The NRC and the Write-in Campaign

17 thoughts on “The NRC and the Write-in Campaign”

1. have been writing comments for decades. Several of my comments refer to EMP and sunspots producing waves of particles that can take down any or all electronic devices with an antenna.

2. The NRC has initiated a Task Force Review of NRC Processes and Regulations Following Events in Japan. The task force has already made two presentations to the Commission and its final report will be presented (and made public) later this month. This task force will be followed by a longer-term review. Information on the status on the review so far is here: http://www.nrc.gov/japan/japan-meeting-briefing.html . We’ll also have more information here and on our website about how to view the upcoming Commission briefing by the task force.

3. > So, while we thank everyone who sent a CitizenLetter, all the available information continues to show that U.S. nuclear power plants are designed and operated so they will protect the public and the environment, even after severe natural events.

   IOW: you did not find even one small lesson in the whole Fukushima accident. Everything in squeaky-clean? All US emergency diesel generators are flood protected? Every single plant has emergency battery-backed lighting? Every single worker knows what to do if total blackout hits hit station? The dams around every plant have large margins, no frantic sandbagging efforts needed (cough… Calhoun… cough)? Every single plant has mobile power generators and pumping cars on standby? NRC has helicopters on standby with mobile power generators and pumps, ready to save a plant in case impossible happens and it *does* lose all means to cool the core?

   Forgive me, but I would feel much more reassured if you *did* find a few “lessons learned” from Fukushima, and announced concrete actions you plan to implement.

4. This campaign should be supported by those in favor of it. IF this will help every citizen, surely there a lot of supporters for this.

5. Anonymous,
   The moderator said approximately 6500 hours per each plant, NOT 6500 hours for all 104 plants. There at least 2 full time resident inspectors at each site plus specialized regional inspections.

6. I have been writing comments for decades. Several of my comments refer to EMP and sunspots producing waves of particles that can take down any or all electronic devices with an antenna.

7. The Foundation for Resilient Societies, petitioner for PRM-50-96, appreciates that the NRC has invited members of the public to comment on this Petition for Rulemaking. PRM-50-96 would provide protection for spent fuel pools under conditions of long-term loss of outside power. We, too, would appreciate comments from nuclear licensees and other members of the public.

   The current comment period for PRM-50-96 is scheduled to end on July 20, only one day after the scheduled July 19 NRC meeting and briefing on the Task Force Review of NRC processes and regulations following events in Japan. Many of the topics in PRM-50-96, including simultaneous diesel generator failure and Loss of Outside Power (LOOP), are similar to those being addressed by the Task Force. An extended comment period would give stakeholders time to consider findings from the Task Force Review in their comments.

   An activist group has informed us that a large number of comments have been submitted to the NRC on PRM-50-96. These comments have not yet been placed on the regulation.gov website. An extended comment period would allow stakeholders to see submitted comments before formulating their own comments.

   We have requested that the NRC extend the comment period for PRM-50-96 an extra 30 days, until August 19, 2011. If you believe that this would be in the public interest, please write Rulemaking.Comments@nrc.gov.

8. I agree that a situation of beginning to build a newer generation of plants starting 10-15 years ago would have been highly preferable to the present situation where a newer generation won’t be started until late this year at the earliest and possibly later than that (especially if an additional 75 day comment period is added for the AP1000 certification process).

   Sadly, the economics of building these newer plants haven’t been attractive enough and electricity demand has not been increasing fast enough to encourage a great deal of nuclear investment. A large component of the economics of new nuclear plants is due to uncertainty, which stems in part from the current licensing processes. Uncertainty is risk, and risk prices up the cost of borrowing.

9. (In response to Mr. Burnell from June 22, 2011 at 9:55 am)
   Mr. Burnell,
   You’re not giving me much to work with here, but you’ve given me enough to make my point.

   Thank you for posting the link to that petition. I was aware of it and I’ve read the whole thing. I hope everyone both pro and anti-nuclear will post a positive comment on it. It is not anti-nuclear it just seeks to close a gaping hole in nuclear safety, it does not seek to close any plants. The reader should note that the NRC has NO WHERE DISPUTED THE CLAIMS I MADE IN MY FIRST POST, reading between the lines this should tell you something.

   I did not bring up this petition because it was not the point of my post. In the original blog post, I felt that you came down a little hard on the use of preformatted letters. I can certainly sympathize, it seems letter writing is a lost art, I can see where it would be kind of annoying getting thousands of letters saying the same thing. That being said, almost every one of the letters you have received was sent by an individual concerned about the safety of your plants. I believe that almost a third of the population lives within 50 miles of a plant, this is how far you are recommending be evacuated in Japan in a mild SBO event. They have seen how the lives of the people of Japan have been destroyed by that accident and they are justifiably worried.

   While I wish that everyone would take the time to hand craft a letter, not everyone can. Some don’t feel that they have the talent, some don’t have the time, and some just feel that others could write it better. I realize also that some of these letters came for vehemently anti-nuclear organizations and if the plants were closed outright the NRC would not have a job, other than ensuring that the waste is guarded for the next 250,000 years.

   That being said the NRC still has a duty to respond to the concerns of these people, I know that all the letters were generic, but there is defiantly a cause for concern. When you say

   “So, while we thank everyone who sent a CitizenLetter, all the available information continues to show that U.S. nuclear power plants are designed and operated so they will protect the public and the environment, even after severe natural events.”

   It conveys the message,” don’t worry folks, we’re professionals, we have everything well in hand”. The situation I detailed in my first post proves that the facts do not support this. We have been lucky, plain and simple. You know as well as I do that the Japanese were just as advanced as we are in regard to nuclear safety. Just a week before Fukushima President Obama said we should “look to the Japanese to see how nuclear safety is done”. And you also know that any talk of earthquakes and tsunamis simply cloud the issue. Japan was caused by a SBO it is irrelevant how the power was lost. Now that brings us to the question is the NRC doing its job, as the your original post seems to assert?

   Every since the first nuclear plant was built the danger of long term blackout has existed. This has been over 50 years. The first one should never have been built if it was fatally dependent on artificial electricity, but they were built without any regard for this, strike one. The Starfish prime nuclear explosion of July 1962 revealed the vulnerability of electrical systems to EMP, still no action(I know NRC was not around yet),strike two. The mild solar storm of 1989 showed that solar storms can damage electric equipment, even at NPPs, like Salem, strike three.

   From what I have read of the petition PRM-50-96 it was WRITTEN AND FILED BY A PRIVATE CITIZEN WITH NO CONNECTION TO THE NUCLEAR INDUSTRY.THE NRC HAD NOTHING TO DO WITH IT EXCEPT TO QUESTION EVEN FILING IF FOR PUBLIC COMMENT. THE PETITION WAS WRITTEN AND FILED BEFORE FUKUSHIMA AND PEOPLE HAVE BEEN WARNING ABOUT THIS SINCE 2003 AND STILL NO ACTION BY THE NRC. This leaves us to conclude two things.

   A. The NRC did not think about protecting the citizens from a well documented danger that a child can see, and should have been addressed before the first NPP left the drawing board, and are thus inept.
   Or
   B.They knew of the danger and simply ignored it and hoped for the best, in which case they are criminally negligent and will be directly responsible if the situation detailed in the my first post comes to pass.

   And this is just one situation that we know of. Commissioner Apostolakis brought up the issue of the nuclear industry “voluntarily” addressing safety problems that it(the industry) identifies. From the line of questioning I concluded that the industry will identify a problem and then they” volunteer” to fix it the and since it is “voluntary” NRC has no role in seeing if it was actually fixed. I think in your recent inspections you found some of these “voluntary “ fixes had not been implemented. So how much don’t we or you know about? Here is an article about the industry “volunteering” to fix something. And as we see in the post about Zion here on the NRC blog the power companies have almost no liability if their plants destroy the country.

   http://www.salon.com/wires/techbiz/2011/06/21/D9O0HULG0_us_aging_nukes_reaction/index.html

   Please don’t think I am addressing you personally, Mr Burnell, but since you are the public face of the NRC and the author of the blog post I had to address my comments to you. I know you personally may have little say over policy. I just took issue with the way the mass of public comments were handled with the standard “were the professions, we have it under control” when the facts do not attest to this in the example I sited and most likely the ones we don’t even know about.

10. As has been noted in comments on earlier blog posts, there is a current Petition for Rulemaking before the NRC regarding alternate power supplies for spent fuel pool cooling, PRM 50-96. You can add your voice to that discussion via http://www.regulation.gov under docket NRC-2011-0069. As you have pointed out, both the Commission, as well as the agency’s task force reviewing information from events in Japan, are considering whether changes to NRC regulations in areas such as station blackout are called for.

    Scott Burnell

11. Anonymous,

    The thousand or so people that are there to keep it running are there to assure that the plant is operating safely and properly.

12. Mr. Burnell,
    You seem somewhat upset that the NRC is receiving thousands of identical letters, so I decided to take the time and write you one personally. I hope that you will take the time to address/correct my allegations/assertions.

    I allege that NO nuclear power plant (NPP) in the US is safe in its current configuration. Every nuclear plant in the US is vulnerable to a long term wide spread loss of power incident.

    Every power plant must have a constant supply of outside electric power from the commercial gird to run cooling for the reactor, even if in shutdown, and the spent fuel pool (SFP). Barring this the plant must have fuel for the emergency generators, of which I believe that plants currently have no more than a 7 day supply of fuel on site.

    If there is a loss of cooling power or station black out(SBO) it is highly probably that the reactor will meltdown, and in the case of GE MK1, breach containment. Or that the spent fuel pool, which is outside primary containment and holds many times the radioactive material (sometimes 40 years worth) that the reactor core does, will boil off and expose the spent fuel rods to air with will cause the zirconium cladding of the rods to experience rapid oxidization and heat up, possibly catching fire and spewing radiation for hundreds of miles around EACH affected plant. DO YOU DISPUTE THIS ASSERTION?

    Now, government and private researchers have identified several natural and man-made situations that can cut power to much of the US for months or years. Namely solar flare, EMP attack, and cyber attack. Solar flares with grid destroying power have been documented before, just not since widespread electrification or NPPs, on average 1 per century and we are overdue. And several, potentially hostile, nations are known to have the capability to destroy the US power grid via EMP or cyber attack, the only reason I have electricity to type this is because these nations have not decided to act…..YET. And please don’t imply that they are afraid of US retaliation, these two attacks can be launched anonymously. If anyone would like to see the government reports I site, simply ask and thou shalt receive.

    I can post comments from NRC officials that state that NPPs have no passive cooling, are not prepared for power outages lasting over a couple of days and various other weakness to long-term wide spread blackout. Simply ask and I’ll post the quotes, you know I have them.

    So the NRC has something know as “defense-in-depth” to protect the country from destruction for a SBO at one of their plants. Let review it, the cooling systems rely on outside electric power, if this is cut they have diesel generators which rely on diesel to run. But wait, what do the oil refineries rely on to make the diesel? Oh, that’s right they rely on the power grid just like the NPP, after a week or so no more diesel……….scratch diesel generators. Next we have 4 hour batteries. And after 4 hour batteries what was it we had? Oh, that’s right………..nothing. So for “defense-in-depth” we have two systems that rely on an electric gird that can be destroyed at any time, a solar flare could be heading for us right now, or a 14 year old could be running our power gird via his laptop halfway around the world as we speak. And after the grid and diesel are gone we have a 4 hour battery.

    Fukushima #1 melted down 3.5 hours after it lost cooling power. And from your report on the Fort Calhoun fire , I’m not making any assertions about this incident only getting a time frame for SFP boil, we have “Current time to boil for SFP is 88.3 hrs”. And how long was it that power could be out for if one of the events I discussed above transpired? That’s right, months or years. The NRC is grossly negligent of its duty in this matter, and the future habitation of North America is in jeopardy at this very moment because of this situation at NPPs. By the way how long is it expected to be before the people around Fukushima can return home after the MILD(power was restored in a few days) SBO event there?
    We are on borrowed time.

    In conclusion, I know some will say that if we lost power for months or years NPPs would be the least of our worries. This is totally FALSE, granted there will be massive casualties, but the country could come back, throw in multiple meltdowns and uncontrolled spent fuel fires all over most of the country and there will be no coming back. The US does not have the resources or ability to deal with this situation, prevention is the only option. I for one am practicing up on my Spanish in the hopes that our neighbors to the south will let me stay with them.

    NRC you are negligent in your duty to protect the American people as long as this situation exists. All plants must be able to withstand a blackout lasting as long as there is enough heat in a SFP to cause a boil off. If the technology does not exist to enable this they should be closed immediately………POINT BLANK. And before you say it I know that Chairman Jaczko addressed this a little in the statement you provided, but he seems to be focusing on SBO lasting weeks, not good enough, again I can post transcripts from meetings if you dispute this. But in his defense he and Commissioner Apostolakis seem to be the only ones on the NRC that have a clue about how dangerous these things are.

    I hope this made you feel a little better about getting all the cookie cutter letters, but there is an old saying about being careful what you wish for because you just might get it. Thanks for the answers to my allegations, that I’m sure you are going to provide. Just remember I’ve read the NRC transcripts and government reports dealing with this issue, so be careful what you say. And also please don’t answer with rambling vague assertions. Simple direct answers to questions would be greatly appreciated, although not anticipated.

13. As an American concerned with our energy future, I feel we should have been phasing out these plants for a newer generation of plants 10 years ago, before they became worn out and dangerous to millions of Americans. At this point, plants like Indian Point are threatening untold millions of lives for a small percentage of the value of the human lives in profit.

    Yours,
    Demosthenes

14. This response seems very appropriate.

    I hope to see the NRC continue to properly vet public comments that are obvious campaigns from obstructionist organizations rather than raising not-yet-resolved safety issues so that focus can be maintained on legitimately not-yet-resolved safety concerns rather than wasting valuable NRC time re-performing activities that have already been completed.

    I hope to see similar vetting utilized within the licensing process for new reactor designs, rather than arbitrarily adding additional commenting periods simply as a result of commenters asking for another opportunity to comment during initially-defined comment period(s) as that is simply another blatantly obstructive activity if a new and legitimate not-yet-resolved safety issue is not raised.

    Sincerely,
    A Younger American concerned with future energy supplies

15. 6,500 man hours translates to 3 people full time. Any given nuclear plant can take a thousand people to keep it running, and you expect three people to be able to assure you that every single part of the plant is operating safely?

16. On average, the NRC expended about 6,500 hours of inspection effort at each reactor site during 2010. We’ll amend the original post to express that more clearly.

17. So, thousands of hours (seeing as the phrase becomes tens of thousands after 10,000) divided by the number of plants in the country comes out to a maximum of about 100 hours per plant, per year. How is that satisfactory by any stretch of the imagination? That isn’t even a full hour every three days? You state elsewhere that you have people on site every day, so they only work for 45 minutes and then leave?

    Sincerely,
    A Nitpicker

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