Two decades, 20 years, 240 months, 1,040 weeks, 7,305 days, or 175,320 hours – plenty of time for an agency professing concern about nuclear safety to resolve one nuclear safety problem.
Yet that safety problem reported to the NRC twenty years ago remains unresolved today.
Is it because there wasn’t sufficient time to do so?
Or was it because there wasn’t sufficient will?
The smart money is on the latter reason.
On November 27, 1992, a colleague and I mailed packages containing a report titled “Susquehanna Steam Electric Station – 10CFR21 Report of Substantial Safety Hazard” to three addressees within the Nuclear Regulatory Commission (NRC): 1) the Regional Administrator for NRC Region I where the Susquehanna nuclear plant was located, 2) the NRC resident inspector assigned to Susquehanna, and 3) the NRC’s Public Document Room (PDR).
Part 21 to Title 10 of the Code of Federal Regulations (10CFR21) legally requires that “any individual director or responsible officer of a firm constructing, owning, operating, or supplying the components of any facility or activity which is licensed or otherwise regulated” by the NRC to notify the agency of a substantial safety hazard. We dutifully reported our finding that the design of the spent fuel pool located inside the reactor building at Susquehanna – and very likely all other boiling water reactors with Mark I and II containments in the U.S. – could cause the failures of the emergency systems used to cool the reactor core and limit the release of radioactivity to the environment during an accident.
The package we sent the NRC contained a six-page letter summarizing the substantial safety hazard and 35 attachments – all the documents between the plant’s owner and us about the matter. All told, the package consisted of over 400 pages. We also mailed copies of the transmittal letter to the Director of the NRC’s Office of Nuclear Reactor Regulation, the NRC’s Chairman, and all of the other NRC Commissioners.
The NRC received our report and almost immediately began handling it, or rather, mishandling it. Here are just some of the things the NRC did with our report:
- They entered our concerns into their allegations program. When we inquired why it wasn’t being handled as a Part 21 report, first the NRC said they didn’t know we wanted it treated that way (despite our subtlety of putting “10CFR21” in its title and in its very first sentence) and then they said we didn’t satisfy the criteria for a Part 21 report. When we pointed out that my colleague was an officer in a company providing consulting service to the nuclear industry and was therefore required by the regulations to report the matter, the NRC agreed to treat it as a Part 21 report.
- During the time the NRC mis-handled our report within their allegations program, I received a call from an NRC senior manager. He informed me that the NRC had called Susquehanna’s owner about our concerns. He told me that despite provisions in the NRC’s allegations program designed to protect the identities of allegers, the company now knew that we’d submitted the report. He advised me to take whatever measures I deemed necessary to protect myself from retaliation by the company. I asked if the company’s representatives had guessed our identities during the call. He said no, the NRC told the company at the beginning of the call that we’d submitted the report.
- In March 1993, I received a call from an engineer at the Seabrook nuclear plant. They were planning modifications to their spent fuel pool and had obtained a copy of our report from the NRC’s Public Document Room. The engineer asked me if he could get a copy of the other half of the report. I didn’t understand his question. He patiently held the phone while I fetched my copy. Then we went through the report page by page until I understood the problem. To reduce the bulk of the report, I’d made two-sided copies of the report’s 35 attachments. I took my original report to a copy store and ordered two-sided copies. But I’d failed to check the copies before mailing them to the NRC. The NRC was missing every other page of most of the report because the copy store had mistakenly only made single-sided copies. The engineer from Seabrook noticed material was missing when he read the report. The NRC – which had already determined our concerns had no significance – had either failed to notice or not even read the report. On March 25, 1993, I mailed a complete copy of the report to the NRC.
- On July 8, 1993, the NRC conducted a public meeting with Susquehanna’s owner about our concerns. We attended this meeting as members of the public. In those days, members of the public could attend NRC’s “public” meetings but were not allowed to utter a word. Making eye contact was permissible, but silence was not only golden, but mandated.
- We requested our own meeting with the NRC. The NRC granted our meeting and scheduled it for October 1, 1993. I mailed the NRC a one-page proposed meeting agenda on August 27, 1993. Within a week, I received a call from the NRC’s project manager for Susquehanna. He explained that the NRC had agreed to meet with us about our Part 21 report, but wasn’t interested in hearing about any new or unrelated issues. He specifically mentioned an item on the proposed agenda as being new. I pointed out that that item was described in some detail on page two of the transmittal letter for our report – which was not missing from the copies I’d mailed out. The NRC agreed to our agenda as proposed.
- On October 1, 1993, my colleague and I drove to Rockville, Maryland to meet with the NRC about our concerns. We prepared our presentation to swap back and forth about every two to five minutes for the express purpose of making it as engaging and riveting as possible. Less than 15 minutes into our presentation, the NRC’s project manager fell asleep in the first row. We knew he was asleep because we could see him from about five feet away and because he was snoring quite loudly.
- In October 1994, Pacific Northwest Laboratories evaluated the risk from the spent fuel pool concerns we’d raised and documented their results in a draft report. My colleague and I provided the NRC with more than 20 pages of comments about the report, describing in considerable detail the many errors and false assumptions it contained. The NRC did not have the risk evaluation updated to address our comments – they had not budgeted for it.
Unlike the NRC, many of these state and federal officials reacted. Phillip Sharp, then Chair of the House Energy and Commerce Committee’s Energy and Power Subcommittee, and Sue Sheridan on his staff were particularly helpful. The Congressman questioned the NRC about our concerns. We learned that the NRC reads every page and every word of letters it receives from Congressional oversight committees.
On July 8, 1994, my colleague and I drove to Rockville, Maryland again, this time for a meeting with NRC Chairman Ivan Selin at his request. Chairman Selin opened the meeting by claiming it had nothing to do with the letters we’d written (although a stack of many, if not all of them, lay before him on the conference table we sat around). For most of the next hour, we discussed the issues and the Chairman listened. He didn’t agree, he didn’t disagree, but he listened. He asked several questions seeking to clarify what we said and occasionally rephrased what we’d said to confirm he’d properly understood us. Chairman Selin listened to us, which made the 10-hour roundtrip worthwhile.
Susquehanna’s owner made several modifications to the plant and revised procedures to resolve the majority of our concerns. They re-routed the power supply for the instruments used to monitor the level and temperature of the water in the spent fuel pool so these parameters could be checked by the operators even when offsite power was unavailable. They replaced protective devices in the ventilation system intended to shut down the system in case of a fire because the original devices would also have shut down this key system if the spent fuel pool water approached boiling. They removed large gates between the spent fuel pools for the Unit 1 and Unit 2 reactors. With the pools cross-tied, emergency systems on Unit 2 could be used to cool the water in both pools in case of a reactor accident on Unit 1 and vice-versa. They added the normally closed valves in the emergency makeup system for the spent fuel pool to the periodic testing and inspection program. These valves had not been tested in many years. And they took several other steps.
They took Andrew Maykuth of the Philadelphia Inquirer on a tour through Susquehanna, pointing out many of the upgrades. When Maykuth inquired how much the upgrades cost, they said well over a million dollars. He then asked if that didn’t mean my colleague and I had been right. The owner insisted that all the upgrades had nothing to do with the concerns we’d raised. If so, why show them to Maykuth?
And while Susquehanna implemented steps to better manage the spent fuel pool risk, other reactors with Mark I and II containments having similar vulnerabilities have not yet done so. And the primary “fix” at Susquehanna – cross-tying the spent fuel pools to allow either unit’s safety systems from cooling both pools – cannot be implemented at single-reactor plants like Pilgrim (MA), Vermont Yankee (VT), FitzPatrick (NY), Duane Arnold (IA), Cooper (NE), Hope Creek (NJ), and Oyster Creek (NJ).
The safety problem basically boils down – no pun intended – to the spent fuel pool being located inside the same building that houses ALL the emergency pumps for providing cooling and makeup water to the reactor core during an accident. At most nuclear plants in the United States, the spent fuel pool is in a separate building. But at most of our 35 boiling water reactors, they share the same building.
So what? Actually, it would be a difference without a distinction but for one thing – the designs do not account for the heat emitted from spent fuel during an accident. At Susquehanna, the spent fuel pool’s design heat load (about 12.6 million British Thermal Units (BTUS) per hour) was more than double the combined heat load (about 5.4 million BTU’s/hour) from all other sources in the building during an accident. But the cooling system for that building had been designed assuming the spent fuel’s heat load was zero. The largest and dominant heat load was neglected. The cooling system could not handle this added heat load.
There’s no emergency system to cool the spent fuel pool’s water under accident conditions, and the cooling system for the building containing the spent fuel pool and ALL the emergency cooling pumps for the reactor core cannot remove the spent fuel’s heat.
Consequently, the spent fuel’s heat will increase the temperature of the spent fuel pool’s water and of the building atmosphere (think about entering a building with a heated pool and feeling the warm, humid air). Electrical equipment inside that building is designed to work within certain temperature, pressure, humidity, and radiation ranges. It doesn’t take long (a handful of hours to a few days at most) for this situation to result in electrical equipment failing due to high temperature and/or humidity. As this electrical equipment fails, more and more emergency pumps stop providing makeup water and cooling for the reactor core. Fukushima demonstrated – three times – the destination for this journey.
If the spent fuel pool begins boiling, the vapor rising from the pool’s surface will eventually cool and be condensed back into water. This water drains by gravity down into the basement of the building – where ALL the emergency pumps for cooling the reactor core are located. Instead of a natural tsunami disabling vital systems as at Fukushima, this human-made tsunami flood produces the same disastrous outcome.
Some of the NRC’s Near Term Task Force recommendations for reducing vulnerabilities of U.S. reactors to hazards revealed at Fukushima address spent fuel pool safety concerns reported twenty years ago by my colleague and me. Had the NRC taken our concerns seriously then, at least those vulnerabilities would have been addressed by now. If they are still unresolved twenty years from now, shame on the NRC. If the unresolved problems contribute to a disaster at a U.S. reactor, it’ll be criminal negligence more than bad luck to blame.
It’s not that the NRC lacks concern about nuclear safety. They are very concerned about nuclear safety, much like all Americans would very much like to win a big lottery pay-off. But to win the lottery, you have to buy a ticket. The NRC all too often treats nuclear safety like a spectator sport. They need to get off the bench and into the safety game.
To help NRC get into the safety game, the President must appoint individuals to the Commission with an unwavering commitment to the expeditious, effective resolution of known safety problems. And the Congress must exercise rigorous oversight to ensure this agency’s inactions don’t put Americans at undue risk, or worse.
If accused of being an effective regulator, the NRC could not be convicted. That must change and change soon.