ML081090526

Pilgrim April 2008 Evidentiary Hearing - Intervenor Exhibit 10, Corrosion: Us Nuclear Plants in the 21st Century: the Risk of a Lifetime, by David Lochbaum, Union of Concerned Scientists. (May 2004) and Using Reliability-Centered..

ML081090526
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Site:	Pilgrim
Issue date:	01/24/2008
From:	Lochbaum D Union of Concerned Scientists
To:	Atomic Safety and Licensing Board Panel, NRC/SECY/RAS
SECY/RAS
References
50-293-LR, ASLBP 06-848-02-LR, Pilgrim-Intervenor-23, RAS J-53
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I DOCKETED USNRC April 15, 2008 (10:00am)

NRC Staff Other .

OFFICE OF SECRETAR*y RULEMAKINGS AND Adcaakem

(*jii) MTM OOM ADJUDICATIONS STAF UNITED STATES OF AMERIL*A*  : -"('/ ,

NUCLEAR REGULATORY COMMISSION Before The Atomic Safy And Licensing Board In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application January 24,2008 DECLARATION OF DAVID LOCHBAUM I, David Lochbaum, prepared the attached reports: "U.S. Nuclear Plants in the 21st Century: The Risk of a Lifetime," (Union Concerned Scientists, May 2004) and Union of Concerned Scientists Issue Brief, "Help Wanted: Dutch Boy at Byron" (Union of Concerned Scientists, October 25, 2007).

I stand by the contents of the reports today.

I declare that under penalty of perjury that the foregoing is true and correct.

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U.S. Nuclear Plants in the 21st Century David Lochbaum UNION OF CONCERNED SCIENTISTS MAY 2004

ii Union of Concerned Scientists

© 2004 Union of Concerned Scientists All rights reserved David Lochbaum is a nuclear safety engineer in the UCS Clean Energy Program. He worked for nearly 20 years in the U.S. commercial nuclear power industry prior to joining UCS in 1996.

He holds a degree in nuclear engineering from the University ofTennessee.

The Union of Concerned Scientists is a nonprofit partnership of scientists and citizens combining rigorous scientific analysis, innovative policy development, and effective citizen advocacy to achieve practical environmental solutions.

The UCS Clean Energy Program examines the benefits and costs of the country's energy use and promotes energy solutions that are sustainable both environmentally and economically.

More information about UCS and the Clean Energy Program is available on the World Wide Web at uwvw.ucsusa.org.

The full text of this report is available on the UCS website or may be obtained from:

UCS Publications Two Brattle Square Cambridge, MA 02238-9105 Or, email pubs@ucstisa.org or call (617) 547-5552.

Cover: A line drawing showing the major components of a nuclear power plant. Source: Nuclear f)egulatory Con-unission.

Desiqn: Mary Zyskowski Printed on recycled paper

U.S. Nuclear Plants in the 21st Century iii CONTENTS

.Figures and Tables iv Acknowledgments v Executive Summary 1 Chapter 1: Introduction 3 The Bathtub Curve 3 Applications of the Bathtub Curve 4 Chapter 2: Nuclear Plant Safety in Region A 5 Lessons Learned by Region A Failures 6 Nuclear Plant Growing Pains 6 Price-Anderson: A Disincentive for Safety 6 Build Now, Pay Later? 7 Public Participation in the Licensing Process 8 Recommendations 9 Chapter 3: Nuclear Plant Safety in Region B 11 Problem Identification and Resolution Programs 12 PRisk Assessment Studies: Ineffective and Inconsistent 12 Technical Specifications: Important, but Often Ignored 14 Box: Davis Besse-The Reactor with a Hole in its Head 15 R~ecommendations 17 Chapter 4: Nuclear Plant Safety in Region C 19 Inadequate Aging Management Programs 20 Reactor License Renewal: Ignoring the Generation Gap 21 P,ecommendations 21 Chapter 5: Conclusion 23 References 24 Appendix: Selected Examples of NRC Generic Communications 27

iv Union of Concerned Scientists FIGURES AND TABLES Figures

1. The Bathtub Curve 4

2. Major Failures at Region A Plants 6

3. Trend of Significant Events at Nuclear Plants, 1988-2002 11

4. Driver Involvement Rate in Fatal Crashes by Age, 2001 12

5. Significant Near-Misses at Nuclear Power Plants, 1988-2001 19 Tables

1. NRC Generic Communications, 1971-2002 7

2. Generic Communications on PWVR Containment Sump Strainer 13 Clogging and BWR Emergency Core Cooling System Strainer Clogging, 1988-1997

3. Reactors Shut Down forYear-Plus Safety Repairs 16

U.S. Nuclear Plants in the 21st Century v ACKNOWLEDGMENTS The author would like to thank Paul Blanch, Alan Nogee, James Riccio, and Ulrich Witte for reviewing all or parts of the report at various stages in its preparation, Heather Tuttle for editorial assis-tance, and Mary Zyskowski for design and layout.

We appreciate the valuable advice and information provided by reviewers, but we note that this report does not necessarily reflect their opinions.The Union of Concerned Scientists is solely responsible for the contents of this report.

1 Union of Concerned Scientists Executive Summary but recent changes to the licensing process linmit the T reactors age,catastrophe he risks for much like the risksasfor change death by nuclear public's role to essentially that of a casual observer.

accident and illness change as people get older. If new reactors are built, we must benefit from Protection schemes must evolve to remain correlat- these hard and expensive lessons by: (1) excluding ed with age if the threat level is to be nmininiized. new reactors from federal liability protection under For people, it means replacing protective measures the Price Anderson Act, thereby removing the for toddlers (such as safety plugs in electrical current disincentive for vendors to design safety outlets) with parental watchfulness against teenage upgrades; (2) verifying safety performance against drinking and driving. It also means testing for signs expectations on prototype reactors before commer-of age-related illness (such as glaucoma, heart cial reactors are built; (3) conducting extensive disease, and osteoporosis) as people get older. For inspections of new reactors during design and nuclear reactors, it means aggressively monitoring construction to verify compliance with safety risk during the three stages of plant lifetime: the requirements; and (4) allowing meaningful public break-in phase, middle life phase, and wear-out participation in the licensing process.

phase.The risk profile for these three phases of life curves like a bathtub. The Union of Concerned Scientists (UCS) identified the best ways to manage The Middle Life Phase the risks from nuclear power at all points along the Increasing the maximum power output while cut-bathtub curve. ting back on safety inspections at existing reactors reduces the margin for error along the middle segment of the bathtub curve. The fact that 27 The Break-in Phase nuclear reactors have been shut down in the past Any new reactors that are built will start out on the two decades for safety problems that took a year or high-risk break-in segment of the curve. Several longer to fix demonstrates that errors are abundant nuclear plant disasters-Fermi, Three Mile Island, and margins for error are still necessary. Many of the and Chernobyl to name just a few--demonstrated safety cutbacks at nuclear plants are being justified the perils of navigating this part of the curve. based on deficient risk assessments.These risk Literally thousands of unexpected safety problems assessments have resulted in poor management surfaced at other nuclear plants. These surprises decisions, such as the decision in 2001 allowing drove safety levels down and nuclear power's costs the Davis-Besse nuclear plant in Ohio to continue up unnecessarily. Public intervention in licensing operating in an unsafe manner. Risk at existing proceedings led to numerous safety improvements, reactors can be best managed by: (1) improving the

U.S. Nuclear Plants in the 2 1st Century 2 oversight of methods used by plant owners to today's safety regulations and the mix of regulations find and fix errors; (2) ending the practice of risk- applicable to today's reactors must be identified and informed decision making using flawed risk studies; reviewed to verify that no safety gaps exist.

and (3) using risk insights not just to reduce unnec-essary regulatory burdens but also to shore up regulatory gaps as well. What Needs to Be Done While the risks and reasons for the risks vary along the bathtub curve, the consequences of fail-The Wear-out Phase ing to manage the risks remain nearly constant-Today's aging reactors, and any reactors granted potentially massive releases of radioactivity into the 20-year extensions to their current 40-year operat- atmosphere with devastating harm to people and ing licenses, face the high-risk wear-out segment places downwind.

of the bathtub curve. Despite efforts to monitor the An aggressive regulator consistently enforcing condition of aging equipment, there are recent federal safety regulations provides the best protec-age-related failures caused by monitoring the right tion against these risks. Sadly, America lacks such areas using the wrong techniques and by monitor- protection. Since UCS began its nuclear safety ing the wrong areas using the right techniques. In project nearly three decades ago, we have engaged addition, nuclear plants seeking license renewal the Nuclear Pegulatory Commission and its conform not to today's safety standards, but to a predecessor, the Atomic Energy Commission, unique assortment of regulations dating back nearly countless times. We advocated enforcement of 40 years with countless exemptions, deviations, existing regulations far more often than for and waivers granted along the way.While each adoption of new regulations. Regulations might individual exemption or waiver may be justified as provide adequate protection, but only when they not reducing safety margins, the cumulative effect are followed. By failing to consistently enforce of so many exceptions can adversely affect safety. the regulations, the NRC exposes millions of To. properly manage the risk at aging reactors: (1) Americans to greater risk than necessary. The multiple inspection techniques must be required for federal government must reform the NRC into high-risk equipment; (2) expanded inspections must a consistently effective regulator so it properly be required for equipment currently considered less manages the risk at all points along the nuclear vulnerable to aging; and (3) all differences between bathtub curve.

3 Union of Concerned Scientists C HAP T ER 1 Introduction In this report, UCS deals only with the highest-here is renewed nuclear power indebate about America's the role energy of future. priority safety problems and recommends steps Some people see new nuclear power plants on the to start the NRC on the path toward necessary horizon, citing proposed legislation calling for reforms. These reforms would lay the proper increased subsidies for an already heavily subsidized foundation for the NRC to resolve long-standing industry as evidence of the pending nuclear revival. safety problems at the more than 100 nuclear plants Others see nuclear power only in America's operating nationwide. Congress must sustain the rearview mirror. As evidence of nuclear power's NRC reform effort through completion of this demise, they cite the eight reactors permanently entire process, to provide the American public closed since 1990 due to unfavorable economics with the protection they expect and deserve.

and the three new reactor designs certified by the Nuclear Regulatory Commission (NRC) in the late 19 9 0 s but collecting dust on the shelf because The Bathtub Curve they are too expensive. The risks for catastrophe change as nuclear reactors Whatever the future holds for nuclear power, the age, much like the risks for death by accident and Union of Concerned Scientists (UCS) identified illness change as people get older. Protection the best ways to manage the risks from nuclear schemes must evolve to remain correlated with power. Existing reactors have not reached and will age if the threat level is to be minimized. For never reach a nuclear nirvana where catastrophes people, it means replacing protective measures for cannot happen.With many of today's reactors being toddlers (such as safety plugs in electrical outlets) relicensed to operate for up to 60 years, proper risk with parental watchfulness against teenage drinking managerment becomes essential in preventing the and driving. It also means testing for signs of age-imagined nirvana from turning into a nightmare. related illness (such as glaucoma, heart disease, None of the proposed new reactor designs is and osteoporosis) as people get older. For nuclear inherently safe, as amply documented by UCS in reactors, it means aggressively monitoring risk dur-the early 1990s and recently reaffirmed by the ing the three stages of plant lifetime: the break-in industry's express demand that the 1957 Price- phase, middle life phase, and wear-out phase. The Anderson Act be amended to extend federal risk profile for these three phases of life curves like liability protection against catastrophes at new a bathtub.

reactors. As long as a single nuclear reactor, of any The bathtub curve is drawn from statistical data age, operates in the United States, Americans must about lifetimes of both living and nonliving things.

be protected from the inherent risks. If you monitored 10,000 widgets-light bulbs,

U.S. Nuclear Plants in the 21st Century 4 automobile tires, cats, cetll phones, or nuclear people, on factors such as environment and life-reactors-and plotted how many expired in the style choices.

first month, the second month, the third month, The right-hand side of the curve, labeled and so on, your graph would curve upward Region C, is the wear-out phase. Due to aging, it on either end from a flat middle section (like a takes less stress to cause failure in this regionjust as bathtub.) The graph might not be synmmetrical, older people are more prone to breaking bones in but it would generally reflect low failure rates in a fall than younger people. Thus, the chances of the nmiddle with higher failure rates on the ends. failure increase with time spent in Region C The left-hand side of the bathtub curve, labeled (NASA, 2001).

Region A in Figure 1, represents the infant mortality or break-in phase of life. Infants are vulnerable to numerous illnesses until they grow Applications of the Bathtub Curve stronger and build up immunities. Similarly, The bathtub curve concept is readily evident in products may fail soon after being put to use due everyday life. A new car comes with a warranty to to manufacturing defects, material imperfections, or cover problems during its break-in phase. When poor workmanship (U.S. Army Corps of Engineers, money is borrowed from a bank to buy a car, the 2001). The steepness of the curve in Region A loan term is typically three or four years-timed depends on factors such as the effectiveness of to be paid offbefore the car enters the wear-out quality control measures applied during product phase. New shoes may be uncomfortable until they manufacturing. are worn in and then remain comifortable until worn out. And even the family pet is more fragile Figure 1 The Bathtub Curve as a puppy and when long in the tooth than in the intervening years.

The mathematical exercise used to generate the bathtub curve does not mean the fate of a specific LU ,:: .;. product or individual is preordained. Consider e Middle Porth a e ahu two identical new cars purchased from the same C

dealer on the same day. The first owner changes the FO N ' EG fJO10N engine oil and performs all other reconmnended TIME maintenance tasks at the prescribed intervals. The Source: NASA, 2001. second owner only changes the radio station. It is far more likely-but not guaranteed-that the first Region B, the middle pornion of the bathtub owner's car will have a longer useful life.

curve, represents the useful lifetime for products The bathtub curve concept also applies to nuclear and the peak health years for living things. power plants. The following sections examine how Accidents and random events still occur, but at a Regions A, B, and C of the bathtub curve dictate lower rate than in Region A. The height (i.e., how the risk from nuclear plant operation and recom-far off the floor) and size (i.e., distance between mend how that risk can be best managed.

ends) of the bathtub in Region B depends, for

5 Union of Concerned Scientists CHAPTER 2 Nuclear Plant Safety in Region A to plant control equipment that required nearly a E where risk forpower very nuclear accident and starts reactor failurein are high. A, Region year's repairs to fix. Age: six months.'

Previously unrecognized vulnerabilities, manufac-turing defects, material imperfections, and poor The Sodium Research Experiment (SR.E) workmanship all contribute to high failure rates reactor in California first attained full power in in newly operating nuclear reactors. As can be May 1958. On July 26, 1959, 12 fuel elements expected, some reactors did not get out of melted when the organic compound used to Region A without experiencing failure. Some cool the reactor core decomposed and blocked of the worst failures include: the cooling flow channels. Age: one year, two months.

• The Fermi Unit 1 reactor in Michigan began commercial operation in August 1966. A partial The Chernobyl Unit 4 reactor started up in meltdown on October 5, 1966, caused extensive August 1984. It suffered the worst nuclear plant damage to the reactor core. Age at time of disaster in history on April 26, 1986, when two failure: two months. explosions destroyed the facility and ignited a reactor fire that burned for more than a week.

" The Three Mile Island Unit 2 reactor began Dozens of plant workers were killed and commercial operation in December 1978. On thousands of people permanently relocated due March 28, 1979, a partial meltdown prompted to radioactive contamination of the surrounding the evacuation of nearly 150,000 people living countryside. Age: one year, seven months.

near the plant. Age: three months.

The SL-1 reactor in Idaho attained full power

• The St. Laurent des Eaux Al reactor in France for the first time on October 24, 1958.An started up in June 1969. Nearly 400 pounds of explosion within the reactor vessel on January 3, fuel melted on October 17, 1969, when the 1961, destroyed the reactor core and killed online refueling machine malfunctioned: everyone at the site-the first fatal nuclear Age: four months.' reactor accident in the United States.

Age: two years, three months.

" The Browns Ferry Unit 1 reactor in Alabama began commercial operation in August 1974.

A fire on March 22, 1975, caused severe damage I The St. Laurent des Eaux AI reactor resumed operation in 1970.

2 The Browns Ferry Unit I reactor resumed operation in 1977.

U.S. Nuclear Plants in the 21st Century 6 Figure 2 Major Failures at Region A Plants plants, but helped lower the risk of failure in the future. The fire at Browns Ferry Unit 1, for exam-ple, forced the rethinking of fire protection at nuclear power plants. New regulations were put in St. Laurentq place to govern the construction of new nuclear Brown 5 1 plants and existing plants underwent substantial retrofits to reduce fire risk. Likewise, the meltdown at Three Mile Island Unit 2 prompted major D changes in the design, maintenance, operation, and regulatory oversight of nuclear power plants.

Had these accidents happened in Region B, the remedial efforts might have been more modest.

RE G I10 NA~

Nuclear Plant Growing Pains TIME Generic communications issued by the NPC S&urre:Adaptedfrom NASA, 2001. demonstrate that nuclear power plants have had their fair share of problems. Table 1 (p.7) shows the number of generic comimunications issued annually Lessons Learned by Region A Failures by the NPC between 1971 and 2002.While some In some of these cases, the equipment intended to of these 2,500-plus issuances addressed non-power prevent accidents actually caused the accidents reactor problems, the majority addressed nuclear themselves or made them worse. For example, plant safety problems caused by bad design, defective workers installed angled metal pieces just below the manufacturing, faulty installation, unanticipated reactor core before Fermi Unit 1 began operation.. interactions, imperfect maintenance, and ineffective This last-minute addition was intended to make the operation. (See the Appendix for representative plant safer by dividing the molten core if it melted examples of these communications.) The shape and slumped to the bottom of the reactor vessel. of the bathtub curve in Pegion A reflects that But one of the metal vanes broke free and blocked unanticipated problems either get flushed out and the cooling flow through the reactor core, caus- fixed or result in the permanent shutdown of the ing--ironically-nuclear fuel to melt. In a far more flawed reactor.

tragic turn of events, the accident at Chernobyl occurred when workers performed a test of a proposed new backup system intended to allow Price-Anderson: A Disincentive for Safety the plant to operate more safely. The Price-Anderson Act was enacted in 1957 as a These accidents revealed problems that were supplemental "insurance policy" for nuclear power not apparent on the blueprints, in the computer plants. Private industry could not afford to develop models, or in the laboratory. The problems required commercial nuclear power plants due to the extensive safety upgrades at the surviving nuclear unprecedented high liability from a catastrophic

7 Union of Concerned Scientists Table 1 NRC Generic Communications, 1971-2002 accident. 7The Wall Street.Journalreported that the cost of the 1986 Chernobyl accident significantly exceeded the collective economic benefits accrued from the dozens of Soviet nuclear power reactors operated between 1954 and 1986 (Hudson, 1990).

No nuclear plant owner wants to see a multi-billion-dollar investment go up in smoke, but Price-Anderson may prevent safety upgrades from being incorporated into new reactor designs.

Without Price-Anderson, the added cost of devel-oping and incorporating safety features is offiset by reduced annual insurance premiums.With Price-Anderson providing equal liability protection regardless of risk, the cost of additional safety fea-tures becomes a financial impediment. The federal government must not encourage new nuclear

-0 1983 43 8' 84 0 135 reactors while discouraging important safety enhancements.

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. : ? :,i more economical. These features, however, are 19 0~i 107 87 largely untested in the field or have very limited "19192 operating experience. Other new reactor designs

,'1993 .. have operated only in cyberspace and have never

_1994r: experienced the trials and tribulations of real-world 1995 0 10 4 58 0 '72. operation. The gremlins hiding in their designs have not yet been exposed, let alone, exorcised.

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U.S. Nuclear Plants in the 21st Century 8 and they become well fitted .... This start-up period, the boards and appeal boards were raised.in thefirst period to the achievement of stable normal operations,is instance by an intervenor. (AEC, 1974) important because it is largely responsiblefor the physical "constitution" and "strength" of the plant thereafter. The NRC also enumerated the following benefits:

Thus, as with a new automobile, it is best not to impose excessive demands on the plant and to continue rated (1) Staff and applicant reports subject to public exami-operation carefully during this period, which, depending nation are performed with greater care; (2) preparation on the plant, can rangefrom afew to several years. We for public examination of issuesfrequently creates a refer to this as the 'fostering" stage of the plant. new perspective and causes the parties to reexamine or Through periodic inspection carried out during the rethink some or all of the questions presented; (3) the fostering stage, it is necessary to identi*f the weaknesses quality of staffjudgments is improved by a hearing of the plant as well as its strengths.At the same time, process which requires experts to state their views in any peculiarities of the plant should be understood and writing and then permits oral examination in detail reflected in operating methods and maintenance, by and (4) Staff work benefits from two decades of which a strong plant constitution can be developed. hearings and Board decisions on the almost limitless (Takuma, 2002) number of technical judgments that must be made in any given licensing application. (Cotter, 1981)

While the experimient with the prototype is under way, no commercial reactors of that type The NRC's Atomic Safety and Licensing Board should be under construction. Instead, results found has documented many examples of reactor safety during the fostering stage should be obtained, improvements resulting from public participation analyzed, and factored into design and regulatory (ASLB, 1984), including:

improvements. Only then should any new nuclear reactors be licensed and built. 1. Design and training improvements at the St.

Lucie nuclear plant in Florida for coping with offsite power grid instabilities.

Public Participation in the Licensing Process Public input on nuclear power plant issues has long 2. Upgraded requirements for turbine blade played an important role in the NRC's licensing inspections and overspeed detection at the process.The NRC itself has found that public North Anna nuclear plant inVirginia.

participation greatly enhances safety levels:

3. Improvement and conformation of the plume Public participation.in licensing proceedings not only exposure pathway Emergency Planning Zone at can provide valuable assistance to the adjudicatory the San Onofre nuclear plant in California.

process, but on frequent occasions demonstrably has done so. It does no disservice to the diligence of either 4. Upgraded effluent-treatment systems at the applicants generally or the regulatory staff to note that Palisades nuclear plant in Michigan and the many of the substantial safety and environmental Dresden nuclear plant in Illinois.

issues which have received the scrutiny of licensing

9 Union of Concerned Scientists

5. Control room design improvements at the to protect the public, such as warning sirens and Kewaunee nuclear plant in Wisconsin. emergency preparedness plans for nearby residents, are not needed. They also contend that the 10-mile

6. Upgraded requirements for steam generator tube emergency-planning zone can be reduced to a leak plugging at the BeaverValley nuclear plant mere 400 meters. If these new reactors are truly so in Pennsylvania. safe that the public need not be protected from technological disaster, then they are also so safe Unfortunately, the NRC, bowing to industry that their owners need not be protected from pressure, recently revised its licensing process to financial disaster.

virtually eliminate public participation, except in the role of casual observer (NRC, 2004).The lack 2. New nuclear reactors must not go directlj,from of public input could drastically curtail discovery blueprints to backyards.

of important areas of safety improvement similar to The United States experienced the pain of building those listed here. production reactors before learning lessons from prototype reactors as described by Daniel Ford, executive director of UCS in the 1970s:

Recommendations The nuclear power plants operating in the United A carefully managed development effort would also States today have long since exited Region A. The have required the building qfprototypesfor the large federal government advocates the construction of plants,just as Rickover did with his submarine new nuclear power reactors to help meet future reactor, which was thoroughly tested in a full-scale electricity needs, but any new reactor would have experimentalfacility at the A.E.C.' remote testing to navigate the same risky part of the bathtub curve station in Idaho. The A.E.C. did not impose such that yielded meltdowns or explosions at Fermi, St. controls on the nuclear industry, which, as officials later Laurent, Three Mile Island, SL-1, and Chernobyl. acknowledged, rushed 'frorn Kittyhawk to the Boeing At best, new reactors might be able to incorporate 747" in less than two decades. The "experiment" of the lessons learned from these nuclear disasters to operating large reactors,whose advanced designs relied lower the left edge of the bathtub curve. At worst, on complex, untried technology, was performed not in they will add their names to the list of infamous a faraway desert but at sites chosen by the utilities on reactors populating Pegion A. the perimeter of the country s major metropolitan areas.

There are issues specific to new reactors that (Ford, 1986) must be addressed to ensure they are managed and operated in the safest way possible. UCS rec- The safety retrofits to some of todayis operating ommends the following risk management policies: nuclear reactors were less effective and more costly than necessary because of this rushed approach.

1. New nuclear reactors must be excluded from There's no reason to replicate this imprudent mistake.

liabilityprotection under the Price-AndersonAct.

Promoters of new nuclear reactors contend that they are so safe that traditional measures employed

U.S. Nuclear Plants in the 21st Century 10

3. The NRC must conduct extensive verifications of Poor quality stopped the Marble Hill, Midland, reactor design and construction to find and correct as and Zimmer nuclear power reactors from starting many safety problems as possible before startup. up despite nearly being completed. Similar woes The nuclear power industry's chronic quality didn't stop the South Texas Project, Grand Gulf, control problems during design and construction Diablo Canyon, and Palo Verde nuclear plants, but are legendary, as is the NRC's consistent inability to they added vast and totally unnecessary sums to the do anything about it. The NRC's own reports3 on price tags. And design problems contributed to the the daunting problems concluded: severity of the SL-1, Fermi Unit 1, Browns Ferry Unit 1, and Three Mile Island Unit 2 accidents.

The principal conclusion of this study is that nuclear The safety and financial implications of shoddy construction projects having significant quality-related construction are still evident today. It must not problems in their desigii or construction were character- be repeated.

ized by the inability or failure of utility management to effectively implement a management system that 4. The licensing processfor new nuclear reactors ensured adequate control over all aspects of the project. must permit meaningful public participation.

• . . The major quality problems that have arisen in Public participation in the NRC's licensing process design were related to shortcomings in management will help to ensure that new reactors are operating oversight of the design process, includingfailure to as safely as possible. The NRC should allow public implement quality assurance controls over the design meetings for residents in and around towns where process that were adequate to prevent or detect new reactors are slated for construction, allow mistakes in an environment of many design changes. public input on new or revised regulations pertain-

• .. The NRC made a tacit but incorrect assumption ing to local plants, and provide opportunities for that there was a uniform level of industry and licensee public comment on revised regulations that affect competence.... Limited NRC inspection resources nuclear plants nationwide.

were so prioritized to address operations first, construction second, and design last, that inadequate inspection of the design process resulted. (NRC, 1984) 3 For examples, see U.S. House, 1984: U.S. House, 1982: and U.S. House, 1981.

11 Union of Concerned Scientists CHAPTER 3 Nuclear Plant Safety in Region B drinks and drives a car with bad brakes is probably T he NRCplant nuclear monitors operation, trendsincluding in severalsafety areas of a greater risk than a sober 16-year-old behind the system failures, unplanned reactor shutdowns, wheel of a well-maintained car.

emergency system starts, and significant events such Some steps taken by the NRC over the years as degraded fuel integrity and unplanned releases of probably prevented plants from lingering too long radioactivity (Collins, 2003).The decreased occur- in Region A. For example, in the late 1980s, the rence of significant events over the past 15 years or NRC determined that safety equipment was being so reflects the normal and expected transition of called upon too often because of poor maintenance nuclear power plants from Region A to Region B on equipment used to make electricity at the plant (Figure 3). ("balance-of-plant" equipment). The NRC's regula-Risk in Region B is lower than in Regions A or tions at that time required safety equipment to be C, but it is not zero and it can increase if safety highly reliable, but the regulations did not govern measures are not followed properly. For comparison how often plant owners could put themselves in purposes, middle-aged drivers are involved in fewer need of that safety equipment. Concerned that fatal motor vehicle accidents than younger and even highly reliable equipment will fail if called older drivers (Figure 4). But a 45-year-old who upon too often, the NRC issued its Maintenance Figure 3 Significant Events at Nuclear Plants, 1988-2002 1.0 0.9 0.90 P-- 0.8 -[ Industry Average z

0.7 - Industry Average Trend 0.3i

0. 0.52.5 z 0.41 LA 0.3 - '6. '2&,

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0.1 - 0.10.0 000 ""R 0.0 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 FISCAL YEAR Source: Dyer, 2004.

U.S. Nuclear Plants in the 21st Century 12 Figure 4 Driver Involvement Rate in Fatal Crashes by Age, 2001 70 -

60 -

0. >

50 -

40 -

z z LU jU 30 -

20 -

00 10 -

E-0 0-DRIVER AGE Source: NHTSA, 2002.

Rule in July 1991. This rule requires plant owners Risk Assessment Studies:

to perform better maintenance on equipment whose Ineffective and Inconsistent failure challenges safety equipment (Callan, 1997). Probabilistic risk analyses (PRAs) attempt to calcu-late the odds of specific events occurring (such as the breaking of a pipe that carries cooling water to Problem Identification and the reactor) and the odds of a plant's numerous Resolution Programs safety systems being unable to prevent damage to "Problem identification and resolution" is how plant the reactor core. All plant owners have conducted owners find and fix safety problems. As shown by risk assessment studies for their facilities. But as Table 2 (p. 13), 27 nuclear power reactors have been reported by the NRC's Inspector General:

shut down since 1984 for more than a year for extensive repairs to safety equipment. The year-plus Senior NRC officials confirmed that the agency is durations of these shutdowns are primafacie evidence highly reliant on informationfrom licensee risk that problem identification and resolution programs assessments.Agency qfficiaLs also noted that there are at these facilities were seriously flawed if not totally no PRA standards, no requirementsfor licensee's dysfunctional.Years of overlooking problems and PKds to be updated or accurate, and that the quality applying "band-aid" fixes at these plants resulted in a of the assessments varies considerably among licensees.

backlog of safety problems that took a long time to (NRC, 2002) resolve. Effective problem identification and resolu-tion programs could save plant operators time and The Davis-Besse reactor in Ohio is the most money in the long term. recent example of the consequences of deficient risk studies (see box, p. 15). UCS documented many instances in which the lack of PRA standards

13 Union qf Concerned Scientists Table 2 Reactors Shut Down for Year-Plus Safety Repairs Reato Loato Shu Don ei Browns Ferry Unit 21 Alabama Septembr 198,,i Mayt 1991 7 1

,Davis-Bese:, 4 .. h'M § 4 4 5 4 .- 4Or'?J... 1C4 . 4  ?. 4 ~.. F, 4zD d~1'986 e

Sequoyah Unit 1 Tennessee August 1885 ':May 1988 S5equqyahrUnitf2 "r nF 8 ~ 9 8'..lk.,'n.4..'

Pilgrim Massachusetts April1986 January 1989 Peach Bottom ni2 . 'PernnsyIvania 9 8-~rt.4..~ -J1rh 1'April21989ý

-U 't2' M arct', -44441.494 .4444444.4, Peach Bottom Unit 3 Pennsylvania March 1987 November 1989 Nine Mile Pon Uni-' 4'-' 'Nv.York New 4 .- DcmMr-twJuy19-Surry Unit 2 Virginia September1I988 September 1989

1'Calvert Cliffs Unit 2r'tn. 4 1 44 t [ ý'ry~land 4 4.41 ,A4 c> 94ar444Yw'44i~4,t. arMyli2.>

Palo Verde Unit 1 'Arizona: { March 41989" June 1990 c-4 Calvedt~ Cffs4UnitP 1ý ' ~ ~ aiin- 4 .. ...4juc~o.44 ,4$t4~4[:, O~45 '"444, FitzPatrick '-New York -- No vember 1'991 -': January 1993 Indian .Point Unr't 3'. "F'~ M'arYkc h'"' 144 4 ='I' South Texas Project Unit 1 Texas Februa'ry ~1993-, ýFebruary 1994-South Texas Project-Unit4. 2- A-4 Texas44 f!,'-~444A~

i., May'9 Salem Unit 1I 444 ,~ New Jersey May 1991: April 1998 "S'alem'Unit:2. ')4 42't 4 0ew N~55 JersePj4P... 4 a-4, ~' '~c~ Jfl 4 .9.73"

-J 4-'A Millstone Unit 2 Connecticut ~ February 1996 May 1999

ýMillstoneLUnit 3 " ý4-44, 44 ýCornectici4 4 t~4.A ~4-4 4...&Az..c 1

ý,7 i'ý4ý.*

.4 .4.4

- 44

=44A,4..4.

Marcb4'1996{k,'

445.44 2 .4i,~ A444.~

-Jn-t9" 44444413 4

4 4 Crystal River Florida Speber 1996 January 1998 LaSal e Uni 1~e 4

t .. .. 4 .a. 4

~ 4 e rý '"44 -~gsA9 LaleUnit 2 Illinois " -September 1996 April 1§999 4

"Clinton"'--'tA 4~4 4j)j in~ol S2, Se4k e4' e4444--

r, 1*996 4.. My,199, DC Cook Unit 1I Michigan Septemberl1997Dembr20

,,DC Cook Unrt2 n=.4'ichgn' h"' A,'tpte eu 9>7,-, .t441June,40004'.

Dai-Bse-'Ohio -" -44 Fe ru 00' 4 -4 arch 2004 Sourrce:Adapied-fromn Lochba~in: 199.9 resulted in safety problems and allowed widely disable safety systems until the issue is resolved, at disparate results for virtually identical reactors which time the studies continue to assume zero (Lochbaum, 2000). Of particular concern is the chance because the problem has been fixed.

NP,C's treatment of generic safety issues.While The problems with risk assessment studies are plant-specific issues are routinely noted and resolved well known, yet the NPC still makes regulatory as one would expect them to be, generic safety decisions based in large part on their suspect results.

issues affecting a large number of plants are assumed And in the case of generic safety issues, the findings not to exist until they are resolved. Incredible as it are clear, yet the NRC is sweeping them under the may seem, the risk assessment studies assume there rug. It's "garbage in, garbage out," with millions of is zero chance that the generic safety issue will American lives in the balance.

U.S. Nuclear Plants in the 2 Ist Century 14 Technical Specifications: Important, cable had disabled one of the component cooling but Often Ignored , water pumps.The Tech Specs only allowed the Technical Specifications, or Tech Specs in industry reactor to continue operating for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with parlance, are part of the operating license issued by this pump broken. The NRC permitted the the NRC to the owner of each power reactor. reactor to continue operating for an additional Among other things, the Tech Specs define the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> while the power cable was replaced.

minimum complement of safety equipment needed The NRC determined that the additional for safe reactor operation and how long the reactor operating time "will not involve a net increase can continue running when one or more pieces of in radiological risk" (Merschoff, 2002). It was the minimum complement are unavailable. later discovered that an isolation valve between In the case of Davis-Besse, the NRC lacked the two redundant component cooling water absolute proof that Tech Specs were violated and headers had been damaged years ago and would allowed the reactor to continue operating despite have leaked excessively if closed following the overwhelming circumstantial evidence that cooling rupture of one header (Becker, 2003).

water was leaking from the reactor vessel, warranting a shutdown within sLx hours.Yet when the NRC In April 2001, workers testing an emergency has absolute proof that Tech Specs are violated, they diesel generator at Prairie Island Unit 2 in rely on circumstantial evidence to allow reactors to Minnesota discovered a damaged engine continue operating. The following are just a few of cylinder. The Tech Specs permitted the reactor many recent examples: to operate for up to seven days with one broken emergency diesel generator. The NRC granted In March 2003, the DC Cook Unit 2 reactor three more days for the reactor to operate in Michigan was operating at full power when without its full complement of emergency workers determined that the motor-driven diesel generators. The NRC's decision was based auxiliary feedwater pump would be out of on the plant owner's risk calculation reporting a service to repair a broken motor longer than the "low likelihood" of an accident coinciding with 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> permnitted by Tech Specs. The plant's an independent failure of the other emergency owner requested pernmission for the reactor to diesel generator (Grant, 2001a).After the broken remain at full power for an additional 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> emergency diesel generator was fixed and while the broken safety pump was repaired. returned to service, the plant's owner discovered The NRC authorized this request based in large the engine cylinder damage had been caused by part on circumstantial evidence that the risk an incompatibility between its fuel oil and associated with extended plant operation was lubricating oil. The Calvert Clifls nuclear plant "less than the risk associated with performing a in Maryland previously experienced this plant shutdown" (Grant, 2003). incompatibility problem in 1996 and the NRC warned all other plant owners about it. But In August 2002, the Diablo Canyon Unit 2 Prairie Island's owner had not taken steps to reactor in California was operating at full power avoid this known problem and as a result, both when workers determined that a faulty power emergency diesel generators were damaged.

U.S. Nuclear Plants in the 21st Century 16

Table, 11/89 nI ni

)ram aiong the. same situation again, we'd p assessment

)ssed aside.

make the ~same decision" to aIloý v them to

17 Union of Concerned Scientists Consequently, Unit 2 was shut down that day for system play an extremely important safety role repairs (Grant, 2001b). because their failure "can compromise front-line system redundancy, leaving few options for In January 2001, workers testing the Division II successful plant shutdown" (NRC, 1996).

emergency diesel generator at the Clinton nuclear plant in Illinois discovered damaged engine bearings.The Tech Specs permitted the Recommendations reactor to operate for up to three days with one U.S. nuclear power plants are now operating in broken emergency diesel generator. The NRC Region B of the bathtub curve.Just as the NRC's granted 11 more days for the reactor to operate actions probably influenced how quickly nuclear without its ftill complement of emergency diesel plants traveled from Region A to Region B, the generators because the plant's owner promised agency's actions-and inactions-can affect how not to test the Division I emergency diesel quickly nuclear plants travel from Region B to generator (and thus determine whether it also Region C. Risk in Region B is not zero, but given had the engine bearing problem) until after that risk increases in Region C, the NRC must the known problem was fixed. (Bajwa, 2001). work to keep plants operating in Region B as long Clinton is a boiling-water reactor model 5 as possible, and properly manage them to keep risks (BWR/5). According to the NRC, 90 percent at a minimum. To best manage the risk while in of the overall threat for reactor core damage at Region B:

I3W1R/5 plants is station blackout, which occurs when the plant is disconnected from its electrical 1. The NRC must overhaul how it assesses problem grid and both the Division I and Division II identification and resolution programs.

emergency diesel generators are unavailable A problem identification and resolution pro-(NRC, 1996). grain is the most important measure of safety performance at a nuclear power plant, and should In November 2000, one of three component find problems before they become self-revealing cooling water pumps at the Fort Calhoun and properly fix them the first time. Inadequate nuclear plant in Nebraska failed when its aged problem identification and resolution programs motor broke down. The Tech Specs permitted were a commnon cause for the 27 year-plus plant the reactor to operate for up to seven days with shutdowns listed in Table 2 (p.13). The NRC one component cooling water pump unavailable. downplays evidence that these programs are The NRC granted 14 additional days to procure inadequate unless they involve equipment that and install a replacement pump motor after nearly caused a meltdown. There should be no determining that the extended outage time for exceptions. The NRC must do a better job of the cooling water pump resulted in "minimal judging the health of these vital programs and force increase in core damage frequency" (Merschoff, them to be fixed and properly used at all times.

2000). Fort Calhoun is a combustion engineer-ing PWR. According to the NRC, support systems such as the component cooling water

U.S. Nuclear Plants in the 2'1st Century 18

2. The NRC must stop making risk-informed safety merit and they can also impose require-decisions usingflawed risk assessment studies. ments in previously undervalued areas.' But in Sound, risk-informed decisions about the nation's practice, the NRC's risk-informed sword is razor-nuclear power plants must be made based on sharp on the side that slashes regulations and dull consistent, accurate risk assessment studies, especial- on the side that enforces regulations.

ly with regard to generic safety issues. But this will The examples given earlier, and dozens like not happen with the NRC's current risk assessment them, show that the NRC abides by or aban-system. The NRC must adopt a system of standards dons its absolute proof standard as necessary to for all power plants and enforce the system across allow nuclear plants to continue operating. The the board-for all plants and for all types of safety NRC must immediately stop admitting or issues-to ensure known risks are properly man- rejecting circumstantial evidence based on the aged and resolved. answer it is seeking. The data must determine the outcome, not vice versa.

3. The NRC must back up its talk about a "double-edged sword" in risk-informed regulation.

The NRC often states that risk insights cut both ways-they can trim regulations having little or no 4 For examples. sce King, 1999; NRC, 1999; OadMcGaffigan, 2001.

19 Union of Concerned Scientists CHAPTER 4 Nuclear Plant Safety in Region C n some respects, nuclear power plants are like it).While the number of significant events has cars. A car that is routinely maintained, washed decreased in recent years, the rate of"near-misses" and waxed regularly, and kept out of the elements (elevated risks of reactor meltdown) appears to have

,will stay rust-free and reliable for years. But even increased in recent years (Figure 5). In other words, with the best care, a car that is driven every day while the number of events is decreasing, their will eventually develop engine problems. Likewise, severity is increasing, with the near-nmisses getting a properly maintained nuclear plant takes longer to nearer and nearer to disaster. This upward trend enter Region, C than a poorly maintained nuclear may simply reflect normal statistical fluctuations or plant. But even the best-maintained nuclear plant increasing risk in Region B from the NRC's enters Region C if operated long enough. flawed risk-informed decisions. More likely, the What is known with absolute certainty is that data suggest that some nuclear plants have entered every nuclear plant operating in the United States Region C and are experiencing higher today is moving toward Region C (if not already in failure rates as expected.

Figure 5 Significant Near-Misses at Nuclear Power Plants, 1988-2001 0.5 L 0.4--

(0.32 0.32 0.3 - 0.286 LU 0.213 LJ 0.2 087 0.18 i0.137 0.133 0.1 0.086 z 0.0 -T- 0006T ' --1 IN E-TL W.

1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 FISCAL YEAR Source: Collins, 2003.

U.S. Nuclear Plants in the 21st Century 20 Inadequate Aging Management Programs acid on the containment floor. This led to the As reactors approach or enter Region C and become discoveiy of a through-wall crack where a major more vulnerable to failure, aging management pro- pipe was welded to the reactor vessel nozzle.

gramns monitor the condition of equipment and This location was specifically examined during structures so as to effect repairs or replacements before the 10-year in-service inspection in 1993, but minimum safety margins are compromised. Unfortun- the crack, which was present at the time, was ately, age-related degradation is being found too often missed because an air gap between the pipe weld by failures than by condition-monitoring activities. area and the inspection detector, a sonar-like In recent years, there have been ample reports of device, created "noisy" output. This noise masked age-related failmues. Here are some examples: the indications of a crack and prevented workers from noticing the problem (Casto, 2001).

On February 18, 2001, workers at Oconee Unit 3 in South Carolina noticed boric acid on On February 15, 2000, a steam generator tube the exterior surface of the reactor vessel head broke at Indian Point Unit 2 in New York and around two CRDM nozzles. Further investigation caused the uncontrolled release of radioactivity found through-wall circumferential cracks in the into the atmosphere. Under its revamped nozzles above the j-groove weld areas where the oversight process, the NRC issued its first red nozzles were attached to the reactor vessel head. finding-a failing grade-to Indian Point for These weld areas, and not the nozzles, were this event because the near-miss was avoidable.

routinely inspected on the premise that cracks, The NRC cited the plant's owner for having if they were going to occur, would occur there detected signs of degradation exceeding federal first (NRC, 2001). regulations during the steamn generator tube inspections in 1997 but failing to do anything On January 9, 2002, operators shut down Quad about it (Miller, 2000).

Cities Unit 1 in Illinois following indication that one of the jet pumps inside the reactor vessel These examples illustrate two fundamental flaws had failed. Subsequent investigation determined in current aging management programs: (1) looking that the hold-down beam for jet pump #20 had in the wrong spots with the right inspection tech-cracked apart and pieces had damaged the niques (as happened with the Oconee and Quad impeller of the recirculation pump, causing it to Cities plants), and (2) looking in the right spots shut off. The jet pump hold-down beam was with the wrong inspection techniques (as happened routinely inspected for cracks, but only at its two with the Sunmmer and Indian Point plants). Aging ends. The hold-down beam for jet pump #20 management programs should find these problems cracked in the middle. Workers also discovered before they become self-revealing, but they are not.

two other hold-down beams with cracks in their As problems in Region C have the potential to be middle regions (Grobe, 2002). much more severe than problems in Region B, strong aging management programs must be in

" On October 7, 2000, workers at the Summer place to help prevent these failures from occurring.

nuclear plant in South Carolina found boric

21 Union of Concerned Scientists Reactor License Renewal: impossible-to determine whether an aging plant Ignoring the Generation Gap will operate safely for 20 more years.A prudent Nuclear plants were originally licensed for 40-year regulator would want to know just how far away operating lifetimes. Several plant owners have already from today's safety standards an aging nuclear plant sought and obtained 20-year license extensions from seeking license renewal is and why it is acceptable the NRC, and many more owners are queuing up for that plant not to meet today's safety standards for to do so.The NRC's license renewal process is based two more decades. The NRC's license renewal on an assumption that all U.S. nuclear plants con- process fails to ask and answer that crucial question.

form to their current licensing basis, the industry This shortfall must be fixed if aging reactors are to term for the set of federal safety regulations that operate for 20 more years.

apply to a specific nuclear power plant,' and a deter-mination that plant owners have effective aging management programs for all equipment and struc- Recommendations tures with an important safety function. However, The NRC's license renewal process questions this assumption and determination, even if valid, whether plant owners have effective aging may not be enough to adequately ensure that management programs, and the answer has always nuclear reactors can operate safely in Region C. been "yes" despite considerable evidence to the The current licensing basis varies from plant to contrary. It is well known that "two wrongs don't plant. Nuclear plants licensed in the same year have make a right," but it takes two rights to make a different current licensing bases due to varying right in aging management-looking in the right exemptions and license conditions. New regulations spots with the right techniques. If today's existing are constantly being generated and existing regula- nuclear reactors are to be in service for another 20 tions revised so that, for examnple, the applicable years, there needs to be sn-ong aging management regulations in 1985 differ significantly from the programs at all reactors to ensure failures are found applicable regulations in 1975.The NRC cannot before it is too late. UCS recommends the issue or revise its regulations unless it determines following reforms:

the regulatory changes either maintain or increase safety levels. Therefore, today's regulations are as 1. The NRC must overhaul how it assesses problem good as, or better than, the 1975 or 1985 regulations identification and resolution programs.

from a safety perspective. Diverse inspection methods lessen the chances If a new nuclear power plant were to be built of overlooking problems when looking in the and operated today, it would have to meet the right spots.

federal safety regulations in effect today. But the NRC's license renewal process fails to define the 2. The NRC must require periodic inspections of generation gap between today's safety requirements areas considered less vulnerable to degradation and and the current licensing basis for an existing deemed outside the inspection scope.

nuclear power plant, making it difficult-if not Out-of-scope inspections increase the chances of 5 Code of Federal Regukoons."Definitioro."rTide 10, ýj54.3.

U.S. Nuclear Plants in the 21st Century 22 finding problenis that would have otherwise Actually, the best way to prevent recurrent prob-been overlooked. lenis at aging nuclear plants would be for the NRC to suspend the issuance of license renewals until

3. The NRC must formally review all differences the nuclear industry has demonstrated that it takes between today's safety regulations and the regula- plant safety seriously. Plant owners will continue to tions applicable to an aging reactor before granting follow lax aging management programs and allow license renewals. failures to reveal themselves unless the NRC It is unacceptable to grant license extensions to irmposes stronger standards. If the NRC required reactors that lag woefu~ly behind in regulations. truly effective aging management programs as a The NRC must confirm that adequate safety mar- condition for license renewal, plant owners would gins exist for reactors up for license renewal and have no choice but to adhere to stronger safety require safety and regulatory upgrades as necessary regulations, regardless of cost. PRight now, they to remedy any shortfalls. have no incentive to do so.

23 Union of Concerned Scientists CHAPTER 5 Conclusion once said, "You can't have one end of a ship sink."

T he riskfrom varies cradle profile to rocking for nuclear just as it chairreactors power This quote is fitting for U.S. nuclear reactors, which does for people. Because the risk is never zero, it are essentially in this very ship.A serious accident at must be properly managed at all times to protect any U.S. reactor, at any point in its lifetime, would against undue risk.The best way to manage nuclear likely dim the future for all reactors.To prevent reactor risk is to have an aggressive regulator unwarranted risk to the American public, Congress consistently enforcing federal safety regulations. must reform the NRC into a consistently effective enforcer of federal safety regulations.

At least this is what UCS considers to be the best way; we've never actually observed such NRC The suggested reforms outlined in this report performance.We have observed, all too often, the would lay the proper foundation for the NRC consequences that arise from a lack of enforcement to resolve long-standing safety problems at the of federal safety regulations. When this happens, more than 100 nuclear plants operating nationwide.

safety margins drop unnecessarily low and the risk Congress must sustain the NRC reform effort to people living near the reactors climbs unaccept- through completion of this entire process, to ably high. provide the American public with the protection The late Henry Kendall, Nobel laureate and they expect and deserve.

former chairman of the UCS board of directors,

U.S. Nuclear Plants in the 21st Century 24 References Atomic Energy Commission (AEC). 1974. "Gulf Casto, C., Nuclear Regulatory Commission. 2001.

States Utility Co. (River Bend Units 1 and 2)." "Virgil C. Summer Nuclear Station-NRC Special Atomic Safety and Licensing Appeal Board. Inspection Report No. 50-395/00-08, Exercise of ALAB-183, RAI-74-3, pp. 10-12. March 12. Enforcement Discretion." Letter to Stephen A.

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"Reactor Safety Improvements Resulting from ops-experience/alloy600/alloy600-files/mlO 10740293.pdf the Hearing Process." Findings presented to the Advisory Committee on Reactor Safeguards. Collins, S.J., Nuclear Regulatory Commission.

August 10. 2003. "Breakout Results/Feedback." Presented at the 15' annual NRC Regulatory Information Bajwa, S.S., Nuclear Regulatory Commission. 2001. Conference. April 18. Online at wwwnrc.gov/

"Notice of Enforcement Discretion for Amergen public-inwolve/conference-symposia /ric/past/2 003 /

Energy Company, LLC, Regarding Clinton Power slides /f.5-collins.pdf Station, TAC No. MB0960, NOED No. 01-6-001."

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001.html.

DyerJ., Nuclear Regulatory Commission. 2004.

Becker, J.B., Pacific Gas and Electric Company. "Regulatory Trends." Presentation Slides. March 10.

2003. "Licensee Event Report 2-2003-002-00/ Online at www.unrc.gov/public-involve/conference-Unanalyzed Condition in the Unit 2 Component symposia/ric/past/2004/slides/w3-dyer.p f Cooling Water System Due to a Valve Liner Failure." Letter to Nuclear Regulatory Ford, D. 1986. Meltdown: The Secret Papers of the Commission. April 17. Atomic Energy Commission. NewYork: Simon &

Schuster. p. 66. August.

Callan, L.J., Nuclear Regulatory Comnmission.

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SECY-97-055. March 4. Online at www.nrc.gov/ Cook, Unit 2 (NOED-03-3-003)." Letter to A.C.

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25 Union of Concerned Scientists Grant, G.E., Nuclear Regulatory Commission. Mangels, J. and J. Funk. 2002. "NRC's Flip-Flop,"

200 Ia. "Prairie Island Nuclear Generating Plant- The Plain-Dealer.August 4.

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NOED No. 01-3-002 (TAC No. MBI1710)." Letter McGaffigan Jr., E., Nuclear Regulatory Conmfis-to J. Sorensen, Nuclear Management Company sion. 2001. "SECY-00-0198-Status Report of LLC. April 18, Online at uww.nrc.gov/reading- Study of Risk-Informed Changes to the Technical rm Idoc-collections/enforcement /notices /2 001 /noed0 1- Requirements of 10 CFR Part 50 (Option 3) and 3-002.html. Recommendations on Risk-Informed Changes to 10 CFR 50.44 (Combustible Gas Control)."

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Unit 2/NRC Special Inspection Report 50-306/01-13." Letter to J. Sorensen, Nuclear Merschoff, E.W., Nuclear Regulatory Commission.

Management Company LLC.June 22. Online at 2002. "Notice of Enforcement Discretion for www. nrc.gov/NRRI/OVERSIGHT/ASSESS/ Pacific Gas and Electric Company Regarding REPOR.TS/prai_2001013.pdf Diablo Canyon Power Plant, Unit 2, NOED No.

02-4-003." Letter to Gregory M. Rueger, Pacific Grobe, J.A., Nuclear Regulatory Commission. Gas and Electric Company. August 23. Online at 2002. "Quad Cities Nuclear Power Station/NRC www. nrc.gov /reading-rm Idoc-collections/eenforcement/

Special Inspection Report 50-254/02-03(DRS)." notices /2 002 /noedO2-4-003. html.

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page.cfm ?pageJD= 181. Myers, L.A., FirstEnergy Nuclear Operating Company. 2002. "LER 2002-005-01 /Davis-Besse Lochbaum, D. 1999. The NRCs New Oversight Nuclear Power Station, Unit No. 1/Date of Process: On the Road to Effective Regulation? Occurrence-September 4, 2002." Letter to the Cambridge, MA: Union of Concerned Scientists. Nuclear Regulatory Commission. December 11.

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U.S. Nuclear Plants in the 21st Century 26 National Aeronautics and Space Administration Nuclear Regulatory Commission. 1996. "Individual (NASA). 2001. "Using Reliability-Centered Plant Examination Program: Perspectives on Maintenance As The Foundation For An Efficient Reactor Safety and Plant Performance." NUREG-And Reliable Overall Maintenance Strategy." 1560Vol. 2, Parts 2-5, pp. 11-37 to 11-40, 11-71.

Presentation slides. November.

National Highway Traffic Safety Administration Nuclear Regulatory Commission. 1984. "Improving (NHTSA). 2002. Traffic Safety Facts 2001:A Quality and the Assurance of Quality in the Design Compilation o*.Motor 1/ehicle Crash Datafrom the and Construction of Nuclear Power Plants."

FatalityAnalysis Reporting System and the General NUREG-1055. May.

Estimates System. Washington, D.C.: NHTSA, National Center for Statistics and Analysis. U.S. Takuma, M., Japan Atomic Industrial Forum, Inc.

Department of Transportation. p. 98. December. 2002. "Japan's Policy on Nuclear Power Plant Life Management." Presentation at the International Nuclear Regulatory Commission. 2004. "Final Atomic Energy Agency Scientific Forum.

Rule: Changes to Adjudicatory Process," Federal September 17-18.

Register 69(9). January 14.

U.S. Army Corps of Engineers. 2001. "Reliability Nuclear Regulatory Commission. 2003. "Potential Analysis of Navigation Lock and Dam Mechanical Impact of Debris Blockage on Emergency Sump and Electrical Equipment." Technical Letter No.

Recirculation at Pressurized-Waater Reactors." 1110-2-560.June 30. Online at mwv. usace. army.mil/

BL-2003-01.June 9. Online at unwtv. nrc.gov/reading- publications/eng-tech-ltrs /etl 1110-2-560/tl.pdf rin Idoc-collectionsIgen-comim /bulletins /2003 /b103 001.pdf U.S. House, Committee on Interior and Insular Nuclear Regulatory Commission. 2002. "Review Affairs, Subcommittee on Energy and the of NRC's Significance Determination Process." Environment. 1984. "Licensing Process at Grand Office of the Inspector General. OIG-02-A-15. Gulf Nuclear Powerplant." Hearing Proceedings.

August 21. Online at wwwv.nrc.gov/reading-rm/ July 24.

doc-collections/insp-gen/2002/02a-15/02a- 15.pdf U.S. House, Committee on Interior and Insular Nuclear Regulatory Commission. 2001. "Circum- Affairs, Subcommittee on Energy and the ferential Cracking of Reactor PressureVessel Head Environment. 1982. "Quality Assurance at the Penetration Nozzles." BL-01-01. August 3. Online Zinmmer Nuclear Station." Hearing Proceedings.

at wuu nrc.gov /readinq-rm /doc-collections igen-comm / September 14.

bulletins/2001/blO100 .html.

U.S. House, Committee on Interior and Insular Nuclear Regulatory Commission. 1999. "All Affairs, Subcommittee on Energy and the Employees Meeting B." Transcript p. 48 lines 10-24. Environment. 1981. "Quality Assurance in Nuclear June 15. Powerplant Construction." Hearing Proceedings.

November 19.

27 Union of Concerned Scientists APPENDIX Selected Examples of NRC Generic Communications Manufacturing Defects " GL88005: Boric Acid Corrosion of Carbon Steel Reactor

• BL-74-06: Defective Westinghouse Type W-2 Control Pressure Boundary Components in PWR Plants. Generic Switch Component. Bulletin. May 22, 1974. Letter. March 17, 1988.

• CR-801-17: Fuel Pin Damage Due to Water Jet from Baffle " GL89008: Erosion/Corrosion-Induced Pipe Wall Plate Corner. Circulr.July 23,1980. Thinning. Generic Letter. May 2, 1989.

• IN-80-40: Excessive Nitrogen Supply Pressure Actuates " GL91015: Operating Experience Feedback Report, Safety-Relief Valve Operation to Cause Reactor Solenoid-Operated Valve Problems at U.S. Reactors.

Depressurization. Information Notice. November 7, 1980. Generic Letter. September 23, 1991.

• CR-81 -01: Design Problems Involving Indicating " IN-97-84: Rupture in Extraction Steam Piping as a Result Pushbutton Switches Manufactured by Honeywell of Flow-Accelerated Corrosion. Information Notice.

Incorporated. Circular.January 23, 1981. December 11, 1997.

CL81 G 011: BWVR Feedwater Nozzle and Control Pod Poor Workmanship Drive Return Line Nozzle Cracking (NUREG-0619).

Generic Letter. February 28, 1981. " BL-73-06: Inadvertent Criticality in a BoilingWater Reactor. Bulletin. November 27, 1973.

• IN-82-43: Deficiencies in LWP, Air Filtration/Ventilation Systems. Information Notice. November 16,1982. " BL-77-04: Calculational Error Affecting the Design Performance of a System for Controlling pH of

" BL-86-03: Potential Failure of Multiple ECCS Pumps Containment Sump Water Following a LOCA. Bulletin.

Due to Single Failure ofAii-Operated Valve in Minimum November 4,1977.

Flow Recirculation Line. Bulletin, October 8, 1986.

" CR-78-04: Installation Error That Could Prevent Closing

" IN-88-76: Recent Discovery of a Phenomenon Not of Fire Doors. Circular. May 15, 1978.

Previously Considered in the Design of Secondary Containment Pressure Control. Information Notice. " CR-79-18: Proper Installation of Target Rock Safety-September 19, 1988. ReliefValves. Circular. September 6, 1979.

" IN-89-44: Hydrogen Storage on the Roof of the Control " IN-85-96:Temporary Strainers Left Installed in Pump Suction Piping. Information Notice. December 23, 1985.

Room. Information Notice. April 27, 1989.

• IN-90-77: Inadvertent Removal of Fuel Assemblies from Material Imperfections the Reactor Core. Information Notice. December 12, 1990.

" BL-79-26: Boron Loss from BWR Control Blades.

• IN-2001-06: Centrifugal Charging Pump Thrust Bearing Bulletin. November 20, 1979. Damage Not Detected Due to Inadequate Assessment of Oil Analysis Results and Selection of Pump Surveillance

" GL85022: Potential for Loss of Post-LOCA Recirculation Points. Information Notice. May 11, 2001.

Capability Due to Insulation Debris Blockage. Generic Letter. December 3,1985.

NOTE: The generic communications cited hereinj, and hundreds like diem, are available through the NRCs Electronic Reading Room.

Online at wvw.nrc.gov/reading-rm/doc-collections/gen-comniZ

T H E R I S K 0 F A L IF ET I M E

'Union of Concerned N uclear powerthe throughout in industry's States been the Unitedhistory, has, less Scientists safe and more expensive than necessary because of ineffective oversight. The Nuclear Regulatory National Headquarters Commission's (NRC) poor regulatory performance Two Brattle Square has contributed to several major disasters and Cambridge, MA 02238-9105 Phone: 617-547-5552 countless close, calls at nuclear plants.

Tol-Free: 800-666-8276 Fax: 617-864-9405 Nuclear plants are at highest risk for failure when Washington, DC Office they begin operation and when they approach the 1707 H Street NW, Suite 600 Washington. DC 20006-3962 end of their useful life.With new reactor designs Phone: 202-223-6133 proposed for construction, and more than 100 Fax: 202-223-6162 aging U.S. nuclear plants seeking extensions tO West Coast Office their operating licenses, the need for an effective 2397 Shattuck Avenue, Suite 203 Berkeley, CA 94704-1567 regulator has never been greater.

Phone: 510-843-1872 Fax: 510-843-3785 In this report, the Union of Concerned Scientists Email describes nuclear plant risks from cradle to grave ucs@ucsusa.org and makes recommendations on how to reform Web the NRC into a consistently effective enforcer of www.ucsusa.org federal safety regulations. With strong regulatory standards and enforcement measures in place, the NRC can provide the American public with the protection they expect and deserve.