The Future of Nuclear Power: Renewal or Re-run? David Lochbaum Director, Nuclear Safety Project February 25, 2008

Slide 2 Reactor design issues: Undetected design errors 21 st century threats New design problems New design solutions New reactor licensing Nuclear’s past (really passed or just paused?) Agenda (Not Hidden)

UCS’s recent report concluded that NRC’s regulations are generally adequate. The safety bar is okay – too many reactors too often are doing the limbo below it. Background: Nuclear Safety Limbo

NRC’s Double Standard Examples (very abridged list): PWR containment sumps (GSI-191), Thermo-Lag and Hemyc fire barriers, uncontrolled and unmonitored leaks of contaminated water

Old Reactor Designs, Bad Reactor Designs In May 1996, the NRC reported that the Millstone nuclear plant had long been operating outside of their design bases. Follow-up NRC inspections and efforts documented that Millstone was not alone.

Old Reactor Designs, Bad Reactor Designs The NRC documented that hundreds of design errors in “new plants” were not detected until after the reactors had operated for years and years. Why did the design reviews, pre-operational testing, and subsequent surveillance tests and inspections ALL fail to detect these hundreds of design errors?

Old Reactor Designs, Bad Reactor Designs How were they detected? Fewer than half were reported found due to intentional, active looking. Luck seems to play a big role.

Old Reactor Designs, Bad Reactor Designs Lest anyone think that the “design errors” merely involved green paint vice red paint, Licensee Event Reports (LERs) are submitted for issues above a safety significance threshold and accident sequence precursors are an even higher threshold.

Old Reactor Designs, Bad Reactor Designs

If new nuclear power reactors are built and operated in the US, the design review, pre-operational testing, and post- licensing surveillance testing and inspection processes must produce the following outcomes: 1)Significantly fewer design errors detected AFTER the reactors commence operation 2)Significantly shorter residence periods for undetected design errors. Fewer undetected design errors and shorter “hiding” times translate into safer, more economical nuclear energy.

21 st Century Threats, 18 th Century Defenses Following the 9/11 tragedy, the NRC undertook what it termed a “top to bottom” review of security for nuclear power reactors. Shortfalls identified by that review were addressed by Order and revised regulations. Curiously, a review triggered by terrorists using suicide aircraft attacks resulted in Orders and regulations which assume a zero percent chance of aircraft attack. Like Paul Revere and the Minute Men, nuclear power reactors only defend against attacks by land and by sea.

21 st Century Threats, 18 th Century Defenses

Nearly 25 years ago, the NRC chartered an industry panel to examine design changes that would make nuclear power reactors less vulnerable to sabotage. The panel identified many feasible design changes – none of which have been incorporated into “advanced” reactor designs like the AP-600, AP-1000, ABWR, etc. To the extent practical and feasible, nuclear power reactors built in the 21 st century must be designed against 21 st century, not 18 th century, threats.

New Reactor Designs, Bad Reactor Designs? AP-1000: To save money, vendor cut way back on concrete and steel. The result is a ratio of containment volume to thermal power below that of today’s PWRs, thereby increasing the risk of containment over-pressurization and failure in event of a severe accident. PBMR: To save even more money, vendor replaced containment structure with less-robust “confinement” structure that will protect the public from an accident unless there is an accident.

New Reactor Designs, Bad Reactor Designs? Generation IV: While the Gen IV reactor designs remain largely conceptual, these concepts rely on two shaky foundation supports – (1) need for uninvented, super- resistance materials, and (2) fuel reprocessing and fast breeder reactors.

New Reactor Designs, Good Reactor Designs? The EPR design appears to be the safest and most secure design among the new reactor designs.

New Reactor Designs, Good Reactor Designs? The EPR design is resistant to aircraft hazards.

New Reactor Designs, Good Reactor Designs? Even the spent fuel pool is resistant to aircraft hazards.

New Reactor Designs, Good Reactor Designs If another nuclear power reactor is built in the US, it must be protected from aircraft hazards to the maximum extent by design features and to the minimum extent by compensatory measures by workers (i.e., fire hose brigades).

New Reactor Licensing Slide 20 The “old” reactor licensing process featured two steps: 1)NRC issuance of a construction permit based upon review of preliminary design information 2)NRC issuance of an operating license based upon review of final design information The “new” reactor licensing process features a single step – NRC’s authorization to build and then operate the reactor.

New Reactor Licensing Slide 21 The “old” reactor licensing process featured information on a specific reactor design to be constructed at a specific site. The “new” reactor licensing process is bifurcated: The NRC certifies a new reactor design without any clue where that reactor might be constructed and operated. The NRC approves a site for a nuclear reactor without any clue of which specific design might be constructed.

New Reactor Licensing Slide 22 “One-step” reactor licensing is at best misleading and at worst an outright lie. By splitting the new reactor licensing process into two separate and distinct parts, the NRC essentially – and we believe intentionally – eliminated meaningful public participation. Who is going to intervene in the certification process for a reactor that may or may not be built in their backyard? Who can intervene in the site permitting process for an unspecified reactor? No one. By design.

Public Participation “No evidence has been found to support industry statements that citizen opposition and regulatory changes have been the primary causes for rising costs, and construction delays.” US House Committee on Government Operations

Nuclear Numbers Nuclear reactors ordered 253 Construction permits issued 175 Operating licenses issued 130 Operating licenses ended 26 Sources: NEI & NRC

Nuclear Numbers 45 of the reactors issued construction permits by the NRC (AEC) were not completed. At least not as nuclear reactors. The Midland and Zimmer plants were completed as fossil-fueled generators.

Walking a Nuclear Tightrope Slide 26 Full report and the 51 year-plus reactor outage case studies available at: Walking a Nuclear Tightrope: Unlearned Lessons from Year-plus Reactor Outages released by UCS on September 18, of the nuclear power reactors licensed by the NRC (AEC) experienced year-plus outages to restore safety levels – 10 reactors did it twice!

Industry Participation “To the contrary, FPC [Federal Power Corporation] statistics show that mismanagement is more of a determinant than regulatory changes and citizen opposition.” US House Committee on Government Operations Mismanagement was a problem during construction. Mismanagement was a problem during operation. Mismanagement will be a challenge during construction and operation of new reactors – time will tell whether that challenge will be successfully met.