By Roger Witherspoon

Operators of the Oyster Creek nuclear power plant have been granted a year’s delay in their required emergency drill inSouth Jerseybecause their state emergency counterparts are still occupied with the aftermath of a summer hurricane and an early fall snowstorm.

Michael Pacilio, president of Exelon Nuclear, which operates the plant, was notified by the Nuclear Regulatory Commission that the exercise originally scheduled for Sept. 27, 2011 could be postponed until the end of June, 2012.  By then, state andOceanCountyemergency offices should be finished cleaning up after real disasters and able to concentrate on simulated safety efforts.

But the postponement raises questions bout the legitimacy of emergency drills which are only conducted when conditions and personnel staffing are optimal.  Emergency planning in New York Cityprior to the 9/11/01 attacks, in New Orleans prior to Hurricane Katrina, and at Fukushima Daiichi prior to the earthquake and tsunami all failed to take into account the impact of multiple emergencies either in proximity or simultaneously.

            The nuclear emergency drills test the cooperation between plant officials and state and local emergency operators and their ability to evacuate thousands of people from regions threatened by spreading radiation. Federal law requires drills involving plant and community emergency organizations every two years at each of the nation’s 104 commercial reactors. These are observed and graded by the Federal Emergency Management Agency. The NRC observes and grades separate drills of internal plant safety systems. Oyster Creek, which had its last monitored, public safety drill October 6, 2009, was required to hold a drill before the end of calendar 2011.

John Lamb, of the NRC’s Office of Nuclear Reactor Regulation, noted in his letter to Pacilio that “Hurricane Irene passed through New Jersey on August 28, 2011, causing widespread damage and flooding in the surrounding area, and that the event required the response of the NJ State Office of Emergency Management, the Ocean County Office of Emergency Management, and the Division of State Police…

“New Jersey OEM has indicated that it is not feasible to reschedule the specific offsite functions that remain to be exercised prior to the end of calendar year 2011.”

In granting the stay, the NRC noted that Oyster Creek personnel have not been idle, and portions of the emergency plan, encompassing a 10-mile zone around the nuclear plant, have been reviewed with local emergency organizations.  Since the 2009 exercise, Lamb wrote, Oyster Creek “has conducted 16 training drills/ exercises/ demonstrations and 32 training sessions that have involved interface with State and local authorities.

“These drills and training sessions did not exercise all of the proposed rescheduled offsite functions, but they do support the licensee’s assertion that it has a continuing level of engagement with the State and local authorities.”

The 2009 exercise did not go smoothly. The Federal Emergency Management Agency (FEMA), which oversees the drills and grades them, gave Exelon a failing grade because during the simulated emergency, several municipalities were not notified of the release of radiation and the need to evacuate or shelter their residents. A remedial drill was held in January, 2010.

These types of drills were considered routine prior to the terrorist attacks in September, 2001. They are not, however, full scale drills: towns or neighborhoods are not evacuated the way public schools are totally emptied during their periodic fire drills. Instead, these “table top drills” use symbolic stand-ins which may not always be appropriate.

           New York City’s drills, for example, had one fireman go from his fire house to a specific location when the “emergency” sounded, and his presence represented the successful, complete relocation of several companies, their equipment and communications.

In fact, the post-9/11 study conducted for the city by McKinsey & Company, and the 2004 study conducted by the national 9/11 Commission found that when theWorldTradeCenterwas struck, fire companies acted on their own, with no coordination, and established multiple, rump, uncoordinated “command posts” downtown. There was no radio coordination between the police and fire departments – which was not an issue in the drills involving one lone policeman and one lone fireman. As a result, the police heard the order to evacuate the unstable towers but the firemen did not.

9/11-Commission member and former Secretary of the Navy John Lehman, Jr., excoriated former NYC Mayor Rudy Giuliani, Fire Commissioner Thomas Von Essen, and Police Chief Bernard Kerick in  a public hearing in May, 2004, stating that their drills and resulting emergency plan “it’s not worthy of the Boy Scouts, let alone this great city.”

Hospitals throughout theNew Orleansarea had held many drills simulating evacuation patients in an emergency. But these called for hospitals or nursing homes to disperse their patients among surrounding facilities. When the levees broke during Hurricane Katrina and the region was inundated, there was nowhere for some of the hospitals’ and nursing home patients to go, with tragic drowning deaths resulting. None of the drills had envisioned the need for multiple evacuations.

More recently the same lack of foresight played out in Japan last spring. The six nuclear reactors at Fukushima Daiichi had backup diesel generators in case their external power lines were down. But these had two or three days’ supply of fuel. It was assumed that extra fuel could always be delivered, and that with six nuclear plants at the site, a single stricken facility could always tap the resources of the others.

            The nuclear complex was helpless when the roads were destroyed by the tsunami and earthquake and all the power plants were cut off.  Hearings in Congress last spring on similarities between the Japanese and American plants’ preparedness revealed that it has long been considered impossible for multiple nuclear plants on the same site – like Salem1 and 2 and Hope Creek– to all have emergencies at the same time. During the past 40 years of commercial nuclear power in America there have been no drills simulating simultaneous nuclear plant meltdowns.

Neil Sheehan, spokesman for the NRC, said the Japanese experience of multiple calamities was not lost on the regulatory agencies planners.

“The point has been raised at the Commission of the need to add more realism to the exercises,” Sheehan said. “The Commissioners acknowledge the need to look atJapanfor some lessons learned and decide if there is a need over the long term for planning changes that take those factors into account.”

Mary Goepfert, spokeswoman for the state Office of Emergency Management, saidNew Jerseyofficials are not sitting idly by and leaving testing up to federal regulators. “The NRC and FEMA require drills they review every other year,” Ms. Goepfert explained, “but inNew Jerseywe run an exercise every year and we do an evaluation to the same standards.

“With Hurricane Irene, the question was how many counties to evacuate. With Oyster Creek, the issue is north and south, or east and west – which way is the wind blowing and what communities might be in the path of radiation.”

Goepfert said the sate has its own experts in the state bureau of Nuclear engineering as well as its own weather forecasting capabilities. “We are not just dependent on information from the plant or federal officials,” she said. “We look at what is the weather and how might it change; what are the conditions of the roads and what roads might not be usable. We will look at hazardous conditions where multiple failures can happen.”

Some independent experts state that while it is important to test how well emergency agencies could operate when their resources are stretched thin, it would be a mistake to hold an Oyster Creek emergency drill at this time.

“You drill to a plan,” said Kenneth Mallette, vice president for the Northeast Region of James Lee Witt Associates. “You don’t just wing it and see what happens. The nuclear industry is taking a look atFukushimaand saying we are going to have to plan for these catastrophic events. And it comes down to staffing – the same people who do the day-to-day emergency issues at the county and local levels are doing double duty now because of actual events.

“So you would have to plan an exercise to ask what do we need when there is not optimum staffing and optimum conditions?  You need plans for when we are short handed to learn how we can react when we have a hurricane and a snowstorm and an accident at the power plant at the same time. In reality, these things could happen and you could be short handed, so how do you handle that as a state agency?”

Mallette, was chief of the emergency management bureau for the NJ Sate Police until his retirement in 2007, said there are residents of Passaic County who are still out of their homes due to flooding and infrastructure damage caused by Hurricane Irene last August. Correcting that problem is still a state priority. But even the best of plans can get surprised.

“What happens when you have a snow storm in October?” he asked. “If you look at risk analysis, nobody thought of snow in the middle of October, and we never thought of what wet snow would do when leaves were on the trees. We look at snow in the middle of winter when the leaves are gone.

“So planners are now going back and saying how do we deal with that? We in the public sector are often exercising to tell everybody how good we are – and that doesn’t do anybody any good. In this case, there is a whole process in New Jersey behind the exercise program. The planning is a living process that is always changing and never stays the same because if it does stay the same, that plan would be doomed to failure.

“Emergency plans are living documents; it is not a stagnant process. You find the gaps and try to fill them and make sure you continue to do things correctly. There is no doubt that the state is going to do that when it comes to radiological planning for their nuclear power plants.”

By Roger Witherspoon

            “…EPA’s insupportable assumption that screening technologies are available at nuclear facilities, threaten the viability of existing plants and their daily contribution to cost-effective electricity….”

Brief, Entergy Corp v US EPA

2^nd Circuit Court of Appeals

July 5, 2005

            For much of the last decade Entergy Nuclear, the owners of the twin Indian Point reactors in New York, have battled environmental regulators from the state and federal government over the continued use of enormous volumes of Hudson River water to quench its power systems. Their federal court suit, joined by a coalition of environmental organizations and New Jersey, New York, and four other states, culminated in a 2009 decision by the U.S. Supreme Court upholding their contention that wedge wire systems were not designed for nuclear power plants and could not meet the requirements of the Clean Water Act. (  http://www.rogerwitherspoon.com/docs/entergybriefentergyvepa1-07.pdf   ).

The High Court also agreed with Entergy’s position that federal regulators could use cost benefit analysis to determine the most effective and reasonable means of ordering compliance with environmental laws, even though that sort of calculus could short change non-commercial aquatic life.

Now it’s time for a full reversal.

On Monday, Entergy began four months of hearings before New York State Administrative Law Judges in an effort to prove that wedge wire systems installed in front of its nuclear plans would nearly eliminate the annual destruction of some two million juvenile and adult fish and some 300 billion hatchlings and baby fish. If the judges agree, Entergy could avoid having to retrofit the plants with an expensive closed cycle cooling system, which functions like the recirculating radiator on an automobile, but on a massive industrial scale.  Such systems range in cost from about $400 million for a mechanical draft which resembles a four story warehouse, to a massive, 150-foot-tall cooling tower costing a projected $1.5 billion.

At stake is the continued operation of the power plants which provide about 5% of the electricity used daily in New York City and adjacent Westchester County. For without the permit from the state Department of Environmental Conservation to take water from and discharge it back into the Hudson River, the plants cannot operate regardless of whether their contested licenses are renewed by the federal Nuclear Regulatory Commission.

Phillip Musegaas, program director for the environmental group Riverkeeper – which was also involved in the 2005 suit against the EPA – said “we do not believe wedge wire is a viable solution. It’s a fact that wedge wire screens have never been used at a nuclear power plant of this size, and we do not believe Entergy has made its case that wedge wire will work at Indian Point.

“And wedge wire screens do not address the thermal discharge issue (  http://bit.ly/nEvEGO ). They are not an effective substitute for closed cycle cooling.”

The thermal pollution from heat dumped into the waterways by power plants using once through cooling is tremendous, particularly at nuclear sites. The thermal discharge at PSEG’s, coal powered, Mercer Generating Station in Hamilton, NJ, for example, dumps about 1.5 billion BTUs of heat into the waterway, according to company records.  The nuclear power plants at Indian Point and Salem however, dump about 30 billion BTUS of heat hourly into their local waterways. That is the equivalent of the heat which would be generated by exploding a nuclear bomb, the size of the bomb which destroyed Hiroshima, in the waters of the Hudson River and Barnegat Bay every two hours, all day, every day. It is one reason by the environmental regulators in both states are pushing for closed cycle cooling systems.

Indian Point is confronting the same issue which resulted in the agreement between the New Jersey Department of Environmental Protection and Exelon Corp., owners of the Oyster Creek Nuclear Generating Station, to shut down the facility on Dec. 31, 2019. The agreement, worked out by Gov. Chris Christie, was formally ratified by the NRC last week. Edward Miller, project manager in the NRC’s plant licensing branch, stated in a letter to Exelon President Michael Pacillio that “we will continue to verify the safe operation of the plant via the planned oversight” and factor into the review programs to end the operations.

Oyster Creek is the first of nine power plants in New Jersey which are being targeted by state environmental regulators which kill an estimated nine million fish in their cooling systems. New Jersey’s efforts to force compliance involve four plant sites operated by PSEG – ranging from the twin reactors at the Salem Nuclear Generating Station, which use 3 billion gallons of water daily, to the Sewaren natural gas plant using 540 million gallons daily; as well as plants operated by Exelon, RC Cape May Holdings, and Calpine.

In New York, environmental regulators are going after 40 power plants, (  http://www.rogerwitherspoon.com/viewer/vwnukegrphc14.html   ) including Indian Point, which kill some $20 billion juvenile and mature fish annually in waterways around the state (  http://www.rogerwitherspoon.com/viewer/vwnukegrphc15.html  ).  But the biggest impacts are created by the  gauntlet of power plants along the Long Island Sound and the lower Hudson River which kill fish by the billions as they migrate up to 200 miles from the Atlantic Ocean to spawning sites along the Hudson River.

The scale of the destruction can be seen in the NRC’s environmental assessment of the twin Indian Point nuclear plants in Buchanan, 30 miles north of Manhattanin the heart of the Hudson Rivertidal estuary. In determining that the overall impact on essential fish habitat is “small to moderate” the agency noted approvingly that  new screens installed in front of the 40-foot-wide intake pipes in 1984 had reduced the destruction of baby fish between 1984 and 1991 by 187 Billion  per year to its present rate of just 300 Billion newly hatched fish  (  http://www.rogerwitherspoon.com/docs/nrc-finalipieis-part2-12-10.pdf   ).

The National Marine Fisheries Service, responding to the NRC’s environmental analysis of Indian Point, (   http://www.rogerwitherspoon.com/docs/nmfs-eisfor1p23-10-10.pdf   )  found  that the “once through cooling systems” are vacuuming up trillions of newly hatched fish – those under a half inches in length – and destroying them in their heat exchangers. The NMFS directly challenged the finding by the NRC that the damage to the aquatic environment is  “moderate”, and asserted there is  “strong evidence” that the decline in  fish stocks along the entire northeast Atlantic seaboard is due more to the destruction of baby fish than to over fishing of adults.

“The NMFS does not reach all of the same conclusions as the NRC with respect to adverse effects that relicensing IP2 and IP3 would have on the fishery resources and their habitats,”  Peter Colosi, the agency’s assistant northeast regional administrator, wrote in an acerbic analysis of the impacts of theHudson Rivernuclear plants.

“Given the immense natural productive potential of the Hudson River Estuary,” Colosi continued, “and taking consideration the staggering numbers of organisms that are lost directly, indirectly, and cumulatively through continued operation of electric generating stations that continue to use once-through cooling techno logy in the Mid-Hudson, the NMFS suggests that the current Indian Point relicensing process is an appropriate and opportune time to apply the Clean Water Act.”

The hearings challenging New York’s attempt to force Entergy to build a closed cycle cooling system as a prerequisite to getting a discharge permit are scheduled to run through February in the agency’s Albany offices. The daily hearings will cover several controversial subject areas, including the wedge wire from Monday through Nov. 8; radioactive materials in the environment from November 14 through December 9; and, and protection of endangered species from December 12 through December 16. Hearings are tentatively scheduled to run through Feb. 24, covering these and other items as needed.

By Roger Witherspoon

     Entergy Nuclear has asked federal regulators to override New York State’s weapons law to allow Indian Point guards to carry heavier weaponry on the nuclear site than standard commercial security guards.

The request comes ten years after terrorists flew a hijacked plane directly over the twin containment domes on the Hudson River en route to a suicidal dive into the World Trade Center 25 miles to the south. In the interim, Entergy and the nuclear industry have waged a two pronged effort: a public relations campaign with advertisements depicting a heavily armed, paramilitary protective force; and a lobbying campaign to dissuade the Nuclear Regulatory Commission from requiring the companies to have significantly more protection than the average commercial guard forces.

In that latter effort, the industry has been successful.  While the exact armaments used by guards  at particular nuclear power plants vary and are not made public, federal regulators do not require operators to have a paramilitary force capable of defending against an armed assault using rocket propelled grenades and other heavy weaponry.

And while the NRC came out with new security guidelines in 2003, these were largely voluntary in keeping with the Bush administration’s anti-regulatory policy. They were made mandatory in 2009, but Indian Point, New Jersey’s Salem, Hope Creek and Oyster Creek plants, and about 60 others around the country were granted waivers so they did not have to incur immediate expenses.

The new request for heavier weapons was submitted to the NRC April 27, and asks for federal “Preemption Authority” to overrule state gun laws. NRC spokesman Neil Sheehan explained that “New York State law prohibits the possession and use of handguns, rifles, shotguns, short-barreled shotguns, short-barreled rifles, machine guns, semi-automatic assault weapons and large-capacity magazines, the possession and use of which have been determined to be necessary at Indian Point for the protection of radioactive material or other property.

“Therefore, Entergy is seeking standalone pre-emption authority to allow Indian Point security personnel to continue to possess and use the standard weapons, devices, ammunition and/or other firearms at the facility.”

NRC spokeswoman Diane Screnci said “this is the first time Indian Point has applied, and there is no requirement to apply again if the request is granted.”

Entergy declined to discuss whether they are currently in compliance with New York’s gun laws and have little more firepower than the average shopping mall or chemical plant, or if they are currently in violation of the law.

The NRC has not rushed to grant the request. Instead, the regulatory agency sent a formal “Request for Additional Information” to the company. According to Screnci, “The September 28^th letter simply informs Entergy that we need more information to complete our review, specifically, it asks Entergy to ‘Describe the impact on Indian Point’s current physical protection program and capabilities, including response capabilities, if the NRC were to elect not to grant stand-alone pre-emption authority to Indian Point’.”

The physical security of nuclear power plants has been an ongoing issue since the 2001 attacks. Within hours of the collapse of the World Trade Center towers the NRC was steering reporters to a video the nuclear industry was circulating a doctored video of a test at the Sandia National Laboratories (  http://bit.ly/gYAXFO ) in which an A-4 fighter jet strapped to a rocket sled was rammed into a one million pound,  12-foot concrete cube at 350 miles an hour. The craft virtually disintegrated with little impression in the concrete.

The industry claimed it was a test of the ability of the nuclear reactors’ containment buildings to withstand the crash of a 767, and the NRC stated that the current fleet of power plants was designed to withstand the crash of a 747.  In fact, the video showed the test of crash reconstruction software developed by the Japanese defense department for use in the simulated crash of a jet into a mountainside.

Within a day of the attacks the NRC was forced to admit that when the current fleet of 104 reactors were designed in the 1950s and early 1960s, there were no 747s and studies conducted by the Corps of Engineers for the agency and the Department of Energy found the containment buildings were not invulnerable to the impacts of wide-bodied commercial jets at speeds over 466 miles per hour (  http://bit.ly/hf6MBs  ).

Entergy executives continued showing the video frequently to elected officials in New York City and the surrounding counties, repeating the false claims of its purpose.

Ultimately, the NRC agreed with the industry that protecting plants from aerial assaults was the job of the government, through increased screening of the air industry and the rapid deployment capabilities of the Air Force. It rejected calls from civic groups for anti-aircraft batteries around nuclear installations.

But concerns lingered about the ability of the guards at these plants to withstand a ground assault from concerted terrorists. The NRC ruled that on 9/11/2001 there were four separate attacks, rather than one concerted, coordinated assault and, as a result, plants needed to be able to defend against a reasonably armed team of about five intruders – not 20.

In light of this 10-year position by the industry and the regulators, the new call for permission to use heavier weaponry at Indian Point stands out. The news that Entergy is only now seeking authority to carry heavy weapons was criticized by Gary Shaw of the Indian Point Safe Energy Coalition, which is seeking to close the twin reactors. “I had no idea they would need permission to carry heavy weapons,” Shaw said.  “Entergy had always given the impression that they had all the firepower they would need to protect the plant, and that proves to be another falsehood.

“Once again, the ugly reality at Indian Point is that their assurances of safety and preparedness for emergency situations prove to be unsubstantiated. Every day that plant runs is another day of risk.”

By Roger Witherspoon 

            Killing the chickens was the worst.

By Roger Witherspoon

            The Nuclear Regulatory Commission may force the nation’s nuclear power plants to reevaluate their earthquake detection and safety systems and the manner in which they calculate their resistance to earthquakes as a result of unexpected damage to American and foreign reactor complexes caused by recent earthquakes.

The agency has been studying the need to upgrade earthquake protections and evaluations since 2005, in partial recognition of the inadequacy of nuclear plant designs based on the fledgling science of seismology in the 1950s and early 1960s. But the extensive damage to the six-reactor  Fukushima Daiichi nuclear complex in Japan, and unexpected damage to the twin North Anna nuclear power plants in Virginia caused by the August 23 earthquake has given new impetus to the NRC’s ongoing work. Though the damage to the North Anna Units 1 & 2, about 40 southeast of Richmond,  are considered minor, the plants remain shut pending a special inspection ordered by Victor McCree, director of Region II, which encompasses southern nuclear operations and the construction of any new reactors anywhere in the country.

The decision to send a formal Augmented Inspection Team followed the notification by Dominion Power, which owns and operates the North Anna plants that the ground motion of the Virginia earthquake, measured at 5.8 in magnitude, “may have exceeded the ground motion for which it was designed.”

All of the nation’s nuclear power plants, which were designed in the 1950s and 1960s, were supposed to be able to handle the acceleration of the ground motion and shaking associated with the largest historically recorded earthquake within a 50 mile radius of the site. For North Anna, a ground motion of .12 of normal gravity is the “design basis” incorporated into the plant’s license. That was based on an earthquake of a magnitude 4.8, and the plant was designed to withstand the gravitational tug resulting from an earthquake of 5.1 in magnitude.

McCree said in a statement that “the AIT provides us with the resources needed to completely understand all of the effects at North Anna and gather important information for the NRC’s continuing evaluation of earthquake risk at all U.S. nuclear plants.”

While the major safety and structural systems at North Anna are apparently undamaged, the transformer providing off site power failed, causing an immediate “station blackout” and shutdown. The plant’s diesel generators kept the reactors and spent fuel pools cool until off site power was restored.

“Not only are the operating reactors getting special attention,” said NRC spokesman Roger Hannah, “but we are also looking at the spent fuel pools and the dry cask storage area, where 25 of the 27 casks moved slightly during the earthquake. They weigh 100 tons or so when fully loaded, and it would take significant movement of the earth for them to fall over. But they moved from a half inch to 4.5 inches on their pad.”

It had been thought that the massive concrete and steel dry casks would be impervious to any eastern earthquakes.  In this case, said Hannah, none of the casks appear to have been breached.

A Shaky Infrastructure

            But on Thursday, the regulatory agency signaled its intention to issue a “generic letter” to all 104 nuclear power plants requesting  a new evaluation of the manner in which earthquakes were analyzed and incorporated into their designs, and what steps, if any, may be needed to strengthen the plants and their support systems. A special inspection of all the nation’s nuclear plants after the  meltdowns at the Fukushima Daiichi plants this spring discovered that  while most plants should be able to withstand known levels of  regional earthquakes, their support systems were not protected. In many cases, should an earthquake trigger a fire, the buildings on plant sites housing firefighting equipment, and the water mains from the municipal water systems were not designed to meet any earthquake standards and could be wrecked in a severe earthquake.

   In addition, all nuclear plants have miles of underground pipes and conduits – many of these encased in concrete and inaccessible to inspections. Virtually all of the ageing plants have leaked radioactive water into the surrounding environment, primarily through these underground systems, or deteriorated spent fuel pools. New York’s Indian Point plants have continuously leaked into what amounts to a radioactive lake under the plants, about 25 miles north of New York City, which is steadily seeping into the Hudson River.

In New Jersey, the twin Salem nuclear plants in Lower Alloways Creek Township have leaked radioactive water into catch basins flowing into the Delaware River, and the Oyster Creek nuclear power plant, in Lacey Township, is still cleaning up a radioactive leak in 2002 that contaminated Barnegat Bay.

The major problem with the earthquake-proof designs of current operating reactors is that the basis for their calculations was wrong.

“All of these numbers were derived in the late 60s,” said Lyn Sykes,  Higgins Professor Emeritus of Earth and Environmental Science at the Columbia University Lamont-Doherty Earth Observatory in New York. “At that time, they didn’t have recordings of earthquakes from the eastern and central part of the US, so they used western earthquakes as models.

“The difference is that for a given sized earthquake, like the last one at 5.8, earthquakes in the east are felt out to a much larger distance.  In California, with softer ground, an earthquake is not felt out to a large distance and damage doesn’t occur out to a large distance. And that does call into question the reliability of their standards.”

Last week’s earthquake, Sykes said, was larger than the design basis for Salem 1&2, Hope and Oyster Creek nuclear plants in New Jersey, and Indian Point 2 & 3 in New York. “For the basis of their designs,” said Sykes, “they used the 1884 earthquake off Sandy Hook near the mouth of New York Harbor, near Coney Island – which gave the quake its name. That quake was about 5.25 in magnitude.”

In that case, he said, the energy associated with last week’s 5.8-magnitude earthquake would be about five times the design basis for these nuclear facilities.

As a percentage of gravitational forces, the design basis  used in the construction is 0.15 G for Indian Point; 0.184 for Oyster Creek; and 0.20 for Hope Creek and Salem 1&2. The difference in their design requirements is based on the solidity of the rocks they are built on.

Building on Jello

            Jon Armbruster a geophysicist at the Earth Institute and co-author with Sykes of an analysis of earthquakes over the last 300 years from Philadelphia to New York, “When they designed these plants, they chose an earthquake and the design basis figure represented how strongly the 1884 quake was felt in the area. There were two other quakes of that magnitude, in 1737 and 1783, and they were felt from Maine to Virginia and caused some chimneys to fall down. The 1884 quake also caused a railway embankment in Peekskill to slump into the river.

In Virginia, the largest earthquake ever recorded was a magnitude 4.8. In the New York City area we have some 300 to 400-year histories and the largest earthquakes known were of a magnitude 5 or 5.3 I don’t think they have been allowing a large enough margin of uncertainty to have planned for a magnitude 5.8.

“What we have learned is that earthquakes around here can occur at a pretty shallow depth. In California, a shallow depth is one or two miles. I’ve been to places around here where earthquakes are not more than 100 meters from the surface. In 1994 there was a magnitude 4.5 earthquake near Redding, Pa., and as closely as we could measure, it was centered 100 yards below the surface. “

            When these five regional nuclear power plants were designed, Armbruster added, it was not known that earthquakes could be generated at shallow depths and designers utilized what little data was available from California and other western earthquakes in their planning.  “The difference between a California quake and one here was not clearly known back then. Now it is known and quantified that the shaking around here is quite different.

“The nuclear plants in southern New Jersey are not built on actual solid rock, though it is on pretty strong material. To an extent, that reduces the shaking. Each reactor design is different and has its peculiarities of design that need to be individually analyzed in a seismic hazard study.

“It’s like building on jello. If you put the apartment building on jello and you shake the bowl, the jello quivers and the apartment building shakes a lot.  To be safe in the earth equivalent of jello you would have to build your nuclear power plant in what amounts to a concrete boat, so it could essentially float when the jello shook and be strong enough to remain standing.”

Jim Norville, a spokesman for Dominion, said the company’s engineers and the NRC inspectors are seeking greater understanding of the differences between east and west coast earthquakes and its implications for the plants critical systems.

We found no significant damage,” he said. But we want a better understanding of why the units shut down.”

So does the NRC. Spokeswoman Diane Screnci said the agency is seeking public comment on a proposed “generic Letter” to plant operators on a review of seismic hazards and design techniques. A generic letter does not carry the weight of an order. Plant managers can dismiss its recommendations by declaring that it is not applicable to their particular operation. But the letter could be turned into an order if there is significant public demand for during the comment period, which is open until October 31. The response from the North Anna inspection and the public input on the generic latter may determine if the NRC mandates retrofitted improvements on existing critical buildings and systems.

Roger Witherspoon writes Energy Matters at www.RogerWitherspoon.com

By Roger Witherspoon

            As the Japanese struggle to prevent a widening disaster in its nuclear fleet from adding to the natural disaster facing that country, America’s nuclear proponents are struggling to show that such a calamity could not happen here.

One Gannett newspaper trumpeted that the local, Indian Point nuclear power plant was designed to withstand earthquakes and would not suffer the same fate as the Fukushima Daiichi plants. The implication was that it could withstand an earthquake similar to the one which struckJapan– though the biggest quakes in the Northeast barely hit 4.0 on the Richter scale and most are of negligible impact.

But for journalists dealing with the subject, it is important to keep two facts in mind:

• America’s nuclear plants were designed to withstand known or anticipated natural disasters. But those plans were made using the technology of the 1950s and early 60s, when they were designed. The science of earthquakes, the advances in engineering, and the analysis of soil mechanics necessary to make modern, earthquake-proof skyscrapers did not exist back in the era of Eisenhower, bobby socks and the Atoms for Peace program. They do not, therefore, meet modern earthquake standards.
• The Nuclear Regulatory Commission does not require a modern analysis of the ability of its 104 power plants to withstand earthquakes. One of the many unsuccessful challenges to the relicensing of the Salem and Hope Creek nuclear power plants on Artificial Island in New Jersey contended that a new, earthquake analysis should be conducted before the plants were granted 20 to 40-year license extensions. The NRC, however, ruled that the issue was settled with the original license and did not need to be revisited.

That is not to state that modern nuclear power plants are vulnerable to the type of unfolding tragedy taking place across the Pacific.  Several years ago, at least one electrical conduit at the Indian Point nuclear plant 30 miles north ofManhattanwas disrupted by an earthquake, though the shift in the earth’s crust was undetectable by the walking public. Repairs were quick and relatively minor. Nuclear power plants are not fragile structures.

But they are man-made and old. Nearly all of them have buried pipes and conduits which have leaked in recent years. To what extent some of those leaks may have been created or exacerbated by years of low level shifts in the earth is not known. But that should be considered and definitely ruled in or out before a blanket grant of earthquake immunity is conferred on the power plant above it.

The same, regularly rumbling Wappinger’s Fault is believed responsible for the tracery of cracks in the Delaware Aqueduct, the water tunnel 800 feet underground which brings up to 70 percent of the drinking water used inNew York CityandWestchesterCountyfrom the reservoirs in theCatskillMountainregion. It should be noted that this is a man made fault, caused by the extensive surface mining of a rock quarry which, in time, altered the tension of local geological formations.

Journalists should pause before buying the line that “it can’t happen here” and quoting it uncritically, particularly considering the earthquake-prone regions of the far west andAlaska. Proponents of nuclear power are on firmer ground stating it is not likely to happen here for both geological and sociological reasons.

In the former case, the number of regions in theU.S.with major known earth quake faults and the presence of a nuclear power plant is small. But with climate change and an increase in hydrofracking, there are new, unmeasured stresses added to the earth – just ask folks inAlabama’s new earthquake zone – which might reasonably deserve a thorough, modern look before any new power plant is built there.

In the latter case, dealing with sociology and risk perception, questions are already being raised about the Japanese decision making process as crutical events unfolded at Daiichi Unit 1 and its nuclear cohorts. Crucial decisions are affected by cultural differences in the perception of risk. Would American reactor operators have ignored possible public criticism and discharged into the air large, continuous amounts of highly contaminated vapor from the reactor rather than let dangerous amounts of hydrogen gas build up?  Was it more important to the Japanese operators to try and manage the gas buildup rather than deliberately dump radioactive material into the public air? Is there a significant, practical difference between making a bad decision to protect the public, and making a bad decision to protect corporate profits?

It will take long, thoughtful, after-action analysis by experts in human factors in complex systems to answer such questions and determine how to incorporate the lessons learned into the NRC’s training program for reactor operators. The NRC is one of the best public agencies when it comes to conducting lessons learned analysis, even if its record of following its lessons is spotty.  Any long term consensus needs outside input from academic think tanks such as the Center for Human Performance and Risk Analysis at the Universityof Wisconsin(  http://www.chpra.wisc.edu/index.php  ).

When they are done, Americans will be in a better position to know just how safe our nuclear industry really is.

By Roger Witherspoon

All six nuclear reactors in the New York/ New Jersey metropolitan area are operating “in a manner that preserved public health and safety” and therefore will receive the minimal oversight during the coming year, the Nuclear Regulatory Commission declared in its annual assessment.

In separate reviews, the NRC concluded that New Jersey’s Hope Creek, Oyster Creek, and twin Salem Generating Station plants and the two Indian Point plants on the Hudson River just south of  West Point “met all cornerstone objectives.” Those assessments put all of the region’s nuclear energy sites among the top echelon of safely operated plants among the 104 reactors in the nation’s nuclear fleet.

But the assessment comes amid growing challenges by civic groups, state, and federal agencies to the operation of some of these plants and the NRC’s reactor oversight process. In addition, the ongoing, metastasizing nuclear disaster in Japan affecting six, American-made, nuclear reactor complexes has raised doubts about the assurances of safety from the industry and regulators that such a catastrophe could not happen here.

“The NRC has already relicensed 62 of the nation’s 104 reactors,” said David Lochbaum, nuclear safety engineer with the Union of Concerned Scientists during one of the daily briefings on the implications of the meltdowns in the Fukushima nuclear complex. “And because of that, it is very difficult for the NRC to impose new standards because they have already approved more than half the plants in the United States and that inertia pretty much makes them stay the course.

“Otherwise, there is an indication that they may have been wrong in the past. The agency hates, more than anything in the world, to suggest that it might have been wrong in the past.  So they would rather continue down the wrong path than admit that they were on the wrong path in the first place.”

In the wake of the terrorist attacks in September, 2001, the NRC began a review of safety systems and security issues which might protect critical plant operations in the event of an assault or natural disaster. But the recommendations were not produced until 2003, and these were voluntary. Rather than spend the money to upgrade, the recommendations were widely ignored, and the NRC turned them in to formal rules in 2009. These improvements included requirements for spare backup diesel generators and batteries to provide power in the event of a station blackout.

But according to the NRC, 62 nuclear plant operators applied for, and received exemptions to the regulations so they did not have to spend the money – including all six regional nuclear power plants. And even if spare generators and batteries are available, the spent fuel pools are only designed to run off power from the grid – they cannot use the spares.

That is of particular concern because the spent fuel pools hold more radioactive material than the operating reactors and, if the water drains, would produce more radioactive fallout. In addition, the spent fuel pools in pressurized water reactors such as Indian Point are in warehouse-type structures rather than concrete containment buildings.

The Pinocchio Effect

When informed at a press conference that officials from Entergy are claiming that the backup systems at Indian Point would prevent their spent fuel pools from overheating Lochbaum retorted: “Have you ever seen the movie Pinocchio? Because that’s a bald-faced lie. They should know better than to say that because it happened at Indian Point in August, 1999.  They had a problem that caused them to be disconnected from the electrical grid. The batteries lasted for seven hours, and then they were depleted.

“Since lightning already struck at Indian Point, it seems a little bit foolhardy for people to claim it will never happen again. And the NRC fined them $210,000 for bad maintenance. I doubt that they could have forgotten such a bad event in their history so quickly.”

In the wake of the Japanese drama, assurances that the plant’s operation and the NRC’s Reactor Oversight Process are effective have been questioned – especially in New Jersey where the twin, General Electric,  boiling water reactors at Salem are identical to those melting down in the Fukushima nuclear complex. In New Jersey, questions have been raised from the State House to the court house.

Governor Christie appointed a Nuclear Review Task Force last week to assess the operations and emergency plans for the four reactors based in the state.  The Task Force is comprised of the heads of the State Police, State Office of Homeland Security, State Board of Public Utilities, and Department of Environmental Protection. They will be assisted by the plant operators, but will have no input from nuclear critics or watchdog groups.

Norm Cohen, head of the civic UNPLUG Salem group, said “There appears to have been no effort or thought in bringing in experts from outside of the state to provide an unbiased review of safety issues at our four aging and vulnerable nuclear plants. We also suggest that the panel hold public hearings at each nuclear site. If not, then this panel will just be a waste of taxpayer dollars.”

Larry Ragonese, spokesman for New Jersey’s environmental agency, said the exclusion of critics in the task force did not mean that its work would be biased in favor of the nuclear industry.

“Of course the operators from PSEG and Exelon are going to have to participate,” Ragonese said. “It’s their plant. We don’t have carte blanche to go into their buildings. But we will have our emergency experts and the nuclear engineers on our staff involved.

“We are not going in there just to hear them tell us everything is fine. If you are foolish enough or pompous enough to think that you can’t learn lessons from what is happening in Japan then you are at fault. We are going out there with a complete open mind. We believe we have safeguards in place in case of an emergency, but we will take one more look.”

The US Court of Appeals in Philadelphia would like another look as well. The Court was hearing a suit filed by the New Jersey Environmental Federation challenging the NRC’s decision to grant a 20 year license renewal to the Oyster Creek Generating Station.

Federation Chair Janet Tauro said “We have been battling them for five years over the relicensing. It is a GE, boiling water reactor such as you see at Fukushima, and the dry well, the containment that surrounds the reactor, is severely corroded. We were troubled that that corrosion did not raise a red flag with the NRC. Exelon failed to prove that the dry well could last another 20 years.

“Keep in mind that there are over 700 metric tons of highly radioactive fuel rods in the spent fuel pool that sits right above it.”

They lost before the NRC, and took their case to federal court. Kevin Pflug of the Eastern Environmental Law Center, the Federation’s attorney, said the group argued that the NRC acted “capriciously” to throw out objections to the license or thoroughly examine the issue of metal fatigue in the containment surrounding the ageing reactor.

“It’s a high burden to show that they acted capriciously”’ Pflug said.  “They normally defer to regulatory agencies.”

But in a surprise move the three-judge appellate court panel, on its own initiative, issued an order March 21 that the NRC “advise the Court what impact, if any, the damages from the earthquake and tsunami at the Fukushima Daiichi Nuclear Power  Station have on the propriety of granting the license renewal application for the Oyster Creek Generating Station.”

The agency has until April 4 to respond.

To the NRC, this is unnecessary. Their  assessments  of the safety of the six plants, made by the NRC’s  Division of Reactor Projects,  follows scores of individual, special inspections held during the year at each facility to check everything from the management of radioactive waste and ageing infrastructure to the ability of plant operators to analyze the root causes of mishaps and shut downs. The plants were all rated “green” in the agency’s color coded assessment process, which was put into place a decade ago and replaced the adversarial regulatory system characterized by monetary fines for different levels of infractions.

Lochbaum, who was part of a panel appointed in 1999 by the NRC to evaluate the pilot for the current Reactor Oversight Program prior to its formal adoption, released a 10-year retrospective of the program just after the troubles began in Japan. Lochbaum found that a lack of resources is hampering the effectiveness of the oversight process.

In each region of the country, he said, the NRC only had enough staff to devote full attention to one or two troubled reactor sites, while the majority stay on the “Licensee Response” list, in which there is minimal oversight.

“Limits on NRC inspection resources may play a role in deciding when plants are moved to and from the Licensee Response column,” wrote Lochbaum.  “When new problem plants emerge with problems that cannot be ignored, previously trouble-plagued plants may be suddenly cured and removed from the list of plants that require heightened NRC involvement.

“And when  trouble-plagued plants improve and move into the Licensee Response column, freed-up NRC resources may allow the NRC to turn to other plants that were previously not on the list but whose problems the NRC can now address.”

That is a juggling act, said Lochbaum, which will not always serve the public well.

By Roger Witherspoon

For the most part, David Lochbaum’s analyses of the escalating problems at the Fukushima Daiichi complex in Japan are in the dry, relatively understated tone of an engineer who has spent nearly 40 years working on nuclear safety issues.

But once in awhile, discussing the interlocking meltdowns in the Mark 1 reactors and their companion spent fuel pools, his Tennessee cadence speeds up and carries a tone with a trace of anger.

“I don’t feel bad,” he said. “I did all I could to avoid this. The folks at the NRC are the ones who should be feeling bad. The reason I’m at the Union of Concerned Scientists today is because of a spent fuel pool fire.”

The year was 1992 and Lochbaum, working for Enercon, the nuclear engineering consulting firm, had established a reputation as the go-to guy to bring systems into compliance with regulatory requirements and industry standards. He was part of a team evaluating the capabilities of the twin reactors at the Susquehanna River Nuclear Power Station in Pennsylvania, which was seeking permission from the Nuclear Regulatory Commission to increase their power and operating temperatures.

“Susquehanna is very similar to the plants in Japan,” recalled Lochbaum. “But it is much bigger. My partner, Don Prevatte, was looking at safety systems and meltdown scenarios in the reactor and I was looking at them in the spent fuel pool system. What we found was that there was a problem with the spent fuel located inside the containment building.

“If there was a reactor accident, the environment produced by the reactor automatically triggers a spent fuel pool accident. And, conversely, if there is a spent fuel pool accident, it automatically triggers a reactor accident. And since they are both in that confined space, the radioactive environment created by one interferes with you being able to get to the other.”

In a sense, it should have been obvious. Having two complex systems next to each other in a single containment building tied their fates together. The design for the pressurized water reactors, on the other hand, utilized separate, adjacent buildings for the reactor and the spent fuel pools.

“In theory,” said Lochbaum,” if you had a reactor accident, the containment would hold and everything would be nice. But when you combine the two systems, everything failed.”

PPL, which owned the plants, declined to invest in a costly fix, so the two engineers put together an inch thick analysis dropped it off at a local copying center and had it mailed to the NRC. It was dismissed within two week.

They didn’t know about the copy error until the following year, when the chief engineer from the nuclear plant at Seabrook, NH called. “He said he got a copy of the report from the NRC and wondered if we had a complete version since they only had every other page,” recalled Lochbaum, his drawl getting noticeably clipped. “It alarmed him enough that they wanted the whole report and wanted to make changes at their plant.

“That’s how we learned that the copy folks had made a mistake and didn’t copy both sides of the paper. It didn’t matter; the NRC dismissed it without even noticing or caring  that every other page was missing.”

The two engineers published their findings about the dangers in the GE’s Mark 1 reactor design and published it in a book titled “Nuclear Waste Disposal Crisis.”  PPL reacted to the resulting publicity by linking the spent fuel pools of the two reactor units and so they could be controlled from either unit.

“Susquehanna had an advantage in that there were two plants there,” said Lochbaum. “In single unit, Mark 1, BWR plants like Vermont Yankee, you have the spent fuel on top of the reactor and you don’t have that luxury – if you have a problem with either the reactor or the spent fuel pool, you’ll have a problem with both.”

The NRC’s response both angered and surprised Lochbaum. But in retrospect, it shouldn’t have.  There were precedents for finding serious flaws in the GE Mark 1. And precedents for having the NRC ignore them.

On Sept. 20, 1972, S. H. Hanauer, a senior engineer at the Atomic Energy Commission, the forerunner of the NRC, wrote a memo (  http://bit.ly/e5WjyK )

to director Joseph H. Hendrie that  an analysis of 10 years’ experience with the Mark 1 reactors showed there were serious flaws in the design.  The smaller containment building, housing both the reactor and spent fuel pool, cost less than two building system employed by pressurized water reactors. But assumptions about the effectives of its system to control a buildup of pressure following an accident were flawed and unlikely to work.

“Recently,” Hanauer wrote, “we have reevaluated the 10-year-old GE test results, and decided on a more conservative interpretation than has been used all these years by GE (and accepted by us). We now believe that the former interpretation was incorrect, using data from tests not applicable to accident conditions.”

Five days later, Hendrie sent back a two-paragraph reply which said, in part, “the acceptance of pressure suppression containment concepts by all elements of the nuclear field … is firmly imbedded in the conventional wisdom. Reversal of this hallowed policy, particularly at this time, could well be the end of nuclear power. It would throw into question the continued operation of licensed plants, would make unlicensable the GE and Westinghouse ice condenser plants now in review, and would generally create more turmoil than I can stand thinking about.”  (  http://bit.ly/gTBYUq )

That rejection was crucial. In essence, their pressure containment system was designed to work in a single failure situation.  Chillers creating ice would force escaping gas to condense back into a liquid, thus relieving pressure and heat in the confined space of the containment building.

The flaw is that there was so little room in the dual function containment building that escaping steam would increase pressure in both areas, though the system was designed to chill only one at a time. It was the nuclear equivalent of the French Maginot Line    (  http://www.maginot-line.com/ ) , with defenses locked to fight in only one direction, and helpless against attacks from the flanks. What Hanauer foresaw when writing his memo on the last day of the summer of 1972 would play out at the end of winter, 2011 in northern Japan.

And, in Lochbaum’s view, it did not have to end this way.

“I feel bad about the situation,” he said yesterday, “but not guilty. Had the NRC done more to correct the flaws in the design of the BWRs things would be better. This wouldn’t be happening.

“But I did more than my share to try and get that thing corrected. They are the ones who should feel guilty now. Not me.”

By Roger Witherspoon

As the Japanese struggle to prevent a widening disaster in its nuclear fleet from adding to the natural disaster facing that country, America’s nuclear proponents are struggling to show that such a calamity could not happen here.

One Gannett newspaper trumpeted that the local, Indian Point nuclear power plant was designed to withstand earthquakes and would not suffer the same fate as the Fukushima Daiichi plants. The implication was that it could withstand an earthquake similar to the one which struck Japan – though the biggest quakes in the Northeast barely hit 4.0 on the Richter scale and most are of negligible impact.

But for journalists dealing with the subject, it is important to keep two facts in mind:

• America’s nuclear plants were designed to withstand known or anticipated natural disasters. But those plans were made using the technology of the 1950s and early 60s, when they were designed. The science of earthquakes, the advances in engineering, and the analysis of soil mechanics necessary to make modern, earthquake-proof skyscrapers did not exist back in the era of Eisenhower, bobby socks and the Atoms for Peace program. They do not, therefore, meet modern earthquake standards.
• The Nuclear Regulatory Commission does not require a modern analysis of the ability of its 104 power plants to withstand earthquakes. One of the many unsuccessful challenges to the relicensing of the Salem and Hope Creek nuclear power plants on Artificial Island in New Jersey contended that a new, earthquake analysis should be conducted before the plants were granted 20 to 40-year license extensions. The NRC, however, ruled that the issue was settled with the original license and did not need to be revisited.

That is not to state that modern nuclear power plants are vulnerable to the type of unfolding tragedy taking place across the Pacific.  Several years ago, at least one electrical conduit at the Indian Point nuclear plant 30 miles north of Manhattan was disrupted by an earthquake, though the shift in the earth’s crust was undetectable by the walking public. Repairs were quick and relatively minor. Nuclear power plants are not fragile structures.

But they are man-made and old. Nearly all of them have buried pipes and conduits which have leaked in recent years. To what extent some of those leaks may have been created or exacerbated by years of low level shifts in the earth is not known. But that should be considered and definitely ruled in or out before a blanket grant of earthquake immunity is conferred on the power plant above it.

The same, regularly rumbling Wappinger’s Fault is believed responsible for the tracery of cracks in the Delaware Aqueduct, the water tunnel 800 feet underground which brings up to 70 percent of the drinking water used in New York City and Westchester County from the reservoirs in the Catskill Mountain region. It should be noted that this is a man made fault, caused by the extensive surface mining of a rock quarry which, in time, altered the tension of local geological formations.

Journalists should pause before buying the line that “it can’t happen here” and quoting it uncritically, particularly considering the earthquake-prone regions of the far west and Alaska. Proponents of nuclear power are on firmer ground stating it is not likely to happen here for both geological and sociological reasons.

In the former case, the number of regions in the U.S. with major known earth quake faults and the presence of a nuclear power plant is small. But with climate change and an increase in hydrofracking, there are new, unmeasured stresses added to the earth – just ask folks in Alabama’s new earthquake zone – which might reasonably deserve a thorough, modern look before any new power plant is built there.

In the latter case, dealing with sociology and risk perception, questions are already being raised about the Japanese decision making process as crutical events unfolded at Daiichi Unit 1 and its nuclear cohorts. Crucial decisions are affected by cultural differences in the perception of risk. Would American reactor operators have ignored possible public criticism and discharged into the air large, continuous amounts of highly contaminated vapor from the reactor rather than let dangerous amounts of hydrogen gas build up?  Was it more important to the Japanese operators to try and manage the gas buildup rather than deliberately dump radioactive material into the public air? Is there a significant, practical difference between making a bad decision to protect the public, and making a bad decision to protect corporate profits?

It will take long, thoughtful, after-action analysis by experts in human factors in complex systems to answer such questions and determine how to incorporate the lessons learned into the NRC’s training program for reactor operators. The NRC is one of the best public agencies when it comes to conducting lessons learned analysis, even if its record of following its lessons is spotty.  Any long term consensus needs outside input from academic think tanks such as the Center for Human Performance and Risk Analysis at the University of Wisconsin (  http://www.chpra.wisc.edu/index.php ).

When they are done, Americans will be in a better position to know just how safe our nuclear industry really is.