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| Responsibility
for Safety |
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Safety
has always been a primary mandate of first the AEC then the NRC.
It has been their responsibility under the Atomic Energy Act of
1954 to establish rules and regulations for the purpose of protecting
the public from accidents involving nuclear power. At times this
duty has conflicted with the assignment to encourage the development
of the nuclear power industry, but at the same time the agency realized
that nothing could be worse for the industry than a major accident
with injuries or loss of life. A loss of coolant accident (LOCA)
with a meltdown and breach of containment has always been a primary
fear, particularly as the size of plants increased. The consensus
of expert opinion was that such an accident was unlikely but the
consequences of one were grave enough to warrant defense in depth
to prevent it. As the size of plants increased so did the consequences
of a potential LOCA. Concern was raised regarding the probability
of a containment maintaining it integrity in the event of a severe
accident. Academic theories of the probabilities and scenarios were
replaced with facts and methods for dealing with actual events in
March 1979 when the accident occurred at TMI 2. Events at TMI did
not follow any of the theoretical models previously developed. Afterward
it was necessary to reexamine a number of assumptions about the
mechanism and results of various accident scenarios. The melting
of over half the fuel in the reactor had not resulted in any breach
of the containment, in fact the fuel had remained in the reactor
vessel. The LOCA had not come about in the way most expected, the
break of a large pipe, but through the failure of a pressure relief
valve to close.
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Defining
Realistic and Attainable Goals |
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The
NRC reexamined many of its regulations in light of the TMI experience,
this included a requirement for licensees to prepare plans for beyond
design basis accidents mitigation or prevention. Accidents of this
sort, so called Class 9 Accidents, were believed to be so improbable
as to be incredible prior to TMI 2. Notice was given of the proposed
change in October of 1980. Over the course of the next two years
the NRC staff backed away from the majority of their previous proposals,
perhaps as a response to industry concerns regarding the potential
costs of retrofitting plants and complying with additional license
requirements. Staff presented a proposal for a policy statement
to the Commission in January 1982 that would require only compliance
with an interim rule on hydrogen control by existing plants and
those with construction permits. This plan was based on the results
of probabilistic risk assessments (PRA) which indicated that risk
estimates for severe accidents in existing plants had been overstated.
Commissioners were wary of placing too much credence in PRAs which
they were not certain were reliable but approved of making a policy
statement rather than a rulemaking. Staff made certain revisions
and returned in July with a proposal that put less emphasis on PRAs
but retained the basic premise that existing plants were safe the
way they were or with a few minor changes. This proposal was opposed
by the Advisory Committee on Reactor Safeguards (ACRS) who felt
that it was not a realistic appraisal of the current state of safety
at nuclear plants. The Commission split on the issue but approved
publishing it for comment.
Industry
not unexpectedly was of the opinion that current plants were far
safer and more resilient than previously believed and produced a
number of studies that they felt supported this position. Meanwhile
further Loss of Fluid Tests were conducted at INEEL which tended
to support the optimistic studies produced by industry. It was demonstrated
that under extremely rigorous situations the ECCS still performed
well in a scale model reactor. Another issue that required resolution
was source term. This referred to the amount of radiation released
in an accident, the source was the damaged reactor and the term
the quantity of radiation released from it. Industry maintained
that prior estimates of source terms had been greatly overstated,
and that even the most severe accident envisioned would cause no
radiation deaths and that existing regulations overestimated cancer
deaths 100 times. They claimed that containment failure was practically
impossible. These conclusions were supported by the Special Committee
on Source Terms of the American Nuclear Society and were borne out
by the TMI experience. NRC sponsored a study on the issue by the
American Physical Society which argued for a more conservative view
until further research could be done.
An
additional source of controversy was how likely an accident was
to occur. There existed a wide range of opinion concerning the potential
frequency of accidents, despite this NRC voted to approve the policy
statement on June 27, 1985. In it they asserted that "on the basis
of currently available information the Commission concludes that
existing plants pose no undue risk to public safety and property
and sees no present basis for immediate action on generic rulemaking".
In response to ACRS prodding the NRC agreed to examine individual
plants for potential site specific circumstances that might affect
the overall safety of the plant. The staff presented a plan to close
out the safety issues in May 1988. In the proposed plan there would
be development of recommendations for improving containments, examination
of methods to limit human error as a factor, and individual plant
examinations (IPEs) to determine site specific risk factors among
other issues. The Commission approved a letter to licensees requesting
the IPEs in October 1988. Staff finished work on the containment
recommendations in January 1989 for the Mark I containment design
used by GE and completed the other five by November 1991. A series
of improvements were outlined for the Mark I, there were no improvements
indicated for the remaining designs. Controversy over source terms
continued as did research. In 1995 the NRC published an updated
document on source terms bringing the closure of the severe accident
question somewhat closer. To this point there remain outstanding
issues to be resolved.
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Planning
for Emergencies |
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Prior
to TMI 2 little attention was paid to emergency planning. In December
1970 the AEC issued a rule, Appendix E of 10 CFR Part 50, providing
guidelines to licensees on what their emergency plans should address.
In 1973 the AEC was designated lead agency for radiological emergency
planning by the Federal Office of Emergency Preparedness. The AEC
provided the states and localities with additional guidance on creating
emergency plans for design basis accidents at nuclear installations.
This guidance included a checklist of 154 items to be included in
an effective plan. In 1977 the NRC pointed out 70 of these items
it considered essential including information about drills and training.
Responses from state and local governments made it clear that there
remained a good deal of confusion on the part of their emergency
management agencies as to what sort of accidents they should be
planning for. NRC and EPA joined together to provide additional
guidance and instruction. This was released in December 1978 in
the form of a 120 page report. It introduced concepts that had not
been previously included such as plume exposure pathways and ingestion
pathways, and advised that Class 9 accidents also be considered.
A Government
Accounting Office report released not long after concluded that
licensees appeared to be prepared but that governmental agencies
were much less so. Only 12 states had plans that met the NRCs guidelines
and it was recommended in the GAOs report that the NRC issue licenses
only in states who had acceptable emergency plans and that measures
be instituted to better inform the public in the event of an emergency.
Ironically, the report was issued on March 29, 1979 during the accident
at TMI 2. The colossal muddle of misinformation and disarray that
occurred during the accident brought about calls from all sides
for improvement. in the aftermath, a number of changes were made
to attempt to meet the demands imposed on NRC by Congressional Oversight
Committees.
Legislation
to make licensing of new plants contingent upon the existence of
adequate emergency plans was defeated by those who feared that this
approach would in effect give states veto power over proposed nuclear
plants or possibly allow them to force the closure of existing plants.
An NRC task force was formed to examine the issues surrounding emergency
planning and produce recommendations, which were presented in August
of 1979. A number of these concerned internal NRC policies and programs
which could be immediately implemented, but two issues were deemed
to require rulemaking. The Commission requested staff to investigate
the emergency planning zones recommended in the joint NRC/EPA proposal
and the issue of licensing being contingent upon approved plans.
Staff expedited the inquiry and concurred with the Joint plan on
zones which had been well received by the states. The issue of contingency
was more difficult to resolve. NRC did not have authority to force
recalcitrant states to participate in the planning process and Congress
refused to extend it the ability to do so which it felt would be
an infringement on states rights.
This
left the NRC without a viable option and it therefore published
a final rule in August 1980 granting existing plants a grace period,
to expire April 1, 1981, to prepare an emergency plan in concert
with the state which would meet guidelines to be established by
the NRC in cooperation with the newly formed Federal Emergency Management
Agency (FEMA). FEMA would be responsible for determining the adequacy
of emergency plans for the areas surrounding the site while NRC
would do the same for the plant site itself. Under this agreement
the NRC would retain the prerogative to determine if each plan was
adequate overall and either issue or refuse to issue permission
allowing operation to continue. Indian Point Units 1 and 2, operated
by Consolidated Edison produced controversy when the emergency plan
was twice rejected by FEMA as inadequate in 1981 and 1982. The finding
of deficiency was largely due to the refusal of Rockland County
to participate. Eventually, the State of New York stepped in on
behalf of the County and the resulting plan was approved in a split
decision by the Commission. A review of the ruling on emergency
planning was undertaken after the divisive battle over Indian Point
and was still in process when similar acrimony arose over the Shoreham
and Seabrook Plants.
The
Shoreham Plant was to be located on Long Island and was vigorously
opposed by local residents particularly after the accident at Chernobyl
in April of 1986. Local government maintained that an effective
emergency plan for the site was not possible and insisted that the
location was untenable. New York State refused to intercede as it
had at Indian Point despite the protests of Long Island Lighting
Company. Seabrook was located in New Hampshire which had cooperated
in emergency planning with Public Service of New Hampshire and FEMA
to produce an emergency plan for the proposed plant. After Chernobyl,
Massachusetts refused to cooperate in the plan and since areas of
the 10 mile zone extended into Massachusetts the plants approval
was threatened unless the NRC was willing to accept a reduced zone
of 2 miles.
The
re examination of the NRCs ruling on emergency plans had meanwhile
reached the conclusion that a rule change was necessary and in February
1987 the staff and Office of General Counsel proposed specific revisions
to the existing rule. These would allow the issuance of a license
in cases where the utility had made a good faith effort to obtain
State or County participation and had developed an emergency plan
for the site that was deemed achievable by NRC and which would likely
garner government cooperation in the event of an actual emergency.
This policy was termed the realism doctrine and erupted into a massive
furor pitting a number of Governors, Senators, and Representatives
opposed to abrogating local control over power. The Commission voted
unanimously to implement the rule with minor changes. In September
1988 the US Court of Appeals upheld the decision. In April 1989
the NRC granted an operating license to the Shoreham Plant, but
under an agreement with the State, Long Island Lighting decided
not to operate the plant. Seabrook received an operating license
in March 1990 despite profound and dedicated opposition by local
citizens and the State of Massachusetts.
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The
Safety Record in Perspective |
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In
a sense safety is like beauty, in the eye of the beholder. It is
possible to look at the record of the nuclear energy industry and
draw a variety of conclusions from what you find there. The industry
looks at the record and sees that no member of the public has ever
been killed or directly injured by their activities, for this they
pat themselves on the back. This of course discounts studies that
attempt to link radiation exposure in small amounts to damage or
injury later in life. It is difficult to prove a causal relationship
between a small exposure and a cancer that does not appear for twenty
years. On the other hand, it is possible to look at the record and
come to the conclusion that nuclear energy poses a serious risk
to those who live near or work at the plants. This latter opinion
leaves aside fact that there is more than a kernel of truth to the
industries claims for safety. The worst accident in US history in
fact did not kill anyone, and no radiation escaped the plant. Industrial
processes of all kinds have accidents, history is full of fertilizer
explosions, grain elevator blow ups, coal mine fires and the like,
no one calls for no more fertilizer plants or grain elevators. In
the end you must determine if you expect the nuclear industry to
be different than any other, they are not, and whether you expect
the operators of nuclear facilities to be more like physicists or
boiler operators.
Perhaps
the initial expectations of the public, built upon the promises
of the salesmen from government and industry who brought us nuclear
power, were too high. Is perfection attainable? Even if it isn't,
is it not worth trying to achieve? Have we been saved from worse
accidents by skill...or luck? The following six accounts comprise
the record of reactor accidents for both the commercial and governmental
operators of nuclear facilities, in the US and abroad. Several are
very widely known, having been much in the news when they occurred,
others less so. Only two of these accidents took place in plants
of the type used for power production in the United States; of the
others, one was an experimental reactor, one a plutonium production
pile, and one a duel purpose plant of a style only used in the former
Soviet Union. The implications that can be drawn as far as the general
safety of nuclear power are necessarily somewhat limited.
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