The Flood Next Time

For nuclear power plants facing aging dams and rising seas, is a captured regulator the last finger in the dike?

Fort Calhoun nuclear plant surrounded by flood waters
Nebraska’s Fort Calhoun nuclear power plant surrounded by flood waters from the Missouri River in June 2011.


At just before 3 local time on the afternoon of March 11, 2011, the operators of the Fukushima Daiichi nuclear power plant already had a problem. An earthquake measuring 9.1 on the moment magnitude scale—the largest to hit Japan since at least 1900—had damaged key systems at the facility, an emergency greatly compounded by the region-wide power outage caused by the massive temblor.

A station blackout (or SBO, as termed by an industry intensely fond of acronyms) at a nuclear power plant is, by design, cause for concern. Light-water reactors—the category that includes the units at Fukushima Daiichi and every one of the 98 still-operating reactors in the United States—function inside a kind of paradox: in order to safely generate a dependable output of electricity, they require a steady input of electricity. A plant’s meters and monitors need electricity; so, too, do many of the motors that raise and lower large, neutron-absorbing boron control rods used to regulate the atomic activity inside a reactor core. And, perhaps most critically, the systems that circulate cool water (crucial for expelling some of the intense heat generated by the fission reaction) through the nuclear reactors, as well as through pools where decades of used but still highly radioactive “spent” fuel is stored, depend on electric-powered pumps.

The SBO at Daiichi triggered a back-up: several diesel-powered emergency generators that would provide enough electricity to run the cooling systems until power could be restored (as long as there were fuel for the generators). But less than an hour later, a wave higher than a four-story building—the tsunami set off by the quake—swept over the seaside site and flooded the nuclear facility, knocking out most of the generators, which had been situated in the basement by General Electric, the plant’s designer.

Without electricity (what is called a “LOOP,” for “loss of onsite power”), the pumps stopped circulating the water, and without that circulation, the temperature inside the reactor cores quickly exceeded boiling. Within three hours, the tops of the zirconium-clad uranium fuel rods were exposed to air, starting a series of chemical reactions hot enough to free hydrogen atoms from their watery bonds. Despite the valiant efforts of hundreds of plant workers, intense heat and pressure built up inside the containment structures. Three reactor cores suffered complete meltdowns, and over the next few days, at least three powerful hydrogen explosions leveled containment buildings and shot plumes of radioactive gas and particulates high into the air, spreading contamination over land and sea. The rest is an ominous and still-evolving history Japan continues to battle nearly eight years on.

Of the currently operating civilian nuclear reactors in the US, scattered across 30 states, about two-thirds sit on the banks of rivers, lakes, or reservoirs. Add in plants on ocean shorelines, and the number of reactors adjacent to large, sometimes unruly bodies of water climbs above 80. But according to a whistleblower at the United States Nuclear Regulatory Commission (NRC)—backed up by information provided by regulators and watchdogs—more than a third of those reactors are either on sites that would no longer meet NRC flood risk guidelines for new reactor construction, or are vulnerable to flooding caused by dam breaks, swelling rivers, rising sea levels, or increasingly severe weather events.

It is that kind of foresight that was once considered the stock and trade of government regulators: examine the science, identify potential problems, and use the power and authority of the government to compel remedies and improve public safety. But in the wake of another Atlantic Hurricane season—where several nuclear plants had to reduce output or (in one case) shut down completely because of the threat of “catastrophic” flooding—it is sobering to note that, while Fukushima has been analyzed and debated by nuclear operators and regulators, the lessons of Japan’s disaster have not sufficiently been taken to heart, nor put into practice. Be it because of debates over cost-benefit assessment or blatant examples of corporate sway, what seems on one level the minutiae of regulatory process are also part and parcel of what growing numbers of Americans see as ineffectual governance by a corrupt—and corrupting—swamp.

* * *

Soon after the start of the Fukushima crisis, the NRC established a panel, known as the Near-Term Task Force (NTTF), to review the disaster in Japan and recommend regulatory changes and plant upgrades to enhance safety at US nuclear facilities. Their findings—often shorthanded as the NTTF report, or the NTTF recommendations—were comprehensive (though not, in some critics’ eyes, comprehensive enough), touching on concerns from seismic reevaluations to emergency response, with lots of technical considerations in between—including dozens of pages on flooding and the LOOP accidents it can cause.

The report came out in July, and by October, the NRC had identified a small selection of the recommendations it considered top tier and requiring implementation “without delay,” as the Commission put it at the time. Central to many of those proposals were the hazards posed by flooding.

But it’s not as if the dangers of flooding were unknown to nuclear regulators (or the industry) before the cascading disaster at Fukushima Daiichi. In fact, at Duke Energy’s Oconee Nuclear Station (ONS) in the northwesternmost corner of South Carolina, regulators and plant owners had been debating the facility’s flood risk and flood preparedness for decades.

“The concern has been around in its current iteration since 2005 or -6, but it has been raised many times in the past,” said Larry Criscione, a reliability and risk analyst at the NRC since 2009. “It was raised in the ‘80s, it was raised in the ‘90s—I think it was raised in the ‘70s as part of [Oconee’s] initial licensing.”

Construction on ONS began in 1967, and its three reactors were all online before the NRC opened its doors in 1975. But documents provided by Criscione show that by 1977, the Commission had identified flood concerns at several plants licensed before the formation of the regulatory body. Oconee is one of them, and an alphabet soup of studies and recommendations—most notably the IPEEE (the Individual Plant Examination of External Events) for Severe Accident Vulnerabilities in 1991—requested its operators assess and plan for what the industry calls “beyond design basis events” (BDBEs), incidents more extreme or powerful than accounted for in a plant’s original design (of which the earthquake and tsunami in Japan later became prime examples).

Oconee is located on the shore of Lake Keowee, an artificial reservoir created by the damming of the Keowee River, and part of a system of dams built in the 1960s and ‘70s that also includes the Jocassee Dam, just 11 miles upstream from Keowee and ONS. What would happen should the Jocassee Dam fail—and just how likely that is to happen—is central to the debate over the flood preparedness at the nuclear plant. And it is central to the life of Larry Criscione.

* * *

That a dam failure would be a BDBE of dire proportions for ONS once seemed beyond debate. “As I understand it, the NRC’s assessment of the consequences of a flooding event at Oconee would be even greater than at Fukushima,” said Tim Judson, executive director of the Nuclear Information and Resource Service, a nuclear industry watchdog. Because Fukushima Daiichi was located on the coast, and prevailing winds blew an estimated 80 percent of the fallout out to sea in the first weeks of the disaster, much of central and southern Japan was spared the high levels of radioactive contamination seen in the prefectures immediately surrounding the failed nuclear plant. Still, more than 150,000 people had to be relocated from a 12-mile radius around Daiichi.

If the Jocassee Dam were to fail, the resulting flood would inundate Oconee with 12 to 17 feet of water in about five hours, according to Duke Energy’s own assessment, filed in the 1990s in response to the IPEEE, and referenced by Criscione in his report to the NRC. A station blackout would follow, and because Oconee’s backup plan involves hydroelectric power generated by the dams on Lake Keowee, and a break of the Jocassee Dam is projected to cause Keowee Dam failure, ONS would suffer a complete LOOP. With no electricity to run the cooling systems, all three reactor cores would melt down in eight to ten hours, and (and again, this is from Duke Energy’s report) the containment buildings would fail within three days. Radioactive contamination would head down river with the flood waters, and an airborne plume would engulf the university town of Clemson, 10 miles to the southeast, and then lay a blanket of fallout 300 miles eastward to the sea.

But at the time—a pre-Fukushima time—Duke argued that this nightmare scenario was so improbable as to not merit the kind of elaborate and expensive safety upgrades required to prevent it.

As Criscione explains it, the NRC evaluates Beyond Design Basis Events by two scales: one is the relative chance that a given event will occur; the other is the resulting danger once it does. For instance, the risk analyst told me, if a meteorite were to crash into a nuclear power facility, the results could be catastrophic, but the chances of a meteor strike are calculated to be so vanishingly small that plant operators are not required to guard against it.

“The term they use in nuclear is ‘credible,’” said Criscione, “you have to protect against credible threats.”

But try to find a place in the regulations where “credible” is defined. “You’ll never be able to,” Criscione told me. Instead, there is an unspoken range: In “the day-to-day business of the NRC, when things are less than one in a million [in any given year], you can make an argument they’re not credible; when they’re more than one in 10,000, they’re certainly credible.”

“When they’re in between,” Criscione continued, “that’s where the debates start to happen.”

“In a case like Fukushima, you see where that falls apart,” cautioned NIRS’s Judson. “The NRC would have very likely determined what happened at Fukushima was outside credibility range—less than one in a million—so therefore they wouldn’t have done anything about it.”

“Despite that,” Judson observed, “it happened, and the consequences are so great it outweighs the entire alleged benefit of the Japanese nuclear power program.” (After the quake and tsunami, one NRC commissioner reevaluated the risks at Fukushima, and determined they had been one in 1,000 in any given year. Or, to put it another way, TEPCO, the operators of Fukushima Daiichi, were lucky for 40 years, until the year they weren’t.)

In the case of Oconee, with the consequences of a Jocassee Dam failure originally agreed to be grim, Duke Energy debated the probability, placing it outside the “credible” one-in-10,000 chance. But by 2010, as Criscione’s NRC-sponsored analysis showed, it was Duke’s assessment that lacked credibility. Taking into account a broader data-set (paleological as opposed to solely the far-more-limited historical record) and the reassessment of critical infrastructure conducted by various US agencies (notably FERC, the Federal Energy Regulatory Commission) in the years after the September 11, 2001 attacks, regulators placed the odds of dam break causing a BDBE at ONS at one in 3,600—about the chance of drawing a straight in poker, as Criscione put it—or if projected over the remaining time on the plant’s license, there’s better than a one-in-200 chance of such an accident before ONS permanently shuts down. That’s not a certainty in any given year, said Criscione, but it is well above the NRC’s unspoken credibility threshold of one in 10,000.

And the NRC and Duke Energy were in the process of negotiating what should be done to address this now-understood-to-be-credible threat when, as Criscione, Judson, and other nuclear watchdogs see it, Fukushima changed everything.

* * *

When the NRC moved to adopt some of the NTTF recommendations (and only a subset of a subset of the report was ever considered by the Commission as formal rules), oversight of implementation was given to the JLD—the Japan Lessons-Learned Directorate (later expanded and renamed, replacing “Directorate” with “Division”)—a group that was supposed to hive off Fukushima-related concerns to allow “the rest of the NRC keep its focus on other important issues faced by the agency,” as JLD’s own web page put it. But almost inherent in that language is a segregation that puts anything dubbed a post-Fukushima upgrade into a new class of oversight—one that, to those on the inside like Criscione, did not meet the urgency of the risks at hand, nor the fanfare of the Commission’s own pronouncements.

As Criscione told me, Duke Energy “came to the NRC” soon after the start of the Fukushima crisis and argued that if there were going to be new rules derived from that disaster, Duke didn’t want to invest in upgrades at Oconee only to find they fell short of post-Fukushima recommendations.

On its face, said Criscione, “that was a reasonable request.” However, what it did in practice was move the Oconee case from staff who had been trying to address it for five years, who had a knowledge of the issues and the history of the debate, to personnel who were, according to Criscione, not only starting from scratch, but were led by “an industry apologist.”

“You’ve got to understand how the JLD operated,” Criscione explained, “the NRC really likes to see the industry fix its own problems.” It’s the nuclear industry that builds the power plants—the Commission just licenses them. The industry designs the plants, and the NRC reviews those designs. “We don’t tell them how to fix problems,” said Criscione, “we review their fixes to their problems to see if they’re accurate.”

When it came to post-Fukushima fixes, Criscione said, “we didn’t approach it with the attitude of ‘We’re the government, we’re going to decide what changes you need to make your plants safe.’ We approached it with the attitude of ‘You’re the plant owners, you prove to us that your plants are safe.’”

The lobbying arm of the industry, the Nuclear Energy Institute (NEI), came to the NRC with standards it had written to address post-Fukushima concerns like flooding and loss of onsite power events. “And,” as Criscione described it, given the general framework of how the NRC operates, “there’s nothing wrong with that.”

“The problem is that the person who was in charge at the JLD,” the one responsible for evaluating standards, the one who had the power to overrule the rest of the staff, as Criscione told me, “was actively seeking a job as a vice president at NEI.”

Criscione was not exaggerating. The NRC executive in question, Jack R. Davis, bragged on his LinkedIn page at the time (saved for posterity at the Environmental Archive) that his work at what was supposed to be the public’s nuclear regulator had “saved the commercial energy generation industry $1.6 billion,” and “achieved 80 percent reduction in the number of customers needing to complete mandated federal safety improvements.” Those Davis saw as his “customers” were in the energy industry, not the American people who were then paying his salary.

Davis didn’t get his job at NEI, but by 2016, he had landed an executive post at Entergy, one of the nation’s largest owners of nuclear power plants, and the company with the ignominious distinction of operating what the NRC has determined are the country’s three worst-rated nuclear facilities in terms of safety.

With respect to Oconee, the transfer of flood issues to the JLD resulted in a projected 17-foot flood being reevaluated down to a five-foot threat, which is coincidentally the height of a flood barrier built outside the plant in the 1980s. It was a coincidence that did not sit well with Criscione, who was charged with evaluating flood safety. In 2012, he forwarded his concerns to the chair of the NRC and to select members of Congress—information that eventually made its way to the environmental group Greenpeace and into a story in the Huffington Post.

The coverage caught the attention of the NRC’s inspector general, who, rather than act on Criscione’s allegations of lax oversite, opened an investigation into his sharing of official documents.

Criscione said he doesn’t believe he is currently under investigation by the Office of the Inspector General (NRC OIG), but he has also not seen a final report on his case, which he’s told is still under review.

* * *

Better than one in every four nuclear plants is at risk of a flooding event, according to Criscione, an event that could lead to a Fukushima-style disaster. With more than 20 reactors along the eastern seaboard vulnerable to hurricanes, flying debris, heavy rains, and massive storm surges, and dozens of others inland near swelling rivers and aging dams—all with a half-century of spent fuel rods stored nearby—the implications for the hundreds of millions of US residents that live near these reactors is at least unsettling. With climate change increasing the frequency and severity of flood-provoking events, the status quo should be unacceptable.

The NRC will tell you it has it all in hand. “Every US reactor site has completed its flooding hazard reanalysis,” Scott Burnell, the NRC’s public affairs officer, told me in an email.

Central to the post-Fukushima seismic- and flood-hazard analysis was something called a “walkdown.” The NRC “asked” US nuclear power plants “to perform a detailed inspection” of “their currently installed seismic and flooding protection features [and] ensure the features met current requirements.” Plant operators were also told to “identify, correct, and report any degraded conditions.” According to the NRC’s website, this phase was completed across the entire US nuclear fleet by November 2012.

But in March 2013, at Arkansas Nuclear One (ANO), a two-reactor facility 80 miles northeast of Little Rock, the accidental dropping of a 550-ton generator component in the truck bay caused enough shaking to rupture a water pipe. Water flooded the plant’s electrical switchgear, interrupting all power to one reactor, and partially disabling the second. Emergency diesel generators kicked in to ward off a bigger disaster, but the accident, which killed one plant worker and injured eight others, revealed that dozens of penetration points had missing or improperly installed seals.

Dave Lochbaum, the director of the Nuclear Safety Project at the Union of Concerned Scientists, contacted the NRC to express his grave concern about the quality of their plant walkdown program. According to Lochbaum, the NRC assured him that ANO was “the only plant in the country with an ineffective flood protection walkdown.”

But in January 2014, rains hit Florida’s Atlantic coast (“Not a monsoon or a once-in-a-blue-moon rain, but a thunderstorm,” Lochbaum said). At the St. Lucie Nuclear Power Plant, 70 miles north of Palm Beach, faulty storm drains caused a 55,000-gallon flood in an auxiliary building. Water penetrated improperly sealed electrical pass-throughs, disabling pumps needed for cooling one of the facility’s two reactors. “The penetration was about five feet off the floor—at eye level during a walkdown, had anybody only been looking,” wrote Lochbaum in an email.

“So, AFTER owners conducted NRC-mandated flood protection walkdowns, and AFTER the owners formally notified the NRC that flood-protection measures were adequate, those assurances were proven false by actual flooding,” Lochbaum wrote. “Apparently,” Lochbaum’s email surmised, “the walkdowns had been more for exercise than for verification of safety.”

The NRC’s industry-friendly approach also troubles Judson. The NIRS director detailed the case of New York’s Nine Mile Point—on the banks of Lake Ontario, 40 miles north of Syracuse—a site that is home to three nuclear reactors, including the oldest still-operating commercial reactor in the US (Nine Mile Point 1, which was commissioned in December 1969). Just last year, a swelling Lake Ontario came within a foot of triggering an “unusual event” (the NRC’s first level of emergency notification). Exelon, the facility’s owner, sprung to action—and applied to the NRC to change the standards so it wouldn’t have to declare an emergency unless the site was so flooded that workers couldn’t access the site by car.

That change was quickly approved by the NRC—an alarming lack of oversite, according to Judson, given the potential for widespread environmental disaster. “Lake Ontario is the drinking-water source for 9 million people,” he said.

* * *

In addition to the examples above, there are a number of sites that worry the experts—among them: Quad Cities Nuclear Generating Station, in Northern Illinois, on the banks of the Mississippi River, Dresden Generating Station, 60 miles southwest of Chicago, at the head of the Illinois River, and Pilgrim Nuclear Power Station in Plymouth, Massachusetts, on the shores of Cape Cod Bay, less than 40 miles south of Boston. What these sites have in common, beyond their remarkable age (online 46 years, the reactors at Quad Cities are the youngest of this group), is their acute vulnerability to the perils of a warming planet.

Riverine flooding, more frequent and more severe this century and unrelated to any dam failures, leave Quad Cities and Dresden in a precarious place almost annually. (Precipitation in this region is expected to increase 37 percent by 2070, according to a NOAA—National Oceanic and Atmospheric Administration—study.) For Pilgrim, a facility that has seen numerous weather-related shutdowns in recent years, a category 5 hurricane could elevate sea level by 22.4 feet, according to plant-owner Entergy—giving the hundreds of tons of irradiated fuel stored outside in concrete and steel “dry casks” about two-and-a-half feet of clearance. But when conservative estimates project a general sea-level rise in the Bay of three feet by 2065, and possibly six feet by the end of the century, the site has less than no margin for error.

Even a partial submersion of a dry cask could block vents, interrupting its convection-dependent cooling mechanism, according to Kevin Kamps, radioactive waste specialist at clean-energy advocacy group Beyond Nuclear. Depending how long this went on, the integrity of the fuel and the steel liner could be affected.

But of course, as perilous as it is for the casks, lined up on a concrete pad less than a football field’s length from the shore, the plight of Pilgrim’s spent fuel pool, filled to over three times its design capacity, worries watchdogs more. Like with all the other reactors, a prolonged interruption of power means a “loss of cooling accident” (LOCA—yes, this has an acronym, too), with limited time before the tightly packed fuel assemblies boiled off their pool and caught fire, potentially covering northern New England with many times the amount of radioactive cesium-137 released by the Chernobyl disaster.

Pilgrim is scheduled to go offline for good this spring, but the spent fuel is expected to remain on site for decades. This was troubling enough to Senator Edward Markey that he contacted the NRC last April asking how the Commission will factor in global warming. “It is imperative,” the Massachusetts Democrat wrote, “that these plants and the NRC regulations fully consider the impacts of climate change on dangerous nuclear waste.”

* * *

As far as the NRC is concerned, it has. “Every US reactor site performs relevant analyses based on location-specific parameters,” wrote the NRC’s Burnell in response to my question about the regulator’s assessment of climate-based changes in risk. In practice that means that predictions for things like precipitation and sea level rise are factored back into the NRC’s models for assessing credible risk. Well. . . sort of.

“My sense is there’s really no uniform methodology,” said Criscione. As to NRC requirements for what needs to be in an assessment, say, for flood risk, Criscione told me, “it’s more of a style guide.”

This wasn’t always the case. “The NRC used to have more deterministic standards,” said Judson, “and there’s a debate to be had about whether that regulatory process was better at safety outcomes than the one they’ve adopted since.” Before about 20 years ago, the process, according to Judson, was more open to the public. “There was a time when the public was able to raise safety allegations with the NRC,” he said, noting instances at several reactors in New England. “The NRC was forced by public acrimony, and in some cases by Congress to step in and regulate.”

Today, under what is called “probabilistic risk assessment,” nuclear plants are expected to meet performance metrics, and that is then weighted with “risk-informed regulation”—the system that evaluates whether a threat is credible enough to merit safety upgrades.

The shift wasn’t just academic. Under deterministic assessment, reactors in Connecticut, Illinois, Maine, and Oregon were taken permanently offline or forced to make significant improvements. But that era, Judson told me, “is largely gone.”

“There were no reactor closures in the US between 1998 and 2013,” he said.

And since 2013, with the shuttering of facilities in Wisconsin, Vermont, California, and New Jersey, as well as Nebraska’s once flood-ravaged Fort Calhoun—and with more expected to close in the next couple of years—could that be evidence of Fukushima-inspired regulatory vigor? Only tangentially. The past decade has also seen a major shift in the energy market. With the fracking boom creating a surplus of natural gas, and the cost of wind and solar generation continuing to fall, nuclear power, which was never able to come anywhere close to its atomic-age promise of being “too cheap to meter,” grew increasingly uncompetitive.

What would have been an affordable safety upgrade 10 years ago is now financially untenable. “Regulations that would have been something minor in the 2008 timeframe, would certainly shut down a plant today in some markets,” Criscione told me, adding, “I think the agency has recognized that, and I think they’ve kind of caved in to some of the economic pressure that the utilities are seeing.”

“Ultimately, it almost always comes down to money,” agreed Judson. “If it passes the ‘credible’ threshold level, the NRC will determine the possible impact of the event and weigh that against what the cost of remedying it or preventing it would be—and they make a determination from that point about whether the cost is justified.”

The NRC, for its part, rejects the views of the whistleblower and the watchdog. “Plant costs were not taken into consideration” on “post-Fukushima Orders,” wrote Burnell, and “none of the plants that have recently either permanently shut down, or have announced plans to do so, asked for financial-based relief from post-Fukushima requirements.”

Except that they have. Pretty explicitly. And it was granted. Pretty explicitly.

Almost exactly a year before Burnell sent me his statement, the NRC granted a request by Entergy to waive post-Fukushima requirements for their Pilgrim nuclear plant, including improvements to vents that could potentially relieve reactor core pressure in the case of a loss-of-power/loss-of-cooling event, new seismic regulations, and, of special note here, new flooding regulations. All this for a plant identical in design to the failed reactors at Fukushima, a plant that is one of the three-worst rated in the US, and a plant that was revealed in a leaked 2016 internal inspection memo to have a staff that is “overwhelmed by just trying to run the station.”

The NRC will counter that Pilgrim’s “operational lifespan”—Entergy has announced plans to shut it down by June—is too short to complete the upgrades. But the Commission granted Pilgrim a 20-year license extension in 2012, meaning regulators and plant operators had thought plant operations could continue through 2032. The reason the plant is shuttering early is because Entergy felt it was not financially viable to maintain it.

Strangely, though, at the same time Entergy was told it would not have to invest in post-Fukushima safety improvements, Pilgrim was starting an expensive refueling cycle, which can require hundreds of extra plant workers and take the plant off line for a month. If regulators had declined to grant the waiver, if Pilgrim had been required to begin plant upgrades to stay open, would Entergy have spent on a refueling that gives their reactor an extra two years of generating power?

Mary Lampert, a longtime environmental activist and the director of Pilgrim Watch, told the Boston Globe in 2017 that the NRC was making an industry-friendly gamble. “Sadly, it’s financial safety rather than public safety,” she said.

* * *

It’s a ratio that bears all the hallmarks of what is called “regulatory capture”—a government agency so close to the commercial sector it regulates that it considers the industry’s interests over the public’s. But with the NRC, it goes a step further.

“Unlike many other federal agencies, the NRC’s continuation is dependent on the perpetuation of its industry,” said Judson. “If nuclear power goes out of business, and reactors shut down, the NRC’s mission starts to drain away.”

(Of course, if the NRC took an interest in nuclear plant decommissioning, they’d have at least another fifty years of work to do. But that is clearly not their inclination.

“The NRC staff concluded that there is no need for regulatory action at decommissioning reactors in light of lessons learned from the Fukushima accident,” wrote Burnell.

Judson put it more starkly: “There is no oversite” at a non-generating plant. “During decommissioning, there are basically no inspections by NRC.”

“Something really bad would have to happen for NRC to send inspectors to a decommission,” he said.)

Perhaps nothing demonstrates the regulator’s deference to the industry in the post-Fukushima era quite like something called FLEX (which is amazingly, despite it always being spelled with all caps, not an acronym). “FLEX,” as the NRC’s Burnell explained to me in an email, “is the industry term for its approach to complying with the NRC’s Mitigation Strategies Order of March 2012 … which the NRC has reviewed and found acceptable.”

But another way to look at FLEX is the way watchdog Judson does: “The thing that the NRC has allowed that the industry is taking credit for, but that aren’t actually real requirements.”

FLEX, as loosely explained in an illustrated web page from the NRC, allows nuclear plant operators to meet LOOP events with three phases of emergency equipment. The first involves the batteries and diesel-powered generators that are part of the backup systems at most US plants—the systems that failed so dramatically at Fukushima Daiichi (as discussed, Oconee does not use diesel generators, relying instead on hydroelectric power from nearby Keowee Dam). The second is portable equipment stored on-site at a nuclear plant that is supposed to take over when the phase one, design-basis backups fail or are exhausted. The third phase of FLEX, according to the NRC-sanctioned industry plan, is backup equipment stored off site, at two industry-maintained “response centers” in Memphis, Tennessee, and Phoenix, Arizona, which can be moved to a faltering reactor “within 24 hours.”

“It’s the sort of thing where OK, sure, it might be value added,” Judson said, “but it’s not part of the design basis of the reactor, and not part of what the NRC can easily regulate.” In fact, while Burnell told me the NRC has inspected the response centers, that is not the same thing as it having to meet an agency rule.

“It’s not a requirement,” Judson observed, “it’s something that [the industry’s] doing voluntarily outside of the regulations.”

And the moving of that equipment to a troubled site also exists outside the regulatory process. “The industry has established standing contracts to airlift phase three cargo to airports close to reactors, and additional contracts (including helicopters) to bring the phase three cargo to a site,” said the NRC’s Burnell, again relying on industry assurances. (And when asked for clarification, Burnell told me that the cargo aircraft were all private contractors, while the helicopters could be private or military, depending on the nuclear facility.)

When I questioned the 24-hour allowance (given that the Fukushima example and the industry’s own projections at Oconee show core damage starting in as few as eight hours after a loss of power), Burnell wrote, “Each plant has determined how long they have to get phase three resupply to the site.” Asked about the possibility of a large-scale, fast-moving weather event affecting multiple nuclear facilities (as was the case with 2012’s Hurricane Sandy), Burnell seemed even more certain: “Cargo aircraft flights from Memphis to East Coast sites will certainly get phase three to the sites in a timely manner, and plant response procedures account for the additional flight time from Phoenix if necessary.”

If only the weather—or a disaster-battered infrastructure, or an overstretched private contractor—could be as sanguine. “It’s very easy to imagine situations where bringing in equipment from off site is just not going to be feasible,” Judson said.

Criscione referenced his analysis of Oconee in the event of a breach of Jocassee Dam, where all four bridges used to access the plant are expected to fail. Looking at Duke Energy’s promise to bring in emergency backup equipment from off site, he said, “I don’t think it’s realistic. There’s a path to success, but I think the odds are slim.”

* * *

But Criscione’s analysis doesn’t, by his account, carry as much weight inside his agency since he blew the whistle on flood preparedness to the NRC commissioners and Congress. “I’m less effective than when I brought the issues forward,” he said. “I’m certainly not invited to the same meetings that I was in the past.”

And Criscione thinks the problem is agency-wide. “People who draw a harder line on the industry have been less involved,” he said, tracing the change to about 2012, when battles over post-Fukushima regulations precipitated a change in the NRC’s chair, and the Japan Lessons-Learned Division took over a lot of the oversite of emergency preparedness and mitigation.

Today, even the JLD has disappeared, absorbed into another spoonful of alphabet soup, the NRR (the Office of Nuclear Reactor Regulation). “Post-Fukushima activities,” Burnell told me, “have been formalized to the point where the agency’s routine reactor oversite is appropriately tracking compliance.”

But to hear critics tell it, appropriateness is in the eye of the beholder. Seven years after the earthquake and tsunami that turned “Fukushima” into disaster shorthand, “things have been done,” said Judson, “I’m not sure I’d say that they’re adequate.”

“A lot of the things that they came up with after evaluating what happened at Fukushima were things that they should have done years before anyway,” he continued. “Now we’ve got emerging threats that the NRC hasn’t dealt with, and that, in all likelihood, it won’t deal with until something bad happens.”

Lochbaum put it this way in an email: “US nuclear power plants are adequately protected against flooding—unless a flood happens.” In a “worst-case failure of the Jocassee Dam, one would not want to be close to Oconee,” he said. “All three reactors are likely to follow Fukushima’s path and reach its destination.”

For Criscione, the clarion call is coming from the inside the house. “I don’t feel good about Oconee, he told me. “From what I see, we’ve been compromised when it comes to flooding.”

(No version of this story may be reprinted without the express written permission of Gregg Levine.)

Yule Fuel

Yes, it’s time for that metaphor again. If you grew up near a TV during the 1960s or ’70s, you probably remember the ever-burning Yule Log that took the place of programming for a large portion of Christmas Day. The fire burned, it seemed, perpetually, never appearing to consume the log, never dimming, and never, as best the kid who stared at the television could tell, ever repeating.

Now, if you have been watching this space about as intently as I once stared at that video hearth, perhaps you are thinking that this eternal flame is about to reveal itself as a stand-in for nuclear power. You know, the theoretically bottomless, seemingly self-sustaining, present yet distant, ethereal energy source that’s clean, safe and too cheap to meter. Behold: a source of warmth and light that lasts forever!

Yeah. . . you wish! Or, at least you’d wish if you were a part of the nuclear industry or one of its purchased proxies.

But wishing does not make it so. A quick look at the US commercial reactor fleet proves there is nothing perpetual or predictable about this supposedly dependable power source.

Both reactors at San Onofre have been offline for almost a year, after a radioactive leak revealed dangerously worn heat transfer tubes. Nebraska’s Fort Calhoun plant has been shutdown since April of 2011, initially because of flooding from the Missouri River, but now because of a long list of safety issues. And it has been 39 months since Florida’s Crystal River reactor has generated even a single kilowatt, thanks to a disastrously botched repair to its containment that has still not been put right.

October’s Hurricane Sandy triggered scrams at two eastern nuclear plants, and induced an alert at New Jersey’s Oyster Creek reactor because flooding threatened spent fuel storage. Other damage discovered at Oyster Creek after the storm, kept the facility offline for five weeks more.

Another plant that scrammed during Sandy, New York’s Nine Mile Point, is offline again (for the third, or is it the fourth time since the superstorm?), this time because of a containment leak. (Yes, a containment leak!)

Other plants that have seen substantial, unplanned interruptions in power generation this year include Indian Point, Davis-Besse, Diablo Canyon, Hope Creek, Calvert Cliffs, Byron, St. Lucie, Pilgrim, Millstone, Susquehanna, Prairie Island, Palisades. . . honestly, the list can–and does–go on and on. . . and on. Atom-heads love to excuse the mammoth capital investments and decades-long lead times needed to get nuclear power plants online by saying, “yeah, but once up, they are like, 24/7/365. . . dude!”

Except, of course, as 2012–or any other year–proves, they are very, very far from anything like that. . . dude.

So, no, that forever-flame on the YuleTube is not a good metaphor for nuclear power. It is, however, a pretty good reminder of the still going, still growing problem of nuclear waste.

December saw the 70th anniversary of the first self-sustaining nuclear chain reaction, and the 30th anniversary of the first Nuclear Waste Policy Act. If the 40-year difference in those anniversaries strikes you as a bit long, well, you don’t know the half of it. (In the coming weeks, I hope to say more about this.) At present, the United States nuclear power establishment is straining to cope with a mountain of high-level radioactive waste now exceeding 70,000 tons. And with each year, the country will add approximately 2,000 more tons to the pile.

And all of this waste, sitting in spent fuel pools and above-ground dry casks– supposedly temporary storage–at nuclear facilities across the US, will remain extremely toxic for generations. . . for thousands and thousands of generations.

There is still no viable plan to dispose of any of this waste, but the nation’s creaky reactor fleet continues to make it. And with each refueling, another load is shoehorned into overcrowded onsite storage, increasing the problem, and increasing the danger of spent fuel accidents, including, believe it or not, a type of fire that cannot be extinguished with water.

So, if you want to stare at a burning log and think about something, think about how that log is not so unlike a nuclear fuel assembly exposed to air for a day or two. . . or think of how, even if it is not actually burning, the high levels of radiation tossed out from those uranium “logs” will create heat and headaches for hundreds of thousands of yuletides to come.

Oh, and, if you are still staring at the Yule log on a cathode ray tube television, don’t sit too close. . . because, you know, radiation.

Merry Christmas.

Imagine a Nuclear-Free California (You Don’t Have To, It’s Already Here)

We welcome our salp overlords. (A chain of salp in the Red Sea; photo: Lars Plougman via Wikipedia)

California has two nuclear power plants. San Onofre, between Los Angeles and San Diego, has been offline for months as everyone tries to find an excuse for the alarmingly rapid wear on new reactor tubing. (Being shut down, however, did not prevent a fire from breaking out this week when a pipe ruptured and released radioactive steam.)

But as of Thursday, Diablo Canyon, the nuclear plant to the north, is also offline–thanks to. . . uh, salp?

Yes, salp–those loveable, gelatinous, jellyfish-like, plankton-eating sea creatures that multiply like, well, salp–have swarmed Diablo Canyon’s water intake system. D-Can draws in tens of thousands of gallons of seawater every day to cool its reactors, and with all that salp clogging the intake pipes, the plant could no longer operate safely.

That may sound like a freak event, but it isn’t. San Onofre had to shut down in 2005 to clear out 11,000 pounds of anchovies that had the bad luck of swimming too close to that plant’s intake filters. . . and in 2004, it shut down, too, but that time it was due to 14,000 pounds of sardines.

And just last year, actual jellyfish (sorry, salps) brought down Florida Power & Light’s St. Lucie nuclear power station. Jellyfish have also previously crippled nuclear facilities in the UK, Israel and Japan.

But back to California, where without nuclear power, the state is heading for a disaster of biblical proportions–we’re talking human sacrifice, dogs and cats living together, mass hysteria!

Actually, no. What will happen is that Pacific Gas & Electric, the owner of Diablo Canyon, and Southern California Edison, San Onofre’s operator, will have to buy electricity (or continue to buy electricity) in order to deliver what they are obligated to deliver. That’s no fun for the big utilities, and maybe it looks biblical to the bean counters, but it is not an energy apocalypse.

Of course, instead of throwing millions after billions to buy surplus electricity elsewhere while also paying to staff, examine and repair its dormant, ancient nuclear facilities, power companies could try to invest more in 21st Century renewable alternatives.

And maybe that would happen if the market were actually, you know, a market. But with tax breaks, loan guarantees, and liability caps, the industry has little motivation to make sound financial or environmental decisions.

But there’s no time like the present to start. And right now, in California, that present is nuclear-free.

A little bit pregnant?

On Thursday, NPR’s Richard Harris delivered a report that regurgitated the nuclear industry’s latest message morph–once “clean, safe, and too cheap to meter,” the 21st Century PR spin has nuclear as the climate-friendly energy option.

The radio piece is ostensibly about how the world’s industrialized nations are failing to meet their climate goals–and this is true (and this is a problem). But Harris does the world and the climate cause no favors when he lazily posits: “Nuclear power produces very little carbon dioxide. . . .”

What does Harris mean by “nuclear power produces very little carbon dioxide?” Is that supposed to be a hedge? If you are isolating the atomic pile generating heat to boil water inside a closed system, then you might as well say “no CO2,” but if you are honest and take into account the whole lifecycle of nuclear fuel–from mining and refining through transportation and storage–then nuclear power produces a prodigious amount of greenhouse gases. Which is it Richard?

Probably just an oversight

The Washington Post published self-serving letter to the editor supporting a recent pro-nuclear editorial, but neglected to include that the letter was written by the current vice president and president elect and sitting member of the board of directors of the unabashedly pro-nuclear American Nuclear Society.

If only Nixon had apologized!

Fukushima Governor Yuhei Sato apologized Wednesday for prefectural officials who deleted records on the spread of radioactive fallout immediately following the start of the Daiichi nuclear crisis in March of 2011. The data from the country’s System for Prediction of Environmental Emergency Dose Information (SPEEDI) could have better informed citizens on when and where to evacuate during the first days after the Tohoku quake and tsunami destroyed safety systems at the Fukushima Daiichi nuclear power plant, and could have also given those trying to piece together what happened inside the reactors important forensic evidence.

At a news conference, Sato said, “A big problem lies in the fact that we failed to fully share the information soon after the nuclear disaster broke out.”

Well, yeah, that–and that you erased it.

Not to worry though, the government “reprimanded” its supervising officials and also “issued strong warnings” to the two government employees that actually did the deleting. So, citizens of Northern Japan, we’re good?

“Let’s Eat Cesium Beef”

That is (as translated by EXSKF) the name of an event in Iwate, Japan designed to encourage people to eat local beef known to be contaminated with radioactive cesium from Fukushima’s fallout.

No, this did not appear in a Japanese version of The Onion (Tamanegi?), this a real event as reported by Kyodo News in a series called “New Happiness in Japan.” Apparently, happiness is knowing you’re only poisoning your children a little bit. . . because there were kids at this thing.

The event was, uh, cooked up by the head of a meat-packing company to show a group of his regular customers–including young couples with kids–that beef containing radioactive cesium, but at levels lower than the provisional safety limits, still tasted OK.

According to the source of the translation, this story has people all over Japan shaking their heads wondering what this meat packer could have been thinking, but there have been several stories over the past year documenting even more official Japanese government efforts to get citizens to consume agricultural products from Fukushima and surrounding regions.

Imagine a nuclear-free Japan

Soon, you won’t have to imagine that, either. The last of Japan’s 50 commercial reactors still online will soon shut down.

Wait? Fifty? Wasn’t it 54? Well, earlier this month, Japan removed the four damaged reactors at Fukushima Daiichi from their official list of the country’s commercial reactors.

Probably wise.

Oh, and, notice, also no mass hysteria. The radiation that has contaminated air, water, and land might have many Japanese very worried, but the country has managed to handle the reduced electrical generating capacity remarkably well. They did this thing called “conservation.” Been doing it for over a year now. Think of all the dogs and cats that have been spared. . . not to mention the salp.

San Onofre: One Leaks, the Other Doesn’t… Yet

For those who thought that, with the new year, nuclear power had turned a page and put its “annus horribilis” behind it–as if the calendar were somehow the friend America’s aging reactors–let’s take a quick look at January 2012.

First, a glance across the Pacific, where the month began with the revelation that the Japanese government purposely downplayed their assessments of the Fukushima disaster–hiding the worst projected scenarios from the public from soon after the March earthquake by classifying the documents as personal correspondence–and ended with discovery of yet another large leak of radioactive water from one of the crippled reactors.

Closer to home, the lone reactor at Wolf Creek, Kansas, was shutdown on January 13 after the failure of a main generator breaker was followed by a still-unexplained loss of power to an electrical transformer. Diesel generators kicked in to run the safety systems until external power was restored, but the plant remains offline while a Nuclear Regulatory Commission inspection team tries to figure out what went wrong.

On the morning of January 30, a power failure caused a reactor at Exelon’s Byron Generating Station to scram, which in turn required a wee bit of venting:

[At] Exelon Nuclear’s Byron Unit 2 atomic reactor near Rockford, IL, primary electrical grid power was lost and safety and cooling systems had to run from emergency backup diesel generators when smoke was seen coming from a switchyard transformer. However, when the plant’s fire brigade responded, they could not find the fire. . . .

As revealed by Exelon’s “Event Report,” offsite firefighters were called in, Unit 1 is still at full power, and Unit 2’s cool down “steam [is] leaving via atmospheric relief valves.”

An initial AP report on the incident stated: “The steam contains low levels of tritium, a radioactive form of hydrogen, but federal and plant officials insisted the levels were safe for workers and the public…[NRC] officials also said the release of tritium was expected. . . .

Because, you know, a scram without some steam is like a coffee with out some cream. Or, as noted in the past, these emergency shutdowns are not subtle, quiet events. They are like slamming the breaks on a speeding car, and they cause all kinds of stresses and strains on reactor systems. Even when backup power kicks in, the process can require the venting of steam to relieve pressure in various parts of the reactor (where depends on the type of reactor and the kind of “unusual event”)–and that steam will often contain tritium, which has molecules so small they can pass from the closed loop that runs through the reactor into the secondary loop (in the case of pressurized water reactors) that powers the turbines.

So, lots of places in the system with varying levels of tritium, which, as Beyond Nuclear points out, is in no way “safe”:

[T]he linear no threshold theory, endorsed by the U.S. National Academies of Science for decades, holds that any exposure to radioactivity, no matter how small, still carries a health risk, and such risks are cumulative over a lifetime. It would be more honest for NRC officials to states that the tritium releases from Byron are “acceptably risky,” in their judgment, but not “safe.” After all, tritium is a potent radionuclide, a clinically proven cause of cancer, mutations, and birth defects, and if inhaled, ingested, or absorbed through the skin, can integrate anywhere in the human body, right down to the DNA level.

And to add insult to the dishonestly undersold injury, the NRC says it can’t yet calculate just how much tritium escaped in this event.

But Wolf Creek and Byron were really just steamy warm ups (as it were) for January’s main event–the Grand-Guignol-meets-the-Keystone-Kops tragic-comedy commonly referred to as SONGS, or the San Onofre Nuclear Generating Station.

San Onofre sits on the California coast, about halfway between San Diego and Los Angeles, and has a long, infamous history of construction screw-ups, safety breaches, lax reporting, falsified records and unusual events. Unit 1 was brought online in 1968–and decommissioned 25 years later; Units 2 and 3 started up in the early ’80s, and are still operating today. . . .

Well, uh, about that. . . .

Officials at the San Onofre nuclear power plant shut down one of the facility’s two units Tuesday evening [January 31] after a sensor detected a possible leak in a steam generator tube.

The potential leak was detected about 4:30 p.m., and the unit was completely shut down about an hour later, Southern California Edison said.

The next day, SCE revealed that yes, indeed, it was a leak that caused them to scram Unit 3, and that they were dealing with it by “reducing pressure“. . . which other people might call “venting.” SONGS is also a PWR, and this leak was also in the loop that spins the turbines and not the one that runs through the reactor, but as noted above, that system still contains some radionuclides. Edison does admit to the release of some radiation, though they make the same “no threat/no harm” assertions common to the other unusual events.

Beyond the usual pushback on that “no harm” claim, it should also be noted here that the leak did no occur in the reactor’s sealed containment building, but in an auxiliary building. . . with doors. . . and people that go in and out through those doors. . . so the question is not whether some radiation escaped into the atmosphere, but “how much?”

But that’s not the scary part.

The leak occurred in Unit 3, and so that had to be shut down, but Unit 2 was already down–offline for two months of refueling and repair. However, the accident in Unit 3 prompted quite the revelation about Unit 2:

Unusual wear has been found on hundreds of tubes that carry radioactive water at Southern California’s San Onofre Unit 2 nuclear plant, raising questions about the integrity of equipment the company installed in a multimillion-dollar makeover in 2009.

. . . .

The problems at Unit 2 were discovered during inspections of a steam generator, after the plant 45 miles north of San Diego was taken off-line for maintenance and refueling. The two huge steam generators at Unit 2, each containing 9,700 tubes, were replaced in fall 2009, and a year later in its twin plant, Unit 3, as part of a $670 million overhaul.

According to the Nuclear Regulatory Commission, more than a third of the wall had been worn away in two tubes at Unit 2, which will require them to be plugged and taken out of service. At least 20 percent of the tube wall was worn away in 69 other tubes, and in more than 800, the thinning was at least 10 percent.

This level of wear might be typical to systems in use for several decades–still not comforting, considering the age of America’s nuclear plants–but to see this degradation in virtually new tubes gives one pause. . . especially one Joram Hopenfeld, retired NRC engineer and researcher:

“I’ve never heard of anything like that over so short a period of time,” Hopenfeld said.

“The safety implications could be very, very severe,” Hopenfeld added. “Usually the concern is in older steam generators, when they have cracks all over the place.”

According to the regulatory commission, the tubes have an important safety role because they represent one of the primary barriers with the radioactive side of the plant. If a tube breaks, there is the potential that radioactivity from the system that pumps water through the reactor could escape into the atmosphere.

About two-thirds of US reactors are of similar design to those at SONGS.

That’s the scary part.

It is scary, of course, because it raises questions about the manufacturing, the installation, and the maintenance of the $670 million rehab at San Onofre–but it also should raise concerns about the repairs, refurbishments and retrofits at dozens of other domestic facilities.

And it also provides another object lesson on the real costs of nuclear power. To put it in context, the San Onofre makeover cost $135 million more than the much-maligned federal loan guarantee extended in 2009 to the now-defunct solar panel manufacturer Solyndra Corporation. (And, unlike it could ever be for a nuclear loan guarantee, the federal government will recoup most of the Solyndra money when company assets are sold.)

Atomic energy advocates will argue that while construction costs are high, once built, nuclear plants run pretty much round-the-clock–24/7/365, as they say.

Except, of course, as the events just described or any of the dozens of other incidents documented here over the last year show, they don’t. Right now, SONGS is generating zero power. None. The same can be said for Wolf Creek, and one of the two reactors at Byron. The Palisades plant in Michigan was shut down five times last year. Ohio’s Davis-Besse facility, offline much of 2011 because of major repairs and a series of questions about cracks in the reactor building, was just given the green light to restart by the NRC, despite the objections of many nuclear watchdogs and US Rep. Dennis Kucinich (D-OH).

Reactors at North Anna, VA, Calvert Cliffs, MD, and Fort Calhoun, NE, were all offline for substantial amounts of time in 2011. A swarm of jellyfish took out Florida’s St. Lucie nuclear plant for several days last summer, and Crystal River, also in Florida, has not produced so much as a single kilowatt in almost two-and-a-half years. And it likely won’t produce any more until 2014 at the earliest, assuming Florida ratepayers pony up another $2.5 billion for repairs.

All of which again underscores that nuclear power is not just phenomenally expensive in every phase of its life, it is an expense always born by ratepayers and taxpayers. And that, of course, just refers to the financial costs.

Those tritium leaks will take some toll on the health of residents in regions near Byron and SONGS, though it will debated just how much. Less debatable now–thanks to a French study released, yes, in January–the everyday dangers of having a nuclear facility in your general area:

In a report certain to cause fear and loathing in the global nuclear industry, an eminent French research institute published a study in the International Journal of Cancer, which notes increased rates of leukemia in children living close to French nuclear power plants (NPPs.)

How much greater?

The study by the Institut National de la Sante et de la Recherche Medicale (French Institute of Health and Medical Research, or INSERM) found a leukemia rate twice as high among children under the age of 15 living within a 3.1-mile radius of France’s 19 nuclear power plants.

France, of course, has a universal health plan, so those costs will directly hit their national budget. The US does not embrace a similar level of responsibility for the health of its citizens, but the costs of increased numbers of childhood cancers will ripple through the economy all the same (well, in reality, even more then all the same).

Still feeling nuclear power’s worst year is behind it?

But, wait, there’s more–a sort of microcosmic calamity to put a grace note on nuclear’s macro-farce: A few days before the leak and the revelations about tube decay, an Edison employee at San Onofre fell into a fuel storage pool while trying to retrieve a dropped flashlight. The worker was not injured in the fall, though he did ingest some unspecified amount of radioactive water–but (and you know what’s coming here. . . wait for it. . . wait for it) SCE said the man “did not suffer harmful radiation exposure.”

Welcome to 2012. One mensis horribilis down, 11 to go.