Friday, September 28, 2018

A Beyond Nuclear Briefing Paper

Beyond Nuclear
6930 Carroll Avenue Suite 400
Takoma Park, MD 20912
Tel. 301-270-2209

A Beyond Nuclear Briefing Paper:
The Subsequent License Renewal of Peach Bottom Atomic Power Station needs to be scientifically informed by an “autopsy” performed on decommissioning nuclear power stations of similar design to “reasonably assurance” material safety margins projected for the second license extension

The Issue
The Nuclear Energy Institute (NEI), the lead organization for the U.S. commercial nuclear power industry, envisions the industry’s “Bridge to the Future” through a series of reactor license renewals from the original 40-year operating license; first by a 40 to 60-year extension and then a subsequent 60 to 80-year extension.  Most U.S. reactors are already operating in their first 20-year license extension and the first application for the second 20-year extension (known as the “Subsequent License Renewal”) is before the U.S. Nuclear Regulatory Commission (NRC) for review and approval. NEI claims that there are no technical “show stoppers” to these second license renewals. However, as aging nuclear power stations seek to extend their operations longer and longer, there are still many identified knowledge gaps for at least sixteen (16) known age-related material degradation mechanisms (embrittlement, cracking, corrosion, fatigue, etc.) that are attacking irreplaceable safety-related systems including miles of electrical cable, structures such as the concrete containment and components like the large reactor pressure vessel. For example, the national labs have identified that it is not known how radiation damage will interact with thermal aging. Material deterioration has already been responsible for near miss nuclear accidents.  As such, permanently closed and decommissioning nuclear power stations have a unique and increasingly vital role to play in providing the still missing data on the impacts and potential hazards of aging for the future safety of dramatic operating license extensions.
The NRC and national laboratories document that a post-shutdown autopsy of sorts to harvest, archive and test actual aged material samples (metal, concrete, electrical insulation and jacketing, etc.) during decommissioning provides unique and critical access to obtain the scientific data for safety reviews of the requested license extensions.  A Pacific Northwest National Laboratory (PNNL) 2017 report concludes, post-shutdown autopsies are necessary for “reasonable assurance that systems, structures, and components (SSCs) are able to meet their safety functions. Many of the remaining questions regarding degradation of materials will likely require [emphasis added] a combination of laboratory studies as well as other research conducted on materials sampled from plants (decommissioned or operating).” PNNL reiterates, “Where available, benchmarking can be performed using surveillance specimens. In most cases, however, benchmarking of laboratory tests will require (emphasis added) harvesting materials from reactors.” In the absence of “reasonable assurance,” it is premature for licensees to complete applications without adequate verification and validation of projected safety margins for the 60 to 80-year extension period. 
Decommissioning is not just the process for dismantling nuclear reactors and remediating radioactive contamination for site restoration. Decommissioning has an increasingly important role at the end-of-reactor-life-cycle for the scientific scrutiny of projected safety margins and potential hazards at operating reactors seeking longer and longer license extensions.                       
The Problem
After decades of commercial power operation, the nuclear industry and the NRC have done surprisingly little to strategically harvest, archive and scientifically analyze actual aged materials. Relatively few samples of real time aged materials have been shared with the NRC.  The NRC attributes the present dearth of real time aged samples to “harvesting opportunities have been limited due to few decommissioning plants.” However, ten U.S. reactors have completed decommissioning operations to date and 20 units are in the decommissioning process. More closures are scheduled to begin in Fall 2018.  A closer look raises significant concern that the nuclear industry is reluctant to provide access to decommissioning units for sampling or collectively share this cost of doing business to extend their operating licenses. Key components including severely embrittled reactor pressure vessels were promptly dismantled by utilities and buried whole without autopsy. Many permanently closed reactors have been placed in “SAFSTOR,” defueled and mothballed “cold and dark” for up to 50 years without the material sampling to determine their extent of condition and the impacts of aging. Moreover, the NRC is shying away from taking reasonable regulatory and enforcement action to acquire the requested samples for laboratory analysis after prioritizing the need for a viable license extension safety review prior to approval. Meanwhile, the nuclear industry license extension process is pressing forward. 
David Lochbaum, a recognized nuclear safety engineer in the public interest with the Union of Concerned Scientists, identifies that nuclear research on the impacts and hazards of age degradation in nuclear power stations presently relies heavily on laboratory accelerated aging---often of fresh materials---and computer simulation to predict future aging performance and potential consequences during license extension.  Lochbaum explains that “Nuclear autopsies yield insights that cannot be obtained by other means.” Researchers need to compare the results from their time-compression studies with results from tests on materials actually aged for various time periods to calibrate their analytical models. According to Lochbaum, “Predicting aging effects is like a connect-the-dots drawing. Insights from materials harvested during reactor decommissioning provide many additional dots to the dots provided from accelerated aging studies. As the number of dots increases, the clearer the true picture can be seen. The fewer the dots, the harder it is to see the true picture.
The Path Forward
1) Congress, the Department of Energy (DOE) and the NRC need to determine the nuclear industry’s fair share of autopsy costs levied through collective licensing fees for strategic harvesting during decommissioning and laboratory analysis of real time aged material samples as intended to benefit the material performance and safety margins of operating reactors seeking license extensions, and;
2) As NRC and the national laboratories define the autopsy’s stated goal as providing “reasonable assurance that systems, structures, and components (SSCs) are able to meet their safety functions” for the relicensing of other reactors, the NRC approval process for Subsequent License Renewal extensions should be held in abeyance pending completion of comprehensive strategic harvesting and conclusive analysis as requested by the agency and national laboratories, and;

3) Civil society can play a more active role in the independent oversight and public transparency of autopsies at decommissioning reactor sites such as through state legislated and authorized nuclear decommissioning citizen advisory panels. 

Link to the Beyond Nuclear Decommissioning Autopsy Whitepaper and documentation

Tuesday, September 18, 2018

DEP Announces $469,501 Settlement to Resolve Civil Penalties for United Refining Company Operating Violations

Dept. of Environmental Protection

Commonwealth News Bureau
Room 308, Main Capitol Building
Harrisburg PA., 17120 
Melanie Williams, DEP

DEP Announces $469,501 Settlement to Resolve Civil Penalties for United Refining Company Operating Violations

Meadville, PA – The Pennsylvania Department of Environmental Protection (DEP) has agreed to a $469,501 Consent Assessment of Civil Penalty with United Refining Company (URC) for violations of the Air Pollution Control Act and Title V Permit at the URC refinery in the City of Warren, Warren County. 
DEP inspections between September 16, 2014, and December 10, 2015, and continuous emission monitoring data, revealed multiple permit violations at the refinery, including:
URC failed to inspect and measure primary and secondary seal gaps for several large storage tanks;
URC failed to repair, empty, or remove from service a large storage tank after a defect had been detected;
URC failed to conduct particulate testing for several air contamination sources; and
URC exceeded emissions limits for sulfur dioxide, nitrogen oxides, and hydrogen sulfide on several occasions for multiple sources from 2010 through 2016.
“DEP is committed to enforcing the conditions of the permits we issue, and keeping Pennsylvania’s air free of excess pollution,” said DEP Secretary Patrick McDonnell. 
DEP issued Notices of Violation for these permit violations. The violations were corrected by URC prior to the Consent Assessment of Civil Penalty and no further action related to these violations is required by URC.

Saturday, September 15, 2018

Peach Bottom: Expanded Actions for LEFM Conditions

Subject:  Acceptance Review for Peach Bottom - License Amendment Request for Expanded Actions for LEFM Conditions (EPID L-2018-LLA-0230)
ADAMS Accession No. ML18254A204

Thursday, September 13, 2018

NRC Preparing for Hurricane Florence

The Nuclear Regulatory Commission resident inspectors at nuclear plants in the Carolinas and Virginia are reviewing the plant operators’ preparations in advance of Hurricane Florence, currently projected to make landfall in the Southeast later this week.

The NRC is also sending additional inspectors to those plants and will activate its regional incident response center in Atlanta, to provide around-the-clock staff support during the storm.

Duke Energy’s Brunswick nuclear plant south of Wilmington, N.C., could face hurricane-force winds, major storm surges and heavy rain. Other plants near the storm’s projected path are also taking precautions.

Nuclear plant operators would declare an emergency if conditions are expected that would require that declaration.

Plant procedures require operators to shut down the reactor well before hurricane-force winds arrive on site. In preparing for Hurricane Florence, the staffs at Brunswick, Surry in southeastern Virginia, Harris near Raleigh, N.C., Robinson near Hartsville, S.C., and some other plants are working through their severe weather procedures, including ensuring that all loose debris and equipment have been removed or secured, and conducting walk-down inspections of important systems and equipment.

NRC inspectors are verifying that all preparations have been completed, and the plants’ emergency diesel generators are available with ample fuel if the storm affects off-site power.

The NRC has also been in touch with officials at the Global Nuclear Fuels-America facility near Wilmington, N.C., the research reactor at North Carolina State University in Raleigh and other NRC licensees in the area to verify their preparations for the storm.

From the NRC Region II incident response center in Atlanta, NRC staff members will monitor Hurricane Florence while remaining in contact with plant operators, NRC on-site inspectors, the NRC’s headquarters operations center, and state emergency officials in the Carolinas, Virginia and all potentially affected states.

The additional NRC inspectors will remain at the nuclear plant sites and the incident response center will remain staffed as long as conditions require.

Tuesday, September 11, 2018

NRC To Hold Meeting Seeking Public Comment on Environmental Review for Peach Bottom Atomic Power Station Subsequent License Renewal‌

Nuclear Regulatory Commission staff will meet in Delta, Pa., on Sept. 25, to hear the public’s views on environmental issues the agency should consider in review of the Exelon Generation application for an additional 20 years of operation for Peach Bottom Atomic Power Station
Units 2 and 3.

The NRC will hold the meeting at the Peach Bottom Inn, 6085 Delta Road in Delta, from 6-8 p.m. Staff presentations will describe the environmental review process and the proposed review schedule. A formal public comment session will follow the presentations. An NRC open house, from 5-6 p.m., will provide the public an opportunity to speak informally with agency staff.

Those preferring to register in advance to comment during the meetings should contact David Drucker at 301-415-6223 or via e-mail at by Sept. 18. Those choosing to speak may also register in person by 5:45 p.m. Individual comments could be limited based upon the time available and the number of people seeking a speaking role. Individuals with special needs for attending or presenting information at the meetings should notify the NRC by Sept. 18.

NRC staff will also consider written comments on environmental issues until Oct. 10, following the publication of a notice in the Federal Register. Please include Docket ID NRC-2018-0130 with the comment, via website.

Exelon submitted the Peach Bottom subsequent license renewal application on July 10. The subsequent license renewal process determines whether an operating reactor can extend its license for an additional 20 years. Theapplication, less proprietary details, is available on the NRC website. In addition, the Harford County Public Library, 2407 Whiteford Road in Whiteford, Md., will maintain a copy of the application’s environmental report for public inspection.

Friday, September 7, 2018

NRC Resumes Review of Application for Texas Consolidated Spent Nuclear Fuel Storage Facility

The Nuclear Regulatory Commission has resumed its safety and environmental reviews of an application by Interim Storage Partners to construct and operate a consolidated spent nuclear fuel storage facility in Andrews County, Texas.
The application was initially filed by Waste Control Specialists in 2016. The company requested the NRC suspend its review in April 2017, pending the anticipated sale of the company. WCS was sold to J.F. Lehman & Co., in January 2018. In March, WCS and Orano, an international nuclear supplier, formed Interim Storage Partners as a joint venture to take over the spent fuel storage project. The new company submitted a revised application to the NRC in June.
When NRC’s review was suspended last year, the staff was in the process of receiving public comment on the scope of its environmental review and had issued a notice of opportunity for an adjudicatory hearing. Those processes will now resume.
The staff will consider all comments previously received on the scope of the environmental review. In a notice published Sept. 4 in the Federal Register, the NRC requested additional public comment through Oct. 19 on environmental issues to be considered in its environmental impact statement. In a separate notice in the Federal Register, published Aug. 29 and corrected Aug. 31, the NRC announced an opportunity to request a hearing, through Oct. 29. The notices include detailed instructions on how to file a hearing request or submit public comment.
The NRC completed its administrative review of the revised application and informed Interim Storage Partners of its decision to resume the review in a letter dated Aug. 21, 2018. The staff expects to complete its safety, security and environmental reviews in the summer of 2020.