Pulling Apart The Numbers on Jeff Donn's AP Story on Nuclear Safety Inspections

I wanted to return to Jeff Donn's piece from earlier this week concerning nuclear safety inspections. As I mentioned in a post from last night, I've been working with NEI's Jim Slider on taking a closer look at it. Jim is an old pro who has worked in the nuclear industry for more than 35 years, beginning his career at NRC's Office of Nuclear Reactor Regulation as a design basis accident analyst.

One of the first things I asked Jim about concerned the figures that Donn cited in his report. According to the story, the GAO report AP obtained a copy of said that NRC cited 10,776 "low-level" violations and 257 "higher-level" violations at U.S. nuclear plants between 2000 and 2012 (see page 3 of the AP story that was posted at ABCNews.com for the aggregate numbers).

Those data points puzzled Jim because according to the Reactor Oversight Process (ROP) that NRC instituted in 2000, NRC categorizes inspection violations from 1 (most significant) to 4 (least significant). The terms "higher-level" and "lower-level" simply aren't used. Given that AP refused to share the GAO report with us, we don't have any way to resolve this discrepancy.

The ROP was instituted to help plant operators and NRC identify problems with the highest level of safety significance in order to prioritize corrective actions (work on violations rated "1" first and take care of the rest in order of safety priority).

Now back to the raw numbers. There is one thing we can be sure of -- that when you add up 12 years (!) worth of statistics you can compile some scary numbers. I'm sure plenty of readers blanched at the figure of 10,776 "lower-level" violations cited by NRC inspectors. But when you realize that those violations were tabulated for 12 full years across 104 U.S. reactors, the numbers look a lot less scary.

Let's just do the math:

• 10,776 "lower-level" violations / 12 years = 898 violations per year / 104 reactors = average of 8.6 "lower-level" violations per year per reactor or less than .75" lower-level" violations per month.

To drill down further, let’s look at one plant site that's come under closer scrutiny of late, Entergy's Indian Point Energy Center:

• 380 "lower-level" violations/12 years = 31.66 per year /2 reactors = average of about 15 "lower-level" violations per year, or around 1.25 per month.

If you reported the numbers in that fashion, it would be a heck of a lot harder to scare the public. Given Donn's history of reporting on our industry, I can't say I'm terribly surprised the numbers were presented that way.

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NRC Shuts Down with Plant Safety Unimpaired

We haven’t talked much about the partial government shutdown because it isn’t our brief – and honestly, who hasn’t been bloviating about it lately? But it did lead the Nuclear Regulatory Commission to depend, at least for awhile, on money described as “carryover” funds to fully operate. Now, that’s gone, too, so the agency has suspended many of its activities:

Beginning on Thursday, we will not conduct non-emergency reactor licensing, reactor license renewal amendments, emergency preparedness exercises, reviews of design certifications or rulemaking and regulatory guidance.

Also suspended for now will be routine licensing and inspection of nuclear materials and waste licensees, Agreement State support and rulemakings, including Waste Confidence. This is just a short list of the actions we are prohibited from performing under Anti-deficiency Act restrictions.

Obviously, the NRC will continue to fund the resident inspectors at the individual facilities, because they’re safety related, what are considered “excepted function” employees. But about 3600 of 3900 employees are furloughed.

The NRC has a management directive that covers this, called Contingency Plan for Periods of Lapsed Appropriations (probably the most neutral way one could put the situation). The interesting part – to me – are the excepted functions that begin on page 13 of the pdf. There’s a lot of them, almost all related to safety and to ensuring that furloughed employees can be recalled to work if they are needed.

Here are just a few (there are 19 categories enumerated) beyond the resident inspectors:

Event Notification - Maintain readiness to accept notification calls regarding emergencies related to nuclear reactors or materials licensees.

Emergency Response - Perform early actions to activate Emergency Operations Centers and provide prompt analysis and advice to licensees and State decision makers. Includes incident response teams when called in for an event.

Site Operations - Maintain capability to send a team of experts to an emergency operations facility in the vicinity of an accident during the first hours following a major reactor incident.

As we’ve seen at other agencies such as the Centers for Disease Control, employees can be called back to work if needed (The directive discusses that, too.).

Once the government reopens, the commission will have to reschedule public meetings and reformulate dates to finish in process activities. NEI has been collecting a list of various meetings and hearings that have been postponed. That’s here. And the NRC blog will be doing this, too – the main NRC site is up but not updating for the duration.

I’ve seen some news reports that note the NRC furloughing employees – that’s the agency that ensures nuclear safety! – but really, the plants themselves do an excellent job of keeping safety a paramount concern and the NRC resident inspectors are still on duty. Reactors are not going to start rattling off their foundations at the news. It’s an unfortunate situation but not a fretful one.

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The NRC blog also answers a nagging question – why should it shut down at all if 90 percent of its funds are collected from licensees?

The bottom line is this: the NRC is not funded directly by the fees we collect. Fees collected by the NRC must be deposited in the U.S. Treasury, and the Congress provides us an appropriation.

So there you are.

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Former NNSA Deputy Administrator Blasts UT-Austin Nuclear Power Plant Security Study

Jerry Paul

Earlier this week, Jerry Paul, a former deputy administrator at the National Nuclear Security Administration, took aim at a study that came out of UT-Austin in August concerning nuclear power plant security.

The following passage comes from an op-ed that appeared in the Fort Worth Star-Telegram.

These are dangerous times. Nuclear security is a serious topic. It calls for assessment by serious people willing to do the hard work of real research.

There is nothing wrong with an academician or anyone else, including political activists, raising questions about public topics including security and even nuclear security. But it should be done in a responsible way and should be based on facts.

If conclusions are to be marketed as university “research,” they should be backed by credible data, authoritative sources’ expertise and peer reviews by unbiased experts.

Merely using the word “nuclear” in a title should not qualify written work for a lower standard of academic or journalistic scrutiny.

Previously, NEI issued a statement critiquing the study, noting many of the same point. NEI's John Keeley wrote a blog post of his own on the day of the report's release:

[A] report like the NPPP's today also fails to acknowledge that the very type of terrorist attack alleged as a vulnerability necessarily represents an enemy of the state incursion within our country. It isn't the obligation of any electric utility to defend against that; that's a job for the highest levels of federal national security.

For more on plant security, please consult NEI's website.

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Department of Defense Makes it Official: It Never Requested Nuclear Security Report from Nuclear Proliferation Prevention Project

Even though the mainstream media has moved on to other topics, there are still a number of other facts we've uncovered concerning the Nuclear Proliferation Prevention Project and its supposed relationship to the Department of Defense (DoD). Earlier this week, a reporter from NEI's Nuclear Energy Overview made a phone call to the Pentagon to get some clarification about the exact relationship between DoD and the published report. Here's an excerpt:

The U.S. Department of Defense did not request or validate a recent study on security at America’s nuclear energy facilities by the Nuclear Proliferation Prevention Project, a DOD official said.

“The Department of Defense did provide funding to the University of Texas at Austin, but did not request a report on that specific topic, nor did we validate its findings,” the Defense Department official said.

That's what we all suspected, but it's nice to get it on the record. We'll have more if events warrant.

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Some Final Thoughts on the Nuclear Plant Security Report by Nuclear Proliferation Prevention Project

As our readers will recall, we spent a considerable amount of time last week responding to a "study" issued by the Nuclear Proliferation Prevention Project on the security of nuclear energy facilities here in the U.S. Over the weekend, Jim Conca, a blogger for Forbes, took a closer look at the report, and made a number of interesting points (emphasis added in bold):

Those of us who have actually worked within the nuclear complex can tell you this study is grossly flawed. You need only read the limited source materials the author used in making her case and the absence of any references that contradict her thesis. And the lack of any expert review.

But if you read the press on this report, it sounds like it was actually commissioned by the “Office of the Secretary of Defense, which provided financial support for the research”. Inquiries to DoD say the report was not requested by the department. DoD just funds the program as a whole at the University and has no knowledge what’s coming out, until it’s out. We all know how this works.

There was no expert peer review, and the report only represents speculations of the student and her advisor. Even the cartoon on the front page is childish. The authors confuse nuclear weapons with nuclear energy, and have no first-hand knowledge of the security aspects of these facilities, since they have no access to such highly classified information.

But hey, just wing it! What could go wrong?

What’s stranger yet is that UT has an amazing number of nuclear experts, any one of whom could have reviewed this report, if asked. UT even has Dale Klein, former NRC chairman and nuclear security expert at the Pentagon (March 5, 2010 Speech). Why was he purposefully ignored?

One other important point that the media missed: Alan J. Kuperman, the head of the Nuclear Proliferation Prevention Project, isn't a neutral academic. In fact, he used to work for the avowedly anti-nuclear Greenpeace. The reference is included in his online bio.

One wonders why that reference wasn't mentioned during last week's media frenzy.

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NEI Responds to NPPP Report on Security at U.S. Nuclear Power Plants

A few minutes ago, NEI issued a statement concerning the security of the nation's 100 operating nuclear reactors. The statement comes in response to the release yesterday of a report by the Nuclear Proliferation Prevention Project. Here's the nut graf:

A report by a graduate research assistant at the University of Texas’ Nuclear Proliferation Prevention Project, released Aug. 15, is an academic paper developed for discussion among academia of the appropriate security levels at nuclear energy facilities. It is not a full assessment of security, nor does the author of the report have access to the safeguarded information that she would need to make such as assessment.

Like many such evaluations that examine the potential theft of uranium fuel from commercial reactors, the NPPP report fails to explain how attackers would be able to dislodge highly irradiated uranium fuel—800 to 1,200-pound, 18-foot-tall fuel bundles—and maneuver them from reactors, storage pools or steel and concrete containers past layers of elaborate security.

See our website for more information on nuclear power plant security.

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A Fresh Perspective on Nuclear Plant Security

Nuclear plants are widely acknowledged to be the best-defended facilities among the nation’s critical infrastructure. Critical, independent security experts share the industry’s belief that nuclear power plants are very well-defended, particularly in comparison to other elements of the nation’s industrial infrastructure. These include assessments from the the U.S. Federal Bureau of Investigation and the U.S. Department of Homeland Security.

The robustness of our industry's security isn't the easiest topic to address in great detail; appropriately, key security features for our sites are Safeguards Information. Still, this NEI video treatment of site security does offer some much-needed perspective relative to reports like today's from Nuclear Proliferation Prevention Project (NPPP).

There's a common/recurring flaw in many such evaluations of nuclear plant security: they ever fail to explain how attackers upon a nuclear power plant will be able to dislodge highly irradiated fuel, stored in tons-weighing 18-foot tall assemblies in reactors, pools, or in megaton dry casks, and maneuver them past layers of elaborate security measures.  

It's also important to remember that the U.S. Nuclear Regulatory Commission holds nuclear power plants to the highest security standards of any American industry, and industry exceeds those standards.

Approximately 9,000 extremely well-armed and highly trained security officers defend the nation’s 62 nuclear power plant sites. This is an increase of approximately 60 percent in the size of nuclear plant security forces since 9/11. These forces, a large percentage from military and law enforcement backgrounds, are drilled and tested regularly to ensure their readiness. Security officers receive hundreds of hours of training before they are deployed.

“Force on force” exercises that use dedicated teams of mock adversaries who specialize in attack strategies and tactics are part of the comprehensive oversight of industry security programs. Each plant site conducts quarterly and annual drills for each security team and undergoes an NRC-evaluated “force on force” exercise once every three years. Ongoing integrated response with federal, state and local law enforcement agencies ensures robust and extensive site protection plans. Based on its regular interactions with federal intelligence and law enforcement authorities, the NRC establishes the threat against which the industry must be protected and sets stringent standards that security forces must meet.

"U.S. nuclear plants were safe and secure before Sept. 11, 2001," Dave Kline, NEI's Director of Security, told me this morning. "They are even safer and more secure today, on the strength of more than $2 billion in additional security investment encompassing substantial physical changes and enhancements at plant sites; the hiring of thousands of additional, highly trained security officers; procurement of more sophisticated detection and access systems; and closer coordination with local, state and federal law enforcement, intelligence experts, and the military."

Some key considerations to keep in mind as you weigh allegations of lax security lobbed by academics versus the time-tested, ongoing assessments of this nation's top-ranking security professionals:

• Every commercial nuclear reactor in the country has conducted an aircraft impact assessment. 
• Industry's Design Basis Threat is reviewed periodically, and threat information is considered for DBT revision. DBT is Safeguards information, and as such can't have its attributes characterized.
•  Frequent Beyond Design Basis Threat drills are conducted, confirming margin in the protective strategies. 
• Contingency planning is in place for loss of large areas of a plant.  

Finally, a report like the NPPP's today also fails to acknowledge that the very type of terrorist attack alleged as a vulnerability necessarily represents an enemy of the state incursion within our country. It isn't the obligation of any electric utility to defend against that; that's a job for the highest levels of federal national security.   

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Regulation, Nuclear Energy and the Cafeteria

Do the regulated always feel overregulated?

One day’s delivery brings a directive stipulating that the sidewalks must be widened to permit two wheelchairs to cross paths without bumping. Another says the school cafeteria must be made accessible by elevator. Trees must be trimmed of branches six feet up their trunks, the orders go, and only government-certified technicians can change a light bulb on city property.

This is from a story in the Washington Post about a small French town (pop. 600) called Albaret-Sainte-Marie and its relationship with regulators in Paris. Now, except for the light bulb changing, all these directives could have truly beneficial outcomes, making life easier for a slice of the population, notably the disabled slice, but if various agencies are all putting their stamps onto the daily life of Albaret-Sainte-Marie simultaneously, the result could drain the town’s resources and kill the town’s overall civic effort to enable a better life for its people.

“We are being strangled,” [Mayor Michel] Therond complained, sifting through a pile of rules and regulations on his desk that he largely ignores — and many of which he does not even understand.

The larger argument against this is that it stifles economic growth, though the balance between beneficial regulation and economic activity is very tough to achieve. And there’s another large argument that edges us closer to the nuclear energy industry.

Therond said the problem has grown acute because France increasingly has a mind-set in which all risks must be eliminated, what is called “the principle of precaution.” “But you just can’t do that,” he objected.

No, you really just can’t do that, though some of the French regulation cited is geared not toward eliminating risk but improving access – those widened sidewalks and elevators to the cafeteria – and that’s an unalloyed good. Therond (or the Post) overreaches a little, but his point is good.

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In the case of nuclear energy and the NRC (and other regulators, including the industry’s safety watchdog, INPO), the issue isn’t to slough off anything that might make plants safer or reduce risk, but to implement the rules and regulations in an order that gets the most essential items done first. This would achieve the regulators goal while not bankrupting utilities or placing undo strain on the work force. It is possible without compromising safety – in fact, it improves safety by giving each item its due.

“This is our No. 1 issue right now,” NEI Senior Vice President and Chief Nuclear Officer Tony Pietrangelo said. “It’s not just an [NRC] regulatory issue. We want to make sure that the focus necessary on safety and reliability at the sites is not inadvertently diverted by the collective weight of meeting both industry and regulatory demands.”

Pietrangelo explained that a “cultural change” is needed to manage the cumulative impact of the regulatory demands made by the NRC and the activities of NEI, the Institute of Nuclear Power Operations [INPO] and the Electric Power Research Institute [EPRI] on the time and resources of nuclear energy facility staff.

And the NRC recognizes it.

Also this week, the NRC’s five-member commission approved the agency staff’s proposals for implementing process enhancements for the cumulative impact of regulation process as described in its October 2012 paper (SECY-12-0137)

And:

The commission’s memorandum directed agency staff to consider more deeply cumulative impact on licensees.

“The staff should continue to develop and implement outreach tools that will allow NRC to consider more completely the overall impacts of multiple rules, orders, generic communications, advisories, and other regulatory actions on licensees and their ability to focus effectively on items of greatest safety import,” the memorandum said.

This was at the March NRC Regulatory Information Conference, so it’s still a big topic.

In setting the industry’s priorities for the Department of Energy’s Fiscal Year 2014 budget request (what the industry would like to see, not necessarily what will come to pass), NEI’s President and CEO Marvin Fertel made a further push in testimony before the House Appropriations Committee:

The industry welcomes the oversight of the NRC by Congress to ensure that the agency effectively prioritizes its activities, based on safety significance, and achieves closure on issues in a timely manner.  The agency is making important initial progress in these areas – addressing the cumulative impacts of its regulatory activities – and the industry believes the agency should be encouraged to continue these efforts.

This is how it happens – through a shared recognition of a problem. The industry is not sloughing off safety – and the regulator acknowledges there could be a more effective approach. This is a topic that’s going to pop up every now and then and has a fairly large chance of being misunderstood. But it enhances safety and reduces risk not the opposite – unless you happen to think all risk can be eliminated all at once.

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And in France? It provides a pretty good example of how not to engage the regulatory process.

The second-floor cafeteria for Albaret-Sainte-Marie’s 70 students will have to be moved to the ground floor, he said, because the cost of an elevator would be prohibitive for a community of 600 residents with an operating budget of just over $500,000.

Let’s keep the atomic café on the second floor – it’s safer there - and find a way to do it that gives both regulatory and industrial concerns their due.

The Post story is worth a read to understand the problem of regulation run amok, even without a specific nuclear angle.

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Guest Post: Responding to Anti-Nuclear Fearmongering

Earlier today, the Washington Post published an opinion piece by Phillip Lipscy, Kenji Kushida and and Trevor Incert entitled, "Protecting nuclear plants from nature's worst." Steve Kerekes, NEI's Director of Media Relations, left the following comment in response at WashingtonPost.com:

This is a pathetic case of opportunistic fear-mongering. To the extent that there really is public concern about U.S. nuclear plants’ ability to withstand extreme events, it centers around what MIGHT happen in fantastical scenarios. This week, here’s what actually DID happen: The largest Atlantic storm ever recorded slammed into the New Jersey shore, creating record human and property devastation, yet every nuclear energy facility in this super-storm’s path – including the oldest nuclear plant in operation – managed through it safely and expertly with no threat or damage. Every … single … one.

Does this mean we should stop looking for safer ways to operate? Of course not, and we never will. At this very moment, the public has the opportunity to comment to the U.S. Nuclear Regulatory Commission on draft guidance that nuclear energy facilities would use to perform flooding hazard assessments as part of the response activities under way to the Fukushima Daiichi accident. This is being done with an eye toward providing another layer of protection above and beyond those that already exist and that make nuclear energy facilities exceedingly capable of withstanding extreme events of all kinds.

The authors – who somehow seem to think that natural events can affect only nuclear facilities and nothing else around them – are simply are wrong in claiming that facilities on the Eastern seaboard have “minimal protection” against inundation. The Salem/Hope Creek plant, for example, is designed for a category 4 hurricane arriving during high tide and a full moon. During Hurricane Sandy, the plant saw river levels consistent with some of the highest levels in its past (between 97 and 98 feet). This was still below the facility’s site grade and more than 20 feet below the water levels it is designed for.

As objective observers seek to better cope with devastating events like Hurricane Sandy, it’s a pretty safe bet that they’ll identify other priorities for action before they feel a need to better fortify the nuclear energy facilities that are our nation’s largest source of low-carbon electricity.

For the latest information on how the nuclear industry has been applying lessons learned from Fukushima since the March 2011 accident, please visit SafetyFirst.nei.org.

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Guest Post: Managing an Unprecedented Plant Challenge at San Onofre

Pete Dietrich, SCE

For most of 2012, the nuclear industry has been keeping a close watch on the situation at San Onofre Nuclear Generating Station, where continuing issues with the plant's steam generators have kept both units offline.

As NEI member company and plant manager Southern California Edison (SCE) has been investigating the source of the problem, it has faced a unique challenge with its own employees: how to communicate about the situation when the path forward is uncertain.

In the following guest post, SCE's Senior Vice President and Chief Nuclear Officer Pete Dietrich describes how he and his team embraced this unique set of circumstances. Today's post is the first in an ongoing series concerning the status of the plant.

Part 1 – Aligning the understanding and expectations of a large plant workforce when the path forward is uncertain
At 3:05 p.m. this past Jan.31, control room operators at our San Onofre Nuclear Generating Station detected a small steam generator tube leak from one of our two units. In accordance with our procedures and their training, operators safely shut down the unit and we began the process of determining the source of the leak. You have probably heard what we discovered during the months of inspections and analysis that followed – a previously unknown steam generator tube-to-tube wear mechanism resulting from in plane vibration that here-to-fore had not been experienced in similarly designed steam generators.

We were gratified that U.S. Nuclear Regulatory Commission inspectors found that our operators responded to the unique event in a faultless manner that protected public health and safety, using the conservative decision-making and questioning attitude that are trademarks of the nuclear power industry.

A large team of technical experts we assembled to help us understand the cause of the leak, including some of the best minds in the business, determined that tube-to-tube contact arising from excessive vibration in certain areas of the steam generators caused the unusual wear. We concluded that the excessive vibration was produced by a phenomenon known as “fluid elastic instability” which results from a combination of factors, including steam velocity, moisture content of the steam, and effectiveness of the supports in the areas where the vibration occurs.

One of the leadership challenges we have faced during the months of analysis of our steam generators has been maintaining a common set of understandings and expectations about our future across a large plant workforce as the investigation was evolving. I refer to this as a leadership issue, rather than merely a communications challenge, because the technical resolution path we are traveling is extremely challenging, even in this highly technical industry. As a result, countless decisions have been required of senior plant leaders about how we remain transparent to employees while not speculating about timelines, operating schedules and even outcomes.

San Onofre Nuclear Generating Station

The same has been true of our relationship with the public. How does a plant maintain its commitment to openness with its neighbors when it isn’t clear exactly what the analysis process will find? How do we describe the path forward when it is not yet clear? That was the leadership challenge, but more importantly, an opportunity to be fully transparent to the public as facts are determined and understood.

Had you been present in our daily briefings, one of the tactics you would have heard discussed frequently to meet this challenge is “communicate, communicate and communicate again.” We established very high communication expectations both up and down the normal channels and among the consultants during these months. I directed plant leaders to communicate well beyond previous levels, and to do so in person as much as possible. And those of us in senior leadership did the same, hosting an increased number of meetings with plant leaders and individual contributors for updates and Q&As. We believe saying “we don’t know yet” is better than saying nothing or speculating.

Another tactic we have used to fill what could otherwise be a risky information gap, as we await research conclusions, has been to continuously identify milestones that can be communicated. This is a way of signaling progress, even minor progress, and thereby offsetting the false impression that a slow, methodical, meticulous review process is a faltering process. At each of these milestones we have stated what we know so far, what we don’t know, and when we will have more information.

A unique and related leadership challenge we faced was to maintain schedule discipline in the face of unknown results of the ongoing investigations and research. In this situation the usual schedule driver of plant restart is no longer effective. At the same time, leaving the recovery schedule open-ended undermines confidence. Our solution was to impose team and individual discipline with short-term project schedule deliverables for identified tasks needed to define alternate success paths for safe return to service—and periodically adjusting the overall plant startup schedule to reflect the understandings coming from the individual short-term tasks. Our project team heard our message—getting to the right solution was the real priority, and meeting near-term commitments was the path to get there.

In addition to our efforts to maintain a cohesive understanding among employees about our prolonged analysis process, we have worked to align expectations about the prospective outcomes. For example, we’re reminding plant employees that, no matter the technical outcome, when a difficult problem is managed well, it can make a significant contribution to industry knowledge; and that contribution impacts the way a plant staff is viewed by industry peers. We will succeed by continually focusing on the nuclear safety aspects of our analysis and decision-making.

Our goal remains to conduct a comprehensive and independently challenged analysis of why relatively new steam generators would develop significant tube wear issues that benefits both San Onofre and the industry by gaining a full understanding of this new degradation mechanism. We will create a corrective action plan that is viewed by our peers and the regulatory authority as comprehensive and is based on prudent decision-making that assures safe operation of the plant. In this way, we will help our industry avoid a repeat of what our operators experienced on that Tuesday afternoon in January.

Thanks to Pete and his team at SCE for all of their hard work -- and for putting the safe and reliable operation of the plant ahead of every other priority. We look forward to future contributions.

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What Does the NRC’s Order on Waste Confidence Mean for New Plant Licensing?

Dry cask storage

It is not every day that the Nuclear Regulatory Commission advises everyone to “take a deep breath,” but when it comes to people misconstruing the facts about new plant licensing activities following a recent order, that is exactly what happened.

In a nutshell—last week, the NRC issued an order saying that it would not issue final reactor licenses or license renewals until the agency addresses a recent federal court ruling on waste confidence. Many people and some news articles mistakenly reported that this means all current licensing reviews and proceedings will come to a screeching halt, which is simply not the case. The order basically means that licensing reviews will move forward, but that final licensing will be put on hold.

The NRC clarified its position in a blog post late last week:

Let’s be clear: Tuesday’s Order was not a “Full Stop” to NRC’s licensing process. The Commission stated that licensing reviews should move forward—only final licensing was put on hold.

NEI’s Vice President and General Counsel Ellen Ginsberg weighed in:

The commission’s order is helpful in that license applicants can continue to pursue their licenses. Although there may be some delay in issuing some renewed licenses, NRC regulations provide that plant operation can continue beyond the original license term and until there is a decision on the renewal application, so long as it has been filed in a timely manner.

A level-headed article in Forbes’ over the weekend provides further background on the NRC’s order and how it relates to new plant licensing activities (bolded text added by me for emphasis):

There has been some fist-bumping this week in the anti-nuclear sector over the recent vacating of two NRC rules by the U.S. Court of Appeals for the District of Columbia Circuit in June; the waste-confidence decision and the storage rule. The judges felt that the agency had failed to conduct an environmental impact statement, or a finding of no significant environmental impact, before ruling that it is safe to store nuclear waste in wet pools and dry casks without a permanent solution in sight. But it was just that the initial NRC rule was too vague, not that this type of storage is unsafe (platts NRC Ruling).

In response, the NRC this week voted unanimously to delay final approval of licenses for new nuclear plants, or renewing the licenses of existing facilities, until the agency responds with a more complete ruling and addresses the dilemma of long-term nuclear waste storage across the country.

The 24 environmental groups that petitioned NRC to respond to the court are acting like they actually stopped all action on nuclear licensing (Marketwatch NRC Ruling). While no final decisions will be made in issuing licenses, the process for licensing new and existing plants will continue as before, the NRC said, which means the impact to the industry will be minimal.

Also, reactors can operate even after their present license expires as long as it is the NRC that is dragging it out. And most reactors have already been relicensed in the last ten years.  Only 18 out of 104 reactors are not and primarily because they have to operate beyond 20 years before they can apply. The four new GenIII plants being built at Vogtle (Georgia) and V.C. Summer (South Carolina) are also not affected at all since their licenses have already been issued.

The NRC’s blog post continues:

Essentially, the Order represents a regulatory agency taking a deep breath while trying to decide the best way to satisfy the Court.

So, let’s all follow the NRC’s advice: inhale, exhale.

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More on Nuclear Energy Facilities, Summer Heat and Water Use

The following guest post was submitted by NEI Media Manager, Mitch Singer.

Perhaps it’s asking too much in today’s media climate (no pun intended), but it would’ve been nice if Ginger Zee refrained from making the flippant comment on America This Morning that cooling ponds near nuclear plants are “either getting too low or too warm for the plants to function safely.” Ginger’s wrong on a number of accounts.

Safety is paramount to the nuclear industry and all plants have contingency plans in place to adjust to extreme weather conditions and continue operating, albeit at a lower electrical power output. All nuclear power plants operate under their respective states’ water discharge permits and when the water’s ambient temperature reaches a certain level the plant’s power output must be lowered. Thus, they continue to “function safely.”

The Browns Ferry Nuclear Plant in Alabama operated by the Tennessee Valley Authority (TVA) provides a great example of how in spite of extreme heat and higher-than-normal water temperatures a nuclear plant can continue to produce electricity. TVA’s Ray Golden explained it clearly to me in a conversation earlier today:

In the summers of 2010 and 2011 TVA had to reduce electrical power output at all three Browns Ferry units up to 50 percent (approximately 500 megawatts each) to maintain downstream river temperatures within the thermal compliance limits associated with its State of Alabama water discharge permit.

Browns Ferry draws water from the Tennessee River to cool plant equipment. In the process of cooling this equipment the water gets heated. This heated water is sent to a series of seven, very large cooling towers. The cooling towers use large fans to cool the water before returning it to the river.

When the river’s upstream ambient temperature rises to 90 degrees, TVA’s water permit does not allow any additional increase in water temperature. In order to comply with this regulation, at times Browns Ferry’s power output has to be lowered.  By lowering power output we reduce the discharge temperature.

During periods of extended high river temperatures and low rainfall, the company’s environmental compliance model requires the need to take prompt action to avoid exceeding any permit limits.

TVA returns Browns Ferry and other fossil-powered generating stations to full power when temperatures and river flow conditions are adequate for full power operation without challenging river temperature permit limits.

TVA has been proactively working on a project to address the issue of summer river temperatures and the requirement to reduce Browns Ferry power output.

In the summer of 2012, TVA completed construction of a seventh cooling tower which provides additional river water cooling during the hot summer months. The seventh tower is twice the size of the existing cooling towers and uses state-of-the-art engineering and equipment to maximize cooling capability. With cooling tower #7 in operation the need to reduce Browns Ferry’s power output has been eliminated so far this summer.

TVA returns Browns Ferry and other fossil-fueled plants to full power when temperatures and river flow conditions are adequate for full power operation without challenging river temperature permit limits.

Unfortunately, there are too many reports such as this morning’s where the issue of context is never considered. The fact is that ANY power plant, including coal and natural gas, that generates electricity through steam turbines and uses cooling water to condense the steam would face similar circumstances under drought conditions.

As my colleague David Bradish pointed out in his July 11 blog post, the National Oceanic and Atmospheric Administration reported that the month of June experienced “170 all-time high temperature records being broken or tied throughout the country.” Yet, America’s nuclear plants operated at an average of 90 percent capacity, as they have done so for most of the past decade. That’s a record of consistency that would make baseball great Cal Ripken take notice.

The Brown's Ferry nuclear energy facility in Alabama. Pic courtesy of TVA.

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SEJ Honors AP Report Criticized by Columbia Journalism Review

We just got the news a few minutes ago that the Society of Environmental Journalists (SEJ) has presented an award for in depth reporting (3rd place) to Jeff Donn of the Associated Press for his series on the safety of nuclear energy facilities. When the series first appeared in June 2011, NEI had this to say:

The coverage has factual errors, fails to cite relevant reports on safety that contradict the reporting, and raises questions about historic operating issues while ignoring more recent evidence of improved performance in areas that it examines.

As it turns out, we're not the only ones who found the series wanting. Specifically, I'm referring to the prestigious Columbia Journalism Review:

[T]he AP series, while it tackles a critically important public policy issue, suffers from lapses in organization, narrative exposition, and basic material selection, what to leave in and what to leave out. Too much is left to rest on inconclusive he-said-she-said exchanges that end up more confusing than illuminating for readers.

CJR's Irene M. Wielawski also concluded: "Reading it was, for me, a hugely frustrating experience." Something tells me she wasn't the only one.

POSTSCRIPT: Click here for additional material we published here on NEI Nuclear Notes, including links to other third party sources that found the AP's work less than convincing. NEI's Chief Nuclear Officer, Tony Pietrangelo, outlined his objections to the reporting in a video report that can be found here.

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U.S. Nuclear Plants Humming Along During June 2012 Heat Wave

Yesterday, the National Oceanic and Atmospheric Administration reported that the month of June experienced 170 all-time high temperature records being broken or tied throughout the country. They also reported that the first half of 2012 has been the warmest first half period on record back to 1895. As such, we wanted to share that most all of the U.S. nuclear plants were humming along at full power during June, helping provide electricity to air conditioners to keep all of us cool during these hot times.

Below are three charts breaking out the daily availability data from the Nuclear Regulatory Commission which we aggregated based on the North American Electric Reliability Council they belong to. You can find the list of plants and their region on page 4 of this report.

The following chart shows a daily average of the 104 nuclear units. Overall, the U.S. fleet was running at a steady average availability of 90.5% during the last four weeks.

And the last chart shows the NERC regions, how many reactors belong to each region in the U.S., and their average availability.

It’s worth pointing out that two of the regions, MRO and WECC, had  a lower average availability factor of 82% and 68%, respectively. This was mainly because three of the 14 reactors in those regions have been in long-term shutdown.

Average availability in MRO is lower because Fort Calhoun is down (1 unit out of 6). If we take Fort Calhoun out of the calculation, the plants that are running in that region have an average availability of 98.2%.

Similarly in WECC, the two San Onofre units are down. If we take San Onofre out, the other six reactors in the region have an average availability of 90.3%.

And in SERC and FRCC, Crystal River (1 unit out of 38) has also been down. Take Crystal River out of the equation, and the plants running have an average availability of 95.5% (vs. 93.0% for all 38).

Performance of Other Technologies

There isn’t similar daily availability data for other technologies to compare their performances to nuclear during the same heat wave. But to give an idea of how they perform annually, below is a chart of average capacity factors for various power sources.

August is typically the summer month for peak nuclear generation. As the summer progresses, we’ll see nearly all nuclear units online by then.

Though this year’s trend isn’t looking promising, hopefully temps will be a bit cooler for everyone during the rest of the summer. Stay cool.

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Looking Back at NEA 2012

After a whirlwind three days in Charlotte at NEA 2012, I'm back in Washington. And while I'm done unpacking my suitcase at home, we're not done unpacking all of the content we created during the conference.

One of the highlights of the conference had to be a roundtable discussion on industry safety and Fukushima that was moderated by NEI's Chief Nuclear Officer Tony Pietrangelo. Joining Tony were Chip Pardee of Exelon, David Lochbaum of the Union of Concerned Scientists and Bill Borchardt of the U.S. Nuclear Regulatory Commission. Luckily, we captured the entire discussion on video, and will be sharing it with you as soon as we're able to get the clip processed and uploaded to our YouTube Channel. In addition, we'll also be combing the questions that were submitted for the session that our panelists weren't able to answer due to time constraints.

Among my favorite moments from the conference had to be getting to see the pride and joy on the faces of our TIP Award winners. That was clearly the case when I got a chance to speak with the combined team from Duke Energy and AREVA that came home with the B. Ralph Sylvia Award, what's know in the industry as the "best of the best."

Click here to watch the video I shot with my iPhone just minutes after Preston Gillespie from Duke strode to the stage to claim the award. (Apologies ahead of time, as in my excitement I botched the name of the award.) For the total download on what won the award for the Duke/AREVA team, be sure to watch the video I embedded below.



We were also honored to be joined by Rep. G.K. Butterfield, a Democrat from North Carolina's 1st District. He spoke on Tuesday morning and delivered the following address:


I promise more tomorrow, but for now, I'll refer you back to the NEA 2012 landing page that was set up on NEI.org for further details. Look for more video tomorrow.

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Your Chance to Ask Questions of Industry Executives at NEA 2012

This morning at around 10:00 a.m. U.S. EDT, NEI's Chief Nuclear Officer, Tony Pietrangelo, will chair a panel session at the 2012 Nuclear Energy Assembly entitled, "Ensuring Operational Safety While Implementing Lessons Learned from Fukushima." Panelists for the session include:

• Charles G. Pardee, Chief Operating Officer, Exelon Generation Company, LLC 

• R. William Borchardt, Executive Director for Operations, U.S. Nuclear Regulatory Commission 

• David Lochbaum, Director, Nuclear Safety Project, Union of Concerned Scientists 

As part of our effort to better leverage social media, we'll be taking questions for panel members from online audiences. You can submit your question either by sending an email to questions@nei.org or simply tweeting the question with the conference hashtag, #NEA2012. Here's hoping our readers can participate.

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Some Questions About AP's Pulitzer Nominee

Yesterday the winners of the 2012 Pulitzer Prizes in journalism and the arts were announced. Though it failed to win a Pulitzer, a series by the Associated Press (AP) on safety at American nuclear plants was nominated in the national reporting category. We were a little taken aback by the news considering some of the criticism that was directed at the series by the Columbia Journalism Review earlier this year:

[T]he AP series, while it tackles a critically important public policy issue, suffers from lapses in organization, narrative exposition, and basic material selection, what to leave in and what to leave out. Too much is left to rest on inconclusive he-said-she-said exchanges that end up more confusing than illuminating for readers.

CJR's Irene M. Wielawski also concluded: "Reading it was, for me, a hugely frustrating experience." One wonders whether the Pulitzer committee might have come to the same conclusion.

POSTSCRIPT: Click here for the formal response to the AP series from NEI's media team. Click here for additional material we published on NEI Nuclear Notes, including links to other third party sources that found the AP's work less than convincing. NEI's Chief Nuclear Officer, Tony Pietrangelo, outlined his objections to the skewed portrayal of plant safety in a video report that can be found here.

UPDATE: Craig Nesbit, Vice President of Communications with Exelon Generation passed along this note:

Nice blog post on the AP. You may not be aware that any news piece can be nominated. Pulitzer nominations are submitted by the organization that owns the publication, not by the Pulitzer panel or some other third party. What's meaningful in the Pulitzer competition is being named a finalist (there are three for each category) and, of course, winning. It is, indeed, unfortunate that AP chose to nominate one of the most factually flawed, confusing and thinly evidenced pieces it has ever run, and I say that as a former chairman of Virginia Associated Press Newspapers and current nuclear industry spokesman.

Indeed, Craig is correct in that the piece in question was named a finalist. Thanks for the clarification.

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SOARCA and the Decreasing Risk of Death

How likely is it that a major accident at a nuclear energy facility would kill you? Japan just had such a major accident and no one died due to radiological exposure – there were industrial accidents at Fukushima that led to worker death but those were specific to occurring at a physical plant. The general public, while suffering displacement and its attendants stresses – not to mention those caused by the earthquake and tsunami that precipitated the accident – has been fatality free.

The NRC has been investigating the risk of death from a nuclear facility accident and has an answer: your risk is vanishingly small.

The study found there was "essentially zero risk" to the public of early fatalities due to radiation exposure following a severe accident. The long-term risk of dying from cancer due to radiation exposure after an accident was less than one in a billion and less than the U.S. average risk of dying from other causes of cancer, which is about two in one thousand.

Another conclusion: severe accidents at nuclear energy facilities would unfold more slowly and potential releases of radioactive material would be much smaller than earlier studies indicated.

The NRC looked at Surry and Peach Bottom for the study because they are different kinds of reactors.

If core cooling is not restored [following an accident], the NRC said containment failure and radiological release could begin at about 8 hours for Peach Bottom and at 25 hours for Surry.

That’s the worst case scenario, of course, with safety systems intended to prevent its occurrence at multiple points. (Remember, though, that this report assumes that all these systems fail and radiation is released – that eventuality is what it wants to model)

The story doesn’t go into evacuation, but the report does:

For the purposes of evaluating accident consequences in the SOARCA project, the most evident part of a plant's emergency response plan is the evacuation of the public in the 10-mile (16-km) plume exposure pathway Emergency Planning Zone (EPZ). Actions in this EPZ could be expanded if the plume projections suggest that the population in a wider area need to take protective actions. Thus, the project team assessed additional aspects of emergency response, including relocation from areas of relatively high potential for exposure, as well as variations of evacuation and sheltering of population groups outside the 10-mile EPZ to a distance of 20 miles from the plant.

The plume is what many think of as a cloud of radiation.

The report also says that existing safety measures—including those put in place after 9/11—would be highly effective in protecting the public. Moreover, even if mitigating measures fail or are not used, “the analyzed accidents would cause essentially zero immediate deaths and only a very, very small increase in the long-term cancer deaths.”

Any industry – from chemical and gas plants to paper mills to refineries – has to know the worst possible event that can happen and figure out how to keep people alive though it and get them out of the way should it occur. These are the risks of an industrialized society and not specific to the nuclear energy industry.

But it does suggest the responsibility industry and government regulators have to know the risks and how to mitigate them. This report, State-of-the-Art Reactor Consequence Analyses (or SOARCA, in Washington-acronym speak), provides a careful analysis and concludes that the risk is present, and must be acknowledged, but it is very, very small.

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