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Optimisation, Detriment and Proportionality – The Need for Checks and Balances. Gregg Butler* º and Grace McGlynn* * Director IDM Ltd † Professor of Science in Sustainable Development, University of Manchester. An admission….
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Gregg Butler*º and Grace McGlynn*
* Director IDM Ltd
† Professor of Science in Sustainable Development, University of Manchester
…..this is not exactly the first time I have presented work by myself, Grace and others in this subject area…..for example ……
Risk, Regulation and Level Playing Fields …….or “Holism Takes a Holiday?” (SRP, Recent legislation: Achievements and future challenges, London, October 2001)
This concluded that very large amounts of money might be being misapplied in guarding against very small risks and detriments from radioactive discharges. Many of those present seemed to agree… at least on the day…….
Sustainable Environmental Regulation (BNES, NEDCON02, Managing Radioactive Discharges to the Environment, Chilton, Oxon, April 02)
Evidence of enormous imputed life valuation for miniscule risks - people agreeing – sometimes ruefully
ALARP and Socio-economic Effects Looking for a Balance?? ……..is anyone committed to getting a balance? Does anyone care?? (SRP ALARP: Principles and Practices, Oxford April 2003)
This concluded that very large amounts of money really werebeing misapplied in guarding against very small risks and detriments from radioactive discharges. Many of those present seemed to agree… at least on the day…
Risk Based Approach to Environmental Decision Making (BNES, NEDCON04, Managing Radioactive Discharges to the Environment, Chilton, Oxon, April 04)
Risk based valuation of detriment - People agreeing – sometimes ruefully – that the results seemed to make sense
Doing the Right Things? Risk and Detriment Valuation and Prioritisation (SRP, Change and Continuity in Radiation Protection, Cardiff, June 2005)
CBA versus new industry structure – will Treasury be impressed by (and fund) disproportionality?? – all the operators agreed mightily – that they wouldn’t!
Optimisation in Cleanup – one or two years on (BNES, NEDCON02, Managing Radioactive Discharges to the Environment, Chilton, Oxon, April 06)
News of NDA Prioritisation work and how it could give a basis for proportionality in the new industry regime…….but it hasn’t shown much sign of doing it to date….
That justifying spend not based on some concept of value for money was going to be difficult
That spending that valued statistical lives at many times the Government policy guidelines was unlikely to impress the Treasury
That the structure set up with the NDA made it very difficult to successfully motivate a concern about spending
‘Commercial mind +/- Strategic mind = ???’
And that money spent disproportionately on discharge reduction was quite likely to be the money that wasn’t spent on reducing hazard potential
The primary safety and environmental concern of nuclear power and the nuclear fuel cycle is that radioactive substances might escape from institutional control, enter the environment, and cause harm to humans and/or biota. There are two main aspects:
In the UK, individual safety is interpreted against the Tolerability of Risk (ToR) framework
Broadly Acceptable: <1 in 1,000,000 per annum risk of fatality (10-6/a)
Tolerable: boundary of tolerability ‘not as widely applicable’ but 1 in 1,000 per annum (10-3/a) just tolerable for workers and 1 in 10,000 per annum (10-4/a) for the public
This is reflected in a Basic Safety Limit of 10-4/a and a Basic Safety Objective of 10-6/a for off-site fatalities
BUT – some discharges are long lived and spread widely, giving rise to very small doses to very large numbers of people over long times. If aggregated, these Collective Doses can predict relatively large numbers of statistical fatalities – which can be misrepresented by anti-nuclear groups and can raise ‘thousands will die’ headlines
Against this background, the ICRP has stated that
The aggregation of very low individual doses over extended time periods is inappropriate, and in particular, the calculation of the number of cancer deaths based on collective effective doses from trivial individual doses should be avoided
Almost all the collective dose from regulated doses is delivered at risks that are ‘broadly acceptable’ or near the bottom of the ‘tolerable’ region
ICRP recommends that aggregating small doses over large populations and long periods should be avoided
SO – an argument can be made that the societal detriment from the discharges of a nuclear site meeting current regulations is negligible
But what would stakeholders think?
Current EA Guidance states:
...calculated average annual individual doses for a population group in the nanosievert (nSv/y) range or below should be ignored in the decision making process as the associated risks are minuscule and the contribution to total doses to individuals will be insignificant. Higher annual doses, up to say a few microsievert (μSv/y) can be considered trivial but may require some consideration particularly if at the higher end of the range. Calculated annual average individual doses in excess of these values should prompt careful consideration of the discharge options being considered.
Put simply, this Guidance states:
Which might lead one to think that, for regulation of doses from current nuclear plants, there was, and should be, little pressure on reducing discharges – consistent with the view that any detriment from the discharges might be considered negligible
BUT doses are subject to Optimisation
Optimisation is based on ALARA ‘as low as reasonably achievable, economic and social factors being taken into account’ driven by Best Practical Means (BPM)
But BPM is a driver until the costs of further control over radioactive substances would be grossly disproportionate to the benefits that would result .... from further reductions and ....
it would be difficult, if not impossible, to reach agreement on a single set of numerical criteria that would be appropriate for all sites.
So optimisation becomes a straight arm-wrestle between the regulator and the regulated.
And what have the results of this arm-wrestle been?
Well you might think that the current Guidance (ignore, think, think harder?) and the ‘inappropriateness’ of summing statistical fatalities would lead to a lower imputed value for the detriment from the low doses caused by regulated discharges than in fields like healthcare and transport that routinely use Cost Benefit Analysis?
On the contrary – many studies (and not just ours – references on request!!) have shown that the values imputed of over £1M per man sievert (or £17M per statistical fatality), nearly all of of this at doses which should, according to the Guidance, be neglected!!!
By avoiding any hint of aggregation and Cost Benefit Analysis we’ve ended up with much higher abatement costs than in the fields which use CBA
The maximum cost which would have been derived using an ‘inappropriate’ method is being exceeded
Babies and bathwater come inexorably to mind!
But after all, ‘it’s only money’, and ‘better safe than sorry’..................but actually this can be important
When applied to new nuclear power projects, inappropriate spend on discharge reductions may increase costs to the utility, and therefore, ultimately, power costs to us..... an inconvenience, one more kick to a faltering economy, but not, on its own, a disaster
But when applied to nuclear cleanup, more serious and immediate considerations emerge ..
In the UK, the Nuclear Decommissioning Authority (NDA) is charged with the mission to ‘deliver safe, sustainable and publicly acceptable solutions to the challenge of nuclear clean-up and waste management .... never compromising on safety, or security, taking full account of our social and environmental responsibilities, always seeking value for money for the tax payer, and actively engaging with stakeholders’
The NDA uses public money which it receives from the Treasury – and funding is both short-term and subject to scrutiny
And it’s a lot of money …
“It is estimated that infections cost the NHS at least ₤2bn a year” - that’s £33 for each UK citizen
NDA’s 2008/9 budget £2.86B is £47 per head
...so the Treasury is surely right to insist that Value for Money is demonstrated – and what can’t be demonstrated won’t get funded
So NDA must demonstrate how it balances
This must surely entail having a methodology for aiding decisions in real situations .....like....
hazard potential’ Δ(SED x years)
Reduced Hazard Potential
Reduced peak discharge Δ(µSv)
Reduced overall discharge Δ(man µSv)
Discharges Hazard Potential or ‘SED score’
There is currently no financial cost/benefit valuation of any sort employed to assess the amount of spend which would be justified to give a given reduction in dose to the public.
The logic used to discredit collective dose valuation can be convincingly employed to argue, with reference to health and safety regulation, that the doses to the public are so low that any detriment from collective dose from the nuclear industry is in fact negligible.
If this logic were upheld, then any benefit from activities to further reduce discharges would be extremely small, and this should be reflected in reduced spending.
In reality, even if the former costing method, based on a 1993 NRPB valuation of £20K per man sievert of collective dose, is used, then the existing spend has exceeded the benefit in cases studied, and this is probably routine.