Synopsis: A task force created by the Nuclear Regulatory Commission has concluded that the Commission's "safety approach is incomplete without a strong program for dealing with the unexpected, including severe accidents" and has recommended a long list of safety improvements to create a "logical, systematic, and coherent regulatory framework for adequate protection" of the American public.
Are nuclear power plants in the United States safe or are they risks to the American public? More immediately, is the Diablo Canyon Nuclear Plant safe to live near or not?
Those are the overriding questions that are raised by a special task force created by the Nuclear Regulatory Commission (NRC) in the wake of the Fukushima nuclear plant meltdowns on March 11. The purpose of the report, the task force said, was "to explore protecting against accidents resulting from natural phenomena, mitigating the consequences of such accidents, and ensuring emergency preparedness."
In other words, what can be learned from the Fukushima disaster, which has left 15,632 dead and 5,226 missing for a total of 20,858 victims? Plus an estimated 5,800 injured. (The numbers are from the EarthQuake Report.)
The report of the "The Near-Term Task Force Review of Insights From the Fukushima Dai-ichi Accident" decided that "the current regulatory approach has served the Commission and the public well and allows the task force to conclude that a sequence of events like those occurring in the Fukushima accident is unlikely to occur in the United States and could be mitigated, reducing the likelihood of core damage and radiological releases." It also said that "operation and continued licensing activities do not pose an imminent risk to public health and safety." (Mitigation is defined as reducing in force or intensity, not prevention.)
But then it proposes a long list of recommendations to address its finding that "NRC's safety approach is incomplete without a strong program for dealing with the unexpected, including severe accidents," adding that "continued reliance on industry initiatives for a fundamental level of defense-in-depth similarly would leave gaps in the NRC regulatory approach." Such industry initiatives are voluntary, not mandatory, the report makes clear. And, it noted, those voluntary initiatives are usually "justified in terms of costs," not by the NRC but by the plant owners.
The report concludes that a "logical, systematic, and coherent regulatory framework for adequate protection" of the public is needed by the NRC. Without using the word, the report's observations and recommendations point to confusion surrounding the NRC regulatory program.
Its recommendations, the task force said, are meant to serve as "significant reinforcements to NRC requirements and programs."
The NRC's overall safety approach laid out by the report is based on the guiding principle that safety standards stem from the design of plants and what those designs can protect against. It is called design basis. There are "requirements for design-basis events with protection and mitigation features controlled through specific regulations or the general design criteria."
Then there is the beyond-design-basis standards which grow out of "events," such as earthquakes of magnitudes greater than what a plant is built to withstand, that are "beyond the design basis" and are "considered to be beyond what was required for adequate protection." The report says "actions to address issues beyond the design basis were largely considered safety enhancements" that are left to "voluntary industry initiatives to address severe accident features, strategies, and guidelines for operating reactors."
It notes that "some (plant) licensees have treated the industry voluntary initiative (the SAMG — severe accident management guidelines — program) in a significantly less rigorous and formal manner, so much so that the SAMG inspection would have resulted in multiple violations had it been associated with a required program."
In fact, the report states, the "Commission has come to rely on design-basis requirements and a patchwork of beyond-design-basis requirements and voluntary initiatives for maintaining safety."
It urges a "comprehensive reevaluation and restructuring of the regulatory framework" and calls on the NRC "to recharacterize its expectations for safety features beyond design basis more clearly and more positively as 'extended design-basis,'" apparently a new term it invented.
The logical conclusion from all this seems to be that the NRC has no means to prevent plants from turning into disasters if their designs are incapable of withstanding "events," as the report calls them, like earthquakes and tsunamis of size and scope greater than the designs can protect against. Such earthquakes cannot be predicted with any reasonable degree of certainty.
Nowhere in the report does it state bluntly that plants are unsafe or the long list of proposed improvements needs to be made to make them safe. But the overall report seems to support the conclusion that if safety of the plants is "incomplete" and significant measures are needed to address that deficiency, they have to be presumed to be less than safe — by the standards on which the recommendations proposed by the task force are based.
And there is nothing in the report to suggest that conclusion does not also cover the Diablo Canyon Nuclear Plant, as the Institute for Energy and Environmental Research (IEER) pointed out in its review of the NRC task report (on pages 12-13 at IEER review of NRC Fukushima Task Force Review2011-07-12).
The IEER's main recommendation is that "the NRC should require a complete revaluation of emergency planning zones, evacuation, and population protection in light of Fukushima, especially in densely populated areas where evacuation in zones extending out 30 or 40 miles will be essentially impossible and asking 10 million or more people to stay indoors for extended periods of months is also equally impossible."
Meanwhile, there have been several other developments that raise questions about nuclear plant safety:
— Whistleblowers have claimed that the NRC's Office of Inspector General is engaged in coverups within the NRC, thereby posing threats to plant safety, including hiding "systemic weaknesses in the way the NRC monitors corrosion," which can and has caused pipes to burst and threaten explosions. The report is from ProPublica, the Pulitzer Prize-winning online news site.
— The Union of Concerned Scientists' review of the NRC task force report urged that "the United States must take concrete steps now to address serious shortcomings in nuclear plant safety and security that have been evident for years." "Nuclear power safety and security must be given the serious attention they deserve—and have not consistently received—from the nuclear industry, the NRC (which oversees the industry), Congress (which oversees the NRC ), and the president (who appoints the NRC commissioners and bears ultimate responsibility for ensuring public safety)."
Also, public support in California for more nuclear plants has dropped sharply since the Fukushima catastrophe, the Public Policy Institute of California reported on July 27 based on a statewide survey. Support declined by 14 points since last July, down to 30% in favor with 65% opposed. It is the lowest level of support since the Institute began polling on nuclear plant support 10 years ago. At the same time, 80% of Californians favor increasing federal funding to develop renewable energy sources such as wind, solar, and hydrogen technology.
In spite of the NRC task force report's shortcomings, it is remarkable because it was written by NRC staff with no input from any independent experts in nuclear energy, but still made the case convincingly that there is an acute need to strengthen "NRC's safety approach." Some might suspect that such a report would be written to protect the agency for whom task force members work for and omit criticisms of NRC safety regulations.
The report is also important because it is likely to guide NRC policies and development of regulations in the coming months and years. The question is which recommendations will lead to action by the NRC and when. It also includes suggestions, which do not carry the force of recommendations, and as such, may not be carried out, despite their importance. Reuters news service reported that the task force report is expected to be followed by a broader six-month review during which the NRC will likely invite industry and public participation.
However, finding the criticisms of the NRC's safety practices within the 96-page report may not be an easy task for most members of the public. Recommendations for changes are highlighted, but the criticisms are buried well within the many complimentary statements about NRC's operations. And the report is written more as a technical document, rather than as a report easy to understand by lay people.
Plus readers must wade through many acronyms like ATWS, SBO, BWR, SMG, CFR, ATWS, PRA, IPE, IPEEE, SSC, EDMG, ERDS — and more — which are defined on first mention, but there is no glossary to refer to for followup reference.
The report has contradictions and inconsistencies. For example, it says that although voluntary safety initiatives by (plant) licensees can enhance safety if implemented and maintained effectively, they should not take the place of needed regulatory requirements. Then it says It must be clear to the public that substituting industry initiatives for NRC regulatory action can provide effective and efficient resolution of issues and will in no way compromise plant safety, and does not represent a reduction in the NRC's commitment to safety and sound regulation.
The Institute for Energy and Environmental Research's report pointed out that the task force assures that there is "the expectation of no significant radiological health effects" among workers at the Fukushima plant, whose reactors melted down. "It does not even qualify this by saying that health effects might be expected among workers, many of whom have experienced external radiation doses well above ten rem (a unit of radiological dosage), in addition to doses due to radioactivity that they breathed and ingested."
In addition, the Institute's report said, the task force provided no basis for expressing "the expectation of no significant radiological health effects" among the general population. "At the very least it is premature. The available facts point in the contrary direction," it said.
Here are some of the report's main criticisms about the NRC's safety approach:
— This regulatory approach, established and supplemented piece-by-piece over the decades, has addressed many safety concerns and issues, using the best information and techniques available at the time. The result is a patchwork of regulatory requirements and other safety initiatives, all important, but not all given equivalent consideration and treatment by licensees or during NRC technical review and inspection.
— A more balanced application of the Commission's defense-in-depth philosophy using risk insights would provide an enhanced regulatory framework that is logical, systematic, coherent, and better understood. Such a framework would support appropriate requirements for increased capability to address events of low likelihood and high consequence, thus significantly enhancing safety.
— The application of the defense-in-depth philosophy can be strengthened by including explicit requirements for beyond-design-basis events.
— Other elements, such as severe accident management guidelines, exist in voluntary industry initiatives. The Task Force has concluded that a collection of such "extended design-basis" requirements, with an appropriate set of quality or special treatment standards, should be established.
— The Task Force recommendation for an enhanced regulatory framework is intended to establish a coherent and transparent basis for treatment of the Fukushima insights. It is also intended to provide lasting direction to the staff regarding a consistent decisionmaking framework for future issues.
— The result is a set of recommendations that take a balanced approach to defense-in-depth as applied to low-likelihood, high-consequence events such as prolonged station blackout resulting from severe natural phenomena. These recommendations, taken together, are intended to clarify and strengthen the regulatory framework for protection against natural disasters, mitigation, and emergency preparedness, and to improve the effectiveness of the NRC's programs.
— The Task Force recommends establishing a logical, systematic, and coherent regulatory framework for adequate protection that appropriately balances defense-in-depth and risk considerations.
— The Task Force recommends that the NRC require licensees to reevaluate and upgrade as necessary the design-basis seismic and flooding protection of structures, systems, and components for each operating reactor.
— The Task Force recommends, as part of the longer term review, that the NRC evaluate potential enhancements to the capability to prevent or mitigate seismically-induced fires and floods.
— The Task Force recommends that the NRC strengthen station blackout mitigation capability at all operating and new reactors for design-basis and beyond-design-basis external events.
— The Task Force recommends that the NRC strengthen regulatory oversight of licensee safety performance.
— In the Task Force's deliberations, it became apparent that the existing guidance (Safety Goals, Regulatory Analysis Guidelines) does not present a completely clear and consistent framework for decisionmaking.
— The concept of design-basis events has been equated to adequate protection, and the concept of beyond-design-basis events has been equated to beyond adequate protection (i.e., safety enhancements). This vision of adequate protection has typically only led to requirements addressing beyond-design-basis concerns when they were found to be associated with a substantial enhancement in safety and justified in terms of cost.
— Although the phrase "beyond design basis" appears only once in the NRC regulations...regulators and industry use it often. Unfortunately, the phrase "beyond design basis" is vague, sometimes misused, and often misunderstood. Several elements of the phrase contribute to these misunderstandings. First, some beyond-design-basis considerations have been incorporated into the requirements and therefore directly affect reactor designs. The phrase is therefore inconsistent with the normal meaning of the words. In addition, there are many other beyond-design-basis considerations that are not requirements. The phrase therefore fails to convey the importance of the requirements to which it refers.
— The NRC inspection and licensing programs give less attention to beyond-design-basis requirements and little attention to industry voluntary initiatives since there are no requirements to inspect against. Because of this, the NRC gives much more attention to design-basis events than to severe accidents.
— The Task Force concludes that the NRC's safety approach is incomplete without a strong program for dealing with the unexpected, including severe accidents. Continued reliance on industry initiatives for a fundamental level of defense-in-depth similarly would leave gaps in the NRC regulatory approach. The Commission has clearly established such defense-in-depth severe accident requirements for new reactors...Taking a similar action, within reasonable and practical bounds appropriate to operating plants, would do the same for operating reactors.
— Some licensees have treated the industry voluntary initiative (the SAMG program) in a significantly less rigorous and formal manner, so much so that the SAMG (severe accident management guidelines) inspection would have resulted in multiple violations had it been associated with a required program. The results of the SAMG inspection do not indicate, nor does the Task Force conclude that, the SAMGs would not have been effective if needed. However, indications of programmatic weaknesses in the maintenance of the SAMGs are sufficient to recommend strengthening this important activity.
Task Force Recommendations
1. Establish a logical, systematic, and coherent regulatory framework for adequate protection that appropriately balances defense-in-depth and risk considerations.
2. Require licensees to reevaluate and upgrade as necessary the design-basis seismic and flooding protection of SSCs (structures, systems, and components) for each operating reactor.
3. As part of the longer term review, evaluate potential enhancements to the capability to prevent or mitigate seismically-induced fires and floods.
4. Strengthen SBO (station blackout) mitigation capability at all operating and new reactors for design-basis and beyond-design-basis external events.
5. Require reliable hardened vent designs in BWR (boiling water reactor) facilities with Mark I and Mark II (designs) containments.
6. As part of the longer term review, identify insights about hydrogen control and mitigation inside containment or in other buildings as additional information is revealed through further study of the Fukushima accident.
7. Enhance spent fuel pool makeup capability and instrumentation for the spent fuel pool.
8. Strengthen and integrate onsite emergency response capabilities such as EOP (emergency operating procedures), SAMG (severe accident management guidelines), and EDMG (extensive damage mitigation guidelines).
9. Require that facility emergency plans address prolonged SBO (station blackout) and multiunit events.
10. As part of the longer term review, pursue additional EP (emergency preparedness) topics related to multiunit events and prolonged SBO (station blackout).
11. As part of the longer term review, pursue EP (emergency preparedness) topics related to decisionmaking, radiation monitoring, and public education.
12. Strengthen regulatory oversight of licensee safety performance (i.e., the ROP, reactor oversight process) by focusing more attention on defense-in-depth requirements consistent with the recommended defense-in-depth framework.
The task force also recommended a number of new rules that the NRC should adopt, orders it should issue and staff actions. The latter include:
Enhancing NRC staff training on severe accidents, including training resident inspectors on SAMGs (severe accident management guidelines), evaluation of potential enhancements to the capability to prevent or mitigate seismically induced fires and floods, reexamine the command and control structure and the qualifications of decisionmakers to ensure that the proper level of authority and oversight exists in the correct facility for a long-term SBO (station blackout) or multiunit accident or both, study the efficacy of real-time radiation monitoring and conduct training on radiation, radiation safety, and the appropriate use of KI (kiloleter) in the local community around each nuclear power plant.
