Scare Crow? Nope, this Girl has a Brain

I work with people in the nuclear energy industry. My goal is to ensure everyone I work with ends up being a better member of the industry. Smarter about how things need to be done, or why things should be done. BUT, there’s much more to nuclear technology and today, I got a reminder.

Go back a year. I was working at my desk, talking to a client on the phone. Suddenly, I felt extremely nauseous. Hanging up the phone, I ran for the bathroom. A few minutes later I had a blinding headache as well. Needless to say, this was very frightening. I just wanted to curl up into a ball. My husband insisted on a trip to the Emergency Room.

The hospital discovered I had a resting pulse of 40. While elite athletes might have such a pulse, I’m a 54 year old woman who rides a desk chair most of the day. All of these things left the ER doctor fairly puzzled. But a big concern was that I was possibly having some kind of brain malfunction.

I don’t know about you, but I rather treasure my brain. I find it generally useful for a variety of things and I want to keep it fairly intact. The doctor agreed that I needed to keep my brain in good working order, but he needed to get a look at what might be going on.

Not many years ago, that would have meant a fuzzy x-ray and possible exploratory brain surgery. OR the doctor would have administered drugs “just in case” to prevent anything further. Now, however, he ordered a CT scan. They dosed me with a contrast chemical (no not radioactive, this time) and put me in this cool circular machine and did a detailed 3D scan of my head.

Sure enough, I still had a brain! I was not the Scare Crow after all. Even better, it all seemed to be working properly. They did find a small something on the back of my head. The doctors agreed that the small something did not cause my symptoms, but wanted to keep an eye on it.

A year later, my regular doctor asked me to have another CT scan to make sure the little small something was still just a little small something. So, today I went in to the radiology folks. In 15 minutes, they had once again scanned my brain and confirmed it was there. I’ll know in a few days what the results are, but I already know that life is good and nuclear technology made it better.

What was wrong a year ago? I may never know. Dehydration? Possibly. A random migraine? Never had one like that, but my father suffered from them for years. What I do know, is that nuclear technology made my life so much better and prevented potential major surgery.

Nuclear technology makes our lives better. Nuclear medicine allows diagnoses and treatments that used to require risky complex surgeries with weeks of painful recovery. Radiation treatment sterilizes our food supply without dangerous chemical residue and prevents food-borne illnesses. Nuclear energy gives us electricity without spewing toxic chemicals into the air. We need to tell the world.

Letter to the Editor of the Wall Street Journal

Two weeks ago (Aug. 18), the WSJ published a Saturday essay from Dr. Richard Muller titled “The Panic Over Fukushima”. I submitted a letter to the editor. Sadly, the WSJ decided not to publish it. However, I wanted to share it with my readers. I might add that anti-nuclear people hate his essay, and a fair number of pro-nuclear people hate it as well. Both claim “bad science” as the enemy. While his science isn’t completely accurate, it does provide something a lay person can get their arms around and understand. And it makes clear how miniscule the risks really are. For that I was glad the essay was published.

I want to thank the Wall Street Journal for Dr. Muller’s Saturday Essay. He did an outstanding job in making clear how even using the most conservative limits and estimates, the radiation released during the accident at the Fukushima Daiichi nuclear facility will not have a measurable impact on the residents of the region. The FEAR that has been instilled by those with an agenda and the hopes of other economic gain has done far more harm to Japan and to the rest of the world by convincing people to abandon nuclear energy.

This reliable form of energy generation has few incidents, so each time anything goes wrong, it is news, even when no one gets hurt and the risks are minimal. Unfortunately, this “no news is good news” method of coverage has left many people under the impression that these plants are dangerous and difficult to operate. Dr. Muller’s article helps clarify the fact that one of the worst nuclear accidents in history has had a minimal environmental impact. I hope that this understanding will allow people in Japan to return to their homes and begin the difficult job of picking up the pieces after a devastating earthquake and tsunami ravaged their lives. Restarting their nuclear facilities will go a long way toward bring Japan back on track as one of the largest economies in the world.

The benefits of the high energy density of nuclear energy are enormous. A typical currently operating nuclear energy facility generates nearly 8000 GWH of electricity every year from a facility that takes less than 2 square miles of land. That’s enough electricity to power more than 650,000 households. It takes only 750-800 people to safely operate the plant. But the impact on the local economy of well-paying jobs and high tax base of these facilities makes most localities very supportive of the plants. The presence of these power plants can attract industry, interested in reliable, low cost electricity. Increasingly new industries are concerned about clean energy and nuclear fills the bill nicely with ZERO carbon emissions, low cost and reliable generation. Only hydro power can come close to nuclear energy’s ability to unleash an economy.

Nuclear Energy can continue to provide clean, low cost electricity to power America, allowing manufacturing and high-tech energy intensive industries to employ thousands and recharge the US economy along the way. Only if we don’t let scare tactics and fear mongers frighten us into the next dark age. Let’s keep the lights on!

Now, tell me what YOU think…

American Nuclear Society’s CNST

Yes, this is another post related to things I learned at the ANS-UWC. I don’t usually dwell so long on one conference, but there was so much interesting information that I wanted to pass along.

Dr. Corradini and the ANS’ CNST

Dr. Michael Corradini, president of ANS spoke about a new project ANS has undertaken – The Center of Nuclear Science & Technology (CNST). The project was started about six months before the earthquake and tsunami in Japan, when Fukushima dominated the news waves. The CNST was put on hold for a period while the ANS concentrated on responding to those events.

A president’s committee within ANS that Dr. Corradini co-chaired was formed a month after the earthquake to assess various aspects of the events at Fukushima, including the level of public knowledge and understanding. One sub-committee was dedicated to assessing the communication effectiveness, trying to understand some of the crisis and risk communication in Japan. There was a clear lack of knowledge in the general public, both in Japan and in the U.S., regarding nuclear technology. No surprise to anyone, we haven’t been communicating enough, we need to do better.

So, Dr. Corradini announced the CNST at this conference. Its primary objectives are to provide education for K-12, teachers, the general public, and policy-makers on nuclear technology. The CNST will be providing fact-based worksheets and websites to help with education. In fact, this year, the CNST has run five sessions in Washington, DC for legislative aides, to help these folks understand a little more about the technology and how it works.

Mr. Freebairn, a Journalist’s View

After Dr. Corradini, Bill Freebairn of Platts talked about the views of nuclear from a journalist’s perspective. Mr. Freebairn is an excellent journalist at Platts, which is a news service for the energy business. His “beat” is primarily nuclear. He opened with a discussion of one of those age-old arguments – Does the media reflect or shape public opinion? His answer “a little of both” – For what it’s worth, I agree.

Mr. Freebairn talked about media coverage prior to Fukushima was mostly local, nationally there was limited interest. After Fukushima, there has been significantly more national press and media attention on nuclear. He acknowledged the limited knowledge of most journalists. Many went into journalism to avoid science and math, they are generalists. This is good and bad. Such journalists ask questions that the general population also does not understand, forcing us technical types to clarify concepts we don’t realize are not well understood. However, they don’t know whose facts are real, making them more vulnerable to wild claims.

Putting it Together

Dr. Corradini’s speech was particularly important to me as I’m involved in many of these issues with ANS. I served as a key spokesman for the ANS in the weeks following Fukushima and worked hard to explain the technology to journalists and talk show hosts all over the world. In addition, I served on the risk communication sub-committee and spent many hours researching risk understanding and communication for that group. Finally, I serve on the Public Information Committee within ANS, which has prime responsibility for the CNST. We are actively working on a grants program to encourage local sections and individuals to develop and use materials to educate the public and local governments about nuclear technology.

After Mr. Freebairn’s talk, I was struck by the two speeches put together. The CNST that Dr. Corradini mentioned and the training sessions we put together for federal legislative aides needs to be rolled out for journalists and local and state government folks. Webinars would allow diverse attendance and teachers to bring some sound science to people that are in positions to make decisions and/or influence public knowledge.

What are YOU doing to help educate the people in YOUR community?

Report from ANS Utility Working Conference – Part 2

Last week, I summarized Tom Kilgore, CEO of TVA’s speech at the opening plenary. Today, I want to write about a couple of the sessions I attended. The first, title “Current State of the Industry,” was right after the opening plenary with Bill Borchardt, Executive Director of Operations for the NRC, and Alex Marion, Vice President for Special Projects at NEI.

Let me place Mr. Borchardt in the organization at the NRC, for those of my readers that may be less familiar with some of the names within the commission. HE is essentially the CEO of the NRC. He reports directly to the five commissioners and has a fair amount of influence in when and how information is presented to them.

Both men gave short presentations and then we had a pretty extended Q&A period. I was far more interested in Mr. Borchardt’s portion so I will concentrate on that.

Action Matrix Summary Update

Most of my readers are probably familiar with the NRC’s Action Matrix Summary. This five column table is an attempt by the NRC to provide more clarity regarding the status of the plants relative to safe performance. Mr. Borchardt announced that the NRC was adding Security performance to the list of cornerstones that comprise the ranking. Although they’ve been inspecting and testing plant security pretty much since 9/11, the NRC was giving the utilities time to improve their performance before including it in this public metric.

Adding security issues to the matrix means that 12 plants move from column 1 – Licensee Response to columns 2 – Regulatory Response or 3 – Degraded Cornerstone. Mr Borchardt emphasized that nothing changes for these plants, they are not any less safe and the added oversight for security was already happening. This just makes the metric more transparent and allows all stake-holders to see more clearly what is going on with each of these plants.

NRC and Public Information

Next, he discussed some of the varying issues at different plants. He talked about the public interest varies greatly plant by plant. I can attest to the truth of this statement. I’ve gone to the NRC annual public meeting at Brunswick stations down the road from me and there were precisely 3 people that were not plant staff, including me. Whereas my friend, Meredith Angwin, attends the same meeting at Vermont Yankee and sees dozens of people not associate with the plant, most of whom are protesting something about VY’s operation.

This discrepancy, he explained, changes the way the NRC has to work with each licensee. Some questioned whether this was changing the enforcement of the regulation, which would clearly be problematic for everyone. Mr. Borchardt was vehement in his denial of that. He was talking more about the length of time reviews might take, the need to have more public meetings and/or the need to more clearly explain the regulatory process, all of these things take time and resources and draw out proceedings that for other licensees are quicker and easier.

Mr Borchardt was directing the problem back to the utilities. Where they have done a poor job of working with the local and state governments and have failed to make nuclear energy understandable, the local population is far less trusting and far more likely to slow-down and complicate proceedings. This is not the NRC’s job and they cannot ignore the concerns raised by local groups.

Taken in conjunction with Tom Kilgore’s admonitions regarding communicating about nuclear in the plenary – I found this to be a powerful message to the utilities to wake-up and figure out how to talk to their local stake-holders, including state and local governments.

Fukushima Response

A significant amount of time was also spent discussing the impacts of Fukushima on the NRC and the effects on the utilities.

  • A walkdown of all systems related to seismic performance. A walkdown is a process by which the plant operator “walks down” every system in the plant to assure themselves and the NRC that the CURRENT plant meets its Design Basis.
  • A re-evaluation of the seismic performance of the plant. This is asking the plant operators to look at current best guidance for seismic activity and evaluate the plants anticipated performance.
  • Two direct mitigation strategies. These are expected to be implemented within 5 years or two outages whichever comes earlier but completed by no later than 12/21/2016:
    • Hardened vents on all Mark 1 and 2 containments (Mark 1’s were required to do this after TMI, it was optional for Mark 2,)
    • More instrumentation of the Spent Fuel Pools
  • In addition, the NRC is looking to improve Emergency Procedures and is working on rulemaking to encourage the streamlining and clarification of EOP, SAMG, EDMG, and the rest of the alphabet soup of emergency procedures. Brownie points to anyone that can spell out the meaning of each acronym in the comments section.

Adequate Vendor Oversight

Finally, there was discussion about adequate oversight of vendors. Those that know me know that this is an area that I work in to try to improve those vendors programs to meet the industry needs. Mr. Borchardt took the industry to task regarding the need for the licensee to own the issues and not try to move responsibility to the vendors. Some in the room tried to push back on this with respect to huge construction projects, but he was having none of it. And I have to agree. If you’re going to build the plant, you have to own getting it done right. If that means hiring a large number of people to ensure it gets done, then hire the people and acknowledge the cost. But, get it right, or go home.

Waste Confidence Ruling

Of course, the issue of the recent court ruling on the waste confidence decision came up. Mr. Borchardt tried to minimize the real impact on the industry in that no license applications (either COL or renewals) were coming up in the very near term and he believes the issues will be resolved within a year or so. I have to disagree in that this simply adds to the public perception that we don’t know what to do with used nuclear fuel. There are a variety of options that should continue to be explored, only one of which would entail permanent storage of this fuel. But that’s the subject of an entirely new blog.

Looks like there will be at least a couple more installments out of the ANS-UWC. In the meantime, tell me what YOU thought about the conference!

Report from ANS Utility Working Conference

I spent Sunday night through Wednesday noon at the 2012 American Nuclear Society Utility Working Conference. That’s a mouthful, so most people refer to it as the ANS-UWC. Marginally better to say, but a lot easier to type. The conference them this year was “Nuclear! Still the one! The right business, The right results, The right way forward”. I guess we like long titles in this business. T-Bow Thibault of TVA was the conference chair and told all speakers that we wanted to learn something new this year. I’d say they hit the mark! Attendance was about 750. Not a record, but a solid number of professionals gathered in one place.

To be honest, until last year, this conference wasn’t on my radar. I’d heard of it through colleagues at GE-Hitachi but mostly as a vendor conference/quality program kind of thing. As an engineering leader, it was simply not on my list of things to do. But it should have been. If prior conferences were anything like the two I’ve attended, there’s great information and really great people to meet and talk to. Describing the great information and people would take far more than a single blog, so I’m just going to hit highlights. If you want to know more, e-mail me with specific questions.

Vendor Technology Expo

Breaks, meals, and evening socials were all in the Vendor Technology Expo that accompanies this conference. The venue was great in that there was plenty of space for networking and talking with non-vendors, but also a number of interesting displays to see from companies all over the industry. I talked with several new folks and learned about some interesting new technologies.

I am particularly intrigued by a display (Bloxr) I saw with a new shielding material that is being used quite successfully in the area of nuclear medicine. The material is significantly lighter than a similar shield made from lead and reduces mixed waste in disposal, both excellent features. I’m looking forward to talking more with the company and getting this material out into the nuclear energy industry as well.

Also interesting to talk to some firms that are working in the Wilmington, NC area where I make my home. I tend to see business as a long ways from home, but there are a number in my own back yard as well.

Opening Plenary

Tom Kilgore, CEO of TVA

This year’s opening plenary speech was given by Tom Kilgore, CEO of TVA. His message was so important, he talked of the need to communicate about this industry clearly and widely. Nuclear energy is the only emission free baseload and we need to let the world know how important that is – not just greenhouse gasses, but particulates, mercury, and other emissions are also zero from nuclear energy facilities. To quote Mr. Kilgore: “Nuclear Energy is not always the easiest option, but jobs, economics, and environment make it the best option.” Change your words, change your worlds. He closed emphasizing that good, safe performance is not enough, we need to communicate, demonstrate, and deliver every day.

Kilgore then switched gears a bit and talked more specifically about TVA. TVA currently has a fairly balanced portfolio with about a fourth each nuclear, coal, and hydro, and a fourth the rest (gas and renewables, mostly). He sees a future that is about 40% nuclear and very little coal. Current growth rates indicate that TVA will need 22% more electricity in 22 years. That’s lower than the prediction of a few years ago, but still represents substantial increased needs. He sees very little coal making that electricity. Good news for the environment, I think.

Finally, he talked pretty frankly about some of the recent issues that TVA has had with their nuclear fleet. He stated quite clearly: Safety first, public and workers. Second, system reliability. After the tornadoes in 2011 shut down transmission lines for as much as month and affected Brown’s Ferry units, they’ve added backups and better transmission lines. 2012 was less severe, but they had no outages. As he spoke, they have some coal units down unexpectedly, but the nuclear stations are all running at 100%. Kilgore talked about the fact that it ultimately comes down to people, well trained, competent people. He’s been trying to drive collaborative improvements in TVA – all stakeholders, undustry, education, regulator.

He closed exhorting all of us to talk more about nuclear energy in clear, understandable terms. The more people know about nuclear energy, the more they support it. We need to keep talking, using simple language, stop hiding behind our jargon. Let employees talk to the public. They want safety as much as, maybe more, than the public does. We most definitely need to stop talking to ourselves and start telling the world!

Josh Bleill, Indianapolis Colts Speaker

After Tom, we were treated to an inspirational speech by Josh Bleill, Iraq war veteran who lost his legs in defense of this country. He talked about his experience and journey through 22 months, multiple surgeries and learning to walk again (two times!). The Colts hired him to be an inspirational speaker. He told us about practicing with 3rd graders. (I’ve talked to 3rd graders, they are a much tougher crowd that we adults.)

He reminded us about service AND having a sense of humor. Closing line:

Don’t do the same things because you always have. Do the right things!

That’s all I have time for today. I’ll be providing insight and comments about the rest of the conference all next week.

NRC and Regulatory Capture

My blog last week got some interesting reactions regarding the larger picture of regulatory issues. I chose to look at quality as it is an area where significant changes in the broader context of quality control have occurred since those regulations were written and an update is overdue. This is also completely within the control of the NRC.

However, it brings up another question. Many have looked at what happened at Fukushima and concluded that the regulator was “captured” by the industry and was no longer an effective independent regulator. Some have accused the NRC of the same problem. Regulatory capture is a real and legitimate concern for all regulators and industry. What are the causes of such “capture”?

Let’s look at each scenario and determine whether the NRC might be affected.

The regulator is also responsible for promotion.

That was the direct cause for demise of the Atomic Energy Commission in the 1970’s. In the original design of the Atomic Energy Act, the Atomic Energy Commission was responsible for both regulation of nuclear power and its promotion. Interestingly, that was the model for the regulation of oil drilling until after the Deepwater Horizon oil spill in 2010.

Today, the NRC has NO role in promoting nuclear power in anyway. They communicate about the technology and their role in oversight. They prefer to present themselves as a competent regulator, which has sometimes been interpreted as promoting the industry.

The regulator and industry are providing jobs for each other

In essence, the regulator is either from industry directly, or guaranteed a position within the industry after departing the regulator. In Japan, TEPCO and NISA, a position on TEPCO’s board of directors was known as “the chair of heaven” and was guaranteed to be given to departing senior members of NISA.

In general, the NRC rarely hires from industry in any place other than entry level review positions. Commissioners also very rarely come from industry. The current five commissioners have virtually NO experience in the nuclear industry. They come from government (DOE, military, or congressional aides) or academia. Former commissioners have frequently gone back to academia or retired. Occasionally, they have become consultants, but with rare exception, NRC commissioners, or other high level staff, have not ended up in high level industry positions. Those exceptions have been looked at quite carefully (Richard Meserve, for example) and, to date, allegations of inappropriate ties have not been borne out by the Justice Department.

Expertise in the regulation can be powerful in assuring compliance within the industry. Putting former regulators in positions of authority can be helpful in enforcing compliance. In reverse, industry expertise in how a technology really works in practice can allow more effective regulation. However, guaranteed positions of employment going either way is clearly problematic.

Payment by industry to Regulator

The industry pays fees and review costs and funds a large fraction of the NRC’s operating budget. From the NRC’s website in response to a question about the oversight of NFS:

Do NRC fees to the licensee create a conflict of interest in regards to fair regulation? Ninety percent of the NRC’s funding is recovered from the plants that it regulates

No. The NRC operates with funds approved by the U.S. Congress that come directly from the U.S. Treasury. The fees collected have no affect [sic] on the approved NRC budget. The fees paid by licensees go directly to the U.S. Treasury …

While the NRC does not benefit directly from the fees paid by industry, clearly its budget is tied to receiving those fees. The separation of fee payment and service rendered (license maintained, or inspections passed) does prevent the NRC from seeing any one licensee as more important or more valuable than another. In fact, some of the fees assessed are directly related to having issues with the licensees. The more issues a facility is having, the more hours of inspection the NRC requires, which results in more fees.

More problematic is the area of new technology. The NRC has so little funding from the government that isn’t tied to income from industry that the efforts to develop regulation for new technologies (like SMR, or Gen IV) will have to come from industry itself. This process is definitely fraught with risk that the NRC may be overly influenced by the industry itself. While the funds do not flow directly to the NRC, they are clearly aware of their own funding sources.

Fundamentally, the problem with this arrangement is the APPEARANCE of regulatory capture. The question is – Do other oversight agencies operate the same way? And do they have any issues?

Conclusion

There is no direct evidence of industry capture by the NRC. They consult with industry on new regulation, but they also encourage the public to weigh in on these regulations. However, inherently, the NRC is parasitic on the industry. If the nuclear industry were to be abandoned entirely, much of the purpose for the NRC would immediately end and the commission’s role would be significantly reduced.

Two areas that should be monitored and considered are the potential for cross hiring to contaminate the independence of the commission and the issue of funding for specific areas of responsibility within the NRC.

How do other agencies get funding and hire and maintained a qualified, yet independent staff?

Nuclear Quality Regulations – Time for a new look?

I’ve spent most of my career working with Nuclear Regulation. One of the most complex series of regulations you can imagine. The U.S. Internal Revenue Service probably sent people over to help the AEC/NRC develop these regulations. They cover a wide variety of issues all under the name of safety and security.

One of the smallest parts of the regulation is actually quality assurance. The majority of this regulation sits as an appendix to one of the largest chapters, Appendix B to 10CFR50. This little collection of requirements is a mere 3 pages long. It draws in 10CFR21 as a part of the regulation which is an additional 9 pages. These regulations were written in the 1970’s with few modifications to clarify and/or expand the application of these regulations.

A little History

Appendix B was written primarily to target plants under construction, whereas the NRC was concerned with control of the engineering, procurement, and construction of nuclear power plants. The original authors split into several teams and fairly quickly generated the text that now forms most of Appendix B. In total, the requirements of 10CFR50 Appendix B apply to designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying. They never imagined that it would become so permanent.

10CFR21 requires immediate notification to the NRC of any facility, activity, or basic component that either contains defects or fails to comply with requirements and creates a substantial safety hazard to the facility. In addition, it provides a means for accepting commercially manufactured items for nuclear safety-related applications. This process is referred to as commercial grade item (CGI) dedication.

Like other regulations, standards were developed by independent organizations. ANS developed the first set, sometimes referred to as ANSI N45.2 and daughter standards. However, ASME stepped in after a few years and created a standard that eventually became known as NQA-1.  The NQA-1 Committee, which consists of a collection of QA experts and managers from all facets of the industry, meets periodically to update the standard to current technology and known issues. Some of these areas include Software Controls, CGI Dedication, and Maintenance.

So what?

The problem is that the regulations were written when few quality standards existed in industry. The NRC’s Appendix B program was a pioneer in demanding quality control, record-keeping, and training of the people performing the work. However, the criteria as written is poorly organized with overlaps and gaps in the requirements. It fails to deal with modern technology in terms of software control, electronic record keeping and document control. These have been left to the cottage industry the has arisen around NQA-1.

ASME issues a new version of NQA-1 every 4 years or so. They are planning to issue a new version in the next few months. The problem is that the NRC just approved the last standard in 2010 and virtually no one has been able to update their programs to reflect that standard. The new standard may well address critical issues, but the ability of the NRC to review and approve and the industry to adopt to the newer standards is not adequate to this continuous modification.

In addition, many of the small suppliers are finding these regulations to be burdensome without actually improving the quality of their products. Many suppliers today comply with ISO-9001 which is an international quality standard. However, the NRC (and ASME) do not recognize that this program provides adequate quality for parts generated under the program. This has created an additional burden to the industry that increases costs without increase quality. For safety-related components, the industry either had to demand that a supplier develop an NQA-1 based program in addition to their ISO programs, or they have to go through a separate dedication process that required testing and more paperwork to validate the part.

It seems to me that it is time, past time in fact, for the NRC to step back and look at the quality requirements in context of international standards (that are used by other nuclear regulators to a high degree of effectiveness) and modify the regulations to reflect these standards. Look at what experts in relevant technologies have done and point to those standards appropriately, stop trying to create independent regulations that are simply increasing costs without improving quality or safety.

Tell me what YOU think is needed?

Spent Fuel Pool #4 – TEPCO’s moving fuel!

I wrote about this pool a year ago when TEPCO (Nuclear Power and The Witch Hunt) made video footage available that showed that this pool was undamaged, and had the fuel within it was also intact, contrary to some rather inflammatory statements from former NRC Chair Jaczko.

In the past week, TEPCO has begun unloading the fuel from this pool. Such an effort represents a major milestone in progress on the site. By unloading this pool, Unit 4 will no longer pose any risk of radioactive releases. TEPCO can more fully concentrate its resources on the far more difficult challenges of cleaning up units 1, 2, and 3.

TEPCO provided photos and videos from the site of the first fuel bundles being removed. However, there is little explanation of what is actually happening. I’ve seen a number of questions regarding this effort. Let me provide a little clarification.

A little Background

Unit 4 was in a refueling outage when the earthquake and subsequent Tsunami struck. During this outage, they were required to replace some equipment inside the reactor vessel itself. In order to do that, the core was completely emptied of nuclear fuel. In addition, fresh fuel planned to be loaded after the repairs were complete had been staged into the pool for moving into the reactor later.

Nuclear fuel for light water reactors is loaded into long thin tubes of zirconium alloy sometimes called “fuel rods.” These rods are about ½ inch in diameter and 12-13 feet long. Because they are so long and skinny, they are pretty flexible by themselves, so they are grouped into bundles for strength and convenience. Think of single piece of paper vs. a phone book. For Boiling Water Reactors (BWRs) like Fukushima, these rods are then grouped into squares of 60-100 rods that are 6 inches in diameter and 14 feet long. BWR fuel also has something called a channel added to it. This box surrounds the fuel and helps to guide the water flowing through the reactor.

Nuclear fuel that hasn’t been loaded into the reactor and bombarded with neutrons is pretty benign stuff. When I worked at GE, I walked through an area we called “the forest” where bundles hang awaiting packing into special boxes for shipping. Unirradiated uranium gives off an occasional alpha particle (the nucleus of a helium atom) which can’t even really escape the bundle. Wearing gloves and regular clothes is more than adequate protection.This fuel is designed such that it can’t start spontaneously fissioning. It requires both a source of neutrons and some water to get the whole thing going, one without the other won’t start the chain reaction, that’s why the fuel is so easy to work with.

What we see

So, in these photos you see a long dark object, that looks a bit like a piece of cast iron dangling from a crane. That is a fuel bundle with a channel on it. In some pictures, you can see a metal cap on the bottom that looks like there’s a handle on it. That’s the lower tie plate that all of the rods are resting in. Some of them are actually screwed into that plate to hold the whole thing together.

The full radiation gear is NOT because that bundle is hanging there. This is fuel that was never placed into the reactor. This means that it is pretty much just like the fuel in that forest. The other fuel in the pool isn’t really affecting them either. The water in the pool keeps the radiation to a minimum. I’ve stood above spent fuel pools without getting even a little radiation from it. They are wearing full protection suits because to get to that platform and work requires moving around on the site and there’s still a great deal of radioactive contamination.

In some pictures they are spraying a bundle down with water and wiping it down. Not completely clear to me why, but an educated guess would say that the water is fresh and they are rinsing off the contaminated pool water (back into the pool as they are standing over top of it. By then wiping the bundle down, they are eliminating any radioactive particles that might have gotten into the pool water and settled on the bundle from events at the other reactors. Yes, it really is that simple decontaminate a surface. Wash it off.

Once they’ve done that, the bundles are being covered with a plastic sleeve. That is frequently done with fresh fuel when it is shipped to keep bits of stuff from getting into the bundles. It’s actually quite possible that bundle could be stored dry in a simple box as it needs neither the cooling nor the shielding that is needed by the exposed fuel.

They have probably 150 or so of these fresh bundles to move out before they start working on the more difficult exposed bundles. Those do require significant shielding and careful planning to remove and transport.

Tell me, what do you think of TEPCO’s progress and how they might go about the next steps?

Russian Gold!

Last week I discussed why the Russians might be asking the NRC for a Design Certification of the VVER. I concluded it had little to do with the supposed “gold standard” of certification the NRC provides. In reality the Russians need any independent certification to participate in the international market with smaller countries that lack resources to do their own certification.

Why should we care? Is this a good thing or a bad thing? Let’s look at the puts and takes.

The Gold

  1. Having the NRC certify the VVER would at least assure the design has a similar safety level and attention to quality that we demand in the U.S. This would be the “gold standard” we believe we have in the US.
  2. The Russians would have to pay for the review for this certification, bringing outside capital into the government. Estimate vary on how much, but the NRC charges a hefty $274/hr to the applicant for the privilege of reviewing their application. The work involves many dozens of reviewers and extends for several years. The AP1000 took five years in the latest round. The VVER would likely take longer. Only twenty full time reviewers can make the costs exceed $10MM.

Note: I’ve heard this phrase from some folks that “the NRC has never rejected a license application”. Here’s what really happens. The reviews are extensive and iterative. The NRC asks many, many questions (for DCD’s they can run to hundreds). And the applicant is paying $274/hr, plus all of their own people’s time in responding. At some point it becomes clear to the applicant that the license is not going to be satisfactory as is. Then the application is withdrawn to stop paying the NRC for further reviews. Sometimes, the applicant will fix the issues and resubmit, but sometimes the request is never resubmitted. So the NRC never rejects an application, but the thing they approve will have been modified to address their concerns and/or the concerns of members of the public who have chosen to intervene (called Intervenors).

The Dross

  1. The NRC has limited qualified resources to do these kinds of reviews. Nuclear expertise is not a quick study of a few months or years. To do a thorough review of a design requires significant expertise in this industry. However, the NRC rarely hires from industry, except at the lowest levels of reviewer. This means that leadership, oversight, and project management have to be grown from within the agency.
    If the NRC chooses to perform a review of the VVER, these highly trained individuals will not be available to perform reviews of designs and other licensing applications for projects that impact the U.S. industry directly.
  2. Providing this certification for the VVER without some commensurate US project means that the U.S. government has helped a competitor to US industry without any benefit of long term jobs and/or security for the United States.

Conclusions

The NRC has in the past demanded that someone demonstrate interest in a design before significant resources are applied to moving the application forward in the process. If they stick to this policy, the VVER may never see the light of day within the NRC.

That is, if the US industry keeps moving new reactor designs and licenses forward. If that effort stalls out, then the VVER may well be a way for the NRC to keep staff on board. You see, the NRC staffed up in anticipation of the dozen or so stated interests in new reactors around the U.S. Rather than lay people off (difficult to do in the government), I’m sure the NRC will fill its time with reviews of these reactors.

All-in-all, I don’t think the U.S. government should be helping Rosatom, a Russian owned and operated company, compete against companies that at least have a major presence and work-force in the U.S, like Westinghouse, GE-Hitachi, B&W, and Nu-Scale. These companies are creating U.S. jobs, and developing U.S. infrastructure as well as competing for international opportunities that will keep the U.S. out there influencing the development of nuclear around the world. A goal that I think is a good one.

Russian Gold? or U.S. Gold Standard

No, this is not a post about the upcoming Olympic Games, although we will talk about some of the countries playing in those games. This is a different set of games and one that affects the nuclear industry playing fields.

The recent announcement of Rosatom’s intent to seek Design Certification for the VVER in the U.S. has created some discussion about why they might be doing this and whether or not it is appropriate for the NRC to review such a submittal. While the NRC will review any acceptable application put before it, NRC staff and the commissioners have mentioned time and again that they are resource constrained and that some activities will have to be deferred while the commission deals with issues arising from events at Fukushima Daiichi in Japan.

So, why might Rosatom request such a certification?

The first reaction was that they are going to seek customers in the U.S. This seems highly unlikely. The market in the U.S. for new reactors has slowed considerable from the high number of announced intentions in 2005. They are also approaching the market with yet another PWR design. There are several already approved (AP-1000) or in review (EPR, APWR, etc). This would seem to be a pretty saturated market for them to successfully compete in. In addition to fighting the uphill battle of willingness to actually buy Russian technology in the U.S., my crystal ball says they are not planning to actually sell any VVERs here in the U.S.

So what’s the real plan?

Some have speculated that Rosatom is seeking U.S. NRC certification in order to sell reactors in a wider market. To date, almost all VVERs have been sold to former USSR states, or nations that have been more closely aligned with Russia in past years (India, for example). Some in the U.S. believe that the NRCs certification is a “gold standard” of sorts with smaller nations that have insufficient resources to perform such detailed certification assessments. In years past, I would have agreed with that assessment. Certainly, Mexico and Taiwan have largely relied upon U.S. regulatory reviews. To a lesser degree, Japan, Switzerland and Spain have as well.

Today, however, the U.S. position as a “gold standard” is in serious doubt. Other regulators have grown up and created their own high standards of review. The French government while perhaps in its earliest days relied up the U.S. has gone their own way for many years, as has Germany, Sweden, and the U.K. In addition, the U.S. has not built a new commercial reactor for many decades, and has never completed a reactor under the new 10CFR52 licensing regime.

All of that said, many smaller nations considering nuclear power for the first time, lack resources and expertise to do a thorough assessment of a design. Thus, in their requests for proposal, they’ve asked that the design be already certified in another country.

What countries are doing certifications of reactors not of “domestic origin”? It turns out, not a whole lot. France has only certified and built designs by AREVA (or its predecessors). South Korea has only certified in country designs as well. China doesn’t really certify designs as near as I can tell. Same in India. I don’t think the Russians actually certify their designs either. Other countries have limited programs with reliance on other countries.

The U.K. has created a robust program of certification in that past few years after several years reorganizing and rewriting its nuclear regulation. The U.S. has the 10CFR52 process that provides a clear certified design.

So Rosatom is requesting certifications from the two countries that really provide those things, most likely to allow them to go after those other markets. Not that the U.S. is a gold standard. It’s just one of a very few countries that fulfill the potential need.

So what might be the next question. Why should we care whether or not the Russian Design gets certified? That is for the next blog. There’s more to that question that meets the casual observer.