Elsewhere at some point(s) since the start of the Fukushima Dai-ichi crisis, I have made statements indicating that the nuclear regulatory infrastructure of Japan and France were something this country should emulate. I was wrong, and very wrong in the case of Japan. Stoneleigh, one of the semi-pseudonymous proprietors of The Automatic Earth, a doomer-ish economy-oriented blog, has put together an excellent, detailed post on the culture of the Japanese nuclear industry. It is not flattering. And, in retrospect, it is not surprising, either. Japan's yin-yang of cohesiveness and crushing conformity are well know, as are the troubles at the MONJU experimental sodium-cooled fast reactor. Some of the other incidents I was not aware of, but I nonetheless should have been more cynical about Japan's nuclear industry.
As with Japan, the French nuclear industry doesn't look so wonderful when examined in detail. Mycle Schneider, an independent consultant on nuclear policy, has authored a report entitled Nuclear Power in France: Beyond the Myth. In it he details the opaque and undemocratic nature of the nuclear power establishment in France. Fortunately for France and its neighbors, this has not resulted in a catastrophic accident like Fukushima, perhaps because the flip side of the arrogance of the elites that run the French program is in internal culture of technocratic excellence. But the lack of clear information does make monitoring the program difficult. The information deficit also makes an accurate tally of subsidies and costs impossible. While I disagree with some of Schneider's energy accounting, he does make a good argument that EdF, the monopoly electricity generator, has overbuilt nuclear generating capacity. This has distorted electricity pricing in France and neighboring countries.
If forced to pick between the two, given the available information, I would definitely choose the French nuclear power program over the Japanese one. I would also choose the American program over the Japanese. In a comparison between the American program and the French one, I think I would favor the French one... slightly. The US is more open than France, but the profit motive drives the numerous operators to a far greater degree than in France, which has led to a number of close calls. Ominously, the US regulatory structure is looking more and more like the Japanese one, with private companies able to dominate the relevant government agencies. This is a disturbing development. Of course, no regulatory framework is perfect, just as no nuclear plant is foolproof. The technology requires constant vigilance. The open question in the US is whether the NRC can re-assert itself to make sure safety is put before profit.