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2012 68: 61Bulletin of the Atomic ScientistsMark Cooper

Nuclear safety and affordable reactors: Can we have both?

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Bulletinof theAtomicScientists

IT IS 5 MINUTES TO MIDNIGHT

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Feature

Nuclear safety and affordablereactors: Can we have both?

Mark Cooper

AbstractThe cost of building new nuclear reactors receives a great deal of attention in market economies, including theUnited States, Japan, and Germany. But in a post-Fukushima era of additional safety regulations, the eco-nomics of keeping a fleet of aging reactors online may command just as much attention. The author reviewsthe experience of the US nuclear reactor fleet in light of the post-Fukushima scrutiny of nuclear safety anddescribes the factors that have influenced, and will likely influence, future decisions about whether to own andoperate nuclear reactors. He shows that safety has been the driver of nuclear costs and that the inability of theindustry to deliver safe reactors at affordable costs is an endemic, long-standing problem. Nuclear power, hewrites, is a complex technology based on a catastrophically dangerous resource that is vulnerable to naturalevents and human frailties, which suggests that nuclear safety and affordable reactors are currently incom-patible and are likely to remain so for the foreseeable future.

Keywordsearly retirement, nuclear economics, nuclear reactors, nuclear renaissance, nuclear safety, too big to fail

Has the heralded Ònuclear renais-sanceÓ finally arrived? InFebruary 2012, for the first time

in more than 30 years, the US NuclearRegulatory Commission (NRC) issueda license to build two new nuclear reac-tors. In March, the NRC approved alicense for two more new reactors, andutilities have submitted applications for23 additional reactors. Two of thosereactors would be at a brand-newnuclear power plant in FloridaÕs LevyCounty, where Progress Energy Floridarecently agreed to a settlement that willallow the utility to collect $350 millionfrom customers over the next fiveyears as a down payment.

Look more closely at whatÕs happen-ing in Levy County, however, and youÕllsee that the nuclear industryÕs slump isnot over yet. The new Levy County reac-tors will not start operating for at leastanother decade, if ever. ItÕs all a questionof money: The utility estimates that thereactors will cost between $17 billion and$22 billionÑnot counting financingcharges and cost overruns, which haveplagued the nuclear industry. (Progressoriginally estimated that the reactorswould cost $5 billion and would com-mence operation in 2016.) With thedemand for electricity growing at asnailÕs pace, and natural gas prices at afraction of what the utility expected

Bulletin of the Atomic Scientists68(4) 61–72

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when it filed its application for a newplant in 2008, opposition to the projecthas mounted, threatening a rerun of the1970s and 1980s, when the majority ofnuclear construction plans were can-celed or abandoned.

The questionable economics of build-ing new nuclear reactors are only part ofthe problem that the nuclear industryconfronts today. It also faces the chal-lenge of keeping its fleet of old reactorsonline. Just eight miles south of whereProgress plans to build its new reactors,the company is struggling to get itsaging Crystal River reactor back in ser-vice. The reactor has been offline sinceSeptember 2009, when engineers cutinto its containment building to replacesteam generatorsÑwork that exposedstructural flaws in the buildingÕs con-crete panels. Attempted repairs haveonly created new cracks. Replacing thepanels, or perhaps the entire contain-ment building, will take years and costmore than $2 billion, if indeed the plantever comes back online.

At many sites around the UnitedStates, the costs of building new nuclearreactors have received a lot of attention,but the economics of existing nuclearreactors have come under far less scru-tiny. Severe accidents like Three MileIsland, Chernobyl, and Fukushima shinea spotlight on safety issues, which createsa major challenge for nuclear economics,because safety can be extremely expen-sive. Suddenly, old reactors do not looklike the cash cows that they are believedto be. In fact, they may be financial dis-asters waiting to happen.

As shown in Figure 1, the assumptionthat nuclear reactors hum along, oncethey are online, is not consistent withthe US experience (Cooper, 2012). Abouthalf of all reactors ordered or docketed at

the Nuclear Regulatory Commissionhave been canceled or abandoned. Ofthose that were completed and broughtonline, 13 percent were retired early, 19percent had extended outages of one tothree years, and 6 percent had outages ofmore than three years. In other words,more than one-third of the reactors thatwere brought online did not just humalong. Another 11 percent were turnkeyprojects, which had large cost overrunsthat were never revealed or documented.

Too expensive to build

A brief review of the economics of newnuclear reactor construction is helpful,

Figure 1. The financial and online status of US

nuclear reactors.

ALL REACTORS ORDERED OR DOCKETED

REACTORS BROUGHT ONLINE

Reactorsbrought online51%

Canceled49%

Outages of 1– 3 years

19%

Earlyretirements

13%

Turnkeyprojects

11%

Fulfillingoriginal license

51%

Outages of 3+ years6%

Sources: Heddleson (1978); Lochbaum (2006); Koomey

(2011); US Energy Information Administration (2011a, 2011b).

62 Bulletin of the Atomic Scientists 68(4)



because the pattern of constructioncosts is one indicator of the patternof subsequent capital expendituresÑparticularly for the repair or replacementof major components. From the point ofview of an investor in a market economy,the decision to build or buy a nuclearreactor involves a financial analysis ofrisk and reward (Cooper, 2009b).Although that calculation has historicallybeen heavily influenced by a number ofpolicies and large subsidies that affectthe prospects of nuclear power, itremains, at root, an economic decision.

Shortly after the start of the twenty-first century, nuclear enthusiasts beganto hype a renaissance in nuclear powerthat would lead to the construction ofhundreds of new reactors, based onbold assumptions about the dramaticallyreduced cost of construction for stan-dardized, modularized reactors. Asshown in Figure 2, those projectionsproved to be as far off the mark as theprojections that typified the buildingboom of the 1970s and 1980s.

During the US construction boom,nuclear reactors suffered severe costescalation (Cooper, 2010). The finalreactors cost more than seven times asmuch as the initial reactors broughtonline and exceeded the original projec-tions by an even wider margin. Theresult was a series of lengthy regulatoryand court proceedings that contestedlarge potential rate increases and madenuclear power a lot less profitable thanthe utilities had hoped.

The pattern repeated itself in thecost projections offered during thepast decade. Rising cost estimatesin the United States, and uncertaintysurrounding several projects under-taken by the French, seem to havederailed the so-called renaissance(Cooper, 2009a). As a result, in theUnited States, more than 80 percent ofthe license proceedings that wereopened at the NRC during this timeperiod are dormant, if not dead, andmore than half of those that are stillactive appear to be unlikely to result in

Figure 2. Overnight costs of reactor construction (2009 dollars/kilowatt).

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

10000

1970 1975 1980 1985 1990 1995 2000 2005 2010

Actual Analysts Utilities/Enthusiasts

Actual

Analysts

Utilities/Enthusiast

Sources: Cooper (2009a); Koomey and Hultman (2007).

Cooper 63



actual construction of new reactors(Cooper, 2009b).

The current difficulties of nuclearreactor construction are reflected inthe fact that, despite the long-standingsocialization of liability for a nuclearaccident (Cooper, 2011e) and efforts tostreamline the licensing process, utili-ties require a combination of federalloan guarantees, early cost recoveryfrom ratepayers, and public entity sup-port to proceed with projects (Cooper,2011a). Even then, it is not certain a pro-ject will be successful. Aside from thesocialization of liability, the other subsi-dies are not generally available to sup-port retrofit or repair costs for existingreactors. Also, itÕs likely there willbe more regulatory scrutiny in thefuture, not less, for both old and newreactors.

Too costly to fix

The US nuclear industry has complainedthat the cost escalation was driven byunnecessary regulationÑregulation thatthe NRC believed was vital to ensure thesafety of the growing fleet of nuclearreactors in the 1970s.1 One thing historyshows clearly is that the link betweensafety regulation and economics existedbefore the 1979 accident at Three MileIsland (Cooper, 2012; Koomey, 2011).Figure 3 covers the construction boom-and-bust period before Chernobyl. By1985, the status of more than 90 percentof all reactors (canceled or completed)had been decided. Figure 3 shows thatthe growth of standards and guidelineswas dramatic, from three in 1970 to 143by 1978, with an even higher total whenrules plus major revisions are counted.

Figure 3. Safety regulation and the disposition of nuclear reactors.

180

160

140

120

100

80

60

40

20

0

1970 1972 1975 1978 1981 19841971 1974 1977 1980 19831973 1976 1979 1982 1985

COMPLETED MEGAWATTS

NUCLEAR REGULATORY COMMISSION FINES IMPOSED (IN THOUSANDS OF US DOLLARS)

OPERATING MONTHS LOST TO LONG-TERM OUTAGES

CANCELED MEGAWATTS

CUMULATIVE NUCLEAR REGULATORY COMMISSION RULES AND REVISIONS

Sources: Heddleson (1978); Komanoff (1981); Koomey (2011); Tomain (1987); US Energy Information Administration (2011a,

2011b).




Enforcement came after the Three MileIsland accident, when the NRC felt com-pelled to ensure compliance with itsrules, and long-term outages rampedup.2 Enforcement altered the economicsof existing reactors.

Ultimately, since the start of the com-mercial industry, one-quarter of all USreactors have had outages of more thanone year. There are three causes of theseoutages:

. ReplacementÑto refresh parts thathave worn out

. RetrofitÑto meet new standardsthat are developed as the result ofnew knowledge and operatingexperience (e.g., beyond-designevents)

. RecoveryÑnecessitated by break-age of major components

The reactors that had extended out-ages were twice as likely to have beencompleted before Three Mile Island,and therefore they were caught in thetransition to greater safety regulation.Construction of these reactors beganwith half as many regulations in placeas for reactors that did not suffer suchoutages, and the number of regulationsthat were applied to these reactors morethan tripled during their constructionperiod. The average cost of an outage(in 2005 dollars) was more than $1.5 bil-lion, with the highest cost topping $11 bil-lion (Lochbaum, 2006).

A second way that enforcementaffected the economics of existing reac-tors involved early retirements. Table 1identifies the US reactors of significantsize that have been shuttered beforetheir licenses expired or kept offline forlengthy periods of time at sites withmajor safety events.

Quantitative and qualitative analysisof the early retirements providesinsight into the decision to retire reac-tors. Early retirement reactors are typ-ically older, smaller reactors builtbefore the ramp-up in safety regula-tion. They are not worth repairing orkeeping online when new safetyrequirements are imposed, or whenthe reactors are in need of significantrepair. On average, compared withreactors that were not retired early,early retirements were:

. Less likely to be pressurized waterreactors (53 percent vs. 63 percent)

. Brought online earlier (on average,1972 vs. 1979)

. Much more likely to have beenbrought online before Three MileIsland (82 percent vs. 50 percent)

. Smaller (558 megawatts vs. 964megawatts)

. Less likely to have suffered asafety-related outage (12 percentvs. 33 percent)

. More likely to have suffereddamage or a component-relatedoutage (24 percent vs. 11 percent)

Qualitatively, the decision to retire areactor early usually involves a combin-ation of factors, such as major equip-ment failure, system deterioration,repeated accidents, and increasedsafety requirements. Economics is themost frequent proximate cause, andsafety is the most frequent factor thattriggers the economic reevaluation.Although popular opposition inspired acouple of early retirements (a referen-dum in the case of Rancho Seco; stateand local government in the case ofShoreham), this was far from theprimary factor, and in some cases local

Cooper 65



Table 1. Significantly early retirements and reactors with outages exceeding 5 years.

REACTOR(LOCATION)

SHUTDOWN(OUTAGE)

YEARS OFOPERATION CAUSE OF SHUTDOWN

ConnecticutYankee (CT)

Economic study showed customers would save money if the plant closed. Other considerations included long-term maintenance costs and the availability of low-level waste disposal.

1996 29

Browns Ferry 1 (AL)Browns Ferry 2Browns Ferry 3

Dresden 1 (IL)

Fermi 1 (MI)

Fort St. Vrain (CO)

Humboldt Bay (CA)

Indian Point (NY)

Trojan (OR)

Zion 1 (IL)Zion 2

Maine Yankee (ME)

Millstone 1 (CT)

La Crosse (WI)

Yankee Rowe (MA)

Peach Bottom 1 (PA)

Unit 1 was shut down for a year after fire damage in 1975. It was repaired and operated from 1976 to 1985, when all three units were shut down because of operational and management issues. Tennessee Valley Authority spent $1.8 billion to restore Unit 1 to operational status.

Minor steam leaks and erosion in steam piping, fuel failures, and corrosion of admiralty brass led to elevated radionuclide levels. While the reactor was offline for decontamination and retrofitting, new regulations were issued, and compliance would have cost more than $300 million.

In 1966, a loose zirconium plate at the bottom of the reactor vessel blocked sodium coolant flow, and two fuel subassemblies started to melt. Less than three years after cleanup was completed and the reactor restarted, the core was approaching the burnup limit.

Control-rod drive assemblies, steam-generator ring headers, low plant availability, and prohibitive fuel costs ultimately shut the plant down.

During a shutdown for seismic modifications, updated economic analyses showed that restarting would probably not be cost-effective.

The emergency core cooling system did not meet regulatory requirements.

Tube leaks requiring replacement of the steam generator along with regulatory uncertainty took the plant offline.

A control-room operator accidentally shut down Unit 1 and tried to restart it without following procedures. The utility later concluded that repairing steam generators would be uneconomical.

NRC staff identified so many problems that “it would be too costly to correct these deficiencies to the extent required.”

After a leaking valve forced a shutdown in 1996, multiple equipment failures were discovered.

The small size of the plant made it no longer economically viable.

Reactor-vessel embrittlement and steam-generator tube damage led to closure.

This was a small, experimental, helium-cooled, graphite-moderated reactor.

(21-year outage)(6.7-year outage)(10.7-year outage)

1978

1972

1989

1976

1974

1992

19981998

1996

1998

1987

1991

1974

182925

18

2

13

16

12

17

2524

23

28

17

32

7

Rancho Seco (CA) Safety concerns coupled with poor performance led to a popular vote to close.1989 14

San Onofre 1 (CA)

Shoreham (NY)

Three Mile Island 1 (NY)Three Mile Island 2

Economic analysis of costs—like the repair of steam-generator degradation and implementation of seismic-retrofit requirements—outweighed the benefits.

Local opposition and concerns about an evacuation plan shuttered the plant before commercial operation began.

Plant went offline for refueling during the 1979 accident at Three Mile Island 2, but was brought back online in 1986. Three Mile Island 2 experienced a partial core meltdown caused by loss of coolant—it rated a 5 on the International Nuclear and Radiological Event Scale. Cleanup took 14 years and cost about $1 billion.

1992

1987

(6.6-year outage)1979

24

0

290.33

Sources: licensee websites (2012); Nuclear Regulatory Commission website (2012); Office of Technology Assessment(1993); Wikipedia (2012).




opposition clearly failed (referendafailed to close Trojan or MaineYankee). External economic factors,such as declining demand or more-cost-competitive resources, can renderexisting reactors uneconomic on astand-alone basis or (more often) in con-junction with one of the other factors.

Under the post-Fukushimamicroscope

Fukushima highlights the fact thatnuclear reactors do not age gracefully.Time not only causes wear and tear; italso exposes reactors to events thatoccur only rarely and reveals designissues that were not recognized ornever addressed when the reactor wasconstructed (Cooper, 2011b).Retrofitting old reactors is costly, sothe trade-off between safety and eco-nomics is put under a microscope.

This scrutiny means more peoplelooking more carefully at a reactorÕstrack record, but even more importantly,more people paying attention to theongoing struggle with safety. The prob-lem is compounded by the factthat reviewing nuclear reactor safetyafter an accident reveals an endemictendency to undervalue safety beforean accidentÑnamely, past violations ofstandards that did not result in enforce-ment actions (Onishi and Fackler, 2011)but instead in lowered standards toavoid increased expenses related tosafety (Donn, 2011; Sullivan, 2011).

The United States, Japan, and theEuropean Union have issued safety rec-ommendations in response to theFukushima accident (Eurosafe Forum,2011; Nakagome, 2011; Nuclear RegulatoryCommission, 2011). By the first anniver-sary of Fukushima, 96 percent of the

reactors in Japan were offline (Fackler,2012). Every reactor in France wasundergoing mandatory upgrades forbackup power and venting, and the overallcost of meeting new safety requirementsthere will add billions to the cost of elec-tricity.3 Germany began closing agingreactors and ultimately decided to aban-don nuclear power. All of this suggeststhat license extensions will be harder tocome by, and additional plants will beretired (Lekander et al., 2011).Implementation will vary from nation tonation, but Òcost increases are inevitable,Óaccording to former Exelon CEO JohnRowe (Malik, 2009).

In the United States, the concernsexpressed about safety affect a largepart of the fleet. The Union ofConcerned Scientists (2012), whichtracks ongoing safety issues at operatingnuclear reactors in the United States, hasfound that leakage of radioactive mater-ials is a pervasive problem at almost 90percent of all reactors, as are issues thatpose a risk of accidents. Figure 4 showsthree issues that have been highlightedby Fukushima: seismic risk, fire hazard,and elevated spent fuel storage. Morethan 80 percent of US reactors face oneor more of these issues. All boiling waterreactors (like those at Fukushima)have at least one of these issues. Three-quarters of US pressurized water reac-tors have an issue. Half of those thatdo not exhibit one of these issues hada near miss in 2011. Clearly, safetyremains a challenge in the UnitedStates, one that has been magnified byFukushima.

Too big to fail

Operating an old nuclear reactor, likebuilding a new one, can be a bet-the-farm

Cooper 67



proposition for a utility. The scale of anaccident like the one at Fukushima(and Chernobyl before it) is so largethat, notwithstanding insurance schemesthat socialize the risk of nuclear power,it can force even the largest utilityinstantly into virtual, if not actual, bank-ruptcy. Considering the expense asso-ciated with such an accident, oldreactors may simply be too riskyÑfinanciallyÑto operate. It appears thatsevere accidents typically cost hundredsof billions of dollars (Cooper, 2012).Even a utility as big as the TokyoElectric Power Company (Tepco), thefourth largest in the world, cannot sus-tain such a massive blow to its bottomline without help.

The fact that governments will step inmay be a mixed blessing, from the inves-tor point of view, and it is definitelyproblematic from the societal point ofview. Companies such as Tepco maybe seen as Òtoo big to fail,Ó like thebanks that received government bailoutsin the financial meltdown of 2008. This

may create a perverse incentive for autility to take risks it should not,although the zombie-like condition ofTepco, and the intense scrutiny thatnuclear utilities endure post-accident,suggest there is a significant price topay after the fact. Unfortunately, itÕsquestionable if this price will be fac-tored into decisions about whether tocontinue operating existing reactorsthat are facing safety issues.

The too-big-to-fail concept is gener-ally applied to financial institutions andfits within a broader class of economicdilemmas known as moral hazard. Thetheory is that, when an outside party(like the government) absorbs some ofthe risk of a transaction, the original par-ties to the transaction (like banks andenergy companies) have an incentive todo things that they would not do if theybore all of the risk (like slack off on safetystandards to save money). In the case offinancial institutions, the governmentfears that letting a bank fail might under-mine confidence in the financial market,putting the entire system at risk. And thefinancial institutions count on this fearand assume the government will not letthem sinkÑand so banks feel freer totake a few more risks. Hence, systemicrisk motivates governments to bail outbanks and, more recently, to imposegreater requirements for safety andsoundness on institutions that posesystemic risk since the institutionsthemselves have less incentive to do so.

Whether investors in utilities shouldcount on this concept as a way to protecttheir investments in nuclear reactors isunclear. In one sense, no nuclear reactoror even nuclear power station in theUnited States is too big to fail. Theymake up too small a part of a highly inter-connected grid to bring down the whole

Figure 4. Significant ongoing safety issues.

Multiple13%

Spent fuel18%

Other17%

Seismic17%

Fire35%

Source: Union of Concerned Scientists (2012).




grid, but the magnitude of a severe acci-dent may be sufficient to undermine theeconomic viability of the utility. Clearly,Tepco is struggling with the financialaftermath of Fukushima and exists onlybecause of the intervention of theJapanese government.

In another sense, the magnitude of theFukushima accident has been so greatthat it demonstrates how a nuclearpower plant can be too big to fail. Anaccident of this severity calls into ques-tion the entire technology, which poses achallenge to the national grid and has alarge impact on the broader nationaleconomy. With utility disruption, griddisruption, and economic disruption,society may feel compelled to step in,thereby absorbing the risk that the util-ity should take.

Lessons for decision makers

Journalists and policy makers frequentlyinsist on simple answers to complexquestions, such as the question ofwhether the world can have nuclearsafety and affordable reactors. Writingjust after Chernobyl, Tomain (1987)posed the question somewhat differ-ently: ÒIs nuclear power not worth therisk at any price?Ó These are extremelycomplex questions, but if a simpleanswer must be provided, it is this: Ifwe use a market standard, nuclearpower is neither affordable nor worththe risk. If the owners and operators ofnuclear reactors had to face the fullliability of a nuclear accident and meetalternatives in a competition unfetteredby subsidies, no one would have built anuclear reactor in the past, nor wouldthey build one today, and they likelywould exit the nuclear business asquickly as they could.

The combination of a catastrophicallydangerous resource, a complex technol-ogy, human frailty, and the uncertaintiesof natural events make it extremely dif-ficult and unlikely that the negativeanswer can be changed to a positive.By bringing intense scrutiny to bear onaging reactors, Fukushima promptspolicy makers and the public to asktough questions about whether agingreactors should be retired or not havetheir licenses extendedÑthe same ques-tions that have generally been askedabout the construction of new reactors.In formulating the answer, the lessons ofhalf a century of nuclear power shouldbe kept in mind. Among the mostimportant of these lessons:

Nuclear power is a non-marketphenomenon

Nuclear socialism is an appropriatedescription of the economics of nuclearpower. It is certainly true that eco-nomics have decided, and will likelycontinue to decide, the fate of nuclearpower, but the fiction that investorsand markets can make decisionsabout nuclear power in a vacuum isdangerous. Given the massive economicexternalities of nuclear power (not tomention the national security and envir-onmental externalities) and the massivesubsidies on which it has alwaysdepended, policy makers decide thefate of nuclear power by determiningthe rate of profit through subsidies.

Match risks and rewards

If the goal is to have cost-efficient deci-sions, risks must be shifted onto thosewho earn rewards. By reducing therate of profit that utilities earn from

Cooper 69



subsidized projects, policy makerscan offset the bias that subsidies (suchas loan guarantees and advanced costrecovery) introduce into utility decisionmaking.

Buy time

Given the severe problems that retrofit-ting nuclear reactors pose, and the currentconditions of extreme uncertainty aboutchanges in safety regulation, it is prudentto avoid large decisions that are difficult toreverse or modify. Flexibility is a valuableattribute of investments, and mistakesshould be kept small (Cooper, 2011c, 2011d).

Learn from history

Sound economic analysis requires thatsunk costs be ignored, but the mandatefor forward-looking analysis does notmean that the analyst should ignore his-tory. Utilities claim that the cost of com-pleting a new reactor or repairing an oldone (the cost Òto goÓ) is lower than thecost of pursuing an alternative fromscratch. The problem is that utilities arejust as likely to underestimate and beunable to deliver on the promised Òto-goÓ costs as they have been when theytried to estimate and deliver on the costto build nuclear reactors. Regulators mustexercise independent judgment and takethe risk of cost overruns into account.

The Fukushima disaster, the worstnuclear accident ever to occur in amarket economy, punctuated half acentury of tension between nuclearsafety and nuclear economics. Intensepost-Fukushima scrutiny has highlightedthe endemic problems that afflict theunderlying technology. The prospectsfor both new and old nuclear reactorsare much dimmer now, possibly signaling

an end of an era in the so-called nuclearrenaissance proclaimed just a decade ago.

Funding

This research received no specific grant from anyfunding agency in the public, commercial, or not-for-profit sectors.

Notes

1. Adverse operating experience has also givenrise to numerous regulatory guides andÒunresolved safety issues.Ó Major examplesare: the 1975 Browns Ferry fire, which led tocostly new rules for fireproof constructionand ventilation; reactor control breakdownsfrom 1978 to 1980 due to power failures toinstruments, which have prompted consider-ation of increased separation of ÒsafetyÓfrom Ònon-safetyÓ instruments; and the 1979Three Mile Island accident, which sparkedan across-the-board review of fundamentalregulatory premises (Komanoff, 1981: 27).

2. Tomain argues that the increase in finesafter Three Mile Island reflected a determin-ation by the NRC that it had to make sure itssafety regulation had teeth in order to pre-vent defective products that had beenexcused from bearing full liability from get-ting to market (Tomain, 1987).

3. World Nuclear News (2012) reports that newsafety-related costs would more than doublea 15-year, $65 billion maintenance program at58 operating reactors in France.

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Author biography

Mark Cooper is a senior research fellow foreconomic analysis at the Center for Energy andthe Environment at Vermont Law School. Hehas over 30 years experience as a publicpolicy analyst and expert witness for publicinterest clients. As such, he has appearedmore than 300 times before public utility com-missions, federal agencies, and state and fed-eral legislatures in more than 40 jurisdictionsin the United States and Canada. He first ana-lyzed nuclear power economics in 1984 beforethe Mississippi Public Service Commission inregard to the construction of the second unit atthe Grand Gulf nuclear power station.


