Sunday, July 27, 2014

The Carbon Regulations: Not What They Seem to Be

Carbon Dioxide
from Wikipedia
The Rules Are Backwards

When the EPA came out with its proposed regulation for carbon dioxide abatement, my first impression was that the rules were political, backwards, and unenforceable. That's still my opinion.

Since I had a very firm opinion,  I immediately wrote an op-ed for my local paper, the Valley News.  I sent the op-ed to several other papers also.   I think the easiest place to read my article and write comments is at Vermont Digger: Carbon Emission Confusion.

What do I mean by "backwards"?  Well, in my opinion, if the electricity sector of a state uses a lot of coal and produces a lot of carbon dioxide---that is the state to target for large reductions.

And why are the rules written by state, anyway? High-carbon producing areas  should be targeted for large reductions.  In the earlier Clean Air Act regulations, the regulations were stricter in non-attainment areas.  That is, if an area did not attain EPA standards for air quality, that area had to implement more stringent controls.  This made sense to me.

The new proposed EPA carbon rules seem to be founded on the reverse principal.  The EPA asks low-carbon-producing states (for example, Washington State and New Hampshire) to reduce their utility carbon footprint by 40 to 70%. They ask high-carbon-producing states (for example, West Virginia) to reduce their carbon footprints by less than 20%.

It's backwards.

Ambiguity in the Goal and in the Rules

At ANS Nuclear Cafe, Jim Hopf does a more careful analysis of the new rules, complete with a map.    He notes some fundamental ambiguities in the EPA documents:
EPA Proposes Power Sector CO2 Emissions Reduction Plan.

Even after reading most of the press releases and other documents on the EPA website and elsewhere, I have been unable to determine with certainty if the national reduction quoted above is a 26–30 percent reduction in actual, absolute emissions (in tons per year), or a reduction in emissions per MW-hr generated. The EPA refers to a 26–30 percent reduction in “CO2 emissions” (suggesting an absolute emissions reduction), but all state requirements are given in units of emissions (tons) per MW-hr.

Hopf notes that the EIA predicts electricity use in the U.S. will grow by about 25% between 2012 and 2030, so the difference between "total U.S. CO2" and "per-kWh CO2" can be  significant.

Hopf does see one potential bright side (or maybe it isn't a bright side). Gas and coal plants are comparatively easy to mothball for a while, and then bring back to service.  Hopf writes that EPA policy may lock in the switch from coal to gas:

Perhaps the main impact of the proposed policy..... is that it cements current plans and policies, and prevents any back-tracking. The most significant example of this concerns the use of gas vs. coal. Without the policy, utilities will go right back to coal if the cost of natural gas rises. The EPA policies will essentially disallow switching back from gas to coal,...And they will do so even if natural gas prices rise in the future; a very important point.

Follow the Money

I hesitate to write this, because it seems so cynical.  But here goes.

I recently finished the book Extortion by Peter Schweitzer. The subtitle of this book is "How politicians extract your money, buy votes, and line their own pockets." This is a very depressing read. The book is very well researched: it is not an "opinion piece." Some parts of the book echo my blog post about the way that Vermont Yankee was a sitting duck for special fee assessments for Vermont (Millions for education, but not one cent for tribute).  However, Schweitzer looked mainly at the national level.

One part of Schweitzer's book seemed very relevant to the carbon rules. Schweitzer explains how complex regulations are lucrative for the people who write them.   Indeed, the rules for carbon abatement are complex, non-intuitive, lengthy and probably (but not certainly) internally inconsistent.  According to Schweitzer, these are hallmarks of legislation that is a perfect set-up for extortion.  (Note: Schweitzer's book was published before the carbon rules were promulgated, and does not discuss these particular rules.)

In the future, somebody is going to have to explain these regulations. Some lawyers are going to be hired to help states and utilities comply with these rules.  Who will these people be?

The people responsible for writing the rules are the people who will probably be hired to help companies comply with them.   Schweitzer explains that there is even a short-hand term for this: "cashing in." A person serves in the government, this person writes (or at least learns) a complicated set of laws or regulations, then the person "cashes in."  She joins the private sector and gets big bucks for helping companies comply with the rules she wrote.

I hope I am wrong.  This is deeply depressing. If I have the correct slant on this, these rules are not about carbon at all.  As I said, I hope I am wrong.

Always Leave Them Laughing

To end on a lighter note, let me link to The Onion's excellent description of the new rules: New EPA Regulations Would Force Power Plants To Find 30% More Loopholes by 2030.




Monday, July 21, 2014

Nuclear Energy Blog Carnival 218: Here at Yes Vermont Yankee

Once again, we are proud to host the Carnival of Nuclear Energy Bloggers here at Yes Vermont Yankee.  The Carnival is a compendium of nuclear blogs that rotates from blog site to blog site, and it is always a pleasure and an honor to host it.  So let's get started on some of the very best blog posts from some of the very best bloggers.

The first post is back-to-basics.  How much energy do we use, and where can we get it?

How carbon-heavy are your personal assistants?
If you want to know why America is among the world’s biggest destinations for immigrants, look at the country’s energy supply. Each American citizen has at her disposal, on average, an annual block of energy of more than 81,000 kilowatt-hours. That is like having a retinue of about 92 human assistants at her beck and call at any hour of the day. These personal assistants heat and transport her water, light her lights, run her computer and Internet, and move her car. As Steve Aplin of Canadian Energy Issues points out, there is nothing inherently wrong with the average American having a block of energy this size. In fact, it is profoundly good that she does. 

However, it is possible to have a retinue of personal assistants who do not emit so much CO2: America’s current use of energy, after all, adds, every 19 months, 1 part per million to the CO2 concentration in the planet’s atmosphere. Aplin urges the de-carbonization of the 28 billion personal assistants serving America, through a known and proven energy technology.  Nuclear energy.
http://canadianenergyissues.com/2014/07/18/how-carbon-heavy-are-your-personal-assistants/

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Next, a completely different look at potentially dangerous technologies.

Comparative dangers?  How about those crystal doorknobs?
At Nuke Power Talk, Gail Marcus discusses a fire in a home in the UK caused by a crystal doorknob concentrating the rays of the sun. Her post is titled "The risk of just about everything."   Marcus reflects on how humankind responds to unexpected risks from technologies, be they simple ones, like a crystal doorknob, or complex ones, like nuclear power plants.
http://nukepowertalk.blogspot.com/2014/07/nuclear-power-and-crystal-doorknobs.html
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Well, while we are considering danger, let's look at the news from Japan.

How safe is “safe enough” in Japan?
The question of “how safe is safe enough” has suddenly emerged in Japan. A few news outlets try to provide an objective answer, relying on the Nuclear Regulatory Authority decisions on restarts. But most seem to opine that no nuclear plant will ever be safe enough. The most extreme news source seems to be Asahi Shimbun. The Asahi makes what are tantamount to fabrications about the situation, and makes no attempt to provide an iota of balance. Les Corrice covers the coverage in his blog, Hiroshima Syndrome.
http://www.hiroshimasyndrome.com/fukushima-commentary.html

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Asahi Shinbun is not the only source of myths.
  • The price of electricity in Germany is pretty hard to determine, what with the taxes and the tariffs and the special breaks for industry. 
  • Speaking of "special breaks," there's a whole movement against the Export Import Bank.  
Nuclear Energy Institute takes on these issues, in two blog posts.

A third post at NEI is a very upbeat look at being a woman and a nuclear engineer.  (Sigh.  I personally love this sort of post.)
  • Being a nuclear engineer at Areva.

5 Myths About the Export-Import bank
Rep. Jeb Hensarling is leading the charge against the reauthorization of the U.S. Ex-Im Bank. The bank is crucial to nuclear exports, and NEI decided to confront some of the myths about the bank that Hensarling has been promoting recently.
http://neinuclearnotes.blogspot.com/2014/07/5-myths-about-export-import-bank.html

Higher and Higher: EEI Uncovers The Cost of Electricity in Germany
Ever since Germany decided to phase out nuclear energy in the wake of Fukushima, local activists have been touting the results of the shift, known in German as the "Energiewende." But what has the cost been to the nation's economy. NEI's Mark Flanagan looks at a recent EEI report that's full of interesting details.
http://neinuclearnotes.blogspot.com/2014/07/higher-and-higher-eei-uncovers-cost-of.html


Being a Nuclear Engineer at AREVA
Abbey Donahue is a Design Project Engineer for AREVA TN, and the professional development chair of the North American Young Generation in Nuclear (NA-YGN). In her blog post to NEI Nuclear Notes, Abbey talks about what she does, why it matters, and why she has such a passion for engineering, energy, and making a positive impact on the world.
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There are other types of nuclear energy, also. Brian Wang at Next Big Future looks at fusion.
Helion's Fusion Engine
Helion Energy's Fusion Engine is the only demonstrated fusion energy source capable of producing both on demand and baseload power at low cost and with minimal environmental impact. Employing a patented staged electromagnetic compressor and direct energy conversion, the Fusion Engine efficiently harnesses fusion energy employing fuel derived solely from water. This IAEA award winning and DOE validated prototype generated the required fusion energy output that allows for
commercialization of economical fusion by 2019. By removing complex tritium systems and steam turbines, the Fusion Engine can be constructed faster and with reduced capital costs. And unlike current nuclear systems, Helion’s fusion technology is inherently safe and generates only clean byproducts. Helion holds the key to unlock the long sought after promise of endless fusion energy.

They got $5 million from DOE and are raising $35 million. The chief researcher John Slough also has a NASA funded direct fusion propulsion project.

http://nextbigfuture.com/2014/07/helion-energy-plans-to-enable.html
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Meanwhile, there's a lot of wind in some parts of the country. Jim Conca at Forbes looks at the energy  possibilities of Tornado Alley.

Wind Turbines Could Rule Tornado AlleyTornado Alley is the optimal place for wind turbines in the United States, pushing capacity factors beyond 40%, and making wind the second largest generator of electricity in Kansas, South Dakota and Iowa. But political forces seek to stop expansion.


Thursday, July 17, 2014

Half a Million Page Views


 Summertime, and the living is easy. So easy that it is easy to lose track of things, such as pageviews.

Yes Vermont Yankee passed the half-million-page-view mark sometime last month.

I don't completely believe the analytics I am showing above, because the blog started in January 2010, not  May 2006.  But I think the trend is correct.  Blog readership remained high even after the announcement that Vermont Yankee will close.

The blog covers Vermont Yankee and regional energy policy.  I am glad it continues to be relevant to its readership.

Readers, I thank you.
Guest bloggers, I thank you.
Blogs that link to this blog, I thank you.

I am pleased that Yes Vermont Yankee has achieved half-million pageviews!

Tuesday, July 8, 2014

The Problems with "Reasonable" Regulation: Guest post by Chris Staubus

Chris Staubus
The Problem with "Reasonable" Regulations.  Guest Post by Chris Staubus.

Meredith Angwin’s post has hit on a concept being used by regulators in areas beyond nuclear power.  Many would think it is “reasonable” to use “best available technology” for such things as cooling water intakes to prevent harm to fish populations and for carbon capture to prevent release of carbon to avoid the impacts of man-made global warming.  There is a much longer list of where “reasonable” is the foundation for regulatory regimes.

Why does “reasonable” seem so pervasive?  It is because it is the battle of emotions over science.  If you are against “reasonable” you are by definition “unreasonable” – emotion.  If regulation is set at a numeric limit –science – many can’t even enter the conversation because of lack of education or lack of interest to delve into the basis for the limit.  One can create a lot more social impact for change by arguing with “emotion” than with science.  More people can join in the argument for “reasonable” than there are scientists, engineers and technologists to refute “reasonable.” By the example Meredith Angwin points out, it is obvious “reasonable” leads to “unreasonable.”

“Reasonable” is also driven by regulators: they never want to regulate less.  So as they regulate more, where  can they push?  They can look at what is “reasonable” or at the state of the art for “best available technology.”  This is a continuous process never ceasing from generation to generation of regulators.  Each batch of regulators wants to do something for their cause of safety, protection of people or environment.

However, once the “reasonable” train leaves the station, the end of the line is “unreasonable.”

Reviewing the Regulatory Environment

A couple points about what has happened to the regulatory environment in our industry.

1. The Frog 

Industry and society need to prevent being slowly boiled like a frog.  If you put a frog in boiling water he will jump out.  He recognizes the danger.  If you put the frog in lukewarm water and slowly increase the heat he doesn’t recognize the problem until it is too late.  This is what has happened in the nuclear power industry.  In the early years our education system didn’t help most in society to understand nuclear power, opening up the regulator and industry to focus on safety at any cost.  After all, that would be “reasonable.”  Now as the heat has been turned-up we are about cooked, because the regulatory burden to get a plant licensed, its cost in time and money along with the additional cost to build and operate have taken an economic power source and has made it significantly less competitive.  Some hope this trend will lead to its extinction.

Our takeaway –
Especially with industries with long asset lifecycles, even small changes in the regulatory regime will suck the lifeblood out of viable products and services.

2.  Excess Regulation Everywhere
        
As consumers and voters, we  need to be alert to how the regulatory environment is changing for foundational industries in this country.  The EPA is changing its regulations, using clean air and clean water acts  as a basis.  What will this potentially do to the daily services and products we consume?  Is there anyone that doesn’t think regulating carbon emissions won’t cost them in their electric bills, fuel or even food bills?  When a utility must pick-up the tab for putting in new cooling towers or new intake structures in response to EPA 316b requirements, this is going to hit their customers in the pocket book.  That means not only homes, but businesses that use power in the production of their goods and services may leave the region or the country seeking lower cost inputs.  What is the cost to society for the loss of those jobs?

Other areas to consider are close to home:  water management, storm water regulations, and property use. Basically, we have to think about the consequences in every case where there are permits, fees and regulations that are being changed.  It is difficult to imagine a regulatory envelope getting smaller.

Our takeaway –
We need to think long term and hold our governments accountable for regulation that is more than just “reasonable.”  As scientists, engineers and technologists we can’t be silent, passive and inert.  We have a voice.

3.  Innovation versus Regulation
        
Major innovation has never been driven by regulation.  In fact regulation tends to hamper innovation.  So one can say society is actually poorer for regulation that inhibits innovation.  At best regulation has created innovations at the margins to protect existing business and revenue streams.  It has not created innovations that have advanced people’s standard of living.  Hence, we are poorer with heavy regulation as a society.  Concerning innovation, regulation is on the par with central planning which is driven by central planners or in this case regulators.  This is not to criticize individuals doing sound jobs.

Success in regulation, by definition, imposes limits.  It places limits to prevent doing too much of something.  This creates a culture that limits.

Our takeaway –
Whenever there is change in the regulatory regime, society must fully understand its implications and think about what yet-to-be-created innovation may be blocked by this regulatory regime or government policy.

Unreasonable Effects on Society

Society will definitely be poorer when regulators pursue “reasonable.”  We must seriously consider how to push back against this emotional gambit.  It seems evident arguing with facts has limited effectiveness.


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About this guest post

Chris Staubus holds a BS in Marine Engineering and an MBA.  He has nearly four decades in the power and utility industries.  He is currently  the General Manager for an engineering consulting firm which supports operating nuclear power plants and nuclear new builds, domestically and internationally.


My recent post, Protecting Against Nothing, the Failings of ALARA, compared the ever-more-stringent requirements of "ALow AReasonably Achievable" (ALARA)  with the more straightforward concept used in drinking water regulation. For drinking water, the question is not "what is achievable" or "what is reasonable."  Drinking water has to meet threshold benchmarks (no more than so many ppm of this ion).  This is a better, more simple way to achieve and assess safety.

In response to that post, Chris Staubus sent me a thoughtful email, and he gave me permission to use his email as a guest post.


Sunday, July 6, 2014

Plant Site Boundary Radiation Measurements and More Unreasoning ALARA

Measuring Low Level Radiation At the Site Boundary

The NRC requires careful control of the maximum radiation dose at the site boundary of a nuclear power plant.  For a non-specialist like myself, the NRC document 10 CFR Part 20 is not easy to interpret.  Plus, power plants in Vermont must meet even more stringent state requirements.  To explain the situation, I will quote a  Vermont Department of Health press release on site monitoring at Vermont Yankee:
The U.S. Nuclear Regulatory Commission limits radiation doses for the general public to 100 millirem per year. The limit set by the U.S. Environmental Protection Agency is 25 millirem per year from radioactivity in water, air and soil. The Vermont Department of Health limits are more restrictive – 20 millirem per year.
In other words, the plant-caused radiation at the site boundary in Vermont must be less than 20 millirems above background radiation, total, per year. Indeed, the radiation at Vermont Yankee plant boundary is at a such a low level that it  cannot be measured easily and reliably, except by specialists.

Detecting 20 millirems per year over the background level of around 300 millirems per year: this is not easy.

Measurements disagree

Predictably, at the low levels of radiation required by Vermont,  measurements are difficult and results can conflict.  Sure enough, Entergy measurements and Vermont Department of Health measurements disagreed.  Basically, low levels of radiation release have to be measured by specialists in measuring low-level radiation.

To resolve the conflict between the Entergy measurements and the Vermont measurements, Entergy engaged Oak Ridge Affiliated Universities (ORAU) to do a third set of measurements.  ORAU has a group that specializes in radiation measurements. The local opponent groups objected to this choice.

The opponents' main accusation was that ORAU was part of the industry and could not be trusted.  Another accusation was that hiring ORAU was a way to fool Vermont citizens into thinking that Entergy had hired Oak Ridge National Laboratory.  (ORAU is basically part of Oak Ridge National Laboratory. It's complicated, and has to do with the difficulty the government has in hiring temporary employees, graduate students, etc. )

Meanwhile, the opponents objections to ORAU and the measurements were not mild-mannered. There were shouted accusations.  I saw a man from VPIRG completely blindside an Entergy employee at a public meeting. The Entergy man on the panel had no idea that the contract with ORAU was going to lead to shouted accusations of being a liar.  It was a sad sight.

However, the Entergy measurements were correct.

But finally, the whole thing was over. The measurements were reviewed, and the Vermont Department of Health issued a final report on the boundary measurements. Here's a quote from the Vermont Department of Health report:

The report concludes that the measurement methodology used by the Vermont Department of Health since 1973 was less accurate than current methods used by Vermont Yankee.

And yes, here's another quote from the same report:

At no time has the dosage from the Vermont Yankee plant posed a measurable risk to public health.

Vermont Yankee was in compliance with Vermont's strict radiation protection laws.

ALARA strikes again


A great deal of money and energy was spent on the boundary-line dose issue, and nuclear opponents took every opportunity to humiliate people from Entergy about the measurements and the contractor.   But what did it all mean?  What was accomplished?

  • Was anybody protected from harm by these repeated measurements of the very small amounts of radiation? No. 
  • Was a great deal of money spent on these measurements? Yes
  • Do ALARA and LNT encourage the fear of the least little bit of radiation, and do they imply that we must constantly strive to reduce even tiny amounts of radiation? Yes.
  • Must we strive to reduce amounts of radiation that are actually so low they are hard to measure? Yes.
  • Do ALARA and LNT help our country have reliable, affordable electricity? No.


I encourage my readers to share their own ALARA stories.





Sunday, June 29, 2014

Tritium: An example of Unreasoning ALARA

Unreasoning ALARA: The need for examples

In Protecting Against Nothing: The Failings of ALARA, I described the ALARA strategy (As Low As Reasonably Achievable) for radiation safety.  This strategy is based upon the idea that there is no safe level of radiation, so radiation protection must constantly attempt to "do better."   The words "reasonably achievable" can be interpreted in unreasonable and expensive ways.

In contrast, protection from contaminants in drinking water is regulated on the basis of drinking water standards: concentrations of harmful substances are kept lower than agreed-upon values.  This is a better and more cost-effective strategy than the ever-more-expensive strategy of ALARA.

I would like to give some examples here. The need for examples was raised (in rather insulting phrasing) in a comment on an earlier post by Howard Shaffer. This is my understanding of what the questioner actually meant to ask:

"You have explained how ' reasonably' achievable could be misused in a regulatory context.  But can you give examples of where ALARA has actually been misused, examples of where excessive radiation protection measures have led to unnecessary costs? I want examples of the supposed excess costs of ALARA in terms of day-to-day operations. This isn't a question about accident prevention costs."

In a few posts, I will describe examples of the unreasonable costs of ALARA at Vermont Yankee.  These are cases in which Vermont Yankee had to go to great expense about radiation protection or paying for elaborate radiation measurements---for trivial amounts of radiation. The levels of radiation had no possible public health consequences.

Today's example: tritium.

Tritium and the Zero-Discharge Plant

Vermont Yankee is a zero-discharge plant.  No tritium must leave the plant boundaries. Why is this?  There is nothing wrong with small discharges of tritium. Canadian plants legally release thousands of curies of tritium per year.

So, Vermont Yankee had a leak in a pipe. The pipe was in a concrete conduit, but eventually, some tritium found its way out of the conduit and into the soil and water.

The small leak was a huge problem for the plant. It cost the plant a great deal of trouble and expense to find, fix and "remediate" this leak, even though the leak released less than a curie of tritium. Meanwhile, the plant gathered a great deal of negative publicity for having had the leak.

In contrast, exit signs containing about ten curies of tritium can be shipped through the mail (or at least they could be at the time that Howard Shaffer bought his tritium sign about three years ago).

In further contrast, Canadian plants are allowed to discharge thousands of curies of tritium per year.  There are no health effects in Canada from these discharges.

Though I posted extensively on tritium, Rod Adams has the best post on the subject. 
http://atomicinsights.com/how-much-tritium-leaked-from-vermont-yankee-before-the-leak-was-stopped/

Adams compares the Vermont Yankee leak with the tritium levels just north of the border.  Vermont Yankee's leak was less than one curie of tritium, while Canadian plants routinely discharge over 5000 curies of tritium a year.

Remediation 


Vermont Yankee found and fixed the leak within a few weeks.

Then,  Vermont Yankee began "remediation."  They pumped groundwater and disposed of it as radiologically contaminated. By doing so, they captured most of the tritium.

Meanwhile, famous hydrological engineers (such as Governor Shumlin) asked Vermont Yankee to pump even more groundwater, for further safety.  Vermont Yankee agreed to pump more.  I don't know how much they spent on pumping, but I suspect the amount was non-trivial.

All for less tritium than is held by a single exit sign.

ALARA Plumbs Some New Depths

As low as reasonably achievable reached some new depths with the great Vermont Yankee tritium scare story.  Of course, a plant should fix a leak if it has one.  Even if nothing but super-pure water is leaking, you fix leaks.  But the remediation?  All the pumping? Large amounts of money and time were devoted to protecting the public from---trivial amounts of radioactivity.

It is often thus with ALARA.  More to follow.

Thursday, June 26, 2014

Protecting Against Nothing: The Failings of ALARA

Partial list of EPA drinking water regulations
ALARA and Reason

In Howard Shaffer's recent guest post: "No Safe Dose" Is Bad Science,  Shaffer described the questionable science behind the Linear Non Threshold (LNT) standard for radiation protection.  In my introductory remarks for his post, I wrote this sentence:


"Protecting" against very low levels of radiation increases the cost of nuclear plants, but the LNT (Linear Non Threshold) model says we must protect against any level of radiation, no matter how small.

An anonymous commenter asked a question about this statement.  He didn't ask directly about LNT.  He asked about LNT's daughter:  ALARA (As Low As Reasonably Achievable). LNT claims that no radiation dose is safe,  and ALARA claims that we must continually attempt to decrease the amount of any radiation dose.

So, back to the commenter's question.   I had claimed that LNT forces us to protect against "any level of radiation," and he asked:

How would you reconcile that statement with the actual U.S. regulatory regime, which relies on the As Low As Reasonably Achievable approach? (Emphasis in the original statement.)

Mineral Water
"Reasonable" is Unreasonable

My answer (edited a bit from the original that I posted).

The term "reasonable" is intrinsically unreasonable. How is reasonable defined? By whom is it defined?

Here's a simplified example of the difference between "reasonable" levels and a threshold level. My town water meets threshold limits for safety. My town provides town water and it sends residents the analysis results for their water. I am proud to say that our town has an excellent municipal water department. The water is safe to drink: all ions and all contaminants are below the EPA levels that define safety for those materials. 

Let's say the EPA safety limit for "A" is 10 parts per million (ppm).  Let's say, in the town water, "A" is at the level of 5 ppm. 

The water is safe. 

Town water and threshold limits

The water is safe, and people can't go to the town select board and insist that new water treatment methods are available and therefore must be acquired by the town.  They can't insist that the town needs to lower the level of "A" from half the EPA safety limit to a quarter of the limit. People can't force the town to upgrade its water system just because those people believe that the new lower limit is "reasonably" achievable. Once the  town water has met  its threshold for safety, further water treatment is not required.

That's the difference between a threshold level--and the unreasonable term "reasonable." 
  • A threshold is a number. A system (water supply, power plant) can do a measurement and prove that it meets the criteria. 
  • In contrast, the term "reasonable" is open to endless expensive interpretations.

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Note: The commenter then asked a second question.  I will answer it in a separate post.