Proposed Revisions to Nuclear Plant Release/Public Exposure Regulations: ANS Response to EPA

By Jim Hopf

DC PerspectivesIn January, the U.S. Environmental Protection Agency issued an Advanced Notice of Proposed Rulemaking (ANPR) concerning 40 CFR 190—the regulations that govern public exposure and release of radioactive materials resulting from normal nuclear power plant operations (it does not pertain to nuclear accidents). The public comment period for the proposed rulemaking ended on August 3.

On August 1, the American Nuclear Society submitted a formal comment to the EPA. I also submitted a comment, personally.

EPA ANPR

In the ANPR, the EPA did not make any proposed changes to the regulations. Instead, the ANPR was a proactive solicitation of public input. The EPA asked if 10 CFR 90, which was issued in 1977, should be revised or updated. It also asked for public input on six specific issues or questions:

  1. Should the 40 CFR 190 public exposure limits be expressed in terms of (individual) dose or health risk?
  2. If dose limits are used, should the dose calculation methodologies be updated, and if so how?
  3. Should release limits for specific isotopes be retained (in addition to public dose limits) and should release limits be applied industry-wide or to individual facilities?
  4. Should a separate groundwater standard be added?
  5. Should specific rules pertaining to spent fuel and waste storage be added?
  6. Should revised or new standards be added to address new or emerging technologies (such as new reactor types or fuel cycle technologies)?

Details about the ANPR in general can be found in the EPA notice. More details about the six issues that the EPA sought public comment on can be found in this EPA slide presentation. Also, more information can be found in a July 15 ANS Cafe post by Rod Adams on the EPA ANPR.

ANS response

ANS submitted a response to the ANPR in an August 1 letter. ANS made some general comments, as well as specific comments on each of the six issues listed above. ANS’s responses are summarized below:

General

ANS stated that the EPA should move forward with a comprehensive rewrite of 40 CFR 190, due to the substantial advances that have occurred since 1977 in the understanding of the health effects of ionizing radiation, particularly in the area of low-level exposure.

ANS also stated that other things have changed, since 1977, with respect to the overall environmental and health context that applies to radiation standards. Public doses from air travel and medical procedures have increased dramatically since then (with medical procedures alone increasing the average public exposure to ionizing radiation by 200 mrem/year), and no detectable public health impacts have resulted from that increase in exposure. Also, as the negative public health and environmental impacts from fossil-fueled power generation have become more clear, there is more of as consensus that nuclear power has significant environmental benefits that may offset any negative impacts from public radiation exposures.

ANS also stated that while 40 CFR 190 specifically applies to the nuclear power industry, the risk modeling methodologies that form the bases of any requirements or limits should be consistent with those used to regulate other (non-nuclear-industry) sources of public radiation exposure.

Issue 1

ANS stated that an individual, total effective dose limit should be applied, as opposed to any kind of health risk limit.

Issue 2

ANS stated that dosimetry methodologies should be based on “effective dose” and urged the EPA to use standards and methodologies that are consistent with other agencies, such as the U.S. Nuclear Regulatory Commission. ANS also suggested using the effective dose definition used in ICRP Publication 103 (in its response to Issue 1), that document being one of the methodologies suggested by the EPA in its Issue 2 question.

Issue 3

ANS strongly recommended that the EPA revise 40 CFR 190 to discard any radionuclide release limits, as they are “duplicative, unnecessary and inconsistent with international practice.” ANS stated that limits on overall individual dose are sufficient to protect public health.

The reason for the radionuclide release limits currently in 40 CFR 190 was that in 1977, large-scale reprocessing was anticipated and there were concerns about long-term buildup (in the environment) from routine radionuclide releases from reprocessing facilities. This issue is far less significant now, given that the United States has not pursued reprocessing. The limits were also based on an extreme application of the linear no-threshold (LNT) theory, with very small doses to very large populations being used to predict significant health impact—something that is now considered questionable scientific practice by most experts.

Issue 4

ANS argued against having any separate regulations or dose criteria for specific public exposure pathways, such as a separate groundwater standard. Instead, limiting total effective dose to an individual, from all pathways, is the best approach for protecting public health.

Issue 5

ANS stated that there should be no specific EPA regulations related to storage of spent fuel and other forms of radioactive waste. Spent fuel and waste storage operations are already rigorously regulated and monitored by the NRC, making EPA involvement unnecessary. Any releases into the environment from storage operations would be covered by limits on overall public exposure (from all nuclear plant operations).

Issue 6

With respect to potential new reactor and/or fuel cycle technologies, ANS reiterated its position that limits on overall exposure (total effective dose) for individual members of the public is the most rational and effective approach for protecting public health. After all, any health impacts will be a function of dose, regardless of the source of that dose. It is clear than any limits on public exposure should be technology-neutral.

My own response

I submitted my own response to the EPA ANPR. My response concurred with ANS positions, and made many of the same points, with a few exceptions.

It is clear that any limits should be on public exposure (dose), and regulations should not distinguish between specific isotopes, pathways, or technologies. While there may be some disagreement over the health risk from a given amount of radiation exposure (rem), there is almost complete agreement that any health impacts from radiation are solely a function of dose (in the case of long-term exposure, at least). The science of dose determination is very well-developed, with the radiological and biological half-lives, and the chemical/biological behavior of various isotopes within the body, being fully accounted for in dose calculations. Dose is dose.

Therefore, it is clear that it is dose, and only dose, that should be controlled. To support the determination of any isotope-specific release limits, the EPA would have to do extensive pathway calculations to equate a given release (of a given isotope) with some predicted dose to a member of the public. That would be duplicative, as plant operators are already required to perform extensive environmental monitoring around the plant sites. This is necessary to determine public doses to comply with EPA and NRC public dose limits. Also, how would any EPA analyses account for differences between various sites (whereas plant operator monitoring and dose calculations are already site-specific)? Limiting dose, as opposed to releases of specific isotopes, maximizes flexibility and places the focus where it should be, i.e., on controlling the maximum overall exposure to members of the public.

As for long-term environmental buildup being a justification for isotope-specific release limits, it seems to me that this problem would be a uniquely small one for the nuclear industry, given the fact that radionuclides decay away (with most of the significant isotopes having relatively short half-lives). Meanwhile, other industries, whose pollutants often do not decay away at all, don’t seem to be asked the same questions (mercury from coal plant emissions being one possible example). Instead, the focus seems to be based solely on immediate (present day) health impacts from their pollution, as determined by various epidemiological studies. In the context of Issue 3, I asked the EPA why this question is seemingly only being asked of the nuclear industry.

Where I differed from ANS

While I agree that any regulations should be based on dose, I didn’t entirely agree with ANS’s position that limits should be placed on individual dose (to some most-exposed member of the public). To be fair, the EPA essentially asked responders to choose between a limit on individual dose or a limit on allowable individual health risk. Given that choice, I would pick a limit on dose, as did ANS. However, I also recommended different, even better, bases for regulations, which were not suggested by the EPA.

Limits on collective dose

Many nuclear professionals believe that repudiating the LNT theory (on low-level exposure health effects) would be key to rationalizing dose (or release) regulations. I’ve often argued that all we need to do is point out that LNT is being selectively applied (to the nuclear power/weapons industry only).

Current public individual dose limits are determined by using LNT to argue that there is some health risk even at very low doses, and then applying an absurdly low limit on allowable health risk (e.g., a 10-4 or 10-6 lifetime cancer risk). This process results in very low limits on individual exposure, that are only applied to nuclear industry related exposures. Much larger doses from other sources, such as natural background, radon, medical, and air travel are simply ignored (not regulated).

The problem with this “logic” is that if you assume LNT, and that the dose response is truly linear all the way down to zero, it then follows (purely mathematically) that total health impact (i.e., cancers or deaths) scale directly with collective exposure, in man-Rem. As I argued to the EPA, the concept of limiting maximum individual risk is not even meaningful. At the end of the day, you either die (from radiation-induced disease) or you don’t, and the number of deaths (which is what you’re really trying to avoid) scales directly with collective exposure (man-Rem). Thus, it is hard to justify placing limits on exposure to a (most exposed) individual, as opposed to limiting overall collective public exposure. The only downside to limits on collective exposure is that it may be somewhat harder to determine (or estimate) than maximum individual exposures.

Limits in individual exposure, as opposed to collective exposure, work against nuclear, since any pollution that nuclear plants release (under normal operations or in an accident) tends to stay localized, whereas many forms of pollution from many other industries drift far and wide. I believe that this is one reason why nuclear plant limits are a small fraction of natural background (far too small to have any measurable public health impact) while fossil fuel generators are still allowed to cause ~10,000 deaths in the United States annually (according to the EPA itself).

Also, the other sources of radiation exposure I listed earlier affect most or all the U.S. population, whereas any nuclear plant releases would affect only a handful of local residents. This results in differences in collective exposure that are even more vast than the differences in individual exposure (between nuclear power sources and other sources). The collective exposure that U.S. residents get annually from radon is far larger than the total public collective exposure that will result from the Fukushima accident, yet nothing is done about it. Such exposures are unregulated. Public exposures from U.S. nuclear plants, under normal operation, are about a million times smaller than the public exposures from these other, unregulated sources.

Based on the above reasoning, I asked the EPA to consider limiting collective public exposure from U.S. nuclear plants, as opposed to limiting the exposure to a maximally exposed individual. I also asked the EPA to put any proposed limits on collective exposure in the context of the collective exposures the U.S. public gets from other sources. I essentially asked how they could apply strict controls limiting nuclear operations to tiny public collective exposures while completely ignoring other sources of collective exposure that are a million times larger.

Cost-benefit analysis

The EPA currently performs cost-benefit analyses to justify most of its proposed regulations in most industries. In fact, the EPA even uses a published dollars-per-life-saved figure of ~$10 million per life as the basis for its regulations. This makes sense (to me) as the basis for any regulations, as one shouldn’t arbitrarily apply limits on doses, or health risks, regardless of the cost. Such policies allow society’s limited public health and safety resources to be applied where they will have the most impact.

Thus, I suggested to the EPA that they go one step further than limiting collective public exposures (man-Rem). I suggested that the best policy of all would be to establish a criterion for how much plant operators should have to spend per public man-Rem avoided. This would be similar to industry ALARA (As Low As Reasonably Achievable) policies currently in place for limiting exposures to plant personnel. If the EPA does not want to leave it up to operators to perform such cost estimates, then, at a minimum, the EPA should keep the $10-million-per-life-saved criterion in mind when determining limits on public collective exposures from plant operations. $10 million per life saved corresponds to a spending requirement of ~$4,000 per man-Rem avoided (based on current LNT estimates of one death per ~2,500 man-Rem). The EPA could consider industry input when determining what limits on public collective exposure would correspond to a cost of ~$4,000 per man-Rem.

I also (again) asked the EPA why nothing at all is being spent to reduce all the other, vastly larger sources of public collective exposure, and inquired about what other practices it should mandate (e.g., radon abatement) that could be performed for $4,000/man-Rem or less.

Distinction between different sources of exposure

ANS alluded to how nuclear industry–related sources of public exposure are treated differently than non-nuclear industry sources when it said that “the risk modeling methodologies that underlie them must be consistent with those used in EPA’s regulatory involvement (or lack thereof) pertaining to all other pathways of public exposure to ionizing radiation.”

I was more direct. I stated that “with the possible exception of medical exposures (that have an offsetting health benefit), all public exposures should be treated equally by regulations, regardless of source.”

It is indefensible to arbitrarily apply strict regulations to some sources of public exposure while ignoring much larger sources of public (collective) exposure. Given this fact, dose limits that are a small fraction of natural background (which ranges up to ~1,000 mrem/year in many places) are hard to justify. When considering collective (as opposed to maximum individual) exposures, strict limits on localized exposures in the vicinity of a nuclear plant are even harder to justify.

Although it is outside the scope of 10 CFR 190, this argument is even more important with respect to setting exposure limits in the event of nuclear accidents. Given the relatively small number of affected people (on the order of 100,000, based on the Fukushima experience), the assumption of LNT should allow individual exposure limits of several Rem/year, as that would still result in overall collective exposures that are smaller than those received routinely by the overall population. Expensive cleanup operations (e.g., to get doses down to 100 mrem/year, as Japan is considering) are hard to justify, given that far larger reductions in overall public collective exposure could be achieved at far lower cost in other areas (such as radon abatement or reducing unnecessary medical exposures).

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Hopf

Hopf

Jim Hopf is a senior nuclear engineer with more than 20 years of experience in shielding and criticality analysis and design for spent fuel dry storage and transportation systems. He has been involved in nuclear advocacy for 10+ years, and is a member of the ANS Public Information Committee. He is a regular contributor to the ANS Nuclear Cafe.

Nuclear Energy Blog Carnival 222

ferris wheel 202x201The 222nd edition of the Carnival of Nuclear Bloggers and Authors has been posted at Atomic Insights.  You can click here to access the latest installment in a long running tradition among pro-nuclear authors and bloggers.

Each week, a new edition of the Carnival is hosted at one of the top English-language nuclear blogs. This rotating feature of nuclear “posts of the week” represents the dedication of those who are working toward a future of energy abundance, improved health, and broadened security through nuclear science and technology.

Past editions of the carnival have been hosted at Yes Vermont Yankee, Atomic Power Review, ANS Nuclear Cafe, NEI Nuclear Notes, Next Big Future, Atomic Insights, Hiroshima Syndrome, Things Worse Than Nuclear Power, EntrepreNuke, Thorium MSR and Deregulate the Atom.

This is a great collaborative effort that deserves your support.  If you have a pro-nuclear energy blog and would like to host an edition of the carnival, please contact Brain Wang at Next Big Future to get on the rotation.

Why TVA Is Completing Watts Bar 2

Got a minute (and 22 seconds)? Catch a quick update on the first new commercial nuclear energy in the United States of the 21st century—in Tennessee.

Mike Skaggs, the Tennessee Valley Authority’s senior vice president for Watts Bar Operations  and Construction, explains how and why Watts Bar Unit 2 will be completed. Watts Bar-2 is scheduled to come online at the end of 2015, and will make nuclear energy a full 40 percent of TVA’s electrical generation. (Much more on Watts Bar-2 here, and more Watts Bar videos at ANS Nuclear Cafe here.)

Thanks to Nuclear Energy Institute Network for sharing this video.

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The Final Entrant – Last Nuclear Utility in Japan Applies for Restart

Shika NPP Unit 2.  Courtesy Hokuriku Electric Power Co.

Shika NPP Unit 2. Courtesy Hokuriku Electric Power Co.

by Will Davis

Yesterday, the saga of nuclear energy in post-Fukushima Japan reached an important milestone as the final utility that owns nuclear power plants in that country applied to the regulator for restart, in an event that snuck under the radar of most news venues.

Hokuriku Electric Power Company yesterday submitted its application to have Shika Nuclear Power Plant Unit 2 examined by the Nuclear Regulation Authority under the revised guidelines for nuclear plant safety. Hokuriku owns only one nuclear power station, Shika, which has two units; Unit 1 is a BWR-5, while Unit 2 is an ABWR that went into commercial operation in March 2006. This application for Unit 2 means a number of things; it marks the end of the final holdout, if you will, by a nuclear utility; it shows that all utilities with nuclear plants will attempt to restart at least one unit; and it answers the question once and for all whether the Japanese utilities unanimously want to continue to include nuclear in their fuel mixes for the future.

Hokuriku has stated that work at the site (which mirrors heavy site work underway at most nuclear plants in post-Fukushima Japan) is not yet complete and that it does not have a specific restart date for this nuclear plant.

Shika Unit 2 had some press before this; this plant, along with Chubu Electric Power Company’s Hamaoka Unit 5, made some notoriety in 2006 when both were shut down for some time due to turbine generator problems. Hamaoka-5 shut down first in June 2006, actually on a turbine trip due to high vibration; this was quickly discovered to be a result of broken blades in the “B” or center (of three) of the low pressure turbines on its Hitachi TC6F-52 turbine generator. Because Shika Unit 2 had the same model turbine generator, it was ordered shut down in July 2006 for inspection; this revealed similar, if not as extensive, damage.

Hitachi paid for repairs to the Hamaoka and Shika turbine generators; the Hamaoka unit was back on-line in February 2007, eight months after the event. Shika Unit 2 however was saddled with a reduced power rating, and was also delayed in its restart while NISA (the former nuclear regulator) dealt with systemic problems at the site. Shika Unit 2 finally restarted in June 2008, rated at 1108 MWe instead of its original designed 1358 MWe. Hokuriku detailed plans to modify the turbine in 2010 and return the plant to its original full rating, but the only increase allowed was to 1206 MWe, which is where the official plant rating lies at the moment according to Nuclear Regulation Authority records. Hitachi has since modified its designs to eliminate the problems that originally caused these failures, which have not recurred in any other Hitachi turbine generators.

The restart applications, as they came

It is now appropriate to briefly detail the nuclear plant restart applications in a neat bunch as we find ourselves at a convenient historical point from which to look back.

The initial applications for restart actually came in a rush; on July 8, 2013, four utilities applied for restart examination for no fewer than 10 reactors at five sites. Quite interestingly, all of these were Mitsubishi pressurized water reactors); their ages varied, with commercial operation starting dates ranging from 1984 to 2009, in two, three, and four loop configurations. These were Hokkaido Electric Power’s Tomari NPP Units 1, 2 and 3; Kansai Electric Power’s Ohi NPP Units 3 and 4 and Takahama NPP Units 3 and 4; Shikoku Electric Power’s Ikata Unit 3; and Kyushu Electric Power’s Sendai Units 1 and 2.

Just four days later on July 12, 2013, Kyushu Electric Power also applied for its Genkai NPP Units 3 and 4. These are also Mitsubishi PWR plants.

As had long been expected, on September 27, 2013, Tokyo Electric Power applied to restart two units at its massive Kashiwazaki-Kariwa NPP—and these, Units 6 and 7, were the first boiling water reactors of any kind to apply to restart. These units are Hitachi-GE-Toshiba ABWRs, and are the newest TEPCO nuclear units.

Chugoku Electric Power applied to restart Shimane NPP Unit 2, a Hitachi BWR-5, on December 25, 2013. Two days later on December 27th, Tohoku Electric Power applied to restart Onagawa NPP Unit 2—another BWR-5, but of Toshiba heritage.

The first application of 2014 was February 14, when Chubu Electric Power applied to restart Hamaoka Unit 4, a Toshiba-Hitachi BWR-5.

Japan Atomic Power Company (JAPC) applied to restart its Tokai Daini NPP, a GE BWR-5, on May 20, 2014. With a commercial operation date in November 1978, this is by far the oldest reactor applied for restart in Japan; the next closest date is Sendai Unit 1, commercially operational in 1984.

It was June before another application was made; on the 10th, Tohoku Electric Power applied to restart Higashidori 1, a BWR-5 of rather recent vintage, having entered commercial service in 2005.

And, of course, as we now know Shika Unit 2 applied yesterday (August 12, 2014,) marking only the third ABWR to apply for restart.

In total, the restart applications include 12 Mitsubishi PWRs, three ABWRs, and a total of five BWR-5 reactors of various heritage, making 20 reactors overall.

Hamaoka NPP: Courtesy Chubu Electric Power Co.

Hamaoka NPP: Courtesy Chubu Electric Power Co.

Kashiwazaki-Kariwa (TEPCO, two units applied), Tomari (Hokkaido, three units), Shika (Hokuriku, one unit applied), Shimane (Chugoku, one unit applied), Ikata (Shikoku, one unit applied), Takahama and Oi (both Kansai, four units total), and Genkai and Sendai (both Kyushu, four units applied) are on the West coast of Japan or on coasts facing west, making a total of 16 of the 20 units that are not subjected to future tsunami from the same fault that triggered the Great East Japan/Tohoku Earthquake and Tsunami. The majority of these 16 units (12) are the Mitsubishi PWR units; three more of these 16 units are the ABWRs applied for restart.

The results of these restart applications are, of course, expected to be an exceedingly mixed bag. Anti-nuclear court rulings, mistrust among prefectural governments, environmental groups, and anti-nuclear activists are already having a major impact on the processes to restart the nuclear plants. It is certain that we will look back on this historical point as a mere footnote; the hard work of both preparing the plants for future events and regaining the public trust all lies mainly ahead, and it is likely to take many years to bottle those results as conveniently as we bottle the applications here.

For more information:

Japanese Utilities Lining Up to Restart Reactors

Preparing to Restart:  Tsunami Safety Measures at Japanese Nuclear Power Plants

Japan’s Nuclear Restarts:  Abe says “Will See To It;” Courts Differ; Plants Prepare

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WillDavisNewBioPicWill Davis is the Communications Director for the N/S Savannah Association, Inc. where he also serves as historian, newsletter editor and member of the board of directors. Davis has recently been engaged by the Global America Business Institute as a consultant.  He is also a consultant to, and writer for, the American Nuclear Society; an active ANS member, he is serving on the ANS Communications Committee 2013–2016. In addition, he is a contributing author for Fuel Cycle Week, and writes his own popular blog Atomic Power Review. Davis is a former US Navy reactor operator, qualified on S8G and S5W plants.

The Latest Sop to Nuclear Opponents

By Howard Shaffer

viewfromVermontVermont Yankee will go into decommissioning at the end of its current fuel cycle. The last day of operation for the nuclear plant is now set for December 29, 2014. Entergy, the owner, elected this course last year after financial analysis indicated the plant’s unprofitability in a future of projected low natural gas prices.

Yet, in the first year after the end of Vermont Yankee’s original 40-year license, natural gas prices and the market price of electricity in the region were so high that the plant remitted $17 million to the state from power sales above 6.1 cents per kilowatt-hour under the terms of its 2002 purchase agreement.

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Vermont legislature

Nuclear opponents have great influence and support in the Vermont legislature and governor’s office. With plant operation ending, there needed to be a mechanism to keep the anti-nuclear crusade going.

The new panel

The legislature created a new panel—the Nuclear Decommissioning Citizens Advisory Panel—to provide representation for nuclear opponents and to set up a new means to access information from the plant. The new panel replaced the Vermont State Nuclear Advisory Panel (VSNAP), which previously had received information from the plant at public meetings, via oral testimony, and public comments and questions. VSNAP had one public member, with the remainder members coming from the legislature and state agencies.

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Vermont State Nuclear Advisory Panel

At the end of the legislative session, the legislature created a new panel by writing it into the budget bill (H885). This new panel, which is advisory only, was created to:

  • Discuss issues related to the decommissioning.
  • Advise the governor, the General Assembly, state agencies, and the public on decommissioning issues.
  • Serve as a conduit for public information.
  • Receive reports on the decommissioning trust fund and other funds.
  • Receive reports on decommissioning; provide a forum for public comments and comment to state agencies and the plant owner

Meetings and an annual report are specified.

The panel consists of 19 members:

  • Four state officials.
  • Two state legislators.
  • Two local government representatives.
  • Six members of the public appointed by the legislature.
  • Two representatives of the plant.
  • One representative of the International Brotherhood of Electrical Workers.
  • Two representatives of adjacent states in the plant’s 10-mile emergency planning zone (EPZ), representing towns in New Hampshire and Vermont, appointed by the states’ governors.

Since the end of the legislative session there has been no further mention of the panel in public sources.

The composition of this new panel, as well as being larger than the one it replaces, is a radical departure from the old one. It includes representatives of the plant, the union, the towns in the EPZ, and several representatives from the public. Including the union is parallel to the practice in Germany of including unions on corporate boards of directors. This is not surprising, since at least one former member of the legislature, now a member of the Vermont Public Service Board, is an advocate of the German approach to energy management.

What will the panel bring?

The previous panel’s meetings were all public and attended by opponents and advocates, myself included. They were contentious but mostly one-sided. The plant was in the position of being a witness to be cross-examined. There was no appeal to the panel’s findings. The meetings were covered in detail by the regional press. The panel, in effect, became a vehicle for anti-nuclear publicity.

The new panel has plant and union representation, so their opinions will be official components of panel deliberation, not testimony from witnesses. The new panel must meet and report periodically. The reports’ format has not been specified, but it is logical to assume that minority opinions will be included, as is the usual government practice.

It is possible that if the previous panel had officially included pro-nuclear voices, the information reaching the public might have been more balanced.

The adjacent states

Governors Hassan (NH) and Patrick (MA)

Governors Hassan (NH) and Patrick (MA)

There are five towns in New Hampshire and seven in Massachusetts that will be represented by a governor’s appointee. As of this writing, there has been no word as to whether the governors have yet been invited by Vermont to make the appointments. The governors will need to determine the process they will use to make these appointments. Since there are pro- and anti-nuclear advocates in all places, the selection process may be difficult. It is possible the governors might ask the selectmen in these 12 towns, which use a town meeting form of government, to recommend a process. This would seem logical, since it would pass the “hot potato” to the towns. If the towns wind up deadlocked, a governor might end up appointing someone from a state government agency. Or, they might choose a qualified state resident from outside the towns.

Keeping engaged

As a New Hampshire resident, and considering myself qualified, I applied for the New Hampshire state position on the Vermont panel. When I applied in June, the governor’s appointments assistant had not heard of this position, nor heard anything from Vermont. With an election coming up in November, including for governor in both Vermont and New Hampshire (two year terms), and with the plant operating until the end of 2014, perhaps it’s not surprising that this issue is far down on their agendas.

I also sent a letter to the selectmen in all five New Hampshire towns, with a copy of the application to the governor.

We’ll see.

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Shaffer

Shaffer

Howard Shaffer has been an ANS member for 35 years.  He has contributed to ASME and ANS Standards committees, ANS committees, national meeting staffs, his local section, and was the 2001 ANS Congressional Fellow. He is a former member of the ANS Public Information Committee, consults in nuclear public outreach, and is coordinator of the Vermont Grassroots Project.  Shaffer holds a BSEE from Duke University and an MSNE from MIT. He is a regular contributor to the ANS Nuclear Cafe.

Nuclear Energy Blog Carnival 221

ferris wheel 202x201It’s time for the 221st edition of the Carnival of Nuclear Bloggers and Authors.  This event circulates among the top pro-nuclear blogs, and each week highlights those items submitted to the host as most important or most timely.  Of course, every week, there is a post made right here at ANS Nuclear Cafe to direct you to the Carnival – but on a rotating basis we host it here, and this week is one of those occasions.  Let’s go in!

Forbes – Jim Conca

Extinction by Traditional Chinese Medicine

An epidemic of poaching is sweeping over Africa, paid for by Chinese and other Asians, fueled by the growing energy production from coal.  Caught up in this frenzy of rituals are animals like the rhinoceros, which may not be long for the world.

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Nuke Power Talk – Gail Marcus

Energy Policy and Disruption: Managing Change

This week, Gail Marcus follows up on a previous post about the impacts of the evolution of energy technologies and takes the discussion a few steps further.  In addition to the always present tendency to protect existing jobs, she points to a study by the US Energy Information Administration (EIA) that shows that mining and related activities are a significant part of the economies of several states in the US.  She notes that this fact creates an additional dimension to the problem – it’s not just replacing one job with another one if the jobs are in different places – and comments on how states might proactively face such changes.

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NewsOK – Robert Hayes

Radioactive Materials in the Oilfield

Oilfield work involves long hours and back-breaking work.  It also involves radioactive material in many ways, including natural radioactivity and man-made radionuclides used in a number of specific ways.

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Yes Vermont Yankee – Meredith Angwin / guest post by George Coppenrath

New England Energy: What were they thinking?

George Coppenrath, a Vermont state senator who served on the Natural Resources and Energy Committee, wrote this guest post.  He wonders what Vermont energy planners were thinking; did they think that closing Vermont Yankee would push energy production to wind and solar?  Did they think natural gas would be inexpensive forever? It looks like they were wrong.

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NEI Nuclear Notes – submitted by Eric McErlain (various authors)

US Technology Exports and Africa:  A delegation from Niger, South Africa and Namibia visited NEI on August 7th to see how peaceful commercial nuclear technology could be exported to those countries.

In a Pit in a Nuclear Free Vermont:  A series of bad choices when it comes to energy policy has led Vermont down a blind alley.

Transatomic Power snags $2 million Investment:  The Founders Fund, a group that provided seed money for Facebook and other Silicon Valley start-ups, has made a $2 million investment in Transatomic Power.

What It Takes to Become an Operations Shift Manager:  Megan Wilson at PG&E talks about what it takes to move up the ladder at California’s only nuclear plant.

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Next Big Future – Brian Wang

India needs to expand nuclear; HTGR in works

India needs to both expand its power system to serve 300 million people, as well as move away from coal fired generation assets.  Nuclear power would, potentially, grow 15 times faster here than other assets.  Also, a piece on shared development of HTGR’s between Japan and Indonesia.

Cameco on track; Cameco’s production target not impacted by process changes.

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Atomic Insights – Rod Adams (guest post by Bill Sacks / Greg Myerson)

Why Does Conventional Wisdom Ignore Hormesis?

In light of repeated assertions that all ionizing radiation is harmful no matter how high or how low the dose, the existence of a beneficial health effect may be surprising.  But nearly a century of laboratory experimentation and epidemiological observation of both humans and animals supports the protective response region and contradicts the conventional wisdom.  Why then does the concept that all ionizing radiation is harmful hang on with such tenacity, and how did it gain a foothold against all evidence to the contrary?

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The Hiroshima Syndrome – Les Corrice

Did Fukushima Daiichi Unit 3 have a “melt through?”

TEPCO says the Unit 3 core may have completely melted and most of it might be embedded in the basemat under the reactor.  The company cautions that their analysis “entails some degree of uncertainty.”  Their degree of uncertainty might be substantial.

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Canadian Energy Issues – Steve Aplin

Fighting darkness and steel with carbide, and carbon with nuclear energy; Canada’s revolutionary past, present and future

What does calcium carbide have to do with nuclear energy?  Steve Aplin of Canadian Energy Issues remembers his spelunking days and their connection to the Second Industrial Revolution.

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That’s it for this week’s entries!  Thanks to all of our submitters, and authors.

Nuclear Matinee: Heavy Lifting at V.C. Summer

Heavy lifts equal heavy progress at the construction site of V.C. Summer-2 and -3 in South Carolina. Following is the latest update on recent major milestones completed at what will be the first new commercial nuclear energy reactors in the United States in 30 years.

Earlier this summer CNBC paid a visit to V.C. Summer and featured the plant and its workers—see CNBC’s Where the Jobs Are: The New Nuclear Generation at V.C. Summer.

Thanks to SCE&G Nuclear YouTube for sharing this video update.

ca20 module lift vc summer

Correcting History Can Be an Uphill Battle

By Rod Adams

In April 2014, ANS Nuclear Cafe published a valuable historical account and analysis of the Three Mile Island accident titled TMI operators did what they were trained to do.

As author Mike Derivan explained in great detail, the operators on duty at TMI-2 during the early morning hours of March 28, 1979, took exactly the actions that they were trained to take when provided indications of low primary plant pressure, combined with pressurizer water level indication that was “pegged high.” That level indicator told operators that the pressurizer was full of water. There were no other direct indications of water level provided.

Derivan has a unique perspective on this historical event; he was the shift supervisor on duty at the Davis Besse Nuclear Power Plant on September 24, 1977, when that plant experienced an event that was virtually identical to the event that initiated the TMI accident. Derivan and his crew initially responded like the crew at TMI; their indications were the same and both crews had been trained to make the same diagnosis and perform the same actions.

The primary reason that the event at Davis Besse turned out to be a historical footnote, while the event at TMI resulted in billions of dollars worth of equipment damage, world-wide attention, and changes throughout the nuclear industry, was that Derivan recognized that he had been trained to make a wrong diagnosis, which led to incorrect actions.

About 20 minutes after his event began, he took a new look at the symptoms his indications were describing and revised his overall diagnosis. That led him to recognize that his plant was experiencing a loss of coolant from the steam space of the pressurizer. He realized that the response of available indicators to that event was unlike the indicator response for loss-of-coolant accidents from any other part of the reactor coolant system. He directed his crew to shut the valves that isolated the stuck power-operated relief valve and to restore water flow from the high pressure injection system into the primary coolant system.

Derivan participated in the required post-event analysis and reporting, so he knew what the Nuclear Regulatory Commission and the plant vendor B&W were told. He was thus uniquely affected by the TMI accident, especially once technical explanations of the accident sequence were available. He spent a considerable amount of time during the subsequent 35 years reviewing the available reports on TMI, trying to understand why the lesson he and his crew had learned in September 1977 had not been absorbed by the operators at TMI.

His conclusion is that the operators never had a chance to absorb and incorporate the lessons he had learned because they were never told that his event happened and never informed how to revise their procedures and training to enable a safer response. Despite all the effort that was put into various commissions and internal lessons learned efforts (Kemeny, Rogovin, the NRC task force that wrote NUREG-0585, etc.), none of the documents clearly state that the specific root cause of the sequence of events that melted 25–40 percent of the fuel material at TMI-2 was that almost everyone associated with pressurized water reactor design and operation misunderstood how the system would respond to a leak in the steam space of the pressurizer.

Unlike any other leak location, a steam leak would provide indications of falling system pressure and rising indicated level in the pressurizer. Since designers, regulators, and trainers assumed that all loss-of-coolant accidents would cause both pressure and pressurizer level to fall, that is what the available training materials—including the computerized simulators—taught operators to expect.

From the start of the accident, operators at TMI were thus placed into a situation that almost no one expected; they did not have an emergency operating procedure to follow. They had strong warnings about not overfilling the pressurizer, so they stopped pumping water into the plant when the level indication showed that the pressurizer was already more full than it should be. That was not an error on their part; it was an error in system response understanding that carried through to all training materials and operating procedures.

It was also an error in processes for sharing operational experience; at the time, the NRC was the only agency that received all reports from operators, so it was the only one that could distribute those reports back out to others that might need the information.

Unfortunately for the hard-working people who chose to become plant operators, the court of public and industry opinion blamed “operator error” as a primary cause of the accident. An excerpt from the history page of the Professional Reactor Operator Society (PROS) provides an operator perspective on how this misapplied responsibility affected members of the elite community of commercial reactor operators.

Remember Three-Mile Island (TMI)? Even if you weren’t in the nuclear business in March of 1979, you couldn’t have missed all the references since. As markers for change go, the event itself will not soon be forgotten, but more important are the lessons learned on all fronts.

Life was not very pleasant for the nuclear plant operators in the early eighties. The Three Mile Island accident started a chain of reforms in the industry that to a large extent were directed at operators. The basis for change was reported to be that the accident was caused by operator error. That announcement was made to the public almost immediately after the accident began and, as the core was uncovering, every special interest group in the nuclear industry was racing to protect its image.

In the days that followed, a media picture of incompetence in the TMI control room emerged. As we operators picked up the bits and pieces of information, it became clear that the picture was somewhat distorted. The TMI operators were being held accountable for deficiencies that legions of engineers, designers, trainers, and regulators had failed to recognize. Operators everywhere began to imagine themselves in a similar situation and realized that the results would probably be the same.

During the next few years, the industry was deluged with solutions to the “problem” of operator incompetence. The solutions ranged from threats of jail sentences to mandatory college degrees for all nuclear power plant operators. Few thought it was necessary to ask operators what tools they needed to help them operate the plants.

In addition to writing his story for distribution and creating an informative website—Nuke Knews—with his collected wisdom about the TMI event, Derivan recently took one more step in his quest for an improved understanding of why TMI happened and who should bear the responsibility.

He wrote a letter to NRC Chairman Macfarlane asking her to remove “operator error” as the root cause of the accident. His letter and supporting documentation can be found in the NRC ADAMS document database with a search for accession number ML14167A165. The NRC’s official response was provided on July 21, 2014, by Thomas R. Wellock, the agency’s historian. It is available in the same place with accession number ML14197A635.

Here is a quote from that response letter:

… none of the five major investigations of the accident commissioned by the NRC, Congress, and President Jimmy Carter claimed that operator error was “the” root cause of the accident.

Virtually all of the studies I reviewed agree with your analysis that while the operators committed errors, the chief culprits behind the accident were industry-wide and regulatory flaws. These included a poor understanding of PWR plant response to loss-of-coolant accidents (LOCA), a failure to circulate information about several precursor events at plants in the United States and Europe, flawed operator training and plant procedures, and inadequate control-room design. While you argue that these reports implicitly blame the operators as a “default position,” my reading of them indicates they were careful to avoid such a conclusion, and some pointedly challenged the thesis that operator-error caused the accident.

It may be correct, as you argue, that more should have been made of the industry’s poor understanding of plant response during a LOCA in the pressurizer steam space, but as you know, the NRC and industry addressed this issue with numerous reforms in training, reporting requirements, and event analysis. In fact, learning from precursor events may be the most important history lesson from TMI. On the 25th anniversary of the accident, NRC Historian J. Samuel Walker published Three Mile Island: A Nuclear Crisis in Historical Perspective. The Davis-Besse event, Walker shows, was a critical missed lesson: “Neither Babcock and Wilcox nor the NRC had taken effective action to draw lessons from Davis-Besse or provide warnings to other plant operators that ‘could have prevented the accident’ at TMI-2.”

In sum, the official reports and NRC histories have been and continue to be in substantial agreement with your overall analysis as to the causes of the accident. Like you, they place the errors committed by the TMI operators in the context of general industry and regulatory failings regarding human factors.

That letter comes close to the pardon that Derivan is seeking, but it might have been better if he had asked for “operator error” to be removed as “a” root cause rather than as “the” root cause.

In the years since the accident, plant designers and regulators have made substantial improvements in their system understanding and in the processes that they use to share lessons learned and operating experience. However, it is still worthwhile to remind everyone, especially as newly designed systems and whole new technologies are introduced, that there is no replacement for a questioning attitude and careful incorporation of operating experience to enable continuous improvement.

There is a useful paragraph on page 2-3 of NUREG-0585 that can serve as a conclusion to remember:

In the Naval Nuclear Propulsion Program, Admiral Rickover has insisted that there be acceptance of personal responsibility throughout the program and that the designer, draftsman, or workman and their supervisor and managers are responsible for their work and, if a mistake is made, it is necessary that those responsible acknowledge it and take corrective action to prevent recurrence. This concept applies equally to the commercial nuclear power program, but it has not yet been achieved.

____________________________

Adams

Adams

Rod Adams is a nuclear advocate with extensive small nuclear plant operating experience. Adams is a former engineer officer, USS Von Steuben. He is the host and producer of The Atomic Show Podcast. Adams has been an ANS member since 2005. He writes about nuclear technology at his own blog, Atomic Insights.

 

tmi b&w 314x200

Nuclear Energy Blog Carnival 220

ferris wheel 202x201The 220th edition of the Carnival of Nuclear Bloggers and Authors has been posted at Next Big Future.  You can click here to access this latest installment of a long running tradition among pro-nuclear authors and bloggers.

Each week, a new edition of the Carnival is hosted at one of the top English-language nuclear blogs. This rotating feature of nuclear “posts of the week” represents the dedication of those who are working toward a future of energy abundance, improved health, and broadened security through nuclear science and technology.

Past editions of the carnival have been hosted at Yes Vermont Yankee, Atomic Power Review, ANS Nuclear Cafe, NEI Nuclear Notes, Next Big Future, Atomic Insights, Hiroshima Syndrome, Things Worse Than Nuclear Power, EntrepreNuke, Thorium MSR and Deregulate the Atom.

This is a great collaborative effort that deserves your support.  If you have a pro-nuclear energy blog and would like to host an edition of the carnival, please contact Brain Wang at Next Big Future to get on the rotation.

Japan Nuclear Restarts: Abe Says “Will See To It,” Courts Differ, Plants Prepare

By Will Davis

HamaokaChubuElectric“I will see to it by some means or other. I will properly deal with it.” So go the reported words of Japanese Prime Minister Shinzo Abe regarding the restart of nuclear power plants in Japan, as printed recently in the Japanese press. At the present time, while the Japanese government and courts seem to be at odds on restarting plants—with the public left in the middle—those at the nuclear plants themselves must count on eventual approval to restart and must ensure required measures are completed properly. Those preparing for restart continue to work toward that end while facing an improving, but not yet by any means certain, situation in the public and legal arenas.

Abe says yes, court says no

Those wishing for nuclear plant restarts in Japan, and especially power companies and large manufacturers (which consider their businesses in great peril), were bolstered by the continued support for nuclear restarts expressed by Abe, although it’s now becoming clear that a one-man fight isn’t what lies ahead. Abe’s recent statement, specifically about Sendai Nuclear Power Plant (NPP), comes on the heels of a public presentation to the Prime Minister of produce from the governor of Fukushima Prefecture—a sure sign that life indeed continues in the prefecture. That rosy picture of recovery stands opposed by courts, however.

Just last May, the Fukui Court issued an order to Kansai Electric barring the restart of reactors at the Oi NPP. The language of the order has more recently been translated into English, and the finding is troubling—the court basically saying that no person or establishment is capable of predicting the maximum severity and effect of prospective natural disasters; and that since the people of Japan generally derive their welfare and well-being from the land, it can be ruled illegal to operate nuclear plants that could in theory lead to the loss of the land and well-being of the people.

Residents in the immediate vicinity of Sendai NPP in Kagoshima Prefecture were this week issued iodine pills as part of a disaster preparedness plan, along with access to pharmacists who could answer questions, according to NHK World. One resident interviewed said that he indeed felt better because of this “ounce of prevention” approach. In some regions, public opinion appears to sway toward the return of nuclear energy, as utilities and prefectural governments make advance preparations and keep the public “in the loop.”

Preparing by building and training

KashiwazakiKariwaAs scenes of quite public debate continue, the utilities meanwhile have long recognized the need to restart their nuclear plants, if at all possible, to begin to recoup some of the massive losses they’re incurring—as a result of having to buy large amounts of fossil fuel and having to build temporary fossil-fired power plants to make up for the loss of generation from nuclear plants. And lest there be any doubt, overall power generation is still far, far short of what it had been with all nuclear plants available.

Some plants have experienced setbacks. This week, Shikoku Electric Power Company announed that its Ikata NPP would delay restarting by up to a year because its on-site emergency control center didn’t meet required revised seismic standards.

Others continue apace. We’ve reported here on the massive amount of time and money that Tokyo Electric Power Company (owner of Fukushima Daiichi) has put into its Kashiwazaki–Kariwa nuclear plant on the opposite coast of Japan; these safety measures continue with further massive construction. A recently published video displays the continued wide effort underway to meet all the required precautions and standards, and is worth viewing in its entirety for anyone interested in the preparations at nuclear plants in Japan:

Click here to watch the TEPCO Kashiwazaki-Kariwa video

Japan’s Nuclear Regulation Authority (NRA) released a report stating that the triggering event for the Fukushima Daiichi nuclear accident was in fact the tsunami, and not the earthquake itself, lending support to safety actions taken at Kashiwazaki–Kariwa and other nuclear plant sites around Japan (including Chubu Electric’s Hamaoka NPP and Kyushu Electric Power’s Genkai and Sendai NPP’s) in the sense that the majority of expenditure lies in prevention of damaging effects from tsunami. A previous Japanese government panel had implicated the quake as the cause, but the NRA’s investigation has resulted in little or no evidence that the quake itself caused any damage to the plants that would have led to core melt. For example, the summary of the NRA report states that any small leaks caused by the quake would not have caused a threat to core integrity within 10 hours, and that there were no detectable signs of any serious breach of primary plant integrity during the time between the quake and the arrival of the tsunami.

It seems assured now—given the work required, the recent court position, and the overall sensitivity of the issue—that none of the nuclear plants in Japan will restart before autumn. As that original hope slips, the public and industry continue to forge a new understanding of the importance of safety in the Japanese nuclear power industry.

For more information:

Hamaoka NPP – 19 minute video of preparations, training entitled “Amassing Our Full Strength in Pursuit of Greater Safety

Nuclear Regulation Authority (Japan) – Overview of Regulatory Requirements

New Regulatory Requirements for Light Water Nuclear Plants (Earthquakes and Tsunami.)  Nuclear Regulation Agency

_______________________

SavannahWillinControlRoomWill Davis is the Communications Director for the N/S Savannah Association, Inc. where he also serves as historian and as a member of the board of directors. Davis has recently been engaged by the Global America Business Institute as a consultant.  He is also a consultant to, and writer for, the American Nuclear Society; an active ANS member, he is serving on the ANS Communications Committee 2013–2016. In addition, he is a contributing author for Fuel Cycle Week, and writes his own popular blog Atomic Power Review. Davis is a former US Navy reactor operator, qualified on S8G and S5W plants.

Nuclear Energy Blog Carnival 219

ferris wheel 202x201The 219th edition of the Carnival of Nuclear Bloggers and Authors has been posted at The Hiroshima Syndrome.  You can click here to access this latest installment of a long running tradition among pro-nuclear authors and bloggers.

Each week, a new edition of the Carnival is hosted at one of the top English-language nuclear blogs. This rotating feature of nuclear “posts of the week” represents the dedication of those who are working toward a future of energy abundance, improved health, and broadened security through nuclear science and technology.

Past editions of the carnival have been hosted at Yes Vermont Yankee, Atomic Power Review, ANS Nuclear Cafe, NEI Nuclear Notes, Next Big Future, Atomic Insights, Hiroshima Syndrome, Things Worse Than Nuclear Power, EntrepreNuke, Thorium MSR and Deregulate the Atom.

This is a great collaborative effort that deserves your support.  If you have a pro-nuclear energy blog and would like to host an edition of the carnival, please contact Brain Wang at Next Big Future to get on the rotation.

Nuclear Matinee: The Mighty Watts Bar FLEX Building

If a tornado just happens to come through… flying steel pipes, telephone poles, or even automobiles will be no match for this building. This is the new Watts Bar FLEX building, housing emergency backup equipment like generators and pumps that could be used to replace equipment in case of damage from a natural disaster. Watts Bar will likely be the first nuclear facility in the United States to comply with all the Nuclear Regulatory Commission’s post-Fukushima requirements, as the Tennessee Valley Authority works toward licensing for Watts Bar Unit 2 with a target date of beginning commercial operation in December next year.

And take a more in-depth tour of the building:

Thanks to the Tennessee Valley Authority for producing the first fine video, and thanks to the Nuclear Energy Institute News Team for producing the second.

FLEX door

Research Reactor License Renewal Challenges

By Rod Adams

The process for renewing research and test reactor (RTR) licenses in the United States has been subject to lengthy delays and periodic backlogs since the early 1980s. Despite the apparent time invested in improvement efforts, the process does not seem to be getting better very fast. The difficulty, schedule uncertainty, and cost of renewing research reactor licenses adds to the burden of owning and operating research reactors. The scale of the challenge may contribute to regrettable institutional decisions that maintaining operable facilities is not worth the trouble.

Here is the background that led me to those conclusions:

A couple of weeks ago, one of the email lists I read provided an intriguing press release announcing the renewal of Dow Chemical Co.’s TRIGA research reactor located in Midland, Mich. The intriguing part of the story was that Dow had initially filed its application to review the license in April 2009 and the 20-year extension was awarded on June 18, 2014, more than five years later. One of the more frequent contributors to the list had the following reaction:

Seriously? It took more than five years to renew a TRIGA license? That in itself might be an interesting story.

I followed up with a request for information to the Nuclear Regulatory Commission’s public affairs office. Scott Burnell replied promptly with the following information:

The background on the staff’s ongoing effort to improve RTR license renewal goes back quite a ways. Here’s a relevant SECY and other material:

http://pbadupws.nrc.gov/docs/ML0921/ML092150717.pdf

http://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML120930333 (March 2012 Commission meeting transcript)

http://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML12087A060 (March 2012 Commission meeting staff slides)

http://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML12240A677 (regulatory basis for rulemaking to improve process)

I’ll check with the staff Monday on what information’s available re: staff hours on the Dow RTR renewal review.

Burnell sent the staff hour estimate for renewing the Dow TRIGA reactor license. Not including hours spent by contractors, the NRC staff took 1600 hours to review the renewal application. Since Dow is a for-profit company, it was charged $272 per hour, for a total of $435,000 plus whatever contractor costs were involved. That amount just covers the cost of regulator time, not the cost of salaries and contracts paid directly by Dow to prepare the license application, respond to requests for additional information (RAI), and engage in other communications associated with the applications.

Based on the cover letter for the issued license, Dow sent 19 letters to the NRC related to Dow’s application during the five-year process.

The references supplied by Burnell provided additional information about the process that is well known within the small community that specializes in research reactor operations, maintenance, and licensing.

For example, the last renewal of the Rensselaer Critical Facility, a 100-Watt open tank reactor that was originally licensed in 1965, was initially submitted in November 2002 and issued on June 27, 2011, nearly nine years later. The NRC did not send Rensselaer an RAI until three years after it had submitted its renewal application.

University of Missouri Research Reactor

University of Missouri Research Reactor (MURR)

In a second example, the University of Missouri-Columbia Research Reactor (MURR) submitted its most recent license application in August 2006. The NRC sent its first set of RAIs in July 2009 and followed up with at least five more sets of RAIs that included a total of 201 questions of varying complexity. According to the NRC’s listing of research reactors currently undergoing licensing review, the MURR license has not yet been issued.

A third example is the Armed Forces Radiobiology Research Institute TRIGA reactor. Its license renewal application was submitted in July 2004 and is still under review. In 2012, AFRRI estimated that it would be spending at least $1 million for its share of the license review process, not including expenditures by the NRC. Since AFRRI is a government organization, the NRC does not bill it for fees. Burnell indicated that the staff hours expended on that project could be 6,000 or more. It is sadly amusing to review the brief provided by the AFRRI to the NRC in 2012 about the process. (See page 52–65 of the linked document.) The following quote is a sample that indicates the briefer’s level of frustration.

Question: Once the licensee demonstrates that the reactor does not pose a risk to the heath and safety of the public, what is the benefit provided to the public by the expenditure of $1M to answer the additional 142 RAIs?

In a quirk of fate, numerous research license renewals have often come due when NRC priorities have been reordered by external events. Research reactors receive 20-year licenses; numerous facilities were constructed in the late 1950s and early 1960s. Dozens of renewals came due or were already under review in April 1979 when the Three Mile Island accident and its recovery became the NRC’s highest priority items.

About 20 years after that backlog got worked off, the 9/11-inspired security upgrades pushed everything else down on the priority list.

TRIGA at Oregon State University

TRIGA at Oregon State University

The research reactor office has experienced staffing shortages, often exacerbated by the small pool of people with sufficient knowledge and experience in the field. When the NRC hunts for talent, it is drawing from the same pool of people that staffs the plants and is responsible for filing the applications for license amendments and renewals.

One aspect of the law that eases the potential disruption of the licensing delays is a provision that allows continued facility operation as long as there was a timely submission of the renewal application. That provision, however, has often resulted in a lower priority being assigned to fixing the staffing shortages and the complex nature of the license application process.

The facility owners don’t want to complain too loudly about the amount of time that their application is taking, since they are not prohibited from operating due to an expired license. NRC budgeters and human resource personnel have not been pressured to make investments in improving their service level; not only do the customers have no other choice, but they have not squeaked very loudly. Here is a quote from a brief provided to the NRC by the chairman of the National Organization for Test, Research and Training Reactors (TRTR).

Position on License Renewal

  • TRTR recognizes the unique challenges imposed on NRC during RTR relicensing in the past decade (staffing issues, 9/11, etc.).
  • TRTR appreciates the efforts made by the Commission to alleviate the relicensing backlog.
  • TRTR appreciates the efforts of the NRC RTR group to update guidance for future relicensing efforts and the opportunity to participate in the update process via public meetings.

Generic Suggestions for Streamlining Relicensing

  • The process has become excessively complex compared to 20 years ago, with no quantifiable improvement to safety.
  • Consider the development of generic thermal hydraulic analysis models for TRIGA and plate-type fueled RTRs (1 MW or less).
  • Similarly for the Maximum Hypothetical Accident analysis.
  • Develop a systematic way outside of the RAI process to correct typographical and editing errors.
  • Develop a generic decommissioning cost analysis based on previous experiences, indexed to power level, and inflation.
  • Endorse the use of ANSI/ANS Standards in Regulatory Guidance.

(Pages 26–28 of the linked PDF document containing several briefs, each with its own slide numbering sequence.)

Once the high priority responses have died down and backlogs of license reviews in progress have reached levels in excess of 50 percent of the total number of research reactors in operation, the NRC has stepped in and directed improvement efforts. The staff has attempted to improve the process by issuing more guidance, but those attempts have often complicated and delayed the applications that are already under review.

The Interim Staff Guidance (ISG) issued in June 2009 appears to still be active; it is difficult to tell how much progress has been made on the long-range plan that ISG outlined. Once again, external events have changed the NRC’s priorities as most available resources during the past three years have been shifted to deal with the events that took place in Japan in 2011 and the effort to come up with some kind of waste confidence determination.

There are no easy solutions, but repairing the process will require focused and sustained management attention.

TRIGA at University of California, Davis

TRIGA at University of California, Davis

______________________

Adams

Adams

Rod Adams is a nuclear advocate with extensive small nuclear plant operating experience. Adams is a former engineer officer, USS Von Steuben. He is the host and producer of The Atomic Show Podcast. Adams has been an ANS member since 2005. He writes about nuclear technology at his own blog, Atomic Insights.

Nuclear Energy Blog Carnival 218

ferris wheel 202x201The 218th Nuclear Energy Blog Carnival has been posted at Yes Vermont Yankee.  You can click here to access this latest installment in a long running tradition  among pro-nuclear authors and bloggers.

Each week, a new edition of the Carnival is hosted at one of the top English-language nuclear blogs. This rotating feature of nuclear “posts of the week” represents the dedication of those who are working toward a future of energy abundance, improved health, and broadened security through nuclear science and technology.

Past editions of the carnival have been hosted at Yes Vermont Yankee, Atomic Power Review, ANS Nuclear Cafe, NEI Nuclear Notes, Next Big Future, Atomic Insights, Hiroshima Syndrome, Things Worse Than Nuclear Power, EntrepreNuke, Thorium MSR and Deregulate the Atom.

This is a great collaborative effort that deserves your support.  If you have a pro-nuclear energy blog and would like to host an edition of the carnival, please contact Brain Wang at Next Big Future to get on the rotation.

EPA Proposes Power Sector CO2 Emissions Reduction Plan

By Jim Hopf

DC PerspectivesWith cap-and-trade and carbon tax proposals going nowhere in congress, the Obama administration is tackling the global warming issue through the administrative branch, using U.S. Environmental Protection Agency regulations. In the transport sector, the administration promulgated vehicle fuel efficiency (mileage) standards. In the power sector, the EPA has proposed regulations requiring that all new power plants emit no more CO2 than a typical natural gas plant—thus, any new coal plants would have to employ CO2 sequestration. And now, the EPA is proposing to address CO2 emissions from existing power plants by establishing CO2 emissions reduction requirements for the power sector.

EPA proposed rules

Under the proposed rules, each state would be required to reduce its power sector CO2 emissions rate (in tons of CO2 per MW-hr) by a certain percentage by 2030. Some interim goals will also apply. Details of the plan are described on the EPA’s website.

When establishing the emissions reduction goals for each state, the EPA considered five likely, low-cost means that the states may employ to reduce emissions. These include:

  • Increased thermal efficiency for fossil plants (6 percent average increase assumed for the coal fleet).
  • Increased use of existing gas-fired plants, in place of coal (usage increased to 70 percent).
  • 5.8 GW of new nuclear and continued operation of “at risk” nuclear units.
  • Increased renewable generation (to 13 percent of overall generation by 2030).
  • Electricity conservation (10.7 percent reduction in demand by 2030).

The EPA is not requiring the exact measures described above to be taken by the states. The above assumptions are simply the basis that the EPA used to arrive at “reasonable” emissions rate reduction requirements for various states. They are steps that states are already taking or are planning on taking, or steps that the EPA believes can be taken at very low cost.

The only requirement is the emissions rate (tons CO2/MW-hr) reduction percentage that applies to each state. Each state is free to choose the means by which it will meet the requirement. States are also free to engage in inter-state emissions trading to meet the goals (thus allowing some states to emit more than the goal if other states manage to emit less). Such trading schemes may result in some effective price being put on CO2 emissions.

The emissions reduction requirements for each state are based on the assumption that the five new nuclear reactors under construction in the United States go into operation. They also assume that the ~5.8 percent of U.S. nuclear capacity deemed to be “at risk” continues to operate (i.e., that any necessary steps or incentives to keep them open are taken). Thus, the proposed regulations do provide a tangible incentive to finish the five plants under construction and keep all existing nuclear plant operating. If any nuclear plants close, or if any of the five construction projects are halted, the states in question would be significantly affected, as they would need to find other, significant sources of reductions that were not otherwise planned.

The requirements are also based on an assumption that, on average, natural gas plants in the state that are in operation or currently under construction will operate with a 70 percent capacity factor (vs. ~55 percent now). Thus, they assume that coal generation will be displaced by increased gas generation from any under-utilized gas-fired plants in the state. They do not assume any new gas plant construction (to replace coal), however.

The requirements are also based on the assumption that renewables will increase to 13 percent of generation, mostly based on existing state renewable generation (portfolio) requirements and other state plans. States are also assumed to reduce power demand by 10.7 percent (vs. current projections, using new demand-side management programs). These demand reductions are essentially treated like non-emitting generation, and are part of the quoted percentage emissions reduction for each state.

State requirements

The state requirements are illustrated in the figure below. State by state requirements are also shown in tabular form here. The state requirements are expressed in terms of percentage reductions in tons of CO2 emitted per MW-hr of generation, from 2012 to 2030.

epa carbon reduction goals 480x304

At first look, many of the state requirements seem odd, with states that already have low emissions (like Washington) having significant reduction requirements, while “coal states” like Kentucky and West Virginia have very small reduction requirements. One would think that such coal states would be the most ripe for reductions, mainly by replacing coal plants (especially old inefficient ones) with gas generation. The reason for this is that the EPA requirements are largely based on existing state plans.

For example, Washington is planning on closing the one large coal plant in the state, which is the source of most of the state’s power sector CO2 emissions. The EPA based its reduction requirement on those plans, and is essentially requiring the state to go forward with them.

The reason for the low reduction requirements for Kentucky and West Virginia is that few if any natural gas plants exist in those states. As stated earlier, the EPA did not consider the construction of new gas-fired plants in any states when making its estimates for “feasible” reductions. It only considered increased utilization of existing gas plants within the state.

Another example that stands out is the large (51.4 percent) reduction required for South Carolina. The primary reason for the strict requirement is the two-unit V.C. Summer nuclear project in the state. Those two reactors will result in a significant reduction in state CO2 emissions, and the EPA is essentially requiring that those projects go forward.

Overall national reduction goal

The EPA states that the proposed rules will result in national power sector emissions in 2030 that are 26 percent to 30 percent below 2005 levels. It should be noted that power sector emissions have already fallen ~15 percent between 2005 and 2013. Thus, the policies would actually only decrease emissions by another ~10–15 percent from today.

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. Looking over all the tabulated state reduction requirements suggests an average (i.e., national) reduction requirement of ~30 percent, in tons/MW-hr. Could the EPA really be referring to a reduction in per MW-hr emissions when it speaks of “CO2 emissions reductions” (i.e., is it using misleading/evasive language)?

This question is significant, since the U.S. Energy Information Administration projects an increase of ~26 percent in overall U.S. electricity generation between 2012 and 2030. Thus, a ~30 percent reduction in tons/MW-hr would result in ~26 percent more emissions than a ~30 percent reduction in absolute emissions (tons/year). The EPA assumed that states would reduce overall electricity use by 10.7 percent, versus current projections (of a 26 percent increase, presumably). However, those reductions are essentially treated like zero-emissions generation, and are included in the state emissions/MW-hr reduction goals. That is, the required percentage reduction in CO2/MW-hr for the state’s power generation is actually less than that quoted, unless the state fails to reduce demand.

Part of the answer lies in the use of 2005 vs. 2012 as a base year. As discussed above, a 30 percent emissions reduction (in tons/year) from 2005 equates to a reduction of only 10–15 percent from 2012 levels. If one assumes that power generation increases by 26 percent, but the tons of CO2 emitted per MW-hr decreases by 30 percent, the resulting overall emissions, in tons/year, would fall by ~12 percent (which lies within the range of 10–15 percent). Thus, I believe we have our answer. Overall emissions will decrease by 10–15 percent, from now to 2030. Emissions intensity (tons/MW-hr) will decrease by a larger amount (26–30 percent), but overall generation will increase somewhat.

It should be noted, however, that the requirements, as written, only limit emissions intensity and do not actually limit absolute emissions (in tons/year). Thus, if overall power generation increases by more than the expected amount, for whatever reason, absolute CO2 emissions will be allowed to increase accordingly. Any restriction or disincentive on CO2 emissions would not increase in response to increased generation.

Political considerations

The EPA’s proposals appear to be designed to minimize political impacts, in my view. As discussed earlier, many if not most of the proposed “measures” are simply ratification of existing policies and plans, such as planned coal plant closures and state renewables mandates. Any new measures are ones that can be achieved at very low cost.

One of the only new aspects is a requirement to increase gas utilization, vs. coal, but even that measure is only applied to states with spare gas capacity, and not to coal states (which have little such spare gas capacity). The EPA’s argument appears to be that constructing new gas plants (as opposed to simply using existing ones more often) would be too expensive. This argument appears weak, given the very low capital cost of gas capacity. It appears to me to be more of a political sop to the coal-dominated states, perhaps to avoid political resistance to the plan. The proposal is designed so that the impact on power generation in the states most politically opposed to the plan are virtually non-existent.

This appears to be a proposal that has a somewhat limited impact on emissions (relative to other/earlier proposals), but also is known to have very limited economic (and political) impacts. My view is that this is an attempt to get at least some sort of global warming policy established. This will set precedent, and establish the principle that this is something that warrants government action. Once the policy is established, policies that require further/continued reductions may be promulgated in the future, especially if (or when) it is seen that this policy had no significant negative impact on the economy. In any event, this is probably the strongest policy that can be attained right now, given attitudes in congress, and some policy is better than none.

Overall impacts

As discussed above, this proposal appears to be far weaker than other global warming proposals that have been put forward, such as the earlier cap-and-trade bill or various CO2 tax proposals.

The plan is estimated to yield a 30 percent reduction in emissions (vs. 2005) by 2030, from the power sector only (and only 10–15 percent from today). That corresponds to a reduction of just over 10 percent in overall emissions, vs. 2005 (and less than half of that vs. today). That compares to the (Waxman-Markey) cap-and-trade bill requirement of ~20 percent in overall CO2 emissions.

It must be noted that power sector emissions reduction options (e.g., replacing coal with anything else) are among the “lowest hanging fruit” with respect to cost effectiveness. A carbon price of $25–$30 per ton, enough to put many if not most existing coal plants out of business, would only add ~25–30 cents to a gallon of gasoline (i.e., not nearly enough to drive any significant changes in the transport sector). Thus, the old cap-and-trade bill was actually far more significant in terms of impacts and reductions demanded. To get a ~20 percent reduction in overall emissions, the reductions from the power sector would have been far greater than 20 percent (its reduction measures being cheaper than other sectors).

It should be noted that coal is still projected to represent ~30 percent of overall generation in 2030, even under these proposals. Coal formerly was over 50 percent, and recently fell to ~34 percent (in 2012). Now, because natural gas prices have gone back up somewhat, coal is back up to ~40 percent. (Note that, whereas when a nuclear plant closes it’s closed forever, utilities turn mothballed coal plants right back on when they become slightly cheaper to operate than gas, with no consideration of the drastic difference in health and environmental impacts.) Thus, all the proposals are doing is bringing coal back down to where it was a couple years ago with no policy input.

My opinion is that, given that shutting down old coal plants and replacing them with gas (if nothing else) represents one of the least expensive means of emissions reduction, any plan that leaves coal’s generation percentage at 30 percent in 2030 simply isn’t trying hard enough.

Indeed, I believe most of the EPA’s proposed reduction measures discussed earlier are estimated to have costs of only ~$15 per ton of CO2. Most carbon tax proposals involve significantly higher CO2 prices.

Most earlier proposals also required more significant reductions in overall (all sector) emissions by 2030. Those requirements, along with other assumptions such as higher natural gas prices, led to significantly different predicted outcomes, including much lower coal use and much higher nuclear use. I seem to recall one EPA study of a cap-and-trade policy that predicted a nuclear generation share of ~60 percent.

Impacts on nuclear

As stated earlier, the EPA’s policies should be a significant help in assuring that existing nuclear construction projects go forward, and in preventing any more nuclear plant closures, as these are the assumptions “baked into” the emissions requirements for each state. Whether or not the policy will stimulate any additional nuclear construction is far less clear.

The emissions goals for each state were based on current plans and additional measures estimated to cost ~$15/ton of CO2. A CO2 price of ~$15/ton is certainly not enough to stimulate much in the way of new nuclear plant construction, although it is probably enough to keep existing plants open. While larger emissions reductions would require higher costs (CO2 prices), the EPA’s analysis and proposals do seem to show that significant reductions can be achieved at very modest costs (and through mere continuation of existing plans and policies); something that is somewhat disconcerting with respect to new nuclear plant prospects.

Perhaps the main impact of the proposed policy, both on nuclear and in general, 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 will instead require some further replacement of coal with gas. We’ve already back-tracked from 34 percent coal use back to ~40 percent. The EPA policies will drive coal use back down to ~30 percent. And they will do so even if natural gas prices rise in the future; a very important point.

That last point is probably the most significant in terms of whether the EPA’s proposed policy will ever result in new nuclear construction projects. If the price of natural gas increases significantly in the future, nuclear may become competitive. The EPA policies would prevent shifting back to coal as an alternative to new nuclear (or renewable) capacity. Preventing a shift back to coal would also tend to keep gas prices up, as a shift back to coal would no longer act as a means of limiting gas demand. On the other hand, if the price of natural gas remains low, the proposed EPA policies would do little, if anything, to stimulate new nuclear construction, in lieu of just using more gas.

Call to action

Another option for increasing the odds of new nuclear plant construction would be to argue for policies that treat all non-CO2-emitting sources the same. As the EPA is leaving it up to each state to determine how to comply with the proposed rules, such policies would most likely be set at the state level. The state emissions goals are based on the continuation of existing renewable generation requirements and plans, and renewables accounting for 13 percent of overall national generation in 2030. The states are free to use nuclear, in lieu of renewables, for some of that generation under the EPA policy.

This is an area where the American Nuclear Society, nuclear engineers, and nuclear advocates need to get involved. The EPA’s proposed rules are now out for public comment. Also, states are beginning to develop plans for how they will respond to the emissions reduction requirements. Nuclear experts and advocates need to make the case for a technology-neutral approach. Certainly, we should advocate neutrality for any new state policies. Cap-and-trade systems in lieu of portfolio standards are also something we could argue for. Revision of existing state renewable portfolio standards to include nuclear (in order to reduce compliance costs) would be a bit more difficult to achieve, but is still worth pursuing.

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Hopf

Hopf

Jim Hopf is a senior nuclear engineer with more than 20 years of experience in shielding and criticality analysis and design for spent fuel dry storage and transportation systems. He has been involved in nuclear advocacy for 10+ years, and is a member of the ANS Public Information Committee. He is a regular contributor to the ANS Nuclear Cafe.