Dr. Gordon Thompson's "devastating critique" of NRC's HLRW storage pool fire risk whitewash

Dr. Gordon Thompson, executive director of the Institute for Resource and Security Studies in Cambridge, MA

Dr. Gordon Thompson at IRSS is based in Cambridge, MA, just outside Boston. Not far to the south is Entergy Nuclear's Pilgrim atomic reactor, a GE BWR Mark I, identical in design to Fukushima Daiichi Units 1-4. Since 1972, more than 600 tons of irradiated nuclear fuel have piled up in Pilgrim's storage pool. Beyond Nuclear has prepared a backgrounder on the catastrophic risks.

Yesterday, to meet the U.S. Nuclear Regulatory Commission's (NRC) arbitrarily short 30-day deadline for public comments on its "Draft Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a US Mark I Boiling Water Reactor" (NRC-2013-013), attorney Diane Curran and expert witness Dr. Gordon Thompson filed a blistering response on behalf of an environmental coalition of 26 groups, including Beyond Nuclear.

In her cover letter to NRC, Curran wrote: "...the Draft Consequence Study is not a credible scientific document. While the study purports to be a broad scientific inquiry into pool fire phenomena, in fact it is a very narrow study that ignores basic pool fire phenomena and important pool fire accident contributors. It misleadingly implies that a severe earthquake causing complete draining of a fuel pool is the primary source of risk to a spent fuel pool, and assumes that open-rack low-density pool storage is not advantageous without even examining it. In short, the Consequence Study appears designed to advance the authors’ pre-determined and unsupported conclusion that high-density pool storage is safe."

Thompson makes clear that a partial drain down of a high-level radioactive waste (HLRW) storage pool is an even worse-case scenario than a complete drain down, for air cooling provided by convection currents -- which might otherwise prevent ignition of the irradiated nuclear fuel's combustible zirconium cladding -- is blocked by the layer of water in the bottom of the pool. Thompson points out that any technically-competent analyst who has been paying attention to pool-fire risks since 1979 would have known that, and charges NRC with being deliberately misleading. He also points out the potentially catastrophic consequences of pool fires -- over 4 million people could be displaced, long-term, from their homes, as even NRC acknowledges.

Curran concluded: "We are appalled that after decades of avoiding and obfuscating this urgent safety issue, the NRC now proposes to rely on this biased and unscientific document to justify continued high-density
pool storage of spent fuel, both in its post-Fukushima safety review and in the Draft Waste Confidence Environmental Impact Statement. We join Dr. Thompson in urging you to withdraw the Draft Consequence Study and begin anew with a study of spent fuel pool fire risks that finally complies with basic principles of sound scientific inquiry."

Curran represented a coalition of environmental groups which, along with a coalition of state attorneys general, prevailed against NRC's Nuclear Waste Confidence at the second highest court in the land. The U.S. Appeals Court for the District of Columbia Circuit ruled that NRC must complete an environmental impact statement on the risks of on-site storage of HLRW at reactors, including in pools. NRC did not appeal the ruling, and quickly acknowledged that the completion of the EIS would prevent finalization of proposed new reactor license approvals, as well as old reactor license extension approvals, for at least two years (NRC had previously admitted that a Nuclear Waste Confidence EIS would take seven years to complete!).

Robert Alvarez, senior scholar at the Institute for Policy Studies, has heralded Dr. Thompson's work as a "devastating critique." Alvarez adds, "Gordon's comments systematically reveal the kinds of scientific malpractice the NRC is resorting to at a time when one of the nation's largest and oldest high-hazard enterprises faces a deepening economic crisis."

Alvarez, formerly a senior advisor to the Energy Secretary during the Clintion administration, knows what he's talking about. Along with Dr. Thompson, now-NRC Chairwoman, Ph.D. geologist Allison Macfarlane, and five more experts, Alvarez published "Reducing the Hazards from Stored Spent Power-Reactor Fuel in the United States," in Jan., 2003. This groundbreaking warning about the potentially catastrophic risks of HLRW pool fires was largely affirmed by a congressionally-ordered National Academy of Science study in 2005; NRC unsuccessfully attempted to block the security-redacted public release of NAS's findings. Alvarez also published a May 2011 report on the hazards of high-density pool storage across the U.S., in the aftermath of the Fukushima nuclear catastrophe. And in June, in a report commissioned by Friends of the Earth, Alvarez focused on the risks of HLRW pool storage at the now permanently shutdown San Onofre nuclear power plant.

Entergy Nuclear announces 800 job cuts nationwide

In an article entitled "Vermont Yankee to cut about 30 jobs: Critics argue loss of work force could pose operation hazards," the Burlington Free Press reports that nationwide, Entergy will slash 800 jobs across its fleet of a "dirty dozen" atomic reactors (see map, left).

Vermont Yankee (VY) is an identical design to Fukushima Daiichi Units 1 to 4, namely, General Electric (GE) Mark I boiling water reactors (BWRs).

Of those 12 reactors in Entergy's fleet, 7 already have received U.S. Nuclear Regulatory Commission (NRC) rubberstamps for risky 20-year license extensions: Arkansas Nuclear One, Units 1 & 2; Palisades, MI; FitzPatrick, NY; Cooper, NE; Vermont Yankee; and Pilgrim, MA.

In addition to VY, Entergy's FitzPatrick, Cooper, and Pilgrim reactors are also GE BWR Mark Is.

The rest of Entergy's fleet either has applied for license extensions, or plans to do so. Indian Point Units 2 & 3 in NY, as well as its Grand Gulf reactor in MS, have already applied for 20-year license extensions. Waterford and River Bend, in Entergy's home state of Louisiana, plan to apply for 20-year license extensions in 2015 and 2016, respectively.

In addition, NRC has also rubberstamped risky power uprates at the following Entergy reactors: FitzPatrick (a Mark I); River Bend (twice, for a total 6.7% uprate); Waterford (twice, for a total 9.5% uprate); Arkansas Nuclear One, Unit 2 (7.5% uprate); Grand Gulf (twice, for a total 14.8% uprate); Indian Point 3; Pilgrim (a Mark I); Indian Point 2 (twice, for a total uprate of 4.66%); Palisades; Vermont Yankee (a Mark I, with whopping 20% uprate, all in one fell swoop); and Cooper (a Mark I).

The article quotes Arnie Gundersen, Chief Engineer at Fairewinds Associates, as to the safety risks associated with such workforce reductions:

' “Thirty is a big deal,” said Vermont Yankee critic Arnie Gundersen, a former nuclear engineer who lives in Burlington. “It’s like a car. As a car gets older it needs more repair, not less and here they are cutting mechanics.”

Gundersen, who served on a 2008 state oversight panel that looked at Vermont Yankee’s operations, said he thought that cutting 30 jobs would have to affect the safe operation of the plant. He noted that the panel concluded that Vermont Yankee was understaffed at that time after increasing output by 20 percent without adding staff.'

FoxBusiness has reported that Entergy Nuclear CEO, Leo Denault, has admitted to investors that "all options are on the table" regarding its non-utility, "merchant" reactors, such as Palisades in MI and its fleet in the Northeast (including Mark Is at Vermont Yankee, Pilgrim, and FitzPatrick), in deregulated, competitive electricity marketplaces. Last February, Denault admitted in a Reuters interview that needed safety repairs were a major financial challenge for Entergy's age-degraded reactor fleet.

Update on July 31, 2013 by admin

Arnie Gundersen, Chief Engineer, Fairewinds Associates, Inc.Vermont Public Radio also reported on this story, quoting Arnie Gundersen (photo, left), Chief Engineer of Fairewinds Associates, Inc., who disagreed with Entergy's conclusion that the workforce reductions would have no impact on the safety risks of operations:

But Arnie Gundersen, a nuclear engineer and Yankee critic, said the reductions will put more pressure on a workforce that is already under stress.

“These cuts are going to cut muscle, there is no doubt in my mind,” he said.

Gundersen chaired a state oversight panel that looked at issues confronting the plant. He said that a decade ago Yankee boosted its power production by 20 percent without adding additional workers. He said the oversight panel concluded five years ago that the plant was under-staffed.

“So I think it’s only gotten worse. The same number of people are carrying the same amount of work, and now there’s going to be 30 less of them,” he said. “At some point, somebody is going to break and miss something. And when you miss something at a nuclear plant that can be a real problem.”

Gundersen said Entergy may choose to close the plant rather than invest about $70 million over the next few years to replace aging equipment and to comply with modifications required as a result of the Fukushima nuclear accident.

Vermont Yankee is a GE BWR Mark I, identical in design and vintage to Fukushima Daiichi.

The Kalamazoo Gazette has reported that about 30 job losses will occur at Palisades in Michigan as well, about 4% of the workforce there. Further reductions than even that are expected in the operations and engineering departments. Gundersen has previously expressed concern about safety risks at Palisades, as well, as in this Fairewinds Energy Education podcast interview with Beyond Nuclear's Kevin Kamps.

Vermont Yankee owner: ‘Expect workforce reductions’

Entergy Nuclear's Vermont Yankee atomic reactor is a GE BWR Mark I, identical in design to Fukushima Daiichi Units 1-4.

As reported by Andrew Stein at the Vermont Digger, Entergy Nuclear is forcing its Vermont Yankee workforce of 650 to essentially re-apply for their own jobs, with indications to up to 10% could be let go as a cost-saving measure.

VY was just named by nuclear economist Mark Cooper as one of the dozen atomic reactors in the U.S. most at risk of "early retirement." Earlier this year, the Swiss financial analysis firm UBS even warned that VY's permanent shutdown could yet occur in 2013. On Feb. 8th, Entergy's brand new CEO, Leo Denault, admitted in a Reuters interview that major needed safety repairs were contributing to the company's financial challenges across its fleet of 12 atomic reactors. 

Raymond Shadis, New England Coalition's Technical Advisor, had this comment regarding the news of VY's workforce reduction: "Asking fewer people to do more work will inevitably impact both reliability and safety. Vermont Yankee is already hurting because revenue from electricity sales barely meet O&M. It is clear that Entergy is desperately seeking a way to make its older, smaller nuclear plants pay but devoting fewer resources to inspection and maintenance is exactly what brought down and ultimately closed VY's sister plants -- Connecticut Yankee and Maine Yankee. Workforce reduction, by-the-way, is not something Entergy brought to the attention of the Vermont Public Service Board in recent hearings on a company proposal to extend operation of Vermont Yankee another twenty years. Really the right, graceful thing to do, would be to shutdown now before they break something and ruin both a lot of people's lives and the tri-state area environment."

Update on July 22, 2013 by admin

The Rutland Herald/Barre Montpelier Times Argus, as well as the Associated Press, have reported that Entergy's impending workforce reductions are not confined to Vermont Yankee, but could well take place nationwide, at Entergy's entire dozen-reactor fleet. The Kalamazoo Gazette has reported on expected layoffs at Entergy's problem-plagued Palisades atomic reactor in southwest Michigan. Entergy's other Mark Is include: Cooper in NE; FitzPatrick in Upstate NY; and Pilgrim near Boston.

New report documents reactors most at risk of "early retirement"

Mark Cooper, Vermont Law SchoolIn a new report, Renaissance in Reverse: Competition Pushes Aging U.S. Nuclear Reactors to the Brink of Economic Abandonment, Vermont Law School energy economist Mark Cooper (photo, left) of Vermont Law School has identified 11 economic, operational, and safety factors contributing to the likelihood that reactors at 38 nuclear power plants in the U.S. could join Crystal River, FL, Kewaunee, WI, and San Onofre, CA in permanently shutting down sooner rather than later. As listed in a press release, Cooper identifies a dozen reactors most at risk of permanent shutdown in the near-term, including half of Entergy's own fleet of a dirty dozen atomic reactors nationwide. Several of the reactors identified as most at risk of sudden closure are identical or similar in design to Fukushima Daiichi (General Electric Mark I and II boiling water reactors): FitzPatrick, NY; Nine Mile Point Unit 2, NY; Oyster Creek, NJ; Pilgrim, MA; Vermont Yankee, VT. The audio recording of yesterday's press conference, which also featured former NRC Commissioner Peter Bradford, has been posted online.

VT PSB rules it can and will hear issues surrounding Entergy VY's impacts on Connecticut River

NRC file photo of VY on the Connecticut River border of VT and NH, 8 miles north of the MA state line

Entergy Nuclear's Vermont Yankee atomic reactor is a GE BWR Mark I, identical in design to Fukushima Daiichi's Units 1-4.

As reported by John Dillon at Vermont Public Radio, the State of Vermont has yet again asserted its right and authority to oversee operations at Entergy's controversial Vermont Yankee (VY) atomic reactor in Vernon near Brattleboro. VY is a Fukushima Daiichi twin design -- a General Electric Mark I Boiling Water Reactor.

This time, the State of Vermont Public Service Board (PSB) has ruled it does have the authority to hear issues involving VY's impacts, such as thermal hot water releases, on the Connecticut River. The PSB is currently holding hearings on whether or not to grant Entergy a renewed Certificate of Public Good (CPG), needed in order to conduct business in the State of Vermont. VY is operating under an expired CPG, which expired on March 22, 2012 -- the first day of VY's U.S. Nuclear Regulatory Commission (NRC) rubber-stamped 20-year license extension. VY is also operating with an expired surface water discharge permit, which expired in 2006. The PSB has ruled that Entergy cannot rely on that expired discharge permit as supposed proof that its impacts on the Connecticut are acceptable.