Category Archives: Nuclear Regulatory Commission

Root cause of Vogtle and VC Summer delays

This column was initially published in the October 16, 2014, issue of Fuel Cycle Week and is republished here with permission.

by Rod Adams

Within a few months of receiving its combined operating license in February 2012 the Vogtle-3 & -4 nuclear power plant project became the subject of reports that it was significantly behind schedule and over budget.

Radio station WABE, Atlanta’s NPR affiliate station, is closely tracking the project and its publicly released reports. WABE has compiled its story segments into a useful print and audio chronology. There are similar stories about the closely aligned Summer-2 & -3 project.

On September 24, I had the opportunity to tour the Vogtle site and learn first-hand how the project is faring. The wrong people are getting blamed. The resulting misperceptions about the projects have the potential to contribute to another lengthy hiatus in nuclear power plant construction in the United States.

The most important thing I learned during my Vogtle visit was that the construction project is moving as rapidly as predicted, that the people on site and in supporting roles are doing a good job, that the workforce hiring challenges are within the predicted boundaries, and that the regulators overseeing the project are performing as expected.

As is demonstrated by the progress being made on the second units at each site, lessons-learned programs are robust and effective.

I also saw a growing inventory of large components that was being stored in an expanding number of temporary structures designed to protect the components from the Georgia red clay and frequently inclement weather.

The second most important thing I learned was that the cost increase and ultimate schedule delay could and should have been predicted on the day that amendment 19 of the AP1000 design certification document was approved in December 2011.

The schedulers could have restarted a clock that should have been put on pause when the U.S. Nuclear Regulatory Commission changed the rules two-and-a-half years earlier with the Aircraft Impact Assessment rule.

Regulatory delays cost time and money

The 36-page Federal Register notice issued in July 2009 acknowledged that the Aircraft Impact Assessment rule was not necessary to provide “adequate protection” and it acknowledged that applying the rule to a project that was already under construction would impose an undue financial burden:

“In making these additions, the NRC is making it clear that the requirements are not meant to apply to current or future operating license applications for which construction permits were issued before the effective date of this final rule. This is because existing construction permits are likely to involve designs which are essentially complete and may involve sites where construction has already taken place. Applying the final rule to operating license applications for which there are existing construction permits could result in an unwarranted financial burden to change a design for a plant that is partially constructed. Such a financial burden is not justifiable in light of the fact that the NRC considers the events to which the aircraft impact rule is directed to be beyond-design-basis events and compliance with the rule is not needed for adequate protection to public health and safety or common defense and security.

What that concession did not admit was the enormous financial and schedule impact of applying the rule to two existing projects for which designs were already certified, firm EPC (engineering, procurement, and construction) contracts were already signed, certified cost and schedule estimates were already submitted to state-level rate regulators, and long lead-time components were already being manufactured.

Instead of moving forward as planned, the Vogtle-3 & -4 and Summer-2 & -3 projects were halted while the engineers began the unpredictable process of designing a compliant shield building using modern, but not-yet-tested construction techniques.

From the moment the redesign effort started, all of the meticulously created schedules and cost estimates became obsolete. As they would say in my previous profession, they were OBE (overcome by events.)

Of course, neither the vendors, Westinghouse and Chicago Bridge & Iron (neé Shaw), nor the utility customers, Southern and SCANA, stopped moving or spending money; there was too much at stake already.

Even though all parties knew that they could not finalize the requirements for the plant’s foundations until the shield building redesign was invented, tested, completed, and approved by the regulator, they could not halt site preparation or component manufacturing.

They could not stop the accumulation of ongoing interest payments on borrowed money. They could not stop construction of the training facilities or the hiring and prequalification training for future operators.

Why not correct the record?

I’ve spent much of the time since my visit trying to understand why no involved party has made a noticeable public effort to correct the record and explain that the delays were outside their control.

The answer I have discovered is completely unsatisfying. I asked some hard questions. Here is an example of the verbal and written replies:

“The issues raised in your questions are subjects of disputes that are currently in litigation. It is not appropriate to comment outside of the litigation process. The parties’ respective pleadings in the litigation set forth their positions.”

Apparently, the vendor team and the owners group would rather litigate and point fingers at each other rather than to tell a truthful story that identifies the real culprit.

Several industry experts have suggested that nuclear plant licensees are extremely reluctant to blame the regulators that still control their destiny.

It is beyond the scope of this commentary to open up the question of whether or not the Aircraft Impact Assessment rule was a reasonable response to the irrational fear induced by the events of 9/11.

It is not even my intention to question the reasonableness of applying the rule that is not required for adequate protection to projects that were already underway.

The mission of this commentary is to explain that the root cause of the schedule delays and cost increases for both the Vogtle-3 & -4 and Summer-2 & -3 projects was a national-level decision to force a substantial redesign after major project decisions had been made.

As long as the regulations do not change again, there now exist several designs that meet the new requirements. Customers that order those designs now should be able to avoid the impact of a midstream design change.

It would be in the best interests of the industry and the projects that are currently underway to make it clear that the Vogtle and Summer projects were the subject of a one-time decision.

They should not be seen as indications that the nuclear industry is incapable of achieving predictable cost and schedule performance.


Adams1Rod 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 Safety” – National Nuclear Science Week, Day 4 (October 23)

NSWlogoDay 4 of the annual National Nuclear Science week is all about Nuclear Safety.

The use of either fission of atoms, or decay of radioisotopes to benefit man (whether that benefit derives from the production of electricity, the diagnosis of a medical patient, the preservation of food, or many other things) brings along with it a serious responsibility to ensure the safety of not only all involved with the process but those uninvolved as well. To this end, a tremendous amount both of time and money are spent by all organizations designing, operating, or using nuclear technology as well as governmental oversight agencies (often called “regulators,” such as the US Nuclear Regulatory Commission.)

The American Nuclear Society’s Center for Nuclear Science and Technology Information has a great page covering the many, varied aspects of nuclear technology safety. Click here to access this CNSTI page.

Don’t forget—you can visit the Nuclear Science Week official website for much more information, including lesson plans, and other resources.

Another Nuclear Design Approved by the NRC

• This week the GE-Hitachi ESBWR design received its Design Certification from the Nuclear Regulatory Commission.

• “Design Certification” is a step in the licensing process for new nuclear power plants that allows a basic design for a nuclear plant to simply be referenced in the actual licensing process for a site, theoretically speeding the process.

ESBWR - Illustration courtesy GE-Hitachi Nuclear Energy

ESBWR – Illustration courtesy GE-Hitachi Nuclear Energy

by Will Davis

Earlier this week, the US Nuclear Regulatory Commission granted design certification to General Electric’s Economic Simplified Boiling Water Reactor nuclear plant design, ending a years-long effort by GE to get design certification (called a DCA) and potentially paving the way to further new nuclear builds in the United States.

Dr. Solomon Levy mentions in his book “50 Years in Nuclear Power: A Retrospective” (American Nuclear Society, 2007) that the SBWR or “Simplified Boiling Water Reactor,” the predecessor design to the just-certified ESBWR, was begun as a design effort in the 1980s along with several other advanced nuclear plant designs. At that time, design was beginning to shift to passive safety features—those that take effect without operator action, which are included in the new design.

American Nuclear Society Treasurer Margaret Harding was with GE in various capacities for many years, and is familiar with BWR series development; she served as Fuel Engineering Leader for the ESBWR project. “The SBWR was a fully natural circulation reactor (meaning there are no pumps to move water through the core), was simpler, and thus less expensive than the forced recirculation designs that came before it such as the BWR/6 and ABWR,” she said. “The SBWR design eventually evolved into the ESBWR, which is even more simplified and has a number of both passive and active safety features.”

Harding said that there was a major push to reduce equipment and piping overall, leading to the decision to use natural circulation (the tendency of hot water to rise over cold water), but this led to the design of a wider, flatter reactor core that will require a slightly higher uranium enrichment than forced circulation BWR reactors and that may be slightly less economical from a fuel consumption standpoint. “But because fuel is such a small percent of your operating costs, that disadvantage isn’t huge,” she added.

Natural circulation BWR plants aren’t new; the Elk River Reactor, built by Allis-Chalmers (originally ACF) for Rural Cooperative Power Association in Minnesota in the late 1950s, was a natural circulation boiling water power reactor. Early problems with recirculation piping in various makes of boiling water reactors were another factor that led to the determined effort over the years to either move the recirculation pumps inside the reactor vessel and eliminate external piping (GE BWR/6, various ASEA–ATOM BWRs and the Hitachi–GE HP-ABWR) or else eliminate them entirely as in the ESBWR.

Of course, ESBWR is fully a GEN III+ plant (light water reactor with advanced safety features) in every sense of the term, with both fully passive and active core cooling features, a core catcher, a new containment, and more. GE-Hitachi has combined proven features from operating experience with a half century of boiling water reactors with advanced features in this design, which also interestingly is near the high end of available outputs with an electrical rating of 1600 MWe gross. The plant is available with either an 1800 RPM turbine generator for utilities that provide 60 Hz power, or a 1500 RPM unit for those that provide 50 Hz.

As of now, only two projects in the United States that have specified the ESBWR are active—namely, DTE Energy’s plan for a new Fermi-3 unit, and Dominion’s plan for a new North Anna Unit 3. DTE submitted to the NRC for a Combined License Application (COL) in September 2008, while Dominion submitted its COL in November 2007. Neither project presently has a planned date of completion for NRC review/issuance of the COL, however. In the case of North Anna-3, much of the delay centers on the fact that while Dominion initially selected the ESBWR, it switched reactor designs from 2010 to 2013 to the Mitsubishi US–APWR and then reverted to the ESBWR.

What’s next? Well, the next design to be certified in the United States might well be the South Korean APR1400. While the review process for this design was thrown back to Korea Hydro & Nuclear Power in December 2013 and remains officially at the “pre-application” status, a recent announcement by Korea Electric Power Company Engineering & Construction (which designs and builds Korean nuclear plants) reveals a sweeping inter-corporate contract among the major players in the South Korean nuclear industry to restart the push for US NRC design certification with actual application made by the end of 2014.

GE-Hitachi's ESBWR displays a number of highly advanced features, including a new containment, passive core cooling, and a core catcher.

GE-Hitachi’s ESBWR displays a number of highly advanced features, including a new containment, passive core cooling, and a core catcher.

For more information:

• GE-Hitachi has a great deal of information available to the public on its website. Click here to access their ESBWR page that includes specifications, illustrations, and very detailed downloadable documents.

See the GE-Hitachi Nuclear Energy press release.


SavannahWillinControlRoomWill 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.  Davis is temporarily managing all social media for the American Nuclear Society.

Surface storage of used nuclear fuel – safe, cost-effective, and flexible

by Rod Adams

In August 2014, the U.S. Nuclear Regulatory Commission approved NUREG-2157, Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel. That action was the end result of several years worth of detailed analysis of the known and uncertain impacts of storing used nuclear fuel on the earth’s surface in licensed and monitored facilities.

As summarized in section 8 of the document, the staff determined that the environmental impact under expected conditions is small and acceptable even for an indefinite period of time. The analysis included consideration of a complete societal breakdown and loss of institutional control and determined that this situation would have an uncertain effect on the safety and security of used nuclear fuel, but determined that there is little likelihood that society will falter that much.

NUREG-2157 both eliminates the hold that was placed on issuing new or renewed nuclear facility licenses and it provides the technical basis supporting a decision to stop working on a geologic repository. If storing used material on the surface is acceptably safe, environmentally sound, and cost-effective for the foreseeable future, it would be a waste of resources to attempt to develop a facility using today’s technology. It is likely that technology will improve in the future. It is inevitable that the material of interest will become easier to handle as the shorter-lived, more active components decay at a rate established by physical laws.

NRC Chairman Allison Macfarlane wrote the following perceptive statement in her comments about her vote on the rule:

In essence, the GEIS concludes that unavoidable adverse environmental impacts are “small” for the short-term, long-term, and indefinite time frames for storage of spent nuclear fuel. The proverbial “elephant in the room” is this: if the environmental impacts of storing waste indefinitely on the surface are essentially small, then is it necessary to have a deep geologic disposal option?

Almost exactly right! We should ask hard questions of those who maintain that “deep geologic disposal is necessary” because “a majority of the public industry, academia, and regulators” say it is. Here are some questions worth asking:

  • Why do you think a mined deep geologic repository is required?
  • What makes it so important?
  • Where is the recorded vote on which you base your claim that it is the majority opinion?
  • If there was a vote, when was that vote taken?
  • Have there been any changes in circumstances that challenge the validity of that determination?
  • Should options besides a mined deep geologic repository be reconsidered?
  • How much will it cost each year to simply defer action into the indeterminate future?
  • From an accounting perspective, aren’t costs that are deferred far into the future worth less, not more, if they are recalculated into today’s dollars?

Those who have read Macfarlane’s full comment should recognize that she is not only the source of the “elephant in the room” statement above, but she is also the source of the assertions that the United States must continue pursuing a mined geologic repository because we have a “long-established responsibility to site a repository for the permanent disposal of spent nuclear fuel,” and she wants to make sure that the NRC’s determination that continued surface storage represents a small environmental impact for the indefinite future does not enable “avoiding this necessary task.”

Last week, I had the opportunity to ask Chairman Macfarlane if she thought that the NRC had a role in deciding U.S. policy on long-term nuclear waste storage. She explained that the only role for the NRC would be to review the license application submitted for any specific facility. The responsibility for planning and developing that facility and obtaining the funds necessary would be under the purview of a different agency.

I asked what the NRC’s role should be if no organization submits an application for a facility. She admitted that its only role in that case would be to continue monitoring existing facilities and approving license renewals or new licenses.

Congress can, and should, make a determination that the plan for nuclear waste for the indefinite future is to continue safely storing used material. It should remove the responsibility for permanent disposal of nuclear waste from the Department of Energy and put it into industry’s hands to solve. Of course, the industry will remain under the watchful eye of the already established federal regulator using procedures and processes that are already in place and continually being refined. It should make use of existing products and services, continue improving those offerings and should consider the need for facility consolidation as that makes economic sense.

Macfarlane and I also agree about when we would begin to believe that the United States can site, license, build, and operate a mined deep geologic repository, as she said:

I will have confidence in the timing when a renewed national consensus emerges on a repository for spent nuclear fuel.

(Emphasis added.)

There is no reason to suspect that a sufficiently bulletproof consensus will ever exist. Recent history has proven that it takes just a handful of people elected or appointed into the right positions to derail even the best laid plans made with strong support throughout the rest of the country.

Though Macfarlane seems concerned about the potential impact if there is a “loss of institutional control,” the controls required to ensure continued safety and environmental protection from used nuclear fuel are simple and easily implemented. As long as we do not believe that future generations will forget how to read, we can be sure enough that they will remember how to keep used nuclear fuel safely isolated.

Many people in Chairman Macfarlane’s generation—which is also my generation—probably believe at least some of the many entertainment products depicting that there is going to be an inevitable dystopia in the future. Those fictional predictions of the future might have made for good reading or viewing, but they are as useful a decision tool as any other wild fiction. Even if their fanciful dystopia becomes reality, used nuclear fuel will be low on the prioritized lists of risks.

Macfarlane has expressed some concerns about the financial responsibility associated with continued storage of used nuclear fuel. Establishing bonds or other forms of continued financial surety is a common business practice. Radioactive materials are not uniquely hazardous or even uniquely long-lived compared to other elements and compounds in common industrial service. We have learned to live with them. We have proven that we know how to protect the public from any harm. There is no reason to expect that society will forget the lessons it has already learned.

A simple financial solution would be to have nuclear plant owners establish a used fuel fund that would be as isolated from their normal finances as their decommissioning funds. The experience that we have with the current Nuclear Waste Fund shows that a tiny fee on each unit of nuclear electricity will grow into a very sizable fund if undisturbed over time. We should stop stealing the capital accumulated by such a fee to pay for other continuing government expenses and we should not fritter it away by conducting geologic studies of the depths under any region that has the proven potential to produce politically powerful majority leaders. (Nearly every state in the union has that potential given the longevity of any proposed repository program.)

In the conclusion of her seven page comment, Macfarlane included the following statement:

Finally, I note that at least one commenter has suggested that development of a repository in the U.S. has developed into a Sisyphean task. I agree that much in the national management of spent fuel and development of a geologic repository over the past decades fits this analogy.

Once again, I agree with Macfarlane’s description of the current situation associated with attempting to site a single geologic repository in the United States.

Americans must remember that we are not subjects of Greek gods condemned to continue the frustratingly impossible task of pushing a rock uphill every day just to have it roll back down at the end of the day. We are free members of a society that has the ability to make choices and to change its mind to adapt to new situations or when new information is revealed. The cancellation of Yucca Mountain through actions of a tiny group of people shows that successfully siting a repository in the United States, with its multiple interest groups and arcane procedural rules, is not possible.

The good news is that we don’t need a repository in order to operate nuclear power plants safely and to store the created residues in a way that produces negligible environmental impacts. We don’t need a government program that can be milked for assets and jobs for decades before being derailed. We don’t need to have the federal government—which means us, as taxpayers—pay the costs of continued storage; the costs are predictable and can be paid with a small fee on each unit of power generation.

Making the choice to quit now and spend our limited resources on something more useful must not be judged as unfair to future generations. Used nuclear fuel has potential value, and we can create savings accounts now that can enable a different long-term solution in the distant future when there is more general agreement that constipating nuclear energy would be a suicidal course of action for society.

As technology improves, assets build up in the coffers of responsible parties, nuclear power plant sites continue to be developed, nuclear power plant sites occasionally become repurposed, and the demand for nuclear fuel changes, future societies can change their mind. Nothing in the above plan precludes any choices for the future; the key action needed today is to stop digging the hole that currently seems to provide no possibility for escape.

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.

ANS Webinar with NRC Chairman Allison Macfarlane

Nuclear Regulatory Commission Chairman Allison Macfarlane today fielded questions from in-person and virtual attendees at a live, unscripted 60-minute webinar on nuclear energy issues. The event—”Bloggers’ Roundtable”—was held in Washington, DC, and was a collaborative effort of the NRC and the American Nuclear Society. The webinar provided an opportunity for nuclear bloggers and social media personalities to discuss the NRC’s perspectives on a wide range of nuclear-related issues.

Webinar recording of A Conversation with U.S. NRC Chairman Allison Macfarlane

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ANS Moderator Margaret Harding noted that many questions referred to the proper purview of the NRC—such as, could the NRC take a stronger role in “promoting” nuclear energy? Should another government entity be in that business? How do you make the jargon of the trade more accessible and understandable to laypersons?

Other questions dealt with the preparations for licensing of small modular reactors; radiation regulation in light of challenges to the linear no-threshold model; rulemaking concerning post-Fukushima safety enhancements; and much more.

Questions that were more technical or required a more detailed response are to be tackled as follow-up responses here at ANS Nuclear Cafe.

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A stand-alone video from today’s virtual forum is under construction—for immediate access please tune in and enjoy the webinar recording. Thank you to NRC Chairman Macfarlane, ANS Moderator Harding, and all attendees.

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Webinar with NRC Chairman Allison Macfarlane—Thursday, Sept. 11, 9 AM Eastern

The American Nuclear Society will host an online webinar for nuclear bloggers—an unscripted question-&-answer session with Nuclear Regulatory Commission Chairman Allison Macfarlane—on Thursday, September 11, 2014, from 9 AM–10 AM Eastern Time

To register for the webinar, click the ‘Register’ link at:

How to submit questions



Participants in the September 11 session may submit questions ahead of time by sending to Paul Bowersox at the American Nuclear Society. The conference call webinar will be listen-only and facilitator Margaret Harding, ANS Treasurer, will take questions via online webinar chat while the discussion is in progress. Those registrants unable to attend via computer may dial in to listen at the number listed on their registration confirmation.



To attend in-person

A limited number of spaces are available for writers to join in person at 2000 M Street, NW, Washington, DC, Conference Room A (basement level). Space is limited to the first 20 respondents.

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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.




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.


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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.

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A reason for holiday cheer–Significant court victories on nuclear waste

By Jim Hopf

DC PerspectivesA United States appellate court recently handed down two long-awaited rulings with respect to Yucca Mountain. As most observers expected, both decisions were decidedly in nuclear’s favor.

Yucca licensing effort

The court essentially has ruled that the administration’s termination of the Yucca licensing process is illegal, as it is in violation of the Nuclear Waste Policy Act (NWPA). On August 13 of this year, the court directed the Nuclear Regulatory Commission to resume the licensing process, but allowed a comment period to determine how best to proceed.

Yucca_Mountain_2 180x144In a more recent (November 18) ruling, the court has given more specific instructions (summarized in this NRC order). It has ordered the NRC to complete the Safety Evaluation Report (SER) for the repository, and to place all licensing documents that support the Yucca application into its official records system, where they can be accessed by the public. The court also requested that the Department of Energy complete an Environmental Impact Statement (EIS) that is required for repository approval.

The administration, as well as the NRC, has tried to argue that even if required by the NWPA, the NRC cannot complete (or continue) the licensing process since Congress has not appropriated the money to do the work. However, it appears that this will not get in the way of the NRC complying with these recent court orders. Documents show that the NRC has $11 million in “unobligated carryover funding” that was originally appropriated in 2011. The NRC staff estimates that $8.3 million will be required to complete the SER.

tour group yucca  mountainA completed SER, with a positive conclusion, would represent a scientific determination by the NRC’s technical staff that the repository would meet all the (strict) technical requirements. Although the full licensing process would still involve steps for legal challenges and other stakeholder input, a final, published SER would essentially settle the scientific/technical question as to whether or not Yucca is a viable solution to the nuclear waste problem.

Nuclear waste fee

The court also handed down a ruling that indefinitely suspends the 0.1 cent/kW-hr fee that the federal government has been collecting from nuclear utilities to support the nuclear waste program. The fund has been collecting ~$750 million per year from nuclear utilities, and has accumulated almost $30 billion, despite the ~$12 billion that has been spent already on the Yucca project. The court order would zero out the fee indefinitely (probably until a new repository project was started, at a new selected site).

The Yucca project has been terminated, or is at least on indefinite hold, and no other repository site is being pursued or characterized. Thus, it is not at all clear what significant (and justifiable) expenses the program would face in the near- to mid-future. Given that any repository operations date has been moved far into the future, any expenses related to shipping and handling fuel have also been moved into the distant future. Thus, the court concluded that there is no reason why additional contributions to the fund are needed and justified.

In an attempt to justify the continuation of the fee, the DOE produced an extraordinarily wide estimated range for the total eventual cost of the repository program; essentially arguing that it had no idea what it would cost. The court sharply disagreed with the DOE’s cost estimates, calling its fee assessment “fundamentally flawed”, “legally inadequate”, and “absolutely useless.” The court, in fact, ridiculed the DOE’s fee assessment (and the absurdly large cost estimate range), saying that it “reminds us of the lawyer’s song in the musical “Chicago”—”Give them the old razzle dazzle.” That is, the court suggested that the DOE was being deliberately dishonest and evasive.

Significant victories

I believe that both decisions will significantly benefit nuclear, for the following reasons:

Impact of SER publication

I’ve always believed that having the NRC publish a SER, which determines that Yucca Mountain is a scientifically and technically sound solution for permanent nuclear waste disposal, would be of significant value to nuclear power, even if the project does not end up going forward.

The fact is that nuclear waste can be stored at plant sites, very safely and at very low cost, due to its miniscule volume. My view is that the biggest negative impact of failure to resolve the nuclear waste problem is that it leaves the public with a false impression that nuclear waste is a unique, intractable problem with no acceptable technical solution. In terms of long-term health/environmental risks, the real truth is that nuclear’s waste problem is more technically solved than that of many, if not most, other industrial waste streams, including those of fossil fuels. The false notion of intractability is a source of significant public opposition to nuclear power. That opposition, in turn, leads to the use of fossil fuels in lieu of nuclear, which results in public health risks and environmental impacts that are orders of magnitude larger than any that will ever be caused by nuclear waste, no matter where or how it’s disposed of.

A SER, with a positive conclusion, published by the NRC’s objective technical staff, could go a long way toward ameliorating those (mostly unfounded) concerns on the part of much of the public. Even if Yucca does not go forward, it can be argued that while Yucca was a technically sound (adequate) solution to the problem, we are choosing to pursue other options that are even better and/or have a greater degree of state and local public support. The point would be that it is not the case that we have no acceptable options (i.e., that we are “doomed” in some respect). We will be able to say that we know the waste will be buried in a way that does not result in significant long-term impacts or risks, given that we know we have at least one technically sound option.

The advantage of a published SER will only be significant if scientists and the nuclear industry and its supporters highlight the SER’s conclusions and strongly make the above case to the public. The publishing of the SER, as well as its scientific significance with respect to the real risks of nuclear waste disposal, will not be noticed by the public unless we make an effort to raise public awareness. A clear message must be sent that the nuclear waste problem has been solved, from a scientific and technical perspective.

Impact of waste fee elimination

As for the waste fee, it’s clear that further contributions are not justified. Not only is there no repository project to spend money on right now, but since any project, and any significant expenditures, have been pushed far down the road, long-term interest on the funds already accrued would likely be sufficient to cover any future expenses. At a minimum, it’s clear that the fee should be suspended until a new site is selected and significant (and justified) program expenditures resume.

One almost has to wonder if the government was deliberately dragging its feet on moving forward with a repository, making the fee essentially a nuclear power tax that the government could use to spend on other things—or, at least, use the trust fund to make the deficit/debt appear smaller. With the fee suspended, and with courts requiring the government to compensate utilities for on-site storage costs, the government may finally have a financial incentive to actually resolve the problem.

The immediate effect of the suspension is to reduce nuclear plant operating costs by 0.1 cents/kW-hr (i.e., $1 per MWh). Given the financial pressures that many older, smaller existing nuclear plants currently (and hopefully temporarily) face, every little bit helps. The fee elimination could well reduce the probability of seeing any more plant closures over the next few years. That, in turn, would significantly benefit both public health and environment, and reduce CO2 emissions.




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.

An Open Letter to The Oregonian

On October 23, The Oregonian newspaper ran an op-ed by Leslie March of the Sierra Club Nuclear-Free Campaign that questioned the independence of the U.S. Nuclear Regulatory Commission. Paul Lorenzini, co-founder of Oregon-based NuScale Power, submitted a rebuttal based on his many years of experience with regulators worldwide.

The Oregonian failed to acknowledge this and other informed opinions by persons with expertise in nuclear energy facility operations and regulations. The ANS Nuclear Cafe is publishing Dr. Lorenzini’s letter as an Open Letter to advance the public dialogue.


By Paul Lorenzini

The Oregonian’s October 23 op-ed piece is an example of trying to “squeeze blood from a turnip.” Based on a recent story by the Associated Press (“US nuke safety varies by region, study shows”) it makes the claim that US nuclear plants are not being properly monitored by the US Nuclear Regulatory Commission (NRC). The facts just don’t support this assertion.

The AP story reports on a recent study by the Government Accounting Office (GAO) on the Nuclear Regulatory Commission. As claimed by the op-ed piece, the GAO cited “183 lower level violations at the [Columbia Generating Station] and four higher level violations from 2000 to the end of 2012. Each of these violations,” the op-ed states, “represents an incident where the reactor’s operation was lacking and could have resulted in a risk to the public.”

First, the word “safety violation” never appears in the GAO report. More important, the 183 so-called violations were in a category called “green,” defined as indicating the “licensee performance is acceptable and cornerstone objectives are met with nominal risk and deviation.” As the AP story made clear, these pose “very low risk, such as the improper upkeep of an electrical transformer.” They are specifically categorized that way to be sure they are not misrepresented—as this op-ed piece has done—to mean they represent some kind of risk to the public.

The theme of the op-ed piece is the claim that the NRC is not doing its job and is too close to the industry. A rather astounding basis for this is the fact that the industry is the source of the NRC’s funding. Just to be clear, the NRC is funded in this way because that’s what nuclear critics wanted. This comment was in reference to industry complaints that 90 percent of the NRC workforce was sent home during the recent shutdown.

Was the nuclear industry upset when too many people were furloughed? You bet. In fact, the president of the Nuclear Energy Institute wrote to the NRC complaining that the operation of nuclear plants was too important to have key people taken off the job during this period. No one understands more than those in the nuclear industry how critically important credible and strong regulation is to the continued use of nuclear power, here and elsewhere.

As an aside, in 2007, together with Oregon State University Professor Jose Reyes, I co-founded a company (NuScale Power) to commercialize a small modular reactor that will make significant advances in the safety of nuclear power plants. As we went to the international market, we learned something very quickly: nearly every international customer we met made it clear that they would not consider our plant until it had been certified by the US NRC. Our regulator is regarded as the premier nuclear regulator in the world, and their approval is universally accepted as the international nuclear “gold standard”.

The op-ed writer was correct that we need a strong nuclear regulator – fortunately for all of us, we have one.


Lorenzini-Photo1 100x150Paul Lorenzini has extensive experience in both executive management and nuclear operations and is dedicated to advancing public understanding of nuclear technologies. He began his career with Atomics International, a division of Rockwell International, after earning his Ph.D. in nuclear engineering from Oregon State University. While developing safety analysis codes for design of the liquid metal-cooled fast breed reactor, he also attended law school and earned his J.D.

After working with a Portland-based law firm, Lorenzini rejoined Rockwell International at the Hanford Nuclear Defense Complex in eastern Washington state, where he was subsequently named vice president and general manager of Rockwell’s Hanford Operations. He later joined PacifiCorp, an electric utility company in Portland, where he spent more than a decade in several executive management positions, including president of Pacific Power & Light, chief executive officer of PacifiCorp Turkey, and chief executive officer of Powercor Australia.

Lorenzini has dedicated his time to many civic roles, including chair of the Citizens Crime Commission, National Executive Board of the Boy Scouts of America, chair of the Neighborhood Partnership Fund, and campaign chair of United Way. He has served in various capacities on the Marylhurst College Board of Trustees, the Portland Chamber of Commerce, the Oregon Symphony, and the Oregon Independent College Foundation. He is the recipient of the Multnomah County Volunteer Award, the Community Partnership Award, and the Crime Commission Annual Citizen Award. He has also served as chair of the Oregon State University Foundation.

Court Finally Rules on Yucca Mountain’s NRC License Review

By Robert L. Ferguson

Shortly after the Obama administration unlawfully terminated the Yucca Mountain Project, three Washington State citizens (Robert L. Ferguson [the author], Bill Lampson, and Gary Petersen) filed suit to hold the President and his administration accountable to the law. Similar suits filed by Aiken County, South Carolina, and the states of Washington and South Carolina; the National Association of Regulatory Utility Commissioners; and Nye County, Nevada, were combined into one lawsuit.

tour group yucca  mountainAfter a year-long wait for the D.C. Circuit Court of Appeals to rule on our lawsuit against the U.S. Nuclear Regulatory Commission for illegally stopping the Yucca Mountain license review, the court finally ruled on Tuesday, August 13, to grant us a writ of mandamus ordering the NRC to follow the law and resume the review.



Two of the judges on the three-judge panel agreed that the NRC had violated the Nuclear Waste Policy Act (NWPA) when its former chairman, Gregory Jaczko, stopped the Yucca Mountain license review at the point when it was nearly complete. Jaczko also withheld the Yucca Mountain Safety Evaluation Reports (SERs), which were due to be released to Congress and the public.

The NRC eventually delivered two volumes of the Yucca Mountain SERs to Capitol Hill, in response to a Freedom of Information Act request from The Heritage Foundation. However, any conclusions about whether or not the site would be safe for storing radioactive waste were omitted from the reports, and the executive summary was gone. The NRC said that the redactions were justified by a Freedom of Information Act exemption that excludes material that could affect a legal process.

One of the legal processes pending against the NRC was our lawsuit, which began in February 2010, and is now at an end in August 2013. It has been a long and personally expensive endeavor, but we accomplished what we set out to do—establish that the President of the United States is not above the law. The court’s ruling confirmed that U.S. laws must be followed regardless of political opinions. It’s regrettable that private citizens had to resort to litigation to compel our elected and appointed government officials to obey the law. I’ve written a book chronicling our legal battle and the politics behind it entitled The Cost of Deceit & Delay: Obama and Reid’s Scheme to Kill Yucca Wastes $Billions.



Circuit Judge Brett Kavanaugh wrote in his opinion, “This case raises significant questions about the scope of the Executive’s authority to disregard federal statutes.” He explained, “The underlying policy debate is not our concern. The policy is for Congress and the President to establish as they see fit in enacting statutes, and for the President and subordinate executive agencies to implement within statutory boundaries.” He concluded that the President and federal agencies “may not ignore statutory mandates or prohibitions merely because of policy disagreements with Congress.”  (Link to the Court’s order here.)



The NRC has $11.1 million left in an account designated for the Yucca Mountain license review. Chief Judge Merrick Garland wrote in his dissenting opinion that the lack of funds makes the court’s ruling “useless” because it amounts to “little more than ordering the commission to spend part of those funds unpacking its boxes, and the remainder packing them up again.”

We disagree. The NRC testified during the court hearing that $10 million would be enough to at least publicly release the Yucca Mountain SERs. Hopefully, they won’t have to unpack too many boxes to find the un-redacted versions.

The value of disclosing to the public the results of the Department of Energy’s costly scientific evaluation of Yucca Mountain, which is located in Nevada, and the NRC’s review contained in the safety reports will settle once and for all whether or not Yucca is a suitable site for the disposal of high-level waste. If the conclusions of the NRC’s review favor licensing the site, doing so will comply with the NWPA and clear the way for building interim storage facilities for nuclear waste, whether or not construction of a repository at Yucca Mountain is authorized by Congress.

The logical next step would be for Congress to modify the NWPA to allow implementation of the Blue Ribbon Commission’s recommendations to establish consolidated storage facilities and create a new organization to manage the nuclear waste program. Congress also should amend the NWPA to allow the separation of the defense waste program from the commercial waste program, to establish a clear path for the disposal of defense waste independent of any future decisions regarding reprocessing of commercial spent fuel.

I want to congratulate and thank our legal team, with special thanks to Andy Fitz, the attorney for Washington State who presented and argued the case before the court for the entire team.

The legal team for the case number 11-1271, known as Aiken County, S.C., et al. v. NRC et al., in the U.S. Court of Appeals for the District of Columbia Circuit, from left to right: Ken Woodington, attorney for South Carolina; James Bradford Ramsey, attorney for the National Association of Regulatory Utility Commissioners (NARUC); the author Bob Ferguson; Barry Hartman, attorney for Ferguson et al.; Andy Fitz, attorney for Washington State; Robert Anderson, attorney for Nye County, NV; Tom Gottshall, attorney for Aiken County, SC; S. Ross Shealy, attorney for Aiken County, SC; and Mary Wilson, attorney for Washington State.

The legal team for the case number 11-1271, known as Aiken County, S.C., et al. v. NRC et al., in the U.S. Court of Appeals for the District of Columbia Circuit: (left to right)
Ken Woodington, attorney for South Carolina; James Bradford Ramsey, attorney for the National Association of Regulatory Utility Commissioners (NARUC); the author Bob Ferguson; Barry Hartman, attorney for Ferguson et al.; Andy Fitz, attorney for Washington State; Robert Anderson, attorney for Nye County, NV; Tom Gottshall, attorney for Aiken County, SC; S. Ross Shealy, attorney for Aiken County, SC; and Mary Wilson, attorney for Washington State.




Robert L. (Bob) Ferguson is a former Deputy Assistant Secretary for Nuclear Energy at the Department of Energy. His career in nuclear energy spans 50-plus years, much of it dealing with managing nuclear waste. His book, The Cost of Deceit & Delay: Obama and Reid’s Scheme to Kill Yucca Mountain Wastes $Billions, is available at

Don’t blame NRC uncertainty for San Onofre retirement

By Rod Adams

The San Onofre Nuclear Generating Station never threatened public health and safety. Unit 2 could have been restarted as soon as its scheduled outage was completed in February 2012. Unit 3 could have been restarted by mid-March 2012. The total cost of the repairs, including purchased replacement power, should have been less than $50 million and been covered by the manufacturer’s warranty.

After spending several hundred million dollars in repairs, consulting fees, regulatory fees, and replacement power costs, Ted Craver, the chief executive officer of Southern California Edison (SCE), announced that his company had decided to retire the plant and give up its operating license. He blamed the long, expensive, and uncertain process of obtaining a licensing amendment for the surprising decision.

Craver failed to explain that there was never a legal requirement for SCE, the plant’s primary owner, to introduce the uncertainty of obtaining restart permission from the Nuclear Regulatory Commission. SCE could have confidently fixed the material condition and moved smartly forward in its legal responsibility to provide its customers with reliable, affordable electricity.

Though it is now impossible to roll back time, unspend the hundreds of millions of dollars, and restore the 2100 MW of clean, reliable, electrical power capacity, it is worth the time to learn lessons that might help prevent recurrence of this costly tragedy in the future.

Aside: Some may think that I am melodramatic in labeling the early death of a nuclear power plant as a tragedy, but that technological marvel represented the lifetime labor of thousands of skilled engineers and technicians. It could have provided 14–16 billion kilowatt-hours of emission free electricity for another 28–48 years. I think that losing it qualifies as a tragedy; other people agree with me. End Aside.

On January 31, 2012, operators for San Onofre Unit 3 recognized the indications of a steam generator tube leak and promptly shut down the reactor. The indications and controls system worked as designed and the licensed operators took the correct immediate actions. The estimated leak rate was 75 gallons per day, which is half of the rate that would require operator action.

The radioactivity that set off the alarm came from intensely radioactive, very short-lived material. The primary coolant in an operating reactor is nearly pure water, but some of the oxygen atoms in water (H2O) exposed to a neutron flux will absorb a neutron and become Nitrogen-16, an isotope that rapidly decays (with an 8-second half life) with a high energy gamma emission. Conservative calculations made by the company indicate that the most exposed person would have received a radiation dose of 5.2E-5 millirem from the coolant that leaked before the plant was shut down.

Aside: I have often marveled at the providence of N-16 production in a water cooled reactor. The intense radioactivity forces a conservative shield design with multiple layers of dense material. That radiation shield turns out to be an effective security vault that also provides a substantial amount of protection against physical attack. N-16 also serves as a nearly perfect tracer to provide advanced warning of something like a steam generator tube leak; it is easy to measure but disappears quickly without leaving any damaging residue. End Aside.

Steam generator tube leaks, though not welcome events, are not particularly unusual. Even under the very conservative rules established for nuclear power plant operations, there is an acceptable rate of tube leakage that does not require an immediate shutdown. By design, steam generators are built with more tubes than required so that some can be plugged without reducing the plant’s ability to produce its rated power output.

As long as technical specifications are not violated and plant owners take technically sound measures to repair leaks and prevent recurrence, there is no preexisting legal requirement to ask regulators for permission before taking action and restoring a nuclear plant that has had a steam generator tube leak to full operating status.

Because San Onofre had recently replaced the steam generators in both Unit 2 and Unit 3, the owners were somewhat surprised by the leak. They were keenly interested in determining the extent of the issue and the root cause. After all, installing those replacement steam generators cost the company about $670 million. They were supposed to last for several more decades. (The plant operating licenses were good for another 8–9 years, but there is every indication that the company planned to apply for 20-year license extensions for both units.)

Not surprisingly, individuals and groups that have been fighting nuclear energy in general and San Onofre in particular raised a public outcry. On February 8, 2012, Senator Barbara Boxer (D., Cal.) sent a letter to the NRC demanding that the agency investigate the plant based on what she described as a series of incidents, none of which had any relationship to each other. (Senator Boxer is not only from California, the home of San Onofre, but she is also the chairman of the Senate Environment and Public Works Committee, which has oversight of the NRC; she has often expressed strong skepticism about nuclear energy.)

On March 13, 2012, NRC Chairman Jaczko responded to Senator Boxer’s letter. That letter is an important piece of history that demands more attention. It provides a clear picture of exactly how tiny the event was and how there was never a risk to public health and safety. Here is a quote:

SONGS operators brought the unit into cold shutdown on February 2, 2012, and began steam generator tube inspections on February 12, 2012. The inspection confirmed the location of the leak was limited to one tube. NRC staff is continuing to review the licensee’s evaluation of the cause of the leaking tube and the licensee’s inspection of 100 percent of the tubes in both steam generators. As in Unit 2, the steam generator tubes will be pressure tested to evaluate their integrity. The root cause of the tube leak has not yet been determined. For both Units 2 and 3, SONGS will evaluate the results of their inspections to determine the appropriate length of time before the next inspection. NRC approval is not required for the licensee to restart Units 2 and 3. NRC inspectors will perform an independent evaluation of the licensee’s operational assessment report and preliminary cause evaluation prior to startup.

(Emphasis added.)

After the leak, SCE solemnly made public statements stating that it was committed to placing its highest priority on safety. As is often the case, it gave the impression that this commitment would best be met by doing everything possible to prevent recurrence of a steam generator tube leak. There is no evidence that anyone in a decision-making position compared the incredibly tiny safety consequences of a tube leak to the negative impact on public health and safety from the electrical power sources that would have to operate because San Onofre was not operating.

On March 23, 10 days after the NRC responded to Senator Boxer’s letter and informed her that the NRC had no legal right to interfere with SCE’s restart, Peter T. Dietrich, SCE senior vice president and chief nuclear officer, wrote a letter describing the actions that the company was going to take to address the conditions found in the steam generators. Even though a 100-percent inspection of the tubes in the steam generators for Unit 2 showed no signs of the tube-to-tube interactions that caused the single tube leak in Unit 3, that letter made the commitment that the company would not restart Unit 2 until the cause of the wear in Unit 3 was determined. It also made the following fateful commitment:

Prior to entry of Unit 2 into Mode 2, SCE will, in a joint meeting, provide the NRC the results of our assessment of Unit 2 steam generators, the protocol of inspections and/or operational limits including schedule dates for a mid-cycle shutdown for further inspections, and the basis for SCE’s conclusion that there is reasonable assurance, as required by NRC regulations, that the unit will operate safely.

(Note: Mode 2 means that the containment is closed and the reactor startup sequence is started. Mode 1 is when the reactor is operating at greater than 5 percent of rated power.)

Though the letter did not explicitly state that the company would ask the NRC for permission before starting up, it handed the NRC the right to schedule the meeting and said that the plant would not start up until after the meeting was held.

On March 27, the NRC responded to Dietrich’s letter with a Confirmatory Action Letter (CAL) that turned the voluntary commitment into a obligation that is still not a legal requirement enforceable by a fine, but that could be enforced with one of several options, including a notice of deviation, an order imposing a legal requirement to meet a commitment, or a demand for information. (Though it contains enough legal language to cause most of us to get a headache, you can read all about the legal status of CALs in the NRC Enforcement Manual starting on page 3-30.)

I’ve been in touch with SCE’s media relations people to find out more about the company’s decision to give the NRC a veto over the company’s ability to operate the plant within the parameters of its existing license. Here is the response I received:


As you know, the CAL memorializes commitments Southern California Edison made to the NRC regarding San Onofre Unit 2. In addition to the words on those pages, we have committed to the public and all stakeholders to place the highest priority on safety. From the moment we identified indications of potential tube wear issues in Unit 2, we believed it was important to understand the cause and potential scope of those issues before restarting Unit 2. Toward that end, we commissioned three independent experts to analyze the causes of the excessive tube wear and from that research we developed corrective actions to prevent the problem. I believe you are familiar with all those details.

You are correct that a CAL is voluntary and the language in the San Onofre CAL includes our commitment to seek NRC approval prior to restart. If we had restarted without NRC approval, SCE would have deviated from its commitment. If we do not honor such commitments, the NRC can impose more stringent enforcement actions. You could argue that the need for restart approval was a “de-facto” requirement.

Instead of making an expansive commitment, SCE could have confidently addressed the material conditions and firmly asserted that it had performed sufficient actions to provide a reasonable assurance that its valuable nuclear power plant would continue to operate safely. There might have been some resistance and some attempts to apply pressure, including increased regulatory attention, but it is hard to imagine that the increased attention and pressure would have resulted in consequences anywhere close to the complete loss of 2100 MW of emission free power generating capacity and the loss of at least 1500 jobs.

san onofre 257x201




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.

Environmental Impact Evaluations – Seeing the Bigger (Nuclear vs. Fossil) Picture

By Jim Hopf

DC PerspectivesAs I discussed last fall, a federal appeals court ordered the Nuclear Regulatory Commission to perform more thorough evaluations in support of its new Waste Confidence Rule, particularly with respect to the potential impacts of long-term storage of spent fuel at plant sites. While those evaluations are being performed, the NRC has suspended all new plant licensing and plant license renewals.

As discussed in that post, most experts believe that this issue will be resolved, in a timely manner, through additional analysis. Permanent cessation of licensing activity (until a repository is sited or built), or substantial new requirements (such as moving all fuel over 5 years old to dry storage) were considered unlikely. The NRC predicted that it could finish the required evaluations in ~2 years.

Reactions to NRC’s Waste Confidence Evaluations

spent fuel pool 180x119Predictably, anti-nuclear “environmental” groups are claiming that the evaluations that the NRC are doing are insufficient. They say that the evaluations should consider waste being stored on site for centuries, consider risks of terrorist attacks, and risks from severe earthquakes like that which struck Fukushima. They also advocate moving all >5 year spent fuel to dry storage. Finally, they say that 2 years is nowhere near long enough for the evaluations, and that all licensing activity should remain suspended for as long as it takes for “adequate” review to be performed.

And now, the attorneys general from four New England states are joining in, filing a petition for the NRC to do a “more thorough” review of the risks/impacts of long term on-site fuel storage. They are asking the NRC to reject the conclusions and recommendations of its technical staff, because they did not “adequately address the risks of spent fuel storage.” The AGs also state that the NRC’s evaluation did not give enough consideration to two options; requiring that all >5 year cooled fuel be placed into dry storage, and not allowing further production of spent fuel until a repository is constructed. (Yes, you heard that right, the AGs from four states are actually asking the NRC to consider shutting down the nuclear power industry.)

What are they after?

One hopes that all the AGs are asking for is for the NRC to do more homework to provide a stronger case. That would allow them to tell the public that they forced the NRC to do a “better job” and look out for their safety. Or perhaps, they’re hoping for the 5-year dry cask storage requirement, allowing them to point to a tangible “improvement” that they can take credit for (or perhaps to just extract a pound of flesh from the industry). One really hopes that they don’t really want the industry to shut down.

In my view, is it’s not that those risks (of long term storage) have not been evaluated. It’s that the people in question don’t like the answer. In other words, they will never be satisfied until the “evaluation” gives them the answer they want, which is that the risks are unacceptable, or that the industry must take some extensive, expensive, and burdensome actions.

Negligible risks/impacts

dry cask 190x141As someone who works in the area of dry fuel storage, I can tell you that the answer is pretty obvious. The risks of spent fuel storage are utterly negligible, compared to other risks that society routinely faces in general, and in particular, compared to the risks associated with alternative (fossil) power generation options. No credible scenario for a significant release from dry storage casks exists. Even terrorist attacks would have a minimal public health consequence.

Spent fuel pool risks are also quite low, and neither the 5-year cask requirement nor a repository would do much to reduce those (small) risks, since almost all the heat in spent fuel pools is from the fuel younger than 5 years. The theory of spent fuel pool cladding melt or fire (in the extremely unlikely, hypothetical event of pool drainage) is quite dubious in the first place, and it is being addressed at the few plants where it is thought to be a potential concern. Also of note is the fact that the spent fuel pools did NOT release any significant amount of radioactivity at Fukushima.

The fact is that nuclear waste is generated in a miniscule volume and, unlike the wastes from fossil plants and other industries, it has always been safely and fully contained, has never been released into the environment, and has never caused any harm. Further evaluation needed? In my view, the health/environmental impact evaluation for long-term onsite storage of used fuel could be adequately given in one sentence:

“The public health risks and environmental impacts of long term onsite storage of used nuclear fuel are clearly orders of magnitude less than those of the fossil fueled power generation that would otherwise be used in place of nuclear generation.”

It’s clear that shutting the industry down until a repository is built will result in fossil fuels being used for most of the replacement power.  Even if new plant licensing and plant life extensions are suspended, for a long time, the result will eventually be some reduction in nuclear generation, and will result in some increase in fossil generation.

San Onofre

san onofre 190x148Meanwhile, in Southern California, the San Onofre plant has been shut down for years due to tube failure problems with its steam generators (as discussed on this site here and here). The NRC has required that the plant remain shut until all the issues are thoroughly investigated; a process that has been taking a very long time. The NRC has been under a lot of political pressure to take its time and do a “thorough” investigation.

Steam generator replacement has been discussed. The utility also proposed running one unit at 70-percent power, based on evaluations showing that it would not result in significant tube vibration and degradation. The NRC has decided to allow public hearings on that (70-percent power) restart request, and having it require a license amendment is even being discussed. In order to meet peak power demand while San Onofre remains shut, two ~50 year old, highly polluting fossil plants in Huntington Beach were taken out of out of retirement and fired up.

In terms of the potential consequences of steam generator tube failure, it seems (based on what I’ve read) that the notion of steam generator tube failures causing a meltdown (i.e., core damage) is a real stretch. The only real potential is that the sudden failure of a large number of tubes could cause a significant fraction of the primary coolant loop water (and the radioactivity therein) to be released into the environment. (Note that even nuclear opponent Arnie Gunderson did not say that steam generator tube failures could cause a “meltdown” in this article.)

While one can only guess what the political/public reaction to such a release would be, its actual health consequences would be negligible to non-existent, particularly in comparison to the ongoing impacts of fossil generation. In reality, what is most likely to happen if things didn’t work out and the tubes started to fail is that some tubes would fail, the plant operators would notice the increase in secondary side activity, and they would safely shut the plant down.

Not only have old, dirty fossil fueled plants been fired up while the whole San Onofre saga played out, but the utility has just announced that it will close both of the reactors due to this issue. This will result in ~2000 MW of additional fossil fueled generation for several decades.

Blinders – Not looking at big picture

huntington beach power plant 190x116The common theme for these two stories is that nuclear risks are being evaluated in isolation. Overall impacts, such as the effects of reduced nuclear on the overall power generation system, are not being considered. Nuclear operations are held to a standard of perfection, or some arbitrary standard that regulators and other politically powerful stakeholders view as being adequate. That, as opposed to being compared to other risks accepted by society or, more importantly, the risks related to the alternative (primarily fossil) generation that would be used in place of nuclear.

Again, what are these people seeking from another several years of waste storage evaluations, when it is obvious, by cursory inspection, that the risks of waste storage are negligible compared to those of fossil generation alternatives? Perhaps they hope that the evaluations will uncover practical steps that could reduce the risks even further. At least the dry storage proposal is ostensibly that kind of step, although whether it is worth the cost and effort is highly debatable.

New England is home to many gross-polluting coal plants (many of which make the “Dirty Dozen” list of top polluters). If those states’ AGs really cared about their public’s health risks, they’d focus their efforts on getting those plants cleaned up or closed. They wouldn’t be wasting any time or effort on negligible risks associated with used nuclear fuel.

Why is the mindset that San Onofre cannot be reopened until everything is completely analyzed, understood, and resolved, and until the chance of steam generator failure is all but eliminated? And if all the hoops result in the plant’s closure, so be it. Where was the environmental impact evaluation that compared the risk of running San Onofre to the health risks of operating two 50-year old fossil plants that are located in a relatively high population density area? Given the limited health consequences of any credible steam generator failure scenario, it seems clear what such an evaluation would show.

It is likely that the operation of the Huntington Beach fossil plants has already had a larger public health impact than what would occur even in the event of a worst-case steam generator failure scenario (i.e., release of primary coolant loop activity). And finally, how about the consequences of the plant being closed?  Have they compared the risks of steam generator failure (low probability times limited consequence) to several decades worth of fossil fueled power generation? How about global warming impact?

Less nuclear = More fossil

smokestacks 150x100One thing that people need to be clear on is that using less nuclear power primarily results in increased use of fossil fuels. That’s certainly what’s happening in Japan. (They’re turning to coal to replace nuclear, since imported oil and gas are costing too much.) In Germany, where a huge effort is being made on renewables, coal generation is being significantly increased to offset the loss of nuclear. Even if Germany did succeed in building enough renewable generation to offset the lost nuclear generation, they’d still effectively be choosing fossil fuels over nuclear, since they could have used the renewables to replace fossil instead.

Reducing nuclear use will not cause renewable generation to increase. Construction of renewable capacity is primarily driven by government mandate and/or large subsidy. The final fraction of renewable generation will likely be close to the maximum practical amount based on intermittentcy limitations.

The only real question is whether the net effect of reduced nuclear would primarily be an increase of gas or coal use. If one assumes future environmental regulations that will limit the use of coal, then arguing that nuclear will be replaced by gas may be reasonable (especially in California). On the other hand, unless coal is limited by policy, one could argue that, in the end, reduced nuclear would mean more coal since the supply of gas will reach its limit at some point. Use of gas to replace nuclear would drive up the price of gas, which would result in more existing coal plants remaining open or operating more hours per year. This is already happening in the United States, now that gas prices have risen somewhat from historic lows. This would result in a net effect of nuclear being replaced by coal.

When pressed, nuclear opponents usually cede that fossil fuels are worse than nuclear (since the facts are actually pretty clear on that point). And yet, it’s generally the case that nuclear plants are closed when anything is out of sorts, and are required to address all the issues before they are allowed to restart. In the interim, fossil fuels are always used in its place, regardless of their much larger health and environmental risks.

You don’t hear people say, although the situation with San Onofre isn’t ideal, that we must keep it operating while the issues are resolved, since firing up old fossil fueled generators would have an unacceptable impact. A no-compromise philosophy is taken for nuclear risks (when anything is not just right), whereas reducing the known, ongoing health risks and climate impacts of fossil generation seems to be treated more like an aspirational goal. Something that we really should do, and will get around to some day (kind of like a New Year’s losing weight resolution). When anything happens, fossil fuels are always the backstop, or default. Although fossil fuels’ impacts are known to be vastly larger, they simply aren’t taken that seriously by our society; definitely not in comparison to our response to any issues with nuclear.

In any event, any REAL environmental impact evaluation would fully consider such issues. It would evaluate the impact of any reduction in nuclear generation, due to waste issues, etc., on the overall power sector. It would objectively compare all the risks of nuclear generation (including those of on-site used fuel storage, or imperfect steam generators, etc.) to the risks and impacts of the generation sources that are likely to be used in its place. If such evaluations were performed, and were objective, nuclear would have nothing to fear.




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.

San Onofre debate now more public – and more technical

By Will Davis

The debate over the continuing investigations into steam generator U-tube problems at San Onofre Nuclear Generating Station (SONGS) last week entered a new phase of heightened publicity and public scrutiny as the Nuclear Regulatory Commission (NRC) released Mitsubishi documents which detailed that company’s investigations into the root causes of the problems.

Friday, March 8, saw the release of a pair of documents which had been redacted by Mitsubishi Heavy Industries (MHI) (redaction here means that sensitive corporate information that competitors could use to advantage had been removed).  This followed the revelation within the previous weeks that an original of this document had somehow fallen into the hands of US Senator Barbara Boxer and US Representative Ed Markey, who then touted the documents as a “smoking gun” showing that plant operator Southern California Edison (SCE) had deliberately installed steam generators already known to be bad.  Allegations circulating the internet pointed to a “flawed design by Southern California Edison” and revealed a lack of clarity in the design process for such equipment.  SCE quickly and strongly responded to the allegations.

Allegations in this matter made by Friends of the Earth (FOE) turned out to be, in fact, complete falsehoods.  So it might be best to examine some of the facts surrounding this case and, as one recent San Diego Union Tribune op-ed piece hinted, “let the experts figure it out.”

RSGs and the Process of Replacement

RSG stands for “Replacement Steam Generator,” and the mystery in the public eye surrounding this process seems only to be growing.

In 2004, the owners of SONGS signed a contract with Mitsubishi to build four RSG’s for the two reactor plants on site.  The San Onofre nuclear plants were originally built by Combustion Engineering (CE), which was merged out of existence some years back (Westinghouse is now essentially the lineal descendant).  SCE chose to contract with Mitsubishi, which had been manufacturing steam generators of various types since 1970, to fabricate steam generators for the plants.

In this process, SCE provided to Mitsubishi a set of specifications—design standards to which the equipment had to adhere—for the steam generators.  The specifications address not just size and weight, but a number of more involved details, such as desired materials.  Mitsubishi then began work on a custom design for these plants based on the specifications.  Mitsubishi used as a reference design steam generators it had built as RSGs for Fort Calhoun Nuclear Generating Station—also a Combustion Engineering plant, but smaller than San Onofre.  A typical steam generator from a CE plant is seen below.

In the original conception of pressurized water reactor plants, the replacement of steam generators was not intended.  In these old designs, however, deficiencies became apparent after some time in operation (which varied widely depending on the plant and particular design), so replacement of these massive pieces of equipment had to be considered.  In some cases, such as Trojan Nuclear Power Plant in Oregon, replacement was required, but instead the plant shut down permanently and was dismantled when the cost structure and public opinion went against them.  This example has not been the norm; and in fact many plants have replaced steam generators.

The original reactor vendors are not using the same facilities or contracts they did when the plants were newly built. The downsizing of the nuclear manufacturing complex after a new construction sales dropoff in the late 1970s led toward an almost wholesale outsourcing of RSG construction today. For example, since Westinghouse ended fabricating RSGs in the USA, it has used ENSA (Spain), Ansaldo (Italy) and Doosan (South Korea) as subcontractors for RSGs, while other RSGs have been supplied to US utilities by AREVA and Mitsubishi. A counter example to this trend is Babcock & Wilcox, which has a contract to replace Davis-Besse’s steam generators this year, as well as a contract for OEM replacements at TVA’s uncompleted Bellefonte units.

In the earliest steam generator replacements, only parts of the steam generators were replaced, but eventually entire units began to be fabricated.  Eventually, as with any technology, improvements were made in design, and RSGs began to be fabricated with the same new, improved materials—such as Inconel-690 tubes—and techniques that were being employed in steam generators being fabricated for entirely brand-new reactor plants.  Replacing steam generators gave operators an opportunity to incorporate both better materials and better designs; the possibility of uprating could also be realized if more heat transfer area were available in the RSGs.   The NRC, recognizing the need to ensure safety with this as with every other practice in the industry, requires that replacement steam generators comply with a strict code that dictates what can, and cannot, be changed—and requires license amendments be applied for and approved when needed.

The above process, as described, is fully what occurred at San Onofre:  SCE provided specifications to MHI, which then completed detailed design and fabrication of the steam generators.

Design Problems

In October 2012, after discovery of the issues leading to San Onofre’s RSG failure, MHI revealed it had made errors in computer analysis of the steam generator design.  An SCE release provided to this author last October contains the following statement:

The Nuclear Regulatory Commission (NRC) determined that computer modeling used during the design phase by the manufacturer, Mitsubishi Heavy Industries, underpredicted the thermal hydraulic conditions in the steam generators which contributed to the unstable tube vibration.  The unstable tube vibration caused the unexpected wear in the steam generators.

As we are now aware, this is only a part of the story. The phenomenon behind the vibration is called Fluid Elastic Instability (FEI). The real problem that allowed FEI to cause vibration serious enough to wear through tubes has to do much more with fundamental design assumptions and then, later, actual fabrication.

Reading of the linked MHI documents reveals clearly that the problem is partly theoretical, partly physical.  On the one hand, an assumption in force in steam generator design industry-wide has held that “if out of plane FEI is prevented by design, in-plane FEI can not occur.”  This has been proven wrong—at least in the San Onofre steam generators—although it must be stated clearly that this event at San Onofre is the first confirmed occurrence of in-plane FEI known in the industry.

We also see in the report (again, quite clearly) that the design of the Anti-Vibration Bars, which restrain the U-tubes, was slightly modified—and was thought to be improved—in Unit 3.  What actually happened was that making the parts to finer (closer) tolerances reduced their contact force—and thus their ability to restrain the U-tubes—and helped lead to the motion-related impact wear.

Public Relations, and Events Outside Regulatory Action

As might be expected, continuous attention is given this situation by the NRC, which has held numerous meetings, inspections, and public hearings on this issue.  The NRC is tasked with ensuring that the plant is safely operated and that it meets all technical requirements. The NRC certainly appears to be solidly on the job, given the sheer number of Requests for Additional Information (RAIs) that it has issued.

Politics has also become an integral part of this story.  Senator Boxer sent a letter to the NRC stating that she had proof that MHI and SCE knew that the equipment was flawed. The letter was issued prior to any release, or public analysis, of the MHI documents.

In her letter, Boxer “calls on the NRC to promptly initiate an investigation” in the midst of what surely must be one of the most deeply technical investigations in NRC history—or in the history of the manufacture of steam generators.  This clearly reveals a lack of perspective on where the MHI report falls in the path between discovery of the issues and development of a resolution.

In response to this ongoing situation, SCE yesterday issued a press release in which Pete Dietrich, SCE Senior VP and Chief Nuclear Officer, states:

The anti-nuclear activists have called the MHI report a ‘bombshell’ which couldn’t be further from the truth …. In fact, the MHI letter explains that SCE and MHI rejected the proposed design changes referenced in the evaluation because those changes were either unnecessary, didn’t achieve objectives or would have adverse safety consequences. 

Our decisions were grounded in our commitment to safety.  SCE did not, and would never install steam generators that it believed would impact public safety or impair reliability.

SCE goes on to state, “The MHI letter specifically confirms that at the time the replacement steam generators were designed, MHI and SCE believed that {excerpt from MHI report} ‘the replacement steam generators had greater margin against U-bend tube vibration and wear than other similar steam generators’.”

In the release, the Nuclear Energy Institute’s Scott Peterson adds that claims by anti-nuclear activist group Friends of the Earth (whose anti-nuclear creed is clearly stated on its home web page) are part of a campaign of moving “from plant to plant with the goal of shutting them down.”  Pointing out the cherry-picked statements that both Senator Boxer and FOE are trying to posit as the ‘proof’ of wrongdoing of SCE, Peterson says: Not providing proper context for these statements incorrectly changes the meaning and intent of engineering and industry practices cited in the report, and it misleads the public and policymakers.”

What’s Next?

This author spoke to SCE’s Jennifer Manfre yesterday about where this continuously evolving situation is headed.  SCE would like to test operate Unit 2 at a  70% power limit for five months, followed by another complete RSG inspection, to assess if the calculational determination that FEI will be avoided here is demonstrated in operation.  Manfre stated that this 70% limit is “very conservative—we set a limit for avoiding FEI, and then set a new arbitrary limit below that to ensure safety, as is always our priority.”

NRC has raised some questions regarding the limit and has asked SCE to be able to demonstrate that the plant is actually safe at 100% power during any of this 70% testing which, as Manfre points out, “goes to the technical specifications for the plant.”  Manfre relates that SCE is preparing to submit, shortly, to NRC its Operational Assessment showing that the plant is indeed safe at 70% and also at 100% for this testing, saying “we essentially did both, to satisfy NRC and technical specifications.”

Manfre also clearly pointed out that the role of SCE in the RSG process is essentially that of being a customer with a required set of specifications, to which a detailed design is completed by a vendor (in this case, Mitsubishi).  SCE did take part in some of the design process (for example, the design of the AVBs) but is not responsible for the overall design of the RSGs.  Mitsubishi, who is responsible, has already begun warranty payments to SCE.

When Manfre was asked to speculate as to what a final resolution to this problem might look like—and was offered examples of a new operating license at a lower power rating to avoid FEI, or physical repairs to the steam generators to allow the full presently-rated power rating—she said we’re not even close to that yet; we need to get through this period of testing.” Anyone in the nuclear industry (and, it might be added, many other industries) can relate to the need to conduct operational testing and analysis before selecting final operational fixes to a complicated technical and physical problem which involves public safety.  Boeing’s problems with the 787 Dreamliner battery fire problem comes to mind as a timely parallel—as does the FAA’s handling of the situation.

Quite clearly with the voluntary release of the MHI documents, the process of investigation has unparalleled transparency for this sort of highly technical matter.  In a February 26 SCE press release, Dietrich says that “this question and answer process is an important part of safety-based technical solutions in the nuclear industry, and it strengthens our ability to communicate to stakeholders the safety principles and proven industry operating experience that the Unit 2 restart plan was built upon,” in reference to the open nature of the NRC Request for Additional Information Process. The latest MHI release builds upon this process.

This open process between plant operator and Federal regulator has now been added to—or, depending on point of view, detracted from—by inclusion in the public domain of releases of sections of the MHI documents taken out of context.   Dietrich, from yesterday’s SCE press release:

As with all engineering evaluations, the MHI letter and report describe a technical evaluation process and need to be read in their entirety to understand the conclusions reached …. The activists are taking portions of paragraphs and sentences out of context, and using them as the basis of their allegations that SCE knew of design defects when the generators were installed, but failed to make changes to avoid licensing requirements.  That is untrue.

Manfre also relates that another ‘next step’ will be the impending full cost summation of the entire RSG process to the California Public Utilities Commission (PUC). The California PUC is under great pressure politically and must demonstrate that all rate impacts are fair and reasonable.  She also points out an upcoming Atomic Safety & Licensing Board hearing covering the scope of the required license amendments.

All of the developing actions and public Federal regulatory hearings can be found on the NRC’s dedicated San Onofre pages.  Developments and press releases from Southern California Edison on this situation can be found on its own dedicated SONGS website.

[Illustrations of San Onofre Nuclear Generating Station courtesy Southern California Edison]


Will Davis is a consultant to, and writer for, the American Nuclear Society. In addition to this, he is a contributing author for Fuel Cycle Week, and also writes his own blog Atomic Power Review. Davis is a former US Navy Reactor Operator, qualified on S8G and S5W plants.



How Can Nuclear Construction Costs Be Reduced?

by Jim Hopf

This month’s post discusses my ideas on an issue I’ve been thinking about for awhile.  Although we have four new reactors under construction in the United States (at Vogtle and Summer), the nuclear “renaissance” has so far not been nearly as strong as many had hoped. This begs the question as to what is holding nuclear back.

Impediments to nuclear growth

Some have suggested the need for even safer reactors, despite the fact that overall nuclear is already among the safest, if not the safest of all energy sources.  The fact that any direct health consequences of Fukushima, which was essentially a worst-case nuclear accident, have been essentially non-existent further suggests that insufficient safety is not the primary area needing improvement (or factor limiting nuclear’s growth).

Others believe that the nuclear waste issue is the main reason holding nuclear back, and that “solving” it (by closing the fuel cycle and through other advances in fuel cycle technology) would “unleash” nuclear to grow and solve our energy problems.  The truth, however, is that indefinite on-site storage of all of a plant’s waste (in the pool and in dry casks), versus having the Department of Energy take it away after a few decades, increases the cost of nuclear power by only ~0.1 cents/kW-hr.  Waste management activities will never be a significant fraction of nuclear power’s total cost, regardless of what waste policy is adopted, or what fuel cycle we develop.  I had thought that the perceived lack of a waste solution would significantly reduce support for nuclear, but it appears that, at least where almost all new US nuclear projects are proposed (in the Southeast), there is an ample degree of public/political support for new reactors.

No, it’s pretty clear that the primary factor holding nuclear back is economics, particularly the high upfront capital cost of new reactors.  The current low price of natural gas, coupled with a weak economy (and associated lack of power demand growth), and the lack of taxes or limits on CO2 emissions does not help, but it is also true that the costs of reactor construction have increased substantially over the past ~8 years (and increases in labor or raw materials costs do not come close to explaining this).  In addition to escalating initial cost estimates, many if not most current reactor projects have been experiencing fabrication issues and cost overruns.

How can we reduce costs?

Based on the above, it seems clear that nuclear research and development should focus primarily on ways to reduce nuclear plant construction costs, and less on fuel cycle or even safer reactor technology.  Even the safest conceivable reactors and fuel cycle will do nothing to help overall public health and safety and reduce environmental impacts if nuclear is not deployed – due to high capital cost – while fossil fuels (which are vastly worse than current reactor technology in terms of public health and safety) are used instead.  Ideally, this is something the Nuclear Regulatory Commission would keep in mind as well.

What is really needed, however, is to have all the experts sit down and perform a thorough, objective evaluation to figure out what is driving nuclear construction costs, and what needs to change to reduce those costs.  In this analysis, everything needs to be on the table—all regulations, policies, and practices. Nothing can be viewed as sacred or unchangeable (i.e., “that’s just the way things are in the nuclear business”).  We need to fundamentally reexamine all of our current policies and requirements, to determine which ones produce the most bang for the buck in terms of public health and safety benefit.

Not only should nuclear requirements be compared to each other (for benefit vs. cost), but nuclear requirements should be objectively compared to the requirements placed on other energy sources and industries.  One mindset that simply must disappear is that of “nuclear exceptionalism”, which views nuclear’s potential impacts/accidents to be uniquely unacceptable (i.e., that radio-isotope pollution is a uniquely unacceptable form of pollution), and that therefore, unlike other industries, no expense should be spared to remove even the tiniest chance of release.  By extension, we should ask why non-nuclear power plants are so much cheaper to build.  Is it that nuclear plants are more complex, or have more safety features, or is it the unique quality assurance requirements that only apply to nuclear?

My personal view is that the main factor leading to high plant construction costs is not the design of the reactors, or various safety features that they employ, but the uniquely strict QA requirements that apply (only) for the fabrication of safety-related nuclear plant components (i.e., “nuclear grade” components). Conversely, I believe that in terms of safety, fundamental reactor design, employed safety features, intelligent operation/training, and maintenance are much more significant (effective) than the application of extremely stringent fabrication quality control requirements.  This is a personal opinion that I welcome comments on—the purpose of this article being to start a discussion.

The costs of nuclear’s unique QA requirements

Having supplier qualifications and requirements for component fabrication that far exceed those applied to any other industry can lead to dramatically higher costs, for multiple reasons.  In addition to the increased costs of compliance, the number of qualified suppliers is much smaller, which in turn results in supply bottlenecks, not enough fabrication capacity to meet demand, and (essentially) a bidding war for components.  This seems to be a far more plausible explanation for the observed increase in reactor construction cost (vs. that initially estimated) than any shortages of labor or raw material.  Conversely, if the nuclear industry could use a more typical set of industrial quality requirements (e.g., ISO-9000), the number of suppliers would increase dramatically, there would be ample supply and significant competition, and costs for nuclear components could drop substantially.

It seems clear that problems complying with fabrication QA requirements, as opposed to reactor design features, are primarily responsible for reactor project cost overruns, since the reactor design was fully understood at the time of the initial cost estimate.  Also, meeting “nuclear grade” fabrication requirements is the reason most often cited in the numerous articles discussing cost overruns at nuclear projects.

At Vogtle, they are having significant problems, and cost overruns, due to the construction of something as simple as the concrete pad that the reactor will sit on.  This comment from an article on the Vogtle difficulties is typical:  The fabricator was “not accustomed to the requirements to document every step in the fabrication process. Correcting the mistakes took eight months for one of its modules….”  In addition to problems such as this, the Vogtle project is literally spending billions of dollars on quality control programs.

Similar problems are occurring for the nuclear projects in Finland and France, QA/fabrication issues being the primary reason for cost overruns.  And yet, those same reactor designs, with all the same safety features, are being built at a fraction of the cost in China.  Why the difference?  I believe that lower labor costs are only part of it.

I’ve also, anecdotally, heard many stories about how the nuclear-grade version of a component often costs several times that of the commercial/industrial-grade version of the same thing.  This is not due to any material difference in the component; just the QA paperwork cost and the (severe) lack of nuclear-qualified suppliers.  I have significant doubts as to whether the safety benefits are worth the additional cost.

Potential negative impacts on safety?

Due to onerous QA requirements, as well as the nuclear industry practice of taking a great deal of time in analyzing everything (“analysis paralysis”), there can be significant reluctance to make changes, including adding safety features or improvements.  In addition to making it more difficult to change, or even fix things, these practices also act to stifle innovation and technological progress in our industry.  The NRC “review barrier” to new, innovative, safer reactor designs is but one example.

Consider the following example: the NRC is debating whether or not to require filters on reactor vents that would remove most of the cesium from any vented air stream that may be necessary to control containment interior pressure in the case of a severe accident.  (Failure to vent was a major factor in the Fukushima event, resulting in a much larger release.)  In my opinion, such a design feature seems to be extremely worthwhile, since it greatly reduces potential cesium releases, and the long-term consequences of severe nuclear accidents pretty much scale (specifically) with the amount of cesium released.  The filters would cost ~$16 million per reactor.

Meanwhile, the Vogtle project was significantly delayed (several months) due to minor, inconsequential variations (from the specified design) in the rebar within the concrete pad that the reactor will sit on. Eventually, the NRC agreed that the alternate configuration was fine, but it took an inordinate amount of time (and money) to reach that conclusion. Under current practices and procedures, addressing any changes or deviations from an approved design is extremely difficult and time-consuming. Did this base pad rebar issue cost the Vogtle project more than $16 million? I’m pretty sure it’s much more than that.

So the question is, which is better bang for the buck in terms of safety: installing cesium filters on containment vents for $16 million, or spending a much larger sum to address (or correct) a small/inconsequential change to the rebar configuration in the plant foundation?  To me the answer is obvious.  Would dramatically reducing the cesium release in the event of a severe accident result in a significant reduction in nuclear’s overall risk?  Absolutely!  A small change in the configuration of the rebar in the (passive) concrete pad that the reactor sits on?  I cannot, for the life of me, imagine how that would have any significant impact on the likelihood or severity of a significant accident/release.

Despite this, whereas the cesium filters may end up not being required, the fact that Vogtle had to do what it did to resolve a minor deviation from licensed design (any deviation from licensed design), is not even questioned.  It’s just “the way things are in our industry”.

There have been some allegations made that the nuclear industry is not doing enough in terms of flood protection or component maintenance at some sites. Improvements in these areas may very well result in measurable reductions in risk, but, in my opinion, excessive (and unique to nuclear) QA requirements make any such responses or improvements so difficult and expensive that the industry is sometimes reluctant to implement them.  That’s both in terms of component fabrication QA requirements and the amount of analysis and review that is required for any actions or changes.  The end result could actually be a net increase in overall risk.

In my view, risks from component fabrication defects are not a significant fraction of overall nuclear risk.  No serious accident has ever resulted from a fabrication defect.  Instead, the rare instances that have occurred resulted from poor reactor design, operator error, or from things the industry just hadn’t thought of.  Fukushima is probably an excellent example of the latter.  They simply didn’t anticipate (or view as credible) a tsunami of that height.  Seawall fabrication defects were not the issue.

In other words, let’s put cesium filters on reactor vents, but pay, say, ~$4 million for them, instead of $16 million, by foregoing the impeccable fabrication and paperwork requirements required for “nuclear grade”, “safety related” components.  Let’s apply the QA requirements/standards that generally apply for other industries, or perhaps even use “commercial grade” filters.  It would surely be better than doing nothing.

Lazy thinking?

I’ve been in the industry long enough to know how most will respond to the above (rash) proposal.  Industry thinking tends to be that if full, nuclear-grade QA requirements are not applied to a component, it’s the same as it simply not being there.  Probability of function is 0%, regardless of the fact that such a failure type (or mode) is completely impossible.

Given the huge costs of nuclear-grade QA requirements, the industry has not put nearly enough time and effort into evaluating the probability of failure of non-nuclear grade/qualified components, and what the nature of any failures would be.  Such evaluations should be followed by detailed probabalistic risk assessment (PRA) analyses to determine what the effect on accident/release frequency (and severity) would be of having various components not be nuclear-grade.  These effects, on risk, should then be objectively compared to other options for reducing risk, such as fundamentally safer reactor designs, or the employment of various safety features (e.g., vent filters).

Such an effort has not been made, however (the NRC’s new “risk-informed” philosophy is a far cry from what I’m talking about).  It’s easy to follow up any analysis or evaluation with the statement: “and it shall be a perfectly constructed component, with zero defects”, without any regard for how much it will cost to make such a guarantee.  That way, one doesn’t need to do the hard task of evaluating the likelihood and consequences of (realistic) component failure.  Also easy is the notion that zero changes or deviations from the approved design are allowed, and that any change at all (no matter how small) requires re-performing and re-reviewing all the associated licensing analyses/evaluations.  How about exercising a little engineering judgment?

One has to ask how other industries handle fabrication defects or deviations. It seems clear it’s not the way the nuclear industry does, given their lower construction costs, shorter schedules, and fewer cost overruns.  It’s not like construction projects such as bridges, tall buildings, oil refineries, chemical plants, or non-nuclear power plants, etc., are not “important to safety”.  In many cases, their potential consequences (of component failure, etc.) are actually just as great.  Yet under nuclear QA logic, all these structures are repeatedly vanishing, crumbling into dust, or simply not performing their design functions, given that they were not built to nuclear-grade standards.  The real truth, of course, is that all these structures have been performing just fine, with acceptable levels of safety.

This is all just an example of the “nuclear exceptionalism” discussed earlier, where nuclear risks (or potential consequences) are treated as being infinitely greater than that of any other endeavor, while the facts clearly show otherwise.  For this reason, uniquely strict QA requirements, unlike those used in any other industry, may be hard to justify.


My personal view is that the low risk of significant release primarily comes from fundamental reactor design, safety features, and operational practices (e.g., operator training).  The onerous, uniquely strict component fabrication QA requirements and procedures that are applied only to the nuclear industry provide relatively little risk reduction relative to how much they are costing.

Thus, my primary recommendation is that while the NRC should definitely thoroughly review new reactor designs, once a reactor design is certified, normal industrial QA requirements should apply to reactor (and reactor component) construction.  That is, the same fabrication/construction requirements and practices that apply to non-nuclear power plants.  This would not only greatly reduce costs directly, but it would result in an enormous increase in the number of suppliers that can participate in nuclear plant construction, which would further greatly reduce costs.

At a minimum, the detailed component failure evaluation I described earlier should be performed, and specific relaxations to fabrication QA requirements should be evaluated and possibly traded for other, more cost-effective measures to reduce risk.  One example of a cost-effective measure, in my view, is the rapid emergency response capability that the industry is now developing.  One lesson learned from Fukushima is that flexibility, and the ability to respond (quickly), is imperative since one can never really predict the sort of events and disasters that potentially may happen in the future.  Another example would be that if one developed a smaller, lower power density reactor that was fundamentally safer (perhaps even unable to meltdown, due to basic size and geometry) but was somewhat more expensive, the QA requirements on at least some components should be relaxed, since the consequences of component failure would be far lower.

One thing seems clear to me.  Given how things are going with current (large) reactor projects, in the developed world anyway, the industry does not appear to be on a success path.  It was given a second chance to show that it could build new reactors at a reasonable cost, and on time and on budget, and it appears to be failing (although things don’t appear to be too bad yet at Vogtle and Summer).  Barring a large increase in natural gas prices AND the enactment of hard, declining limits on CO2 emissions (that would force a phaseout of coal), it appears that few new nuclear plants will be built in the future in the developed world.  Something has to change; something that will significantly reduce plant construction costs.

Small modular reactors, built in an assembly-line-like fashion, may offer a way forward; a development that I will discuss in a later post.  As for large reactors, the ideas presented in this article are my best attempt to figure out what could be done to change an otherwise fairly bleak picture.  I again remind everyone (and the NRC) that the environmental and public health benefits of nuclear (which are huge) will not be realized if nuclear is not deployed and fossil fuels are used instead.  We need to make a concerted effort to do what’s necessary to reduce nuclear plant construction costs, not only in the area of technology development and deployment, but in the areas of regulations and QA requirements as well.

I hope to start an active discussion on this topic, and hear other people’s ideas on what could be done to reduce nuclear plant construction costs.



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.