating) concrete cask. If it isn't too hot for dry storage (i.e., older fuel), then it isn't what is driving the safety issue at the spent fuel pool. Thus, in either case, it's a solution in search of a problem - given the fact that hotter fuel cannot be removed from the pool itself, it is more useful to focus upon the problem at hand.

The underlying pathology here - in other words, why seemingly simple-sounding solutions like this are so seductive - is because it gives the illusion of "doing something" about the (perceived) problem. In this case, this is done through a somewhat primitive technical analogy - we  have a thick concrete containment for the reactor as a safety mechanism, therefore spent fuel should similarly always be in a thick concrete containment. It simultaneously ignores where the solution is technically inappropriate ("younger," hotter fuel) and how it fails to address the root problem (i.e., keeping the spent fuel both cooled and well-shielded - which is done by ensuring the integrity of the water levels in the spent fuel pool). Fundamentally, it is an example of how not to do engineering - engaging in a top-down method of choosing a solution first and making it work to fit the problem.

Under ordinary circumstances, this leads to bad outcomes - wasted money and sub-optimal solutions (or even solutions that are simply inappropriate). In the worst-case scenario, this kind of thinking actually makes things worse, namely by committing time and resources away from evaluating actual safety improvements - and thus where well-meaning concern of outsiders who are fixed upon a particular solution without understanding the actual problem can actually do more harm than good.