NRC rapidly rubber-stamping regulatory exemptions for industry under excuse of Covid-19 response

As exemplified by a letter dated March 28, 2020 (ironically enough, the 41st anniversary of the 3/28/1979 meltdown at TMI-2), regarding weakening worker fatigue rules at nuclear power plants, the U.S. Nuclear Regulatory Commission (NRC) is quickly approving numerous forms of exemptions and waivers from nuclear safety regulations, with the supposed excuse that the Covid-19 national pandemic emergency requires it.

As shown in NRC's letter to the Nuclear Energy Institute's (NEI) Dr. Jennifer Uhle* (who used to work as a senior technical staffer at NRC's Office of Regulatory Research), depending on the job involving safety-significant systems, structures, and components (SSCs) at nuclear power plants, workers will now be allowed to work 12-hour shifts, and in some cases even 16-hour shifts, per day. 86-hour work weeks are also poised to be approved.

A conference call between NRC staff and nuclear industry representatives took place on Thursday, April 2nd, one in a series of Covid-19-related regulatory relief discussions since March 20th, in which it was clear that industry is getting everything it is asking for, and then some. NRC justifies its approvals with false assurances that no compromise on safety will be allowed.

How inspections, repairs, and replacements of safety-significant SSCs can go undone, and not impact safety, has not been adequately explained by NRC.

Similar impacts on nuclear power plant security are also likely under NRC consideration at industry request at this time as well. However, NRC and industry have hidden behind a veil of secrecy regarding most to all nuclear power plant security-related subject matter, ever since the 9/11 attacks. Such secrecy could easily conceal regulatory weakening on security requirements as a supposed response to the Covid-19 pandemic.

Truck drivers on U.S. interstates are limited to 10-hour driving shifts, after which they must rest for at least 8 hours before resuming driving. This is to prevent sleep deprived, overstressed drivers causing wrecks on the highways that could kill a number of people, and depending on what's being hauled, cause a hazardous release to the environment.

But as revealed by the CRAC-II report (Calculation of Reactor Accident Consequences, also known as the Sandia Siting Study, or NUREG/CR-2239), peak early deaths (acute radiation poisoning fatalities) downwind and downstream of a reactor core meltdown could be as high as 100,000 (as at Salem Unit 1 or Unit 2 in NJ very near Wilmington, DE). Peak early (radiation) injuries could be as high as 610,000 (as at Limerick Unit 1 or 2 in Montgomery County, PA). And property damages could be as astronomical as $314 billion in 1982 dollar figures (as at Indian Point Unit 3 near New York City). See the CRAC-II figures, compiled here.**

When adjusted for inflation alone, not accounting for economic and real estate development downwind and downstream since 1982, that latter property value figure surmounts $841 billion in year 2019 dollar figures.

Reports by Ed Lyman of UCS regarding the terrorism risks at Indian Point (his 2004 "Chernobyl on the Hudson?"), as well as the 2016 report by Princeton researchers von Hippel and Schoeppner about irradiated nuclear fuel storage pool fire risks, shows that property damages into the trillions of dollars are possible, depending on which reactor(s) are involved where, and which way the wind happens to be blowing, where rainouts occur, etc.

How NRC can say safety risks won't increase as quality of work decreases, mistakes get made, as a shrinking nuclear workforce is pressured to work longer and longer hours, has not been adequately addressed.

The spread of Coronavirus to nuclear power plants like Fermi 2 in Monroe County, Michigan, currently undergoing a large-scale refueling outage, just adds to the stress levels.

NRC has refused to learn lessons, as from the Fukushima nuclear catastrophe in Japan, but also from the aftermath of 9/11. As documented by Project On Government Oversight on 9/11/2002, in a report entitled "Voices from Inside the Fences," the nuclear power industry worked its security guard forces to the breaking point in the year after the 9/11 attacks -- 72-hour work weeks were the new normal. But this took a physical, emotional, even psychological toll. One security guard at Palisades nuclear power plant in Michigan suffered a nervous breakdown on the job, while heavily armed. Luckily, neither she nor anyone else was harmed in the incident. Numerous frightening incidents were reported, due to overworked security guards reaching their breaking point.

Why did the nuclear power industry do this? To avoid having to hire additional security guards, who would have to be trained, as well as paid benefits. The industry found it more "cost effective" (profits boosting) to pay its already extant guard forces overtimes, and work them to the breaking point.

Similar dynamics are afoot now. Industry is pulling regulatory relief requests off the shelf, dusting them off, and presenting them to NRC as needed in light of the Covid-19 pandemic. NRC is only too happy to oblige.

As the Japanese Parliament concluded in its 2012 root cause investigation of the Fukushima nuclear catastrophe, it was not the earthquake and tsunami that caused the triple meltdown and very narrowly averted high-level radioactive waste pool fire. What left those three reactors so vulnerable to a natural disaster in the first place?, the parliamentary investigators asked. It was collusion, they concluded. The collusion between the nuclear power industry (Tokyo Electric Power Company), its so-called supposed "regulator," and elected officials.

But we have such collusion in spades in the U.S., between the nuclear power utilities, the NRC, and elected officials at all levels of government.

Given the increasing risks, and regarding that latter category -- elected officials -- please take action. Contact both your U.S. Senators, and your U.S. Representative. Urge them to exercise congressional oversight on the NRC and the nuclear power industry, in order to protect the health, safety, and environment of their constituents, including you. Urge your Congress Members to hold NRC's feet to the fire, and now allow the nuclear lobby to win yet more "regulatory relief" (regulatory retreat, regulatory weakening) for an industry that is already way too out of control.

*Jennifer Uhle was deployed to Palisades, MI to try to call public concern re: pressurized thermal shock/embrittled reactor pressure vessel risks. It didn't work.

She also presented to the NRC Commissioners several years ago, re: QHOs. QHO are Qualitative Health Objectives. In a sense, QHOs are a "bag limit" for how many humans atomic reactors are allowed to kill. There are two categories of QHOs for reactors. The first is in terms of routine radiation releases during normal operations. The QHO allows for a 1/10th of 1% increase in the number of fatal cancers downwind and downstream, as occur in the U.S. annually anyway, from all causes. 1/10th of 1% of such a large number, is itself a significant number.

The second category of QHO is in regards to reactor accidents and large-scale releases of hazardous radioactivity. Again, the QHO allows for a 1/10th of 1% increase in the number of nuclear accident deaths downwind and downstream, as occur in the U.S. annually anyway, from accidents from all causes. 1/10th of 1% of such a large number, is itself a significant number, especially if such things as car wrecks and opiod overdose deaths are included as "accidental deaths," which they very well could be.

QHOs are kept very quiet, which is what made Jennifer Uhle's presentation to the NRC Commissioners about them so remarkable, as brief and in passing as it was.

**NRC first tried to conceal the CRAC-II results. But Ed Markey, then a Democratic US Rep. from MA (now a US Senator) forced NRC to reveal the figures in congressional hearings. But NRC has long disavowed the figures. And several years ago, NRC attempted to do away with CRAC-II, by replacing it with SOARCA (an odd acronym, short for State of the Art Reactor Consequence Analysis.). SOARCA essentially concluded there would be no casualties, and no property damage, and there would likely be no meltdowns, and even if there was one, containment would hold.

Fukushima would seem to have debunked that NRC fantasy.

In June 2011, AP reporter Jeff Donn reported that "Populations around US nuke plants have soared" since 1982. That is, CRAC-II's casualty estimates would likely be much worse now, as more concentrated populations around US reactors mean more people would be killed and injured. (Was the word choice "soared" a poke at the absurd SOARCA acronym?!)