Why Are U.S. Nuclear Plants Better Prepared for Emergencies Than Fukushima? Here's a Checklist.

Tom Kauffman

The following is a guest post written by NEI's Tom Kauffman. Though Tom works in NEI's media relations shop, he also spent 23 years working at Three Mile Island, seven of those as a licensed reactor operator.

Former NRC Chairman Dale Klein was justified in criticizing an anti-nuclear panel’s comparison of the potential of an accident at nuclear energy facilities in New York and Massachusetts with the 2011 accident at Fukushima Daiichi. “Comparing the accident at Fukushima Daiichi to a hypothetical accident at Indian Point or Pilgrim is intellectually dishonest and resembles the classic fear mongering intended to create unnecessary anxiety," Klein said. "Comparing the US nuclear power plants to those that have not added new safety systems and procedures is simply wrong.”

As the former Chairman points out, the U.S. and Japanese nuclear industries have very different approaches to nuclear safety. The differences developed over several decades and are profound. Below is a comparison of some of the key safety factors.

	U.S.	Japan
REGULATORY STRUCTURE	NRC is a single, transparent, independent federal agency.	Had four agencies with overlapping authorities. Two promoted the industry. An independent safety regulator was formed post-Fukushima.
PLANT OPERATIONS COMMAND & CONTROL	All decisions rest with the on-duty, federally licensed senior reactor operators.	For some key safety-related decisions, plant operators seek the approval of government officials.
REACTOR OPERATOR LICENSING	All reactor operators are individually licensed by the NRC and must fully requalify every two years to maintain their license.	Only shift supervisors are licensed by regulator. Others are certified by company.
CONTROL ROOM SIMULATORS	All reactor operators are required to be trained and tested on a full-scale replica simulator that is identical to their facility’s control room.	Replica simulators are not required.
SAFETY CULTURE	Industrywide safety culture program encourages all workers to be engaged in safety and to freely report safety concerns.	No established safety culture program.
INDUSTRY SELF-POLICING	Institute of Nuclear Power Operations (est.1980) continuously monitors industry safety and presses for continuous improvement.	An entity modeled after INPO is being formed post-Fukushima.
POST 9/11 ACTIONS	Enhanced security and added safety equipment to mitigate effects of extreme events such as large fires, explosions and aircraft impact.	No significant post 9/11 protective actions.
EMERGENCY PREPAREDNESS	Comprehensive, federally mandated emergency response plans require quarterly, full-scale drills and biennial graded drills involving local, state and federal authorities.	Emergency planning well below U.S. standards. No required or graded emergency drill protocols.

For more information on how the U.S. nuclear industry differs from Japan's, watch this video featuring NEI's Tony Pietrangelo.

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What You Won't Hear When Gregory Jaczko, Peter Bradford and Arnie Gundersen Take to the Podium in New York and Boston This Week

Tom Kauffman

The following is a guest post written by NEI's Tom Kauffman. Though Tom works in NEI's media relations shop. He also spent 23 years working at Three Mile Island, seven of those as a licensed reactor operator.

This week in New York and Boston, anti-nuclear activists have scheduled panel discussions designed to scare the public into pressuring politicians into shuttering local nuclear power plants.

The members of the panel are:

• former NRC chairman Gregory Jaczko;
• Peter Bradford, former NRC commissioner; and 
• anti-nuke extremist Arnie Gundersen, an engineer who never lets science or facts get in his way.

So what can you expect to hear from this trio? We figure it's more or less a combination of the three following assertions: 1) The nuclear accident in Japan can happen here. 2) All U.S. nuclear energy facilities are unsafe. 3) All U.S. reactors should be permanently shut down.

On the other hand, there are some facts they are sure to ignore:

• Not one person in Japan was killed due to the nuclear accident at the Fukushima Daiichi nuclear facility. And despite Gundersen's prediction that "about a million cancers," would result from the accident in Japan, the U.N. Scientific Committee on the Effects of Atomic Radiation determined that no significant radiation related health issues have been found in Japan or elsewhere. 

• During the accident in Japan, Gregory Jaczko's claim that the Unit 4 used fuel pool was empty was later proven false by NRC staff. This mistake, along with his resistance to correct it, likely made things worse for the Japanese. 

• All U.S. nuclear energy facilities are prepared for extreme events. Despite this, not one U.S. nuclear energy facility is subject to earthquakes or tsunamis the magnitude of those that caused the accident in Japan. 

• After more than a half-century (more than 7,500 reactor-years) of operation, including the accident at Three Mile Island, there is no evidence that any member of the public has been harmed by the radiation from any U.S. nuclear energy facility. 

• Gregory Jaczko’s call for a 50-mile evacuation zone around the Fukushima plant during the Japan accident was proven to be unnecessary and put people at risk. 

• The NRC has determined there is no scientific basis for expanding the 10-mile-radius Emergency Planning Zone (EPZ) around U.S. nuclear power plants. 

• The U.S. and Japanese nuclear energy industries are profoundly different in their approaches to nuclear safety with the U.S. industry effectively being decades ahead in levels of physical protection, regulatory control, safety culture and security. 

• While Gundersen likes to tout his experience as a "licensed reactor operator," others who have taken a closer look at his background have concluded he's engaged in puffing up his resume. And when he's challenged to show his work, he comes up empty.

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A Reader's Guide to the San Onofre Steam Generator Situation

For a number of weeks, we've been paying close attention to our colleagues at Southern California Edison (SCE) as they work to resolve a problem with the steam generators at the San Onofre Nuclear Generating Station or SONGS. Unit #2 and #3 at SONGS have been out of service for several weeks ever since leaks were detected in the steam generators of both units.

In a press briefing earlier this week, SCE's CNO delivered some good news, and said that there's a 50% chance that one or both of the plant's reactors will be back in operation by the Summer. The thing to remember here is that SCE and the U.S. Nuclear Regulatory Commission won't allow the plant's two reactors to restart until both parties are convinced that it is safe to do so.

For real time updates from SCE, please visit SONGSCommunity.com.

A number of outside observers, most notably Arnie Gundersen of Fairewinds Associates, have been commenting on the situation as well, with Gundersen publishing a pair of reports in conjunction with Friends of the Earth concerning the steam generators.

As the staff at SONGS continue to work on a solution, I thought it would be a good idea to collect a number of blog posts that taken together could serve as a rejoinder of sorts to Gundersen.

First, we should probably point to a post by Will Power at Atomic Power Review (APR) from last month that lays out the issue in very clear terms. Next, here's a post at NEI Nuclear Notes that Victoria Barq wrote after a conversation with Alex Marion, NEI's Vice President for Nuclear Operations. It covers the content of Gundersen's initial report.

More recently, Meredith Angwin, who normally blogs at Yes Vermont Yankee, provided a guest post at APR that dives a little deeper into the issue. To wrap things up, we should point to a blog post by Dan Yurman over at Idaho Samizdat that pulls on a couple of loose threads in Gundersen's reports.

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Arnie Gundersen Authors Another Shoddy Report

Nuclear consultants Fairewinds Associates and anti-nuclear activists Friends of the Earth are at it again with a new “report” that seeks to create concern, with little to no substance, over steam generator tube leaks at San Onofre Nuclear Generating Station (SONGS). The report, “Steam Generator Failures at San Onofre,” claims that without a thorough root cause analysis of why the plant’s recently installed steam generator tubes have become worn, that:

“…radioactive releases might be significantly larger than those that occurred after the January 2012 tube leak. Such an accident would cause implementation of the California emergency evacuation plan and closing of the San Clemente beach and Interstate I-5, potentially for an extended period of time.”

Fairewinds’ opinion misleads the general public to believe that the plant already released a large amount of radiation, which in fact, it has not. In a February 17 press release, Southern California Edison (SCE) clarified:

The radioactivity released to the atmosphere during the steam generator tube leak was barely measurable – 4E-5 millirems or 0.00004 millirems -- which is 200 times less than you would receive by having a smoke detector in your home for a year.

The steam generator tube wear leads to very minor leakage within the steam generator, which is something that can easily be detected by sophisticated monitors (as proven in this case) before any significant release of radiation would occur.

In addition, the statement implies that Southern California Edison (SCE), the plant’s owner, is putting Californians at risk, which is an even more egregious stretch of the truth. Not only does the nuclear industry make safety its top priority, but the people who work at the plant also live in close proximity and have a personal stake in the plant’s safe operation.

Given the fact that some news articles have already referenced the misleading Fairewinds report and other activist organizations are using it to push their anti-nuclear campaigns, I decided to get further analysis on this report with NEI’s Alex Marion, an electrical engineer who sits on the American Society of Mechanical Engineers Board on Nuclear Codes & Standards. In a nutshell, here’s what he had to say:

The issue at SONGS demonstrates the stringent safety practices in the U.S. nuclear energy industry. SONGS detected there was an issue with the steam generator tubes while implementing its rigorous inspection program, which has been accepted by the Nuclear Regulatory Commission. This involves examining the steam generator tubes and if degradation is found, then a more comprehensive examination is conducted that may include pressure testing of the tubes or sending samples of tubing to a metallurgical laboratory for independent evaluations. Once a root cause for the problem is discovered, the plant can fix the problem and restart. However, the plant will not continue operations until this analysis has been completed.

Why is a “root cause analysis” important?

Marion:

Basically, what you have is a large heat exchanger that uses heat from the primary reactor cooling water that flows within the thousands of tubes to transfer heat to a separate flow of water that surrounds the tubes. The water that flows outside of the tubes is converted to steam, which is used to drive turbine generators and make electricity. Because of vibrations that result from the water flow during plant operations, the tubes may rub against supporting structures resulting in “wear,” or thinning of the tube wall. This is a known form of wear that occasionally occurs, however, it was not expected to have occurred on as many tubes as had been found at San Onofre. A root cause analysis will determine what caused this unanticipated wear and how it can be minimized.

The Gundersen report suggests that the tube degradation is an anomaly and that the plant should continue to be shut down indefinitely. Is there a technical basis for this?

Marion:

We agree that the extent of wear in recently installed steam generator tubes is unusual. This is why we believe that you cannot effectively address the issue until a root cause analysis is completed, which is exactly what SCE is doing now, in close coordination with Mitsubishi and the Nuclear Regulatory Commission.

The report also calls into question SCE’s “like-for-like replacement” of its steam generators recently, suggesting that had the replacements been duplicates, “the problems that San Onofre is currently experiencing would have been dramatically reduced or entirely eliminated.” What does he mean by this?

Marion:

Utilities are allowed to replace equipment without prior NRC review and approval if certain criteria are satisfied. The criteria ensures that the replacement equipment still fulfills all safety requirements and does not deviate from the original plant design in a way that could compromise safe operation. Key features of the replacement steam generators at SONGS were modeled or tested to confirm their performance capability and structural integrity to demonstrate that they satisfied the design requirements.

In terms of “like-for-like” replacement, SONGS focused on the principle of form, fit and function. The new steam generator included a new, improved tube alloy versus the one which was previously used. They were able to demonstrate that with improved materials and enhanced design features, the steam generators could be installed and operate within the plant design limits with minimal modifications to the plant systems, instrumentation and controls.

Besides the fact that this report includes misleading claims for the general public, what is your overall conclusion about it?

Marion:

The report calls for Southern California Edison to keep SONGS shutdown until a thorough and systematic root cause analysis has been completed. That is precisely what is occurring now. The plant will remain shut down until the root cause is established and addressed and the NRC deems it can safely restart.

Once again, Fairewinds and its counterparts at Friends of the Earth have created a report that does little other than advance their anti-nuclear agenda. Their tactics, which unfortunately are picked up in news media and further disseminated by flights of television advertisements, do a disservice to the public by mischaracterizing the strong safety record of the U.S. nuclear industry.

The Nuclear Regulatory Commission has documented actions that must be taken before SCE is permitted to restart the San Onofre reactors. The company must demonstrate to the NRC that 1) the cause of the tube wear in both steam generators is well understood and 2) it will appropriately address the issue in order to ensure safe operation. Elmo Collins, the head of the NRC’s West region office, said:

Until we are satisfied that has been done, the plant will not be permitted to restart.

San Onofre is a safe nuclear plant and is a vital contributor to California’s electricity supply. Learn more about how Southern California Edison is working diligently to identify and fix the problem with its steam generator tubes in a new video with the company’s president Ron Litzinger.

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When Asked for Proof, the Associated Press and Arnie Gundersen Come Up Empty

It's been a full week since we first raised some questions about a claim made by Arnie Gundersen about soil samples he took in Japan recently. Gundersen claims the lab results he obtained indicated that the soil would be classified as radioactive waste here in the U.S. -- a statement that was reported by the Associated Press in a subsequent story. We had our doubts about the story, so NEI decided to do some investigating of its own.

24 hours later, we sent an email to the AP asking questions about how they went about reporting the story. We wanted to know how they were able to verify Gundersen's claims without working with a radiation protection professional who could properly interpret the data. We wanted to know why the story lacked any specifics about the lab results that Gundersen provided to the AP. We were also concerned that the AP identified Gundersen as a "nuclear consultant" when in fact he has long track record as an anti-nuclear activist and is currently employed by the state of Vermont as it seeks to close the Vermont Yankee Nuclear Power Plant.

AP responded to our note with a one-line response that there would be no correction, but didn't include any additional details concerning their reporting. We sent a followup note asking additional questions, and 48 hours later we've yet to receive any response. Yesterday, we sent a note to Gundersen challenging him to publish his test results so a third party might be able to verify them. We also requested the name of the lab and the name of a contact there so we could ask them some questions too. We heard back from Fairewinds this afternoon, and they're refusing to share the results of the lab tests with us.

So what can we learn from all this? First, when it comes to the AP, there seems to be a surprising lack of consistency in generally accepted standards of journalism. According to the Society of Professional Journalists Code of Ethics, reporters should "Test the accuracy of information from all sources and exercise care to avoid inadvertent error." From where we sit, there isn't any proof that the AP did anything to verify Gundersen's claims. Absent any specific test results or the identity of the lab that did the testing, one is almost forced to conclude that nothing was done to provide independent verification of Gundersen's claims at all prior to publication.

That's a pretty serious transgression if you ask me. After all, we're talking about a business where one old adage says, "If your mother says she loves you, check it out." Did Gundersen get a free pass? There's certainly no evidence to the contrary at this point.

POSTSCRIPT: This isn't the first time we've found fault with AP's reporting, and we're not the only ones who've identified flaws in their reporting on nuclear energy issues over the past year. Click here for a critique of the AP's reporting on nuclear energy that appeared recently at the Columbia Journalism Review. Our Chief Nuclear Officer, Tony Pietrangelo, sat down with NEI's John Keeley to discuss that AP series on our YouTube Channel.

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NEI to Arnie Gundersen: Share Your Test Results With Us

It's been about 24 hours since we sent our last note to the Associated Press concerning claims that Arnie Gundersen has made about some soil samples he took in Japan recently -- soil samples that he says would have been classified as radioactive waste here in the U.S.

While we've yet to get a response from the AP, we're going to open an additional avenue in our inquiry to get to the bottom of this story. Here's a note I sent to Arnie Gundersen at Fairewinds Associates a few minutes ago.

Dear Mr. Gundersen,

For the past week or so, many of us here at NEI have had serious questions concerning claims you made to the Associated Press about the soil samples you took in Tokyo. In order for us to resolve these questions, we'd like to ask you to provide us with a complete copy of the results of the test results you've been referencing. We'd also like to obtain contact information for the laboratory that you used, in order that we may be able to ask some follow up questions about the results and the exact methodology used to derive them.

We look forward to hearing back from you.

Thanks,

Eric McErlain
Senior Manager, Web Communications
Nuclear Energy Institute

I'll let you know if and when we hear back from him.

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AP on the NEI Challenge: A Response That Raises More Questions Than It Answers

Our readers will recall that last week we forwarded a note to some editors at the Associated Press concerning some irregularities I identified in a story that ran earlier in the week that contained a claim from anti-nuclear activist Arnie Gundersen that soil samples he took in Tokyo would be classified as low level radioactive waste in the U.S.

Late on Friday afternoon we received a one line answer from Cara Rubinsky, the AP's New England Editor: "We have reviewed your concerns and obtained a copy of the report from the lab that did the testing. We do not believe a correction is warranted."

Considering the details we shared in our message to the AP, the response seemed less than adequate. Here's the latest note I shared this morning with Rubinsky, AP Editor Evan Berland and reporter Dave Gram.

Hi Cara,

Please forgive me if I find your response to be insufficient, and hardly in the spirit or the letter of your organization's own published standards. In fact, your reluctance to provide precise details in response to my query raises more questions than it answers. With this in mind, I have several follow up questions that I must insist you answer:

1. Which laboratory performed the testing on the soil samples? Are you planning on publishing the lab report? Will you share the precise results with your readers? If not, why not? Why didn't the AP provide the precise results in your initial report?

2. How did Dave Gram go about reporting the original story? Did he obtain the lab report from Arnie Gundersen before he wrote the story, or did he simply rely on the statements that Gundersen made in the video posted at the web site of Fairewinds Associates?

3. Once you obtained the lab report, how did you go about verifying Gundersen's claims? Did Gram verify the results of the lab tests before the story was published, or did your team simply attempt to verify them after the fact once we had lodged our complaint? Your one line response to our initial query seems to imply that this might have been the case.

4. Did you consult a health physicist or other radiation protection professional at any time in the course of your reporting? If not, why not?

5. Why didn't you disclose Gundersen's role as a paid consultant for the state of Vermont? Were you and your reporter aware that Gundersen was being compensated for his work there? Other public reports claim that Gundersen is paid somewhere between $185 and $300 per hour for his work. Don't your readers deserve to know this in order for them to fully evaluate his claims?

I look forward to a more constructive response.

Best,

Eric McErlain
Senior Manager, Web Communications
Nuclear Energy Institute

As always, we'll keep you informed as to what happens next here.

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NEI Questions Associated Press Reporting on Gundersen Radiation Claims

By now I'm sure most of you have seen the AP story that ran earlier this week that quoted Arnie Gundersen saying that soil samples he took in Tokyo would be classified as low level radioactive waste in the U.S. Yesterday, I published a short blog post on the subject after speaking with NEI's Chief Health Physicist, Ralph Andersen.

After discussing the situation further with our media relations staff, we decided to take our case directly to the AP. The following note was sent to AP Editors Karen Testa and Evan Berland in Philadelphia this afternoon. We'll provide updates once we hear back from them.

Dear Ms. Testa:

I am writing to you in reference to an unbylined Associated Press story that appeared in a number of newspapers earlier this week with the headline, "Vt. consultant Gundersen: Tokyo soil is N-waste." The claim made in this article by Arnie Gundersen of Fairewinds Associates that soil collected in Japan could be classified as radioactive waste does not seem to have been independently verified, and hence should not have been published by the AP in violation of long established journalism standards. I believe a correction is in order.

In order to classify an object or a substance as radioactive waste, it takes more than simply triggering a Geiger counter. In the United States, the U.S. Nuclear Regulatory Commission has explicit guidelines. U.S. Nuclear Regulatory Commission licensees who need to dispose of items that have become irradiated -- in the case of nuclear power plants this often means water purification filters and resins, tools, protective clothing and other plant hardware -- have two options. In the first case, you can ship the waste to a certified disposal site. However, there are cases where the levels of radioactivity are so low that you can actually petition the NRC to dispose of it in an alternate manner.

However, if someone who is not a regulated licensee finds materials that have been irradiated, different regulations come into play. In the case of Japan, the levels of radiation found beyond Fukushima Prefecture -- and that includes the Tokyo metropolitan area -- are so low that our resident health physicist says that there are no regulations that would require the soil there to be disposed of. Furthermore, without seeing the report from the lab that Gundersen used, it would be impossible for any radiation protection professional to completely evaluate his claims. If a radiation protection professional with 40 years of experience in our industry wasn’t able to verify Mr. Gundersen’s claims, then how was your reporter able to do that?

In none of the articles that I have seen in various newspapers is there any specificity provided to readers on radiation levels—simply broad claims attributed to Mr. Gundersen. Furthermore, there isn’t any evidence in the articles that your reporter attempted to verify Mr. Gundersen’s claims with any independent third parties. According to the Society of Professional Journalists Code of Ethics, reporters should, "Test the accuracy of information from all sources and exercise care to avoid inadvertent error." In this case, it seems clear to us that the reporter failed to do either, which makes us wonder why it was ever published.

We would also dispute your characterization of Mr. Gundersen as merely a "consultant on nuclear issues." Mr. Gundersen has a long history of working as an anti-nuclear activist, and has a direct financial interest in seeing plants shut down, something he is already working actively to accomplish while in the employ of the state of Vermont as it seeks to close the Vermont Yankee Nuclear Power Plant. According to an article that appeared in the Burlington Free Press in February 2010 and is featured prominently on Mr. Gundersen's own Web site, he and his wife Margaret have been paid up to $47,000 by the state to provide just these sorts of consulting services.

Failing to fully disclose this financial relationship is a failure of reporting, and reinforces the need to vet any statement by Mr. Gundersen with a credible third party before publication.

During a conversation earlier this week with one of your Philadelphia-based editors, I learned that this article was written by AP's Dave Gram. Steve Kerekes, NEI's Senior Director of Media Relations, contacted Mr. Gram directly by e-mail about the story earlier this week. Mr. Gram has yet to respond -- a reaction that is in direct contravention of the AP's own Statement of News Values and Principles. They read, "Any time a question is raised about any aspect of our work, it should be taken seriously."

If the AP truly stands by that statement, one that was first committed to paper by your organization in 1914, you should immediately review Mr. Gram’s reporting and issue a correction to every AP member newspaper that ran the story.

Sincerely,

Eric McErlain
Senior Manager, Web Communications
Nuclear Energy Institute

Please recall that this is not the first time that we've taken issue with the AP's reporting -- and that others have noticed. More later.

UPDATE: At 5:42 p.m. I received an email from Cara Rubinsky, the AP's New England News Editor, saying that they were looking into our questions. If and when they provide any answers, I'll share them with you here.

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