Category Archives: Nuclear Regulatory Commission

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:

https://ansbrief.webex.com/ansbrief/onstage/g.php?d=667766847&t=a

How to submit questions

Macfarlane

Macfarlane

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.

Harding

Harding

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.

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Adams

Adams

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

 

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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.

FLEX door

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.

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Hopf

Hopf

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

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.

Jaczko

Jaczko

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.

Kavanaugh

Kavanaugh

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.)

Garland

Garland

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.

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Ferguson

Ferguson

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 Amazon.com.

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:

Rod

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

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Adams

Adams

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

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.

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Hopf

Hopf

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

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]

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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.

Recommendations

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.

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Hopf

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

2012 ~ The year that was in nuclear energy

Plus a few pointers to what’s in store for 2013

By Dan Yurman

Former NRC Chairman Gregory Jackzo

On a global scale the nuclear industry had its share of pluses and minuses in 2012. Japan’s Fukushima crisis continues to dominate any list of the top ten nuclear energy issues for the year. (See more below on Japan’s mighty mission at Fukushima.)

In the United States, while the first new nuclear reactor licenses in three decades were issued to four reactors, the regulatory agency that approved them had a management meltdown that resulted in the noisy departure of Gregory Jazcko, its presidentially appointed chairman. His erratic tenure at the Nuclear Regulatory Commission cast doubt on its effectiveness and tarnished its reputation as one of the best places to work in the federal government.

Iran continues its uranium enrichment efforts

The year also started with another bang, and not the good kind, as new attacks on nuclear scientists in Iran brought death by car bombs. In July, western powers enacted new sanctions on Iran over its uranium enrichment program. Since 2011, economic sanctions have reduced Iran’s oil exports by 40 percent, according to the U.S. Energy Information Administration.

In late November, the U.S. Senate approved a measure expanding the economic sanctions that have reduced Iran’s export earnings from oil production. Despite the renewed effort to convince Iran to stop its uranium enrichment effort, the country is pressing ahead with it. Talks between Iran and the United States and western European nations have not made any progress.

Nukes on Mars

NASA’s Mars Curiosity Rover is a scientific and engineering triumph.

Peaceful uses of the atom were highlighted by NASA’s Mars Curiosity Rover, which executed a flawless landing on the red planet in August with a nuclear heartbeat to power its science mission. Data sent to Earth from its travels across the red planet will help determine whether or not Mars ever had conditions that would support life.

SMRs are us

The U.S. government dangled an opportunity for funding of innovative small modular reactors, e.g., with electrical power ratings of less than 300 MW. Despite vigorous competition, only one vendor, B&W, was successful in grabbing a brass ring worth up to $452 million over five years.

The firm immediately demonstrated the economic value of the government cost-sharing partnership by placing an order for long lead time components. Lehigh Heavy Forge and B&W plan to jointly participate in the fabrication and qualification of large forgings for nuclear reactor components that are intended to be used in the manufacture of B&W mPower SMRs.

Lehigh Forge at work

The Department of Energy said that it might offer a second round funding challenge, but given the federal government’s overall dire financial condition, the agency may have problems even meeting its commitments in the first round.

As of December 1, negotiations between the White House and Congress over the so-called “fiscal cliff” were deadlocked. Congress created this mess, so one would expect that they could fix it.

The Congressional Budget Office has warned that if Congress doesn’t avert the fiscal cliff, the economy might slip into recession next year and boost the unemployment rate to 9.1 percent in the fourth quarter of 2013, compared with 7.9 percent now. Even record low natural gas prices and a boom in oil production won’t make much of a difference if there is no agreement by January 1, 2013.

Japan’s mighty mission at Fukushima

Japan’s major challenges are unprecedented for a democratically elected government. It must decontaminate and decommission the Fukushima site, home to six nuclear reactors, four of which suffered catastrophic internal and external damage from a giant tsunami and record shattering earthquake. The technical challenges of cleanup are daunting and the price tag, already in the range of tens of billions of dollars, keeps rising with a completion date now at least several decades in the future.

Map of radiation releases from Fukushima reported in April 2011

  • Japan is mobilizing a new nuclear regulatory agency that has the responsibility to say whether the rest of Japan’s nuclear fleet can be restarted safely. While the government appointed highly regarded technical specialists to lead the effort, about 400 staff came over from the old Nuclear Industry Safety Agency that was found to be deficient as a deeply compromised oversight body. The new agency will struggle to prove itself an independent and effective regulator of nuclear safety.
  •  Japan has restarted two reactors and approved continued construction work at several more that are partially complete. Local politics will weigh heavily on the outlook for each power station with the “pro” forces emphasizing jobs and tax base and the anti-nuclear factions encouraged by widespread public distrust of the government and of the nation’s nuclear utilities.
  • Despite calls for a phase out of all nuclear reactors in Japan, the country will continue to generate electric power from them for at least the next 30–40 years.
  • Like the United States, Japan has no deep geologic site for spent fuel. Unlike the United States, Japan has been attempting to build and operate a spent fuel reprocessing facility. Plagued by technical missteps and rising costs, Japan may consider offers from the United Kingdom and France to reprocess its spent fuel and with such a program relieve itself of the plutonium in it.

U.S. nuclear renaissance stops at six

The pretty picture of a favorable future for the nuclear fuel cycle in 2007 turned to hard reality in 2012.

In 2007, the combined value of more than two dozen license applications for new nuclear reactors weighed in with an estimated value of over $120 billion. By 2012, just six reactors were under construction. Few will follow soon in their footsteps due to record low prices of natural gas and the hard effects of one of the nation’s deepest and longest economic recessions.

The NRC approved licenses for two new reactors at Southern’s Vogtle site in Georgia and two more at Scana’s V.C. Summer Station in South Carolina. Both utilities chose the Westinghouse AP1000 design and will benefit from lessons learned by the vendor that is building four of them in China. In late November, Southern’s contractors, which are building the plants, said that both of the reactors would enter revenue service a year late. For its part, Southern said that it hasn’t agreed to a new schedule.

The Tennessee Valley Authority recalibrated its efforts to complete Watts Bar II, adding a three-year delay and over $2 billion in cost escalation. TVA’s board told the utility’s executives that construction work to complete Unit 1 at the Bellefonte site cannot begin until fuel is loaded in Watts Bar.

The huge increase in the supply of natural gas, resulting in record low prices for it in the United States, led Exelon Chairman John Rowe to state that it would be “inconceivable” for a nuclear utility in a deregulated state to build new reactors.

Four reactors in dire straights

In January, Southern California Edison (SCE) safety shut down two 1100-MW reactors at its San Onofre Nuclear Generating Station (SONGS) due to excessive wear found in the nearly new steam generators at both reactors.

SCE submitted a restart plan to the NRC for Unit 2 in November. The review, according to the agency, could take months. SCE removed the fuel from Unit 3 last August, a signal that the restart of that reactor will be farther in the future owing to the greater extent of the damage to the tubes its steam generator.

The NRC said that a key cause of the damage to the tubes was a faulty computer program used by Mitsubishi, the steam generator vendor, in its design of the units. The rate of steam, pressure, and water content were key factors along with the design and placement of brackets to hold the tubes in place.

Flood waters surround Ft. Calhoun NPP June 2011

Elsewhere, in Nebraska the flood stricken Ft. Calhoun reactor owned and operated by the Omaha Public Power District (OPPD), postponed its restart to sometime in 2013.

It shut down in April 2011 for a scheduled fuel outage. Rising flood waters along the Missouri River in June damaged in the plant site though the reactor and switch yard remained dry.

The Ft. Calhoun plant must fulfill a long list of safety requirements before the NRC will let it power back up. To speed things along, OPPD hired Exelon to operate the plant. In February 2012, OPPD cancelled plans for a power uprate, also citing the multiple safety issues facing the plant.

In Florida, the newly merged Duke and Progress Energy firm wrestled with a big decision about what to do with the shutdown Crystal River reactor. Repairing the damaged containment structure could cost half again as much as an entirely new reactor. With license renewal coming up in 2016, Florida’s Public Counsel thinks that Duke will decommission the unit and replace it with a combined cycle natural gas plant. Separately, Duke Chairman Jim Rogers said that he will resign at the end of 2013.

China restarts nuclear construction

After a long reconsideration (following the Fukushima crisis) of its aggressive plans to build new nuclear reactors, China’s top level government officials agreed to allow new construction starts, but only with Gen III+ designs.

China has about two dozen Gen II reactors under construction. It will be 40–60 years before the older technology is off the grid. China also reduced its outlook for completed reactors from an estimate of 80 GWe by 2020 to about 55–60 GWe. Plans for a massive $26-billion nuclear energy IPO (initial public offering) still have not made it to the Shanghai Stock Exchange.  No reason has been made public about the delay.

India advances at Kudanlulam

India loaded fuel at Kudankulam where two Russian built 1000-MW VVER reactors are ready for revenue service. The Indian government overcame widespread political protests in its southern state of Tamil Nadu. India’s Prime Minister Singh blamed the protests on international NGOs (non-governmental organizations).

One of the key factors that helped the government overcome the political opposition is that Nuclear Power Corporation of India Limited told the provincial government that it could allocate half of all the electricity generated by the plants to local rate payers. Officials in Tamil Nadu will decide who gets power. India suffered two massive electrical blackouts in 2012, the second of which stranded over 600 million people without electricity for up to a week.

Also, India said that it would proceed with construction of two 1600-MW Areva EPRs at Jaitapur on its west coast south of Mumbai and launched efforts for construction of up to 20 GWe of domestic reactors.

India’s draconian supplier liability law continues to be an effective firewall in keeping American firms out of its nuclear market.

UK has new builder at Horizon

The United Kingdom suffered a setback in its nuclear new build as two German utilities backed out of the construction of up to 6 Gwe of new reactors at two sites. Japan’s Hitachi successfully bid to take over the project. A plan for a Chinese state-owned firm to bid on the Horizon project in collaboration with Areva never materialized.

Also in the UK, General Electric pursued an encouraging dialog with the Nuclear Decommissioning Authority to build two of its 300-MW PRISM fast reactors to burn off surplus plutonium stocks at Sellafield. The PRISM design benefits from the technical legacy of the Integral Fast Reactor developed at Argonne West in Idaho.

You can’t make this stuff up

In July, three anti-war activitists breached multiple high-tech security barriers at the National Nuclear Security Administration’s Y-12 highly enriched uranium facility in Tennessee. The elderly trio, two men on the dark side of 55 and a woman in her 80s, were equipped with ordinary wire cutters and flashlights.

Y-12 Signs state the obvious

The intruders roamed the site undetected for several hours in the darkness of the early morning and spray painted political slogans on the side of one of the buildings. They were looking for new artistic venues when a lone security guard finally stopped their travels through the plant.

The government said that the unprecedented security breach was no laughing matter, firing the guards on duty at the time and the contractor they worked for. Several civil servants “retired.” The activists, if convicted, face serious jail time.

None of the HEU stored at the site was compromised, but subsequent investigations by the Department of Energy found a lack of security awareness, broken equipment, and an unsettling version of the “it can’t happen here” attitude by the guards that initially mistook the intruders for construction workers.

The protest effort brought publicity to the activists’ cause far beyond their wildest dreams and produced the predictable uproar in Congress. The DOE’s civilian fig leaf covering the nation’s nuclear weapons program was once again in tatters.

So long Chu

Given the incident at Y-12, Energy Secretary Steven Chu, who came to government from the quiet life of scientific inquiry, must have asked himself once again why he ever accepted the job in Washington in the first place.

DOE Energy Secretary Steven Chu

Chu is expected to leave Washington. That he’s lasted this long is something of a miracle since the Obama White House tried to give him the heave ho this time last year after the Solyndra loan guarantee debacle, in which charges of political influence peddling by White House aides colored a half a billion dollar default on a DOE loan by a California solar energy company.

The predictable upswing in rumors of who might be appointed to replace him oozed into energy trade press and political saloons of the nation’s capital.

Leading candidates are former members of Congress, former governors, or just  about anyone with the experience and political know how to take on the job of running one of the federal government’s biggest cabinet agencies. It’s a short list of people who really can do the job and a long list of wannabes. With shale gas and oil production on the rise, having a background in fossil fuels will likely help prospective candidates.

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Dan Yurman published the nuclear energy blog Idaho Samizdat from 2007–2012.

Post-election outlook for nuclear energy

By Jim Hopf

In my September post at the ANS Nuclear Cafe, I discussed the Democratic and Republican party platforms, along with their potential impacts on nuclear energy. With the 2012 U.S. elections now behind us, this post provides a post-election follow up, and discusses the impacts of the election results on nuclear’s prospects over the near- to mid-term.

With the reelection of Barrack Obama, and minor gains by Democrats in the House and Senate, the election results portend a continuation of the status quo, for the most part. Impacts of the election in various areas that may impact nuclear’s prospects are discussed in the sections below.

Yucca Mountain

I’ve always taken great issue with the Obama administration’s actions on Yucca mountain, and maintain that, at a minimum, the Nuclear Regulatory Commission licensing process should be finished, even if a political decision is made to not pursue the project. It is clear to most observers that the NRC technical staff (which had completed its review) was about to conclude that the repository met all the technical requirements, before the process was terminated near the finish line, for political reasons. The public has a right to know that Yucca would have met all the requirements, and that yes indeed there is a viable, acceptable technical solution to the nuclear waste problem.

With the reelection of Obama and with (Democrat) Harry Reid remaining as Senate majority leader, the current status quo on Yucca Mountain will remain. Reid will continue to block funding for completion of NRC licensing, and the (Obama/Reid-appointed) NRC chair will likely cooperate with the effort to stop the process. As was the case before the election, whether the NRC will complete the licensing process will be primarily determined by the courts.

Yucca Mountain is one area where a Romney administration may have been more helpful to nuclear, but it’s not clear whether there would have been any meaningful difference. Romney was also making anti-Yucca statements (such as “states should have the right to decide if they want the repository”) during the campaign. Republicans winning the Senate would have made a far larger difference, as Reid would have lost the Majority Leader position, which is essential to his ability to block Yucca. On the other hand, if the president is not interested in changing the situation, even that may have not made much difference.

It seems that completion of the licensing process (the best we can hope for in the near term) is up to the courts at this point, and would have remained so regardless of who won the election. Also unclear is whether the lack of progress on the waste issue is having a significant effect on how much nuclear power there will be over the near-to-mid term. I’ve grown to believe that it is not as critical an issue as I formerly thought.

Fukushima–related upgrades and regulations

Whereas the anticipated regulations and required plant upgrades that will result from NRC’s response to Fukushima will add costs for existing nuclear plants (and to a small extent, new plants), it is unlikely that the outcome of the election would have had any significant impacts on those regulations. No parties or candidates have made any significant statements on the NRC’s actions in this area.

Nuclear plant loan guarantees

The Obama administration had supported increasing the nuclear loan guarantee volume by a factor of several (to over $100 billion) but could not get it through Congress. On the other hand, the Obama administration has been dragging its feet in actually approving any loan guarantees, even for the Vogtle and Summer plants. With the current budget situation, any increase in loan volume is unlikely.

It is unlikely, however, that Romney or the Republicans would have been better in the area of nuclear loan guarantees. Although the Republicans are ostensibly pro-nuclear, many in the Republican party are opposed to loan guarantees for any energy projects.

Finally, the overall impact of the nuclear loan guarantees is no longer clear. Indications are that other factors such as lack of power demand and low natural gas prices, as opposed to the lack of loan guarantees, are the primary reason that no plants other than Vogtle and Summer (and Watts Bar) are going forward. As for the Vogtle and Summer projects themselves, they appear to be going forward even without the government loan guarantees.

Climate change policies

Although the Obama administration is not planning to propose a cap-and-trade system or a carbon tax in the near future, Obama has stated that the nation needs to have a “conversation” about climate change, implying a desire to develop some type of policy.

It seems clear that the chances of some type of policy or progress on climate change are far greater under Obama and the Democrats then they would have been under Romney and the Republicans, who had explicitly promised to block all such efforts. For example, the chances of the Clean Energy Standard policy (being debated and developed in Congress) moving forward would definitely be greater under the Democrats. Any type of climate change policy that creates a disincentive to emit CO2 would be tremendously beneficial to nuclear, particularly over the longer term.

Although climate change had fallen off the agenda in recent years, and in the last election, there are reasons to believe that it will (again) rise in importance. Increasing numbers of Americans believe that climate change is a serious issue. As the economy improves, issues like the environment are expected to become more important in voters’ minds. Also of note is the fact that even some conservative organizations are starting to consider a CO2 tax as a better approach than cap-and-trade, as well as a potential source of government revenue in lieu of increased income tax rates (as one example).

Election impacts on coal

It is clear that the reelection of Obama has hurt coal’s future prospects. The coal companies themselves, as well as the stock market, confirm this. Coal company stocks fell substantially after the election, and some coal companies have laid off workers.

Under Obama, the Environmental Protection Agency is in the process of significantly tightening up air pollution requirements, which would significantly impact the oldest (and dirtiest) coal facilities. To stay in operation, such plants would have to spend large amounts of money on air pollution controls. Given the current low cost of natural gas, these requirements will render those facilities uneconomic, and many are expected to close. With Obama’s reelection, the EPA is also expected to proceed with a rule that requires all new power plants to emit no more CO2 than a typical gas-fired plant; a requirement that essentially precludes the permitting of any new coal plants.

In contrast, Romney (and the Republicans) campaigned on the promise to stop any tightening of air pollution limits, and perhaps even rolling requirements back. Their message was that they would act not only to keep existing coal plants open (including the oldest ones), but to increase the use of coal in the future. They emphatically opposed any efforts to reduce power-sector CO2 emissions.
With respect to any impact on nuclear’s future prospects, policies that result in the closure of old coal plants would help, the only question being how much. Any retired coal-fired generation will be replaced by gas-fired generation (as opposed to nuclear), at least over the short to mid-term. Over the longer term, however, the resulting increase in gas demand will result in higher natural gas prices, which in turn would make nuclear more competitive.

Regardless of any impact they may eventually have on nuclear, these air pollution and global warming policies are the right thing to do, in my personal opinion. Nuclear professionals and advocates need to ask themselves why, specifically, they support nuclear, i.e., why it’s important. Given our abundant reserves of coal (let alone gas), coupled with coal generation’s low cost, the economic and energy security arguments for nuclear may appear relatively weak—if they come from someone who doesn’t care so much about the environment, and therefore would have no problem with expanded fossil fuel use. The most compelling argument for nuclear (for me, anyway) has always been its environmental benefits. By extension, if one cares about air pollution and global warming, these policies are something to be celebrated, whether or not it is nuclear that replaces the old, dirty coal plants.

Wind tax credit

The reelection of Obama, and the Democrats’ small gains in Congress, make it somewhat more likely that the (~2 cent/kW-hr) wind energy production tax credit will be extended, for at least some period of time. Romney had stated that he would seek to end the tax credit, whereas Obama supports it. Even now, however, it is not clear that it will be extended, given the great need to cut government spending. This is true despite the fact that many Republican lawmakers, from farm states mainly, support the tax credit.

The wind power tax credit has some degree of negative economic impact on both new nuclear plant projects and existing plants. Wind often produces surges of power at times of very low power demand, which can actually lead to a negative market price for power over some time periods. The tax credit makes it still profitable to run the windfarms even under such conditions. These situations have a significant negative economic impact on existing nuclear generators in the region, which cannot shut down over short time periods. These problems are particularly acute in Illinois, where wind is being introduced and there is a large amount of nuclear generation (without much fossil generation that can be cut back in times of low wind demand). As a result, Exelon (the regional utility) has changed its position and is now opposing the extension of the wind power tax credit.

One final potential impact of the wind tax credit is that since it will result in more wind power, gas demand will be somewhat lower in the future, which may result in lower natural gas prices that would in turn make nuclear somewhat less competitive.

A legitimate issue that nuclear supporters should have with the wind tax credit is the question of fairness, i.e., why one non-polluting form of energy should benefit from large subsidies and (often) outright government mandates, whereas another, nuclear, does not. Yes, new nuclear plants also get a tax credit, but unlike with wind, the credit is limited to just the first few plants. Another issue is whether wind is being sufficiently penalized for its intermittent nature (producing power when it is least needed). Perhaps having the tax credit not apply during periods of very low demand, or some type of mechanism to support the electricity price during such glut periods, should be in order.

Natural gas

I have saved the best for last. Most experts agree that the single most important factor that affects nuclear’s future prospects is the price of natural gas. If gas remains at current (very low) prices over the long term, not only will few, if any, new nuclear plants be built (beyond Vogtle and Summer), but even the continued operation of existing plants may be threatened.

A perfect example of this is the recently announced closure of the Kewaunee nuclear plant. The plant lies within a “merchant” market, where the price of electricity is determined by the “last” supplier (highest variable cost), which is usually a gas plant. With the low price of natural gas, market prices for power in the region are very low. At current prices, Kewaunee is losing money. (This came as a shock to me, as the whole idea with nuclear is that whereas the initial capital cost is high, the operating cost, once built, is extremely low, low enough to easily compete with anything—or so I thought.)

If anything, the reelection of Obama and the Democrats somewhat increases the chances that the price of natural gas will increase in the future. They are considering tightening regulations on the fracking process, to a greater extent than the Republicans would have (although neither party is showing a significant degree of interest). Also, as I discussed earlier, Obama’s policies concerning coal (and perhaps global warming in general) can only lead to higher demand for gas, which would act to increase prices.

It seems that the common wisdom today is that natural gas prices will remain low for a very long time. Others have a different view, although they seem to be in the minority, at present. To me, it seems clear that gas prices will increase significantly in the future, at least from today’s historic lows, for several reasons:

First, the cost of natural gas is extremely sensitive to the balance between supply and demand. As the economy improves, and gas demand increases (especially if large numbers of old coal plants are retired), gas prices will increase, a lot. Second, gas costs several times what oil does, on an energy equivalent (per BTU) basis. Given that these two fuels are supposed to be largely interchangeable, this situation cannot last. (Right now several proposals for using natural gas for transportation are being explored.) Third, natural gas costs 3–4 times as much (as current U.S. prices) in Europe and 5–6 times as much in Japan. This is also a situation that won’t last, and plans are being made right now to export U.S. gas to world markets. And finally, today’s natural gas prices are far lower than what it actually costs to extract the gas (about half, actually), and producers are losing money hand over fist. This, again, is a situation that cannot last.

Summary

The election results largely preserve the status quo concerning policies that affect nuclear and energy in general. So, as to whether or not Romney and the Republicans would have been better or worse for nuclear, it’s a mixed bag of offsetting effects. In any event, few new nuclear plant projects are expected over the short term due to the current low price of natural gas in the United States. Over the longer term, nuclear’s future looks significantly brighter, especially if a serious global warming policy is (eventually) implemented.

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Hopf

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

Spent Fuel Pool at Oyster Creek

By Will Davis

As the Eastern half of the United States falls under siege by Hurricane Sandy and combined weather fronts—which together are being termed ”Frankenstorm”—the nuclear community is targeted by nuclear opponents keen on capitalizing on this severe weather event. A recent piece quoting Arnold Gundersen asserts that Oyster Creek Nuclear Generating Station is facing serious problems should it lose offsite power, saying essentially that the plant will be unable to provide cooling for the spent fuel in its spent fuel pool.

This allegation is without merit.

This document—a memorandum from the Nuclear Regulatory Commission  staff to the then-operator of Oyster Creek—spells out the spent fuel pool (SFP) cooling arrangements in place back in 2000. It includes the following description of the SFP cooling arrangements:

Make up water to the SFP is normally provided by the condensate system from the condensate storage tank (CST) which has a nominal capacity of 525,000 gallons. The condensate pumps can provide 250 gallons per minute (gpm) with one pump operating or 420 gpm with two pumps. Additional makeup can be provided from the demineralized water storage tank (nominal capacity 30,000 gallons) by connecting the demineralized water transfer pumps to the SFP with hoses. The fire protection system can also provide makeup from the fire pond to the CST using the 2,000 gpm diesel driven fire pumps through a permanent connection.

The SFPCS {Spent Fuel Pool Cooling System} removes decay heat from fuel stored in the SFP through its associated heat exchangers to the reactor building closed cooling water (RBCCW) system. The SFP water is maintained within its TS limits by these systems. The SFPCS consists of two SFP pumps, two SFP shell and tube heat exchangers, two augmented fuel pool pumps, and one augmented fuel pool plate and frame heat exchanger. In addition, the SFPCS also includes interconnections with the condensate demineralizers and the condensate systems which filter and demineralize the SFP water as well as provide makeup water to the SFP. The SFPCS operates continuously to maintain the SFP water temperature at or below the Oyster Creek TS limit (maximum of 125 degrees Fahrenheit (F)).

As we can see, a total loss of offsite power (LOOP) scenario has clearly been considered—otherwise, diesel fire pumps would not have been mentioned.

Oyster Creek Nuclear Energy Facility

Plants designed to handle spent fuel pools during loss of offsite power

Oyster Creek, like all other operating U.S. nuclear plants, was built to design considerations (10 CFR 50 Appendix A) that set limits on design that includes the protection of spent fuel pool from events both man-made (operational) and natural. The plant has been designed to handle the full heat load of the spent fuel placed in the pool—even with a loss of offsite power.

Spent fuel pool cooling has received greater attention since the Fukushima Daiichi accident; during that accident and for some time after, many had wrongly assumed and asserted that the spent fuel pools were in dire condition. In fact, some even claimed that Fukushima Daiichi Unit 4 was going to collapse and that the spent fuel was going to trigger a cataclysm. Those allegations were refuted at the time, multiple times,  and have been proven false.

Even though early post-Fukushima assumptions about spent fuel pools were overly unrealistic, the NRC has emphasized SFP cooling and level measurement as a part of its post-Fukushima action plan. Many experts and the Nuclear Energy Institute consider this approach sensible. NEI points out, however, via NEI Nuclear Notes that moving SFP actions to Tier 1 in no way implies that operating U.S. nuclear plants aren’t already safe. Read that post here.

The Safety Evaluation Report related to license renewal of Oyster Creek at the NRC contains the following information about Oyster Creek’s spent fuel cooling system:

The SFPCS (Spent Fuel Pool Cooling System) is designed for both normal and accident conditions of loss of offsite power coincident with a single active component failure.  The augmented SFPCS is designed to provide a seismically qualified cooling loop capable of providing cooling during such conditions.

As if that were not enough:

Exelon – Oyster Creek Safety and Emergency Planning Fact Sheet

Clearly, there is provision for SFP cooling at Oyster Creek using two SFP systems—the one that was originally installed and an augmented system installed when the pool capacity was increased—and also it’s a fact that the plant, like all others in the path of the storm, is and has been well aware of the approach of this storm and has even more personnel (and NRC inspectors) on site than usual, making full preparation for any event. “Any event” includes extended loss of offsite power.

Oyster Creek has multiple cooling systems for spent fuel pool

UPDATE:  Exelon has re-confirmed to the American Nuclear Society by telephone and e-mail that Oyster Creek does in fact have numerous, redundant cooling systems for the spent fuel including closed-loop and service water systems. Exelon tells us that if required, two locomotive–sized diesel engines are ready and standing by should offsite power be lost, to provide power to those two backup systems during the refueling outage should an extended LOOP scenario arise.

Exelon has, as expected by many, declared an Unusual Event at Oyster Creek due to the rising water levels. Below are excerpts from Exelon’s press release on this declaration (emphasis added):

 Oyster Creek Generating Station Declares Unusual Event

Lowest of four NRC emergency action levels reached due to high water levels

Forked River , NJ (October 29, 2012) Exelon Nuclear declared an “Unusual Event” at Oyster Creek Generating Station at 7 p.m. today after water levels in the plant’s intake structure reached higher than normal levels.

This is an anticipated declaration required by procedures and is the result of Hurricane Sandy’s impact on the region. There is no challenge to the safety of the plant. Oyster Creek is currently shut down for planned maintenance and refueling.

Oyster Creek is a robust and fortified facility, capable of withstanding the most severe weather. When the storm was identified, operators performed a host of plant inspections to ensure that all safety systems were operational and that outside equipment and materials were properly secured.

An Unusual Event is the lowest of four emergency classifications established by the U.S. Nuclear Regulatory Commission. There is no danger to the public or plant employees associated with this declaration.

Exelon Nuclear has notified all appropriate federal, state and local emergency response officials of the Unusual Event.

Oyster Creek is about 60 miles east of Philadelphia in Ocean County, New Jersey. The plant produces 636 net megawatts of electricity at full power, enough electricity to supply 600,000 typical homes, the equivalent to all homes in Monmouth and Ocean counties combined.

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For more information

Below is a brief video interview with the Nuclear Energy Institute‘s Everett Redmond, director of Nonproliferation and Fuel Cycle Policy. He breaks down in straightforward language the purpose and design of spent fuel pools to store used fuel at nuclear energy facilities. This is a basic overview that does not address specific nuclear energy facilities.

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Will Davis is a writer and Social Media consultant for ANS, is a Contributing Reporter to Fuel Cycle Week, owns and writes the Atomic Power Review blog, and is a former US Navy Reactor Operator, qualified on S8G and S5W reactor plants.

ANS staff members also contributed to this report and compiled additional resources for readers.

Video: NRC Inspection at Davis-Besse Nuclear Power Station

The Davis-Besse nuclear power plant, operated by FirstEnergy Nuclear Operating Company, is located on the shores of Lake Erie about 20 miles east of Toledo, Ohio. The 908-MWe pressurized water reactor came online on July 31, 1978.

On October 1, 2011, the plant shut down so that a new reactor vessel head could be installed. During preparations for installation, FirstEnergy identified cracks in the outermost shield building, the concrete structure that protects the steel reactor containment vessel from adverse outside conditions.  The U.S. Nuclear Regulatory Commission has conducted numerous inspections of the shield building and determined that the cracks do not affect the integrity of the shield building, and that the plant is safe for continued operation.

This interesting video released by the NRC takes viewers inside Davis-Besse to see the installation of the new reactor head, and includes interviews with NRC inspectors who oversaw its installation and testing, and conducted the safety reviews of the reactor shield building.

More detailed information at the NRC blog.

FirstEnergy recently opened a $6 million advanced Emergency Operations Facility dedicated for Davis-Besse emergency training and exercises.

Davis-Besse is under consideration for a 20-year operating license renewal from the NRC. Despite the NRC’s determination that the plant is safe for continued operation, the cracks in the shield building concrete remain a point of contention in regard to the license renewal, and the Atomic Safety and Licensing Board will hear oral arguments November 5–6 by intervenors on the issue.

Update on Nuclear Waste Confidence Court Ruling

By Jim Hopf

As I discussed in a June 20 ANS Nuclear Cafe post, a federal appeals court rejected the Nuclear Regulatory Commission’s new nuclear Waste Confidence rule, and ordered the NRC to perform a more thorough evaluation that addresses potential risks and health and environmental impacts of very long term storage of nuclear waste at nuclear sites (until a final disposal option is developed).

As discussed in that post, anti-nuclear organizations were hopeful that the court ruling would lead to a halt in NRC licenses for new plants and plant life extensions, while others believed that the impact would be minor, the main result simply being more work to be done by the NRC. Recent events have shown both sides to be right, to some degree.

NRC’s response to the court ruling

In September, the NRC instructed staff to develop an environmental impact statement (EIS) to evaluate very long term storage of used nuclear fuel, and a revised Waste Confidence ruling. The NRC expects to complete the work in ~24 months. The NRC’s analysis will address issues raised by the court, including the impact if a repository is never built, as well as risks to spent fuel pools from leaks or fires.

The upshot is that the NRC believes that it can address the issues raised by a court, within a reasonable time period.

Suspension of licensing activity

On the other hand, and to the delight of nuclear opponents, the NRC also announced that it will not issue any final licenses for new nuclear power plants or 20-year life extensions (for existing plants) until the revised EIS and Waste Confidence ruling are completed and the court’s issues are addressed.

The NRC’s decision appears to affirm the nuclear opponents’ position that new plants or extended operation of existing ones cannot be justified in the absence of a valid Waste Confidence determination. On the other hand, most experts (as well as the NRC) believe that the issue can be resolved with additional analysis and evaluation. At worst, some additional measures and costs may be involved, such as moving more fuel from spent fuel pools to dry storage casks, spent fuel pool modifications and upgrades, more rigorous long-term monitoring of dry storage casks, or the possibility of repackaging stored spent fuel, if necessary.

Limited impact

As serious as it sounds, the impacts of the suspension of licensing are minor to non-existent, at least over the short-to-mid term.

For both new plants and plant life extensions, the NRC has stated that it will continue with all on-going work on license applications. The NRC will simply not formally release any final licensing decisions. Thus, the NRC’s completion of work related to any license applications will not be delayed. The only parties that would be affected are those that were expecting final licensing decisions over the next ~two years.

With respect to new plants, both of the reactor projects at Vogtle, in Georgia, and Summer, in South Carolina, can still go forward, since they have already received their final construction and operating licenses (COLs). A few other plant projects (e.g., the Levy project in Florida) are in the licensing process, but most if not all of these other projects are currently planning to only obtain the license, and have not decided (yet) to proceed with construction. It is unlikely that any projects other than Vogtle and Summer would have decided to start construction over the next two years anyway (for several reasons, including lack of demand for new capacity and low natural gas prices). Thus, the two-year hiatus in (final) licensing decisions is not expected to have any impact on new plant projects.

With respect to existing plants, there are several plant life extension applications before the NRC. In theory, there are many such applications that would be affected by the two-year licensing freeze. However, plants are allowed to keep operating while life extension applications are in NRC review (and would only be required to shut down in the event of a formal rejection of a life extension application by the NRC). Thus, the freeze in final licensing decisions will not result in any plant shutdowns, or any other impacts on such plants.

For the above reasons, the two-year freeze in final licensing decisions by the NRC is not expected to have any impact on the industry. The only potential impact will come ~two years from now, after the completion of the revised EIS and Waste Confidence ruling, in the form of additional requirements related to used fuel storage.

My perspective

As I discussed in my earlier post, I find the court’s characterization of stored used nuclear fuel as a significant public health and environmental risk to be absurd, given the perfect, several-decade record of (dry and wet) fuel storage, and the lack of potential impact from dry fuel storage casks under any scenario. Unlike, say, fossil-fueled power generation, stored nuclear fuel has never had any impact at all on public health or the environment, and almost certainly never will.

As for the environmental impact analysis, I can sum it up in one sentence: “The public health risk and environmental impact from extended storage of used nuclear fuel is negligible compared to the impacts of the fossil-fueled power generation that would be otherwise used, in place of nuclear generation that was shut down or never built due to lack of ‘confidence’ in used fuel storage.”

I’m still waiting on a similar “waste confidence” evaluation for fossil-fueled plants, or a plan to capture, contain, and store all of their wastes/pollutants, for as long as they remain hazardous. How can our society get it so backwards in terms of which energy sources have a serious, intractable “waste problem”, and which source is the only one with a valid, acceptable long-term plan?

I work in the dry storage area, and I know that the maximum potential release from a dry storage cask that could result from any form or system degradation, any type of accident, or (even) any potential terrorist attack, would not have significant off-site consequences (certainly nothing that would approach even the daily impact from U.S. fossil-fueled generation).

We have already started detailed evaluations of the issues related to very long term dry fuel storage. Currently, opinion is that no significant degradation of the fuel assemblies is expected to occur, even over 100 years or more of dry storage. As the fuel decays, temperatures inside the cask will decrease (as will radiation levels). This reduces the driving force behind many potential fuel assembly degradation mechanisms. The metal components of dry storage systems, including the canisters that contain the assemblies, are expected to hold up well (and already have, over decades of storage). Whether the concrete vaults/silos (storage casks) that the canisters are placed in will be able to hold up over the very long term is somewhat less clear. That would be a problem that is easily solved, however, as the inner canister could simply be extracted and placed within a new concrete container.

Based on my dry storage experience, it seems to me that, along with (possibly) requiring some spent fuel pool upgrades, all the NRC should have to do to adequately resolve the court’s concerns is require some additional monitoring of dry storage casks, along with (perhaps) some additional money to be set aside by utilities to cover any potential issues that may occur down the road (including the possibility of some repackaging, decades from now).

One thing that should be obvious is that storage of used nuclear fuel is “acceptable”, even if it is assumed to remain on the nuclear plant site indefinitely, since any public health risks and environmental impacts are negligible compared to those associated with fossil-fueled power generation (gas as well as coal).

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Hopf

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