ML081090526
| ML081090526 | |
| Person / Time | |
|---|---|
| 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 | |
| Download: ML081090526 (34) | |
Text
I DOCKETED USNRC April 15, 2008 (10:00am)
OFFICE OF SECRETAR*
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NUCLEAR REGULATORY COMMISSION Before The Atomic Safy And Licensing Board In the Matter of Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application Docket # 50-293-LR 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 T
he risks for catastrophe change as nuclear reactors age, much like the risks for death by accident and illness change as people get older.
Protection schemes must evolve to remain correlat-ed with age if the threat level is to be nmininiized.
For people, it means replacing protective measures for toddlers (such as safety plugs in electrical outlets) with parental watchfulness against teenage drinking and driving. It also means testing for signs of age-related illness (such as glaucoma, heart disease, and osteoporosis) as people get older. For nuclear reactors, it means aggressively monitoring risk during the three stages of plant lifetime: the break-in phase, middle life phase, and wear-out 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 risks from nuclear power at all points along the bathtub curve.
The Break-in Phase Any new reactors that are built will start out on the high-risk break-in segment of the curve. Several nuclear plant disasters-Fermi, Three Mile Island, and Chernobyl to name just a few--demonstrated the perils of navigating this part of the curve.
Literally thousands of unexpected safety problems surfaced at other nuclear plants. These surprises drove safety levels down and nuclear power's costs up unnecessarily. Public intervention in licensing proceedings led to numerous safety improvements, but recent changes to the licensing process linmit the public's role to essentially that of a casual observer.
If new reactors are built, we must benefit from these hard and expensive lessons by: (1) excluding new reactors from federal liability protection under the Price Anderson Act, thereby removing the current disincentive for vendors to design safety upgrades; (2) verifying safety performance against expectations on prototype reactors before commer-cial reactors are built; (3) conducting extensive inspections of new reactors during design and construction to verify compliance with safety requirements; and (4) allowing meaningful public participation in the licensing process.
The Middle Life Phase Increasing the maximum power output while cut-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 nuclear reactors have been shut down in the past two decades for safety problems that took a year or longer to fix demonstrates that errors are abundant and margins for error are still necessary. Many of the safety cutbacks at nuclear plants are being justified based on deficient risk assessments.These risk assessments have resulted in poor management decisions, such as the decision in 2001 allowing the Davis-Besse nuclear plant in Ohio to continue operating in an unsafe manner. Risk at existing 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 find and fix errors; (2) ending the practice of risk-informed decision making using flawed risk studies; and (3) using risk insights not just to reduce unnec-essary regulatory burdens but also to shore up regulatory gaps as well.
The Wear-out Phase Today's aging reactors, and any reactors granted 20-year extensions to their current 40-year operat-ing licenses, face the high-risk wear-out segment of the bathtub curve. Despite efforts to monitor the condition of aging equipment, there are recent age-related failures caused by monitoring the right areas using the wrong techniques and by monitor-ing the wrong areas using the right techniques. In addition, nuclear plants seeking license renewal conform not to today's safety standards, but to a unique assortment of regulations dating back nearly 40 years with countless exemptions, deviations, and waivers granted along the way.While each individual exemption or waiver may be justified as not reducing safety margins, the cumulative effect of so many exceptions can adversely affect safety.
To. properly manage the risk at aging reactors: (1) multiple inspection techniques must be required for high-risk equipment; (2) expanded inspections must be required for equipment currently considered less vulnerable to aging; and (3) all differences between today's safety regulations and the mix of regulations applicable to today's reactors must be identified and reviewed to verify that no safety gaps exist.
What Needs to Be Done While the risks and reasons for the risks vary along the bathtub curve, the consequences of fail-ing to manage the risks remain nearly constant-potentially massive releases of radioactivity into the atmosphere with devastating harm to people and places downwind.
An aggressive regulator consistently enforcing federal safety regulations provides the best protec-tion against these risks. Sadly, America lacks such protection. Since UCS began its nuclear safety project nearly three decades ago, we have engaged the Nuclear Pegulatory Commission and its predecessor, the Atomic Energy Commission, countless times. We advocated enforcement of existing regulations far more often than for adoption of new regulations. Regulations might provide adequate protection, but only when they are followed. By failing to consistently enforce the regulations, the NRC exposes millions of Americans to greater risk than necessary. The federal government must reform the NRC into a consistently effective regulator so it properly manages the risk at all points along the nuclear bathtub curve.
3 Union of Concerned Scientists C HAP T ER 1
Introduction here is renewed debate about the role of nuclear power in America's energy future.
Some people see new nuclear power plants on the horizon, citing proposed legislation calling for increased subsidies for an already heavily subsidized industry as evidence of the pending nuclear revival.
Others see nuclear power only in America's rearview mirror. As evidence of nuclear power's demise, they cite the eight reactors permanently closed since 1990 due to unfavorable economics and the three new reactor designs certified by the Nuclear Regulatory Commission (NRC) in the late 199 0s but collecting dust on the shelf because they are too expensive.
Whatever the future holds for nuclear power, the Union of Concerned Scientists (UCS) identified the best ways to manage the risks from nuclear power. Existing reactors have not reached and will never reach a nuclear nirvana where catastrophes cannot happen.With many of today's reactors being relicensed to operate for up to 60 years, proper risk managerment becomes essential in preventing the imagined nirvana from turning into a nightmare.
None of the proposed new reactor designs is inherently safe, as amply documented by UCS in the early 1990s and recently reaffirmed by the industry's express demand that the 1957 Price-Anderson Act be amended to extend federal liability protection against catastrophes at new reactors. As long as a single nuclear reactor, of any age, operates in the United States, Americans must be protected from the inherent risks.
In this report, UCS deals only with the highest-priority safety problems and recommends steps to start the NRC on the path toward necessary reforms. These reforms would lay the proper foundation for the NRC to resolve long-standing safety problems at the more than 100 nuclear plants operating nationwide. Congress must sustain the NRC reform effort through completion of this entire process, to provide the American public with the protection they expect and deserve.
The Bathtub Curve The risks for catastrophe change as nuclear reactors age, much like the risks for death by accident and illness change as people get older. Protection schemes must evolve to remain correlated with age if the threat level is to be minimized. For people, it means replacing protective measures for toddlers (such as safety plugs in electrical outlets) with parental watchfulness against teenage drinking and driving. It also means testing for signs of age-related illness (such as glaucoma, heart disease, and osteoporosis) as people get older. For nuclear reactors, it means aggressively monitoring risk dur-ing the three stages of plant lifetime: the break-in phase, middle life phase, and wear-out phase. The risk profile for these three phases of life curves like a bathtub.
The bathtub curve is drawn from statistical data about lifetimes of both living and nonliving things.
If you monitored 10,000 widgets-light bulbs,
U.S. Nuclear Plants in the 21st Century 4 automobile tires, cats, cetll phones, or nuclear reactors-and plotted how many expired in the first month, the second month, the third month, and so on, your graph would curve upward on either end from a flat middle section (like a bathtub.) The graph might not be synmmetrical, but it would generally reflect low failure rates in the nmiddle with higher failure rates on the ends.
The left-hand side of the bathtub curve, labeled Region A in Figure 1, represents the infant mortality or break-in phase of life. Infants are vulnerable to numerous illnesses until they grow stronger and build up immunities. Similarly, products may fail soon after being put to use due to manufacturing defects, material imperfections, or poor workmanship (U.S. Army Corps of Engineers, 2001). The steepness of the curve in Region A depends on factors such as the effectiveness of quality control measures applied during product manufacturing.
Figure 1 The Bathtub Curve LU e Middle Porth e
a ahu F O N EG fJO10N C
TIME Source: NASA, 2001.
Region B, the middle pornion of the bathtub curve, represents the useful lifetime for products and the peak health years for living things.
Accidents and random events still occur, but at a lower rate than in Region A. The height (i.e., how far off the floor) and size (i.e., distance between ends) of the bathtub in Region B depends, for people, on factors such as environment and life-style choices.
The right-hand side of the curve, labeled Region C, is the wear-out phase. Due to aging, it takes less stress to cause failure in this regionjust as older people are more prone to breaking bones in a fall than younger people. Thus, the chances of failure increase with time spent in Region C (NASA, 2001).
Applications of the Bathtub Curve The bathtub curve concept is readily evident in everyday life. A new car comes with a warranty to cover problems during its break-in phase. When money is borrowed from a bank to buy a car, the loan term is typically three or four years-timed to be paid offbefore the car enters the wear-out phase. New shoes may be uncomfortable until they are worn in and then remain comifortable until worn out. And even the family pet is more fragile 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 product or individual is preordained. Consider two identical new cars purchased from the same dealer on the same day. The first owner changes the engine oil and performs all other reconmnended maintenance tasks at the prescribed intervals. The second owner only changes the radio station. It is far more likely-but not guaranteed-that the first owner's car will have a longer useful life.
The bathtub curve concept also applies to nuclear power plants. The following sections examine how Regions A, B, and C of the bathtub curve dictate the risk from nuclear plant operation and recom-mend how that risk can be best managed.
5 Union of Concerned Scientists CHAPTER 2
Nuclear Plant Safety in Region A E very nuclear power reactor starts in Region A, where risk for accident and failure are high.
Previously unrecognized vulnerabilities, manufac-turing defects, material imperfections, and poor workmanship all contribute to high failure rates in newly operating nuclear reactors. As can be expected, some reactors did not get out of Region A without experiencing failure. Some of the worst failures include:
- The Fermi Unit 1 reactor in Michigan began commercial operation in August 1966. A partial meltdown on October 5, 1966, caused extensive damage to the reactor core. Age at time of failure: two months.
" The Three Mile Island Unit 2 reactor began commercial operation in December 1978. On March 28, 1979, a partial meltdown prompted the evacuation of nearly 150,000 people living near the plant. Age: three months.
- The St. Laurent des Eaux Al reactor in France started up in June 1969. Nearly 400 pounds of fuel melted on October 17, 1969, when the online refueling machine malfunctioned:
Age: four months.'
" The Browns Ferry Unit 1 reactor in Alabama began commercial operation in August 1974.
A fire on March 22, 1975, caused severe damage to plant control equipment that required nearly a year's repairs to fix. Age: six months.'
The Sodium Research Experiment (SR.E) reactor in California first attained full power in May 1958. On July 26, 1959, 12 fuel elements melted when the organic compound used to cool the reactor core decomposed and blocked the cooling flow channels. Age: one year, two months.
The Chernobyl Unit 4 reactor started up in August 1984. It suffered the worst nuclear plant disaster in history on April 26, 1986, when two explosions destroyed the facility and ignited a reactor fire that burned for more than a week.
Dozens of plant workers were killed and thousands of people permanently relocated due to radioactive contamination of the surrounding countryside. Age: one year, seven months.
The SL-1 reactor in Idaho attained full power for the first time on October 24, 1958.An explosion within the reactor vessel on January 3, 1961, destroyed the reactor core and killed everyone at the site-the first fatal nuclear reactor accident in the United States.
Age: two years, three months.
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 St. Laurentq Brown 5 1
D RE G I10 NA~
TIME S&urre:Adapted from NASA, 2001.
Lessons Learned by Region A Failures In some of these cases, the equipment intended to prevent accidents actually caused the accidents themselves or made them worse. For example, workers installed angled metal pieces just below the reactor core before Fermi Unit 1 began operation..
This last-minute addition was intended to make the plant safer by dividing the molten core if it melted and slumped to the bottom of the reactor vessel.
But one of the metal vanes broke free and blocked the cooling flow through the reactor core, caus-ing--ironically-nuclear fuel to melt. In a far more tragic turn of events, the accident at Chernobyl occurred when workers performed a test of a proposed new backup system intended to allow the plant to operate more safely.
These accidents revealed problems that were not apparent on the blueprints, in the computer models, or in the laboratory. The problems required extensive safety upgrades at the surviving nuclear 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 place to govern the construction of new nuclear plants and existing plants underwent substantial retrofits to reduce fire risk. Likewise, the meltdown at Three Mile Island Unit 2 prompted major 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.
Nuclear Plant Growing Pains Generic communications issued by the NPC demonstrate that nuclear power plants have had their fair share of problems. Table 1 (p.7) shows the number of generic comimunications issued annually by the NPC between 1971 and 2002.While some of these 2,500-plus issuances addressed non-power reactor problems, the majority addressed nuclear plant safety problems caused by bad design, defective manufacturing, faulty installation, unanticipated interactions, imperfect maintenance, and ineffective operation. (See the Appendix for representative examples of these communications.) The shape of the bathtub curve in Pegion A reflects that unanticipated problems either get flushed out and fixed or result in the permanent shutdown of the flawed reactor.
Price-Anderson: A Disincentive for Safety The Price-Anderson Act was enacted in 1957 as a supplemental "insurance policy" for nuclear power plants. Private industry could not afford to develop commercial nuclear power plants due to the unprecedented high liability from a catastrophic
7 Union of Concerned Scientists Table 1 NRC Generic Communications, 1971-2002 1983
- 1985
- 1985' 1987 1988 1989 1990 "1 91 92
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- 1999, 2000o 2001 2002
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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 reactors while discouraging important safety enhancements.
Build Now, Pay Later?
Some new reactor designs represent the next evolutionary step for nuclear power, incorporating features intended to make the plants safer and more economical. These features, however, are largely untested in the field or have very limited operating experience. Other new reactor designs have operated only in cyberspace and have never experienced the trials and tribulations of real-world operation. The gremlins hiding in their designs have not yet been exposed, let alone, exorcised.
In order to avoid unnecessary risks, any new reactor design must first undergo a multiyear testing period. The need for and objectives of this testing was explained by a senior executive of the Japanese nuclear industry:
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U.S. Nuclear Plants in the 21st Century 8
and they become well fitted....
This start-up period, the period to the achievement of stable normal operations, is important because it is largely responsible for the physical "constitution" and "strength" of the plant thereafter.
Thus, as with a new automobile, it is best not to impose excessive demands on the plant and to continue rated operation carefully during this period, which, depending on the plant, can range from afew to several years. We refer to this as the 'fostering" stage of the plant.
Through periodic inspection carried out during the fostering stage, it is necessary to identi*f the weaknesses of the plan t as well as its strengths. At the same time, any peculiarities of the plant should be understood and reflected in operating methods and maintenance, by which a strong plant constitution can be developed.
(Takuma, 2002)
While the experimient with the prototype is under way, no commercial reactors of that type should be under construction. Instead, results found during the fostering stage should be obtained, analyzed, and factored into design and regulatory improvements. Only then should any new nuclear reactors be licensed and built.
Public Participation in the Licensing Process Public input on nuclear power plant issues has long played an important role in the NRC's licensing process.The NRC itself has found that public participation greatly enhances safety levels:
Public participation. in licensing proceedings not only can provide valuable assistance to the adjudicatory process, but on frequent occasions demonstrably has done so. It does no disservice to the diligence of either applicants generally or the regulatory staff to note that many of the substantial safety and environmental issues which have received the scrutiny of licensing boards and appeal boards were raised.in thefirst instance by an intervenor. (AEC, 1974)
The NRC also enumerated the following benefits:
(1) Staff and applicant reports subject to public exami-nation are performed with greater care; (2) preparation for public examination of issues frequently creates a new perspective and causes the parties to reexamine or rethink some or all of the questions presented; (3) the quality of staff judgments is improved by a hearing process which requires experts to state their views in writing and then permits oral examination in detail and (4) Staff work benefits from two decades of hearings and Board decisions on the almost limitless number of technical judgments that must be made in any given licensing application. (Cotter, 1981)
The NRC's Atomic Safety and Licensing Board has documented many examples of reactor safety improvements resulting from public participation (ASLB, 1984), including:
- 1. Design and training improvements at the St.
Lucie nuclear plant in Florida for coping with offsite power grid instabilities.
- 2. Upgraded requirements for turbine blade inspections and overspeed detection at the North Anna nuclear plant inVirginia.
- 3. Improvement and conformation of the plume exposure pathway Emergency Planning Zone at the San Onofre nuclear plant in California.
- 4. Upgraded effluent-treatment systems at the Palisades nuclear plant in Michigan and the Dresden nuclear plant in Illinois.
9 Union of Concerned Scientists
- 5. Control room design improvements at the Kewaunee nuclear plant in Wisconsin.
- 6. Upgraded requirements for steam generator tube leak plugging at the BeaverValley nuclear plant in Pennsylvania.
Unfortunately, the NRC, bowing to industry pressure, recently revised its licensing process to virtually eliminate public participation, except in the role of casual observer (NRC, 2004).The lack of public input could drastically curtail discovery of important areas of safety improvement similar to those listed here.
Recommendations The nuclear power plants operating in the United States today have long since exited Region A. The federal government advocates the construction of new nuclear power reactors to help meet future electricity needs, but any new reactor would have to navigate the same risky part of the bathtub curve that yielded meltdowns or explosions at Fermi, St.
Laurent, Three Mile Island, SL-1, and Chernobyl.
At best, new reactors might be able to incorporate the lessons learned from these nuclear disasters to lower the left edge of the bathtub curve. At worst, they will add their names to the list of infamous reactors populating Pegion A.
There are issues specific to new reactors that must be addressed to ensure they are managed and operated in the safest way possible. UCS rec-ommends the following risk management policies:
- 1. New nuclear reactors must be excluded from liability protection under the Price-Anderson Act.
Promoters of new nuclear reactors contend that they are so safe that traditional measures employed to protect the public, such as warning sirens and emergency preparedness plans for nearby residents, are not needed. They also contend that the 10-mile emergency-planning zone can be reduced to a mere 400 meters. If these new reactors are truly so safe that the public need not be protected from technological disaster, then they are also so safe that their owners need not be protected from financial disaster.
- 2. New nuclear reactors must not go directlj, from blueprints to backyards.
The United States experienced the pain of building production reactors before learning lessons from prototype reactors as described by Daniel Ford, executive director of UCS in the 1970s:
A carefully managed development effort would also have required the building qfprototypes for the large plants, just as Rickover did with his submarine reactor, which was thoroughly tested in a full-scale experimental facility at the A.E.C.' remote testing station in Idaho. The A.E.C. did not impose such controls on the nuclear industry, which, as officials later acknowledged, rushed 'frorn Kittyhawk to the Boeing 747" in less than two decades. The "experiment" of operating large reactors, whose advanced designs relied on complex, untried technology, was performed not in a faraway desert but at sites chosen by the utilities on the perimeter of the country s major metropolitan areas.
(Ford, 1986)
The safety retrofits to some of todayis operating nuclear reactors were less effective and more costly than necessary because of this rushed approach.
There's no reason to replicate this imprudent mistake.
U.S. Nuclear Plants in the 21st Century 10
- 3. The NRC must conduct extensive verifications of reactor design and construction to find and correct as many safety problems as possible before startup.
The nuclear power industry's chronic quality control problems during design and construction are legendary, as is the NRC's consistent inability to do anything about it. The NRC's own reports3 on the daunting problems concluded:
The principal conclusion of this study is that nuclear construction projects having significant quality-related problems in their desigii or construction were character-ized by the inability or failure of utility management to effectively implement a management system that ensured adequate control over all aspects of the project.
- .. The major quality problems that have arisen in design were related to shortcomings in management oversight of the design process, including failure to implement quality assurance controls over the design process that were adequate to prevent or detect mistakes in an environment of many design changes.
- .. The NRC made a tacit but incorrect assumption that there was a uniform level of industry and licensee competence....
Limited NRC inspection resources were so prioritized to address operations first, construction second, and design last, that inadequate inspection of the design process resulted. (NRC, 1984)
Poor quality stopped the Marble Hill, Midland, and Zimmer nuclear power reactors from starting up despite nearly being completed. Similar woes didn't stop the South Texas Project, Grand Gulf, Diablo Canyon, and Palo Verde nuclear plants, but they added vast and totally unnecessary sums to the price tags. And design problems contributed to the severity of the SL-1, Fermi Unit 1, Browns Ferry Unit 1, and Three Mile Island Unit 2 accidents.
The safety and financial implications of shoddy construction are still evident today. It must not be repeated.
- 4. The licensing process for new nuclear reactors must permit meaningful public participation.
Public participation in the NRC's licensing process will help to ensure that new reactors are operating as safely as possible. The NRC should allow public meetings for residents in and around towns where new reactors are slated for construction, allow public input on new or revised regulations pertain-ing to local plants, and provide opportunities for public comment on revised regulations that affect nuclear plants nationwide.
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 T
he NRC monitors trends in several areas of nuclear plant operation, including safety system failures, unplanned reactor shutdowns, emergency system starts, and significant events such as degraded fuel integrity and unplanned releases of radioactivity (Collins, 2003).The decreased occur-rence of significant events over the past 15 years or so reflects the normal and expected transition of nuclear power plants from Region A to Region B (Figure 3).
Risk in Region B is lower than in Regions A or C, but it is not zero and it can increase if safety measures are not followed properly. For comparison purposes, middle-aged drivers are involved in fewer fatal motor vehicle accidents than younger and older drivers (Figure 4). But a 45-year-old who drinks and drives a car with bad brakes is probably a greater risk than a sober 16-year-old behind the wheel of a well-maintained car.
Some steps taken by the NRC over the years probably prevented plants from lingering too long in Region A. For example, in the late 1980s, the NRC determined that safety equipment was being called upon too often because of poor maintenance on equipment used to make electricity at the plant
("balance-of-plant" equipment). The NRC's regula-tions at that time required safety equipment to be highly reliable, but the regulations did not govern how often plant owners could put themselves in need of that safety equipment. Concerned that even highly reliable equipment will fail if called upon too often, the NRC issued its Maintenance Figure 3 Significant Events at Nuclear Plants, 1988-2002 P--
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U.S. Nuclear Plants in the 21st Century 12 Figure 4 Driver Involvement Rate in Fatal Crashes by Age, 2001
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Rule in July 1991. This rule requires plant owners to perform better maintenance on equipment whose failure challenges safety equipment (Callan, 1997).
Problem Identification and Resolution Programs "Problem identification and resolution" is how plant owners find and fix safety problems. As shown by Table 2 (p. 13), 27 nuclear power reactors have been shut down since 1984 for more than a year for extensive repairs to safety equipment. The year-plus durations of these shutdowns are primafacie evidence that problem identification and resolution programs at these facilities were seriously flawed if not totally dysfunctional.Years of overlooking problems and applying "band-aid" fixes at these plants resulted in a backlog of safety problems that took a long time to resolve. Effective problem identification and resolu-tion programs could save plant operators time and money in the long term.
Risk Assessment Studies:
Ineffective and Inconsistent 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 the reactor) and the odds of a plant's numerous safety systems being unable to prevent damage to the reactor core. All plant owners have conducted risk assessment studies for their facilities. But as reported by the NRC's Inspector General:
Senior NRC officials confirmed that the agency is highly reliant on information from licensee risk assessments. Agency qfficiaLs also noted that there are no PRA standards, no requirements for licensee's PKds to be updated or accurate, and that the quality of the assessments varies considerably among licensees.
(NRC, 2002)
The Davis-Besse reactor in Ohio is the most 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
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-4 arch 2004 Sourrce:Adapied-fromn Lochba~in: 199.9 resulted in safety problems and allowed widely disparate results for virtually identical reactors (Lochbaum, 2000). Of particular concern is the NP,C's treatment of generic safety issues.While plant-specific issues are routinely noted and resolved as one would expect them to be, generic safety issues affecting a large number of plants are assumed not to exist until they are resolved. Incredible as it may seem, the risk assessment studies assume there is zero chance that the generic safety issue will disable safety systems until the issue is resolved, at which time the studies continue to assume zero chance because the problem has been fixed.
The problems with risk assessment studies are well known, yet the NPC still makes regulatory decisions based in large part on their suspect results.
And in the case of generic safety issues, the findings are clear, yet the NRC is sweeping them under the rug. It's "garbage in, garbage out," with millions of American lives in the balance.
U.S. Nuclear Plants in the 2 Ist Century 14 Technical Specifications: Important, but Often Ignored,
Technical Specifications, or Tech Specs in industry parlance, are part of the operating license issued by the NRC to the owner of each power reactor.
Among other things, the Tech Specs define the minimum complement of safety equipment needed for safe reactor operation and how long the reactor can continue running when one or more pieces of the minimum complement are unavailable.
In the case of Davis-Besse, the NRC lacked absolute proof that Tech Specs were violated and allowed the reactor to continue operating despite overwhelming circumstantial evidence that cooling water was leaking from the reactor vessel, warranting a shutdown within sLx hours.Yet when the NRC has absolute proof that Tech Specs are violated, they rely on circumstantial evidence to allow reactors to continue operating. The following are just a few of many recent examples:
In March 2003, the DC Cook Unit 2 reactor in Michigan was operating at full power when workers determined that the motor-driven auxiliary feedwater pump would be out of service to repair a broken motor longer than the 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 owner requested pernmission for the reactor to 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 /> while the broken safety pump was repaired.
The NRC authorized this request based in large part on circumstantial evidence that the risk associated with extended plant operation was "less than the risk associated with performing a plant shutdown" (Grant, 2003).
In August 2002, the Diablo Canyon Unit 2 reactor in California was operating at full power when workers determined that a faulty power cable had disabled one of the component cooling water pumps.The Tech Specs only allowed the 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 this pump broken. The NRC permitted the reactor to continue operating for an additional 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.
The NRC determined that the additional operating time "will not involve a net increase in radiological risk" (Merschoff, 2002). It was later discovered that an isolation valve between the two redundant component cooling water headers had been damaged years ago and would have leaked excessively if closed following the rupture of one header (Becker, 2003).
In April 2001, workers testing an emergency diesel generator at Prairie Island Unit 2 in Minnesota discovered a damaged engine cylinder. The Tech Specs permitted the reactor to operate for up to seven days with one broken emergency diesel generator. The NRC granted three more days for the reactor to operate without its full complement of emergency diesel generators. The NRC's decision was based on the plant owner's risk calculation reporting a "low likelihood" of an accident coinciding with an independent failure of the other emergency diesel generator (Grant, 2001a).After the broken emergency diesel generator was fixed and returned to service, the plant's owner discovered the engine cylinder damage had been caused by an incompatibility between its fuel oil and lubricating oil. The Calvert Clifls nuclear plant in Maryland previously experienced this incompatibility problem in 1996 and the NRC warned all other plant owners about it. But Prairie Island's owner had not taken steps to avoid this known problem and as a result, both emergency diesel generators were damaged.
U.S. Nuclear Plants in the 21st Century 16
- Table, 11/89 n I ni the. same situation again, we'd p make the ~same decision" to aIloý
)ram aiong assessment
)ssed aside.
v them to
17 Union of Concerned Scientists Consequently, Unit 2 was shut down that day for repairs (Grant, 2001b).
In January 2001, workers testing the Division II emergency diesel generator at the Clinton nuclear plant in Illinois discovered damaged engine bearings.The Tech Specs permitted the reactor to operate for up to three days with one broken emergency diesel generator. The NRC granted 11 more days for the reactor to operate without its ftill complement of emergency diesel generators because the plant's owner promised not to test the Division I emergency diesel generator (and thus determine whether it also had the engine bearing problem) until after the known problem was fixed. (Bajwa, 2001).
Clinton is a boiling-water reactor model 5 (BWR/5). According to the NRC, 90 percent of the overall threat for reactor core damage at I3W1R/5 plants is station blackout, which occurs when the plant is disconnected from its electrical grid and both the Division I and Division II emergency diesel generators are unavailable (NRC, 1996).
In November 2000, one of three component cooling water pumps at the Fort Calhoun nuclear plant in Nebraska failed when its aged motor broke down. The Tech Specs permitted the reactor to operate for up to seven days with one component cooling water pump unavailable.
The NRC granted 14 additional days to procure and install a replacement pump motor after determining that the extended outage time for the cooling water pump resulted in "minimal increase in core damage frequency" (Merschoff, 2000). Fort Calhoun is a combustion engineer-ing PWR. According to the NRC, support systems such as the component cooling water system play an extremely important safety role because their failure "can compromise front-line system redundancy, leaving few options for successful plant shutdown" (NRC, 1996).
Recommendations U.S. nuclear power plants are now operating in Region B of the bathtub curve.Just as the NRC's actions probably influenced how quickly nuclear plants traveled from Region A to Region B, the agency's actions-and inactions-can affect how quickly nuclear plants travel from Region B to Region C. Risk in Region B is not zero, but given that risk increases in Region C, the NRC must work to keep plants operating in Region B as long as possible, and properly manage them to keep risks at a minimum. To best manage the risk while in Region B:
- 1. The NRC must overhaul how it assesses problem identification and resolution programs.
A problem identification and resolution pro-grain is the most important measure of safety performance at a nuclear power plant, and should find problems before they become self-revealing and properly fix them the first time. Inadequate problem identification and resolution programs were a commnon cause for the 27 year-plus plant shutdowns listed in Table 2 (p.13). The NRC downplays evidence that these programs are inadequate unless they involve equipment that nearly caused a meltdown. There should be no exceptions. The NRC must do a better job of judging the health of these vital programs and force them to be fixed and properly used at all times.
U.S. Nuclear Plants in the 2'1st Century 18
- 2. The NRC must stop making risk-informed decisions using flawed risk assessment studies.
Sound, risk-informed decisions about the nation's nuclear power plants must be made based on consistent, accurate risk assessment studies, especial-ly with regard to generic safety issues. But this will not happen with the NRC's current risk assessment system. The NRC must adopt a system of standards for all power plants and enforce the system across the board-for all plants and for all types of safety issues-to ensure known risks are properly man-aged and resolved.
- 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 safety merit and they can also impose require-ments in previously undervalued areas.' But in practice, the NRC's risk-informed sword is razor-sharp on the side that slashes regulations and dull on the side that enforces regulations.
The examples given earlier, and dozens like them, show that the NRC abides by or aban-dons its absolute proof standard as necessary to allow nuclear plants to continue operating. The NRC must immediately stop admitting or rejecting circumstantial evidence based on the answer it is seeking. The data must determine the outcome, not vice versa.
4 For examples. sce King, 1999; NRC, 1999; Oad McGaffigan, 2001.
19 Union of Concerned Scientists CHAPTER 4
Nuclear Plant Safety in Region C n some respects, nuclear power plants are like cars. A car that is routinely maintained, washed and waxed regularly, and kept out of the elements
,will stay rust-free and reliable for years. But even with the best care, a car that is driven every day will eventually develop engine problems. Likewise, a properly maintained nuclear plant takes longer to enter Region, C than a poorly maintained nuclear plant. But even the best-maintained nuclear plant enters Region C if operated long enough.
What is known with absolute certainty is that every nuclear plant operating in the United States today is moving toward Region C (if not already in it).While the number of significant events has decreased in recent years, the rate of"near-misses" (elevated risks of reactor meltdown) appears to have increased in recent years (Figure 5). In other words, while the number of events is decreasing, their severity is increasing, with the near-nmisses getting nearer and nearer to disaster. This upward trend may simply reflect normal statistical fluctuations or increasing risk in Region B from the NRC's flawed risk-informed decisions. More likely, the data suggest that some nuclear plants have entered Region C and are experiencing higher failure rates as expected.
Figure 5 Significant Near-Misses at Nuclear Power Plants, 1988-2001 L
LU LJ z
0.5 0.4--
(0.32 0.32 0.3 -
0.286 0.213 0.2 087 0.18 i0.137 0.133 0.1 0.086 0006 0.0 1 IN
-T-E-
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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 As reactors approach or enter Region C and become more vulnerable to failure, aging management pro-gramns monitor the condition of equipment and structures so as to effect repairs or replacements before minimum safety margins are compromised. Unfortun-ately, age-related degradation is being found too often by failures than by condition-monitoring activities.
In recent years, there have been ample reports of age-related failmues. Here are some examples:
On February 18, 2001, workers at Oconee Unit 3 in South Carolina noticed boric acid on the exterior surface of the reactor vessel head around two CRDM nozzles. Further investigation found through-wall circumferential cracks in the nozzles above the j-groove weld areas where the nozzles were attached to the reactor vessel head.
These weld areas, and not the nozzles, were routinely inspected on the premise that cracks, if they were going to occur, would occur there first (NRC, 2001).
On January 9, 2002, operators shut down Quad Cities Unit 1 in Illinois following indication that one of the jet pumps inside the reactor vessel had failed. Subsequent investigation determined that the hold-down beam for jet pump #20 had cracked apart and pieces had damaged the impeller of the recirculation pump, causing it to shut off. The jet pump hold-down beam was routinely inspected for cracks, but only at its two ends. The hold-down beam for jet pump #20 cracked in the middle. Workers also discovered two other hold-down beams with cracks in their middle regions (Grobe, 2002).
" On October 7, 2000, workers at the Summer nuclear plant in South Carolina found boric acid on the containment floor. This led to the discoveiy of a through-wall crack where a major pipe was welded to the reactor vessel nozzle.
This location was specifically examined during the 10-year in-service inspection in 1993, but the crack, which was present at the time, was missed because an air gap between the pipe weld area and the inspection detector, a sonar-like device, created "noisy" output. This noise masked the indications of a crack and prevented workers from noticing the problem (Casto, 2001).
On February 15, 2000, a steam generator tube broke at Indian Point Unit 2 in New York and caused the uncontrolled release of radioactivity into the atmosphere. Under its revamped oversight process, the NRC issued its first red finding-a failing grade-to Indian Point for this event because the near-miss was avoidable.
The NRC cited the plant's owner for having detected signs of degradation exceeding federal regulations during the steamn generator tube inspections in 1997 but failing to do anything about it (Miller, 2000).
These examples illustrate two fundamental flaws in current aging management programs: (1) looking in the wrong spots with the right inspection tech-niques (as happened with the Oconee and Quad Cities plants), and (2) looking in the right spots with the wrong inspection techniques (as happened with the Sunmmer and Indian Point plants). Aging management programs should find these problems before they become self-revealing, but they are not.
As problems in Region C have the potential to be much more severe than problems in Region B, strong aging management programs must be in place to help prevent these failures from occurring.
21 Union of Concerned Scientists Reactor License Renewal:
Ignoring the Generation Gap Nuclear plants were originally licensed for 40-year operating lifetimes. Several plant owners have already sought and obtained 20-year license extensions from the NRC, and many more owners are queuing up to do so.The NRC's license renewal process is based on an assumption that all U.S. nuclear plants con-form to their current licensing basis, the industry term for the set of federal safety regulations that apply to a specific nuclear power plant,' and a deter-mination that plant owners have effective aging management programs for all equipment and struc-tures with an important safety function. However, this assumption and determination, even if valid, may not be enough to adequately ensure that nuclear reactors can operate safely in Region C.
The current licensing basis varies from plant to plant. Nuclear plants licensed in the same year have different current licensing bases due to varying exemptions and license conditions. New regulations are constantly being generated and existing regula-tions revised so that, for examnple, the applicable regulations in 1985 differ significantly from the applicable regulations in 1975.The NRC cannot issue or revise its regulations unless it determines the regulatory changes either maintain or increase safety levels. Therefore, today's regulations are as good as, or better than, the 1975 or 1985 regulations from a safety perspective.
If a new nuclear power plant were to be built and operated today, it would have to meet the federal safety regulations in effect today. But the NRC's license renewal process fails to define the generation gap between today's safety requirements and the current licensing basis for an existing nuclear power plant, making it difficult-if not impossible-to determine whether an aging plant will operate safely for 20 more years.A prudent regulator would want to know just how far away from today's safety standards an aging nuclear plant seeking license renewal is and why it is acceptable for that plant not to meet today's safety standards for two more decades. The NRC's license renewal process fails to ask and answer that crucial question.
This shortfall must be fixed if aging reactors are to operate for 20 more years.
Recommendations The NRC's license renewal process questions whether plant owners have effective aging management programs, and the answer has always been "yes" despite considerable evidence to the contrary. It is well known that "two wrongs don't make a right," but it takes two rights to make a right in aging management-looking in the right spots with the right techniques. If today's existing nuclear reactors are to be in service for another 20 years, there needs to be sn-ong aging management programs at all reactors to ensure failures are found before it is too late. UCS recommends the following reforms:
- 1. The NRC must overhaul how it assesses problem identification and resolution programs.
Diverse inspection methods lessen the chances of overlooking problems when looking in the right spots.
- 2. The NRC must require periodic inspections of areas considered less vulnerable to degradation and deemed outside the inspection scope.
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 been overlooked.
- 3. The NRC must formally review all differences between today's safety regulations and the regula-tions applicable to an aging reactor before granting license renewals.
It is unacceptable to grant license extensions to reactors that lag woefu~ly behind in regulations.
The NRC must confirm that adequate safety mar-gins exist for reactors up for license renewal and require safety and regulatory upgrades as necessary to remedy any shortfalls.
Actually, the best way to prevent recurrent prob-lenis at aging nuclear plants would be for the NRC to suspend the issuance of license renewals until the nuclear industry has demonstrated that it takes plant safety seriously. Plant owners will continue to follow lax aging management programs and allow failures to reveal themselves unless the NRC irmposes stronger standards. If the NRC required truly effective aging management programs as a condition for license renewal, plant owners would have no choice but to adhere to stronger safety regulations, regardless of cost. PRight now, they have no incentive to do so.
23 Union of Concerned Scientists CHAPTER 5
Conclusion T
he risk profile for nuclear power reactors varies from cradle to rocking chair just as it does for people. Because the risk is never zero, it must be properly managed at all times to protect against undue risk.The best way to manage nuclear reactor risk is to have an aggressive regulator consistently enforcing federal safety regulations.
At least this is what UCS considers to be the best way; we've never actually observed such NRC performance.We have observed, all too often, the consequences that arise from a lack of enforcement of federal safety regulations. When this happens, safety margins drop unnecessarily low and the risk to people living near the reactors climbs unaccept-ably high.
The late Henry Kendall, Nobel laureate and former chairman of the UCS board of directors, once said, "You can't have one end of a ship sink."
This quote is fitting for U.S. nuclear reactors, which are essentially in this very ship.A serious accident at any U.S. reactor, at any point in its lifetime, would likely dim the future for all reactors.To prevent unwarranted risk to the American public, Congress must reform the NRC into a consistently effective enforcer of federal safety regulations.
The suggested reforms outlined in this report would lay the proper foundation for the NRC to resolve long-standing safety problems at the more than 100 nuclear plants operating nationwide.
Congress must sustain the NRC reform effort through completion of this entire process, to provide the American public with the protection they expect and deserve.
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U.S. Army Corps of Engineers. 2001. "Reliability Analysis of Navigation Lock and Dam Mechanical and Electrical Equipment." Technical Letter No.
1110-2-560.June 30. Online at mwv. usace. army. mil/
publications /eng-tech-ltrs /etl 1110-2-560/tl.pdf U.S. House, Committee on Interior and Insular Affairs, Subcommittee on Energy and the Environment. 1984. "Licensing Process at Grand Gulf Nuclear Powerplant." Hearing Proceedings.
July 24.
U.S. House, Committee on Interior and Insular Affairs, Subcommittee on Energy and the Environment. 1982. "Quality Assurance at the Zinmmer Nuclear Station." Hearing Proceedings.
September 14.
U.S. House, Committee on Interior and Insular Affairs, Subcommittee on Energy and the Environment. 1981. "Quality Assurance in Nuclear Powerplant Construction." Hearing Proceedings.
November 19.
27 Union of Concerned Scientists APPENDIX Selected Examples of NRC Generic Communications Manufacturing Defects
- BL-74-06: Defective Westinghouse Type W-2 Control Switch Component. Bulletin. May 22, 1974.
- CR-801-17: Fuel Pin Damage Due to Water Jet from Baffle Plate Corner. Circulr.July 23,1980.
- IN-80-40: Excessive Nitrogen Supply Pressure Actuates Safety-Relief Valve Operation to Cause Reactor Depressurization. Information Notice. November 7, 1980.
- CR-81 -01: Design Problems Involving Indicating Pushbutton Switches Manufactured by Honeywell Incorporated. Circular.January 23, 1981.
G CL81 011: BWVR Feedwater Nozzle and Control Pod Drive Return Line Nozzle Cracking (NUREG-0619).
Generic Letter. February 28, 1981.
- IN-82-43: Deficiencies in LWP, Air Filtration/Ventilation Systems. Information Notice. November 16,1982.
" BL-86-03: Potential Failure of Multiple ECCS Pumps Due to Single Failure ofAii-Operated Valve in Minimum Flow Recirculation Line. Bulletin, October 8, 1986.
" IN-88-76: Recent Discovery of a Phenomenon Not Previously Considered in the Design of Secondary Containment Pressure Control. Information Notice.
September 19, 1988.
" IN-89-44: Hydrogen Storage on the Roof of the Control Room. Information Notice. April 27, 1989.
Material Imperfections
" BL-79-26: Boron Loss from BWR Control Blades.
Bulletin. November 20, 1979.
" GL85022: Potential for Loss of Post-LOCA Recirculation Capability Due to Insulation Debris Blockage. Generic Letter. December 3,1985.
" GL88005: Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants. Generic Letter. March 17, 1988.
" GL89008: Erosion/Corrosion-Induced Pipe Wall Thinning. Generic Letter. May 2, 1989.
" GL91015: Operating Experience Feedback Report, Solenoid-Operated Valve Problems at U.S. Reactors.
Generic Letter. September 23, 1991.
" IN-97-84: Rupture in Extraction Steam Piping as a Result of Flow-Accelerated Corrosion. Information Notice.
December 11, 1997.
Poor Workmanship
" BL-73-06: Inadvertent Criticality in a BoilingWater Reactor. Bulletin. November 27, 1973.
" BL-77-04: Calculational Error Affecting the Design Performance of a System for Controlling pH of Containment Sump Water Following a LOCA. Bulletin.
November 4,1977.
" CR-78-04: Installation Error That Could Prevent Closing of Fire Doors. Circular. May 15, 1978.
" CR-79-18: Proper Installation of Target Rock Safety-ReliefValves. Circular. September 6, 1979.
" IN-85-96:Temporary Strainers Left Installed in Pump Suction Piping. Information Notice. December 23, 1985.
- IN-90-77: Inadvertent Removal of Fuel Assemblies from the Reactor Core. Information Notice. December 12, 1990.
- IN-2001-06: Centrifugal Charging Pump Thrust Bearing Damage Not Detected Due to Inadequate Assessment of Oil Analysis Results and Selection of Pump Surveillance Points. Information Notice. May 11, 2001.
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 Scientists National Headquarters Two Brattle Square Cambridge, MA 02238-9105 Phone: 617-547-5552 Tol-Free: 800-666-8276 Fax: 617-864-9405 Washington, DC Office 1707 H Street NW, Suite 600 Washington. DC 20006-3962 Phone: 202-223-6133 Fax: 202-223-6162 West Coast Office 2397 Shattuck Avenue, Suite 203 Berkeley, CA 94704-1567 Phone: 510-843-1872 Fax: 510-843-3785 Email ucs@ucsusa.org Web www. ucsusa.org N
uclear power in the United States has, throughout the industry's history, been less safe and more expensive than necessary because of ineffective oversight. The Nuclear Regulatory Commission's (NRC) poor regulatory performance has contributed to several major disasters and countless close, calls at nuclear plants.
Nuclear plants are at highest risk for failure when they begin operation and when they approach the end of their useful life.With new reactor designs proposed for construction, and more than 100 aging U.S. nuclear plants seeking extensions tO their operating licenses, the need for an effective regulator has never been greater.
In this report, the Union of Concerned Scientists describes nuclear plant risks from cradle to grave and makes recommendations on how to reform the NRC into a consistently effective enforcer of 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.