Though I have a deep and abiding respect for the vast majority of the people I have met who work in the nuclear energy industry, it is time for me to risk losing a few friends with some brutal honesty. Decision making has become unbalanced in the “conservative” direction to a point of a dangerous degree of groupthink. The safety and security of the nation is being endangered from excessive efforts to seek perfection in nuclear energy; there is an immediate need to introduce more effective decision making that includes diverse perspectives and an analytical method that recognizes the risks of NOT using nuclear energy.
I was inspired to make this diagnosis after listening to the Southern California Edison (SCE) press event recorded on October 4, 2012. The subject of the press event was to explain the company’s response to a Confirmatory Action Letter from the Nuclear Regulatory Commission regarding a steam generator tube leak experienced on January 31, 2012. Both of the 1100 MWe uranium fueled generators on the San Onofre site have been shutdown ever since that date.
I think it is worth reminding readers that the most exposed person might have received a maximum radiation dose equal to 5.2E-5 millirem (0.000000052 rem) as a result of the leak. During the phone call, I head one of the SCE representatives state that the leak rate into the steam generator from the leaking tube did not exceed regulatory limits for continued operation; it was simply high enough to cause the operators to recognize an abnormal condition and decide to shut down the plant.
It is also worth reminding people that the primary coolant in a normally operating light water reactor contains such small amounts of radioactive material that about 1/3 of the light water reactors in the world are boiling water reactors that do not even have steam generators to isolate the primary from the secondary coolant – they use their primary coolant directly in steam turbines. As long as you wait a minute after removing water from a neutron flux, it is quite benign. A frequently retold story in the nuclear world is that Admiral Rickover once offered to drink a glass of coolant during testimony to Congress. (Apparently a more complete truth was that the glass was actually Controlled Pure Water (CPW), which is primary coolant that has been through a filter.)
As of June 30, 2012, the closing date for SCE’s most recent financial statement (10-Q), the company has spent $117 million dollars to purchase replacement electricity net of avoided nuclear fuel costs. SCE owns just 78.21% of the plant, so I calculate that the total cost of replacement power for the first five months of the outage was $150 million.
In addition, SCE spent $48 million on consultants and outside experts to diagnose both the extent of the conditions in the steam generators and the root causes that led to those conditions. SCE was only reporting its share of the cost, so that indicates that the total bill for the consultants as of June 30, 2012 was $61 million. I’ll assume that the number SCE reported includes the cost of additional NRC fees, which add up at the rate of $274 per professional staff-hour.
In other words, the total cost of that tiny leak of primary coolant was $211 million during the first 150 days after the event and the costs continue to accumulate at a rate of approximately $1.4 million per day.
The company representatives kept repeating the mantra that the discussion was all about “safety”, but they did not mention that there was NEVER a safety risk to the public from the event that caused the shut down. There is also a minuscule risk to the public from starting up; all of the steam generator tubes that were found to be at risk of leaking have been plugged and the cause of the problem is understood well enough so that it is unlikely to reoccur.
Even if generating steam and producing valuable, emission free electricity eventually resulted in another leak, the plant’s detection equipment has proved that it is adequate. It is sensitive enough to warn operators to shut down before ever releasing any radioactive material that could have any possibility of causing a human health effect.
It is expected behavior in the nuclear world to always default to a “conservative” approach that avoids any risk of making a mistake that has the remotest possibility of releasing the tiniest amount of radioactive material to the public. That approach, as admirable as it may sound to the people who enforce the culture, ignores reality. There is nothing made by man that is perfect and there is no way to produce electricity that is completely without risk.
However, there are real dangers associated with burning fossil fuel to replace nuclear electricity, with laying off talented workers during a time of economic stress, with planning to automatically curtail electricity to certain customers in order to ensure grid reliability, and with restoring retired power plants to emergency operating status. There are also country wide systemic dangers associated with driving up the cost of nuclear power plant insurance, with increasing the perception that owning a nuclear plant is always financially risky and with repeating the mantra that not operating a nuclear power plant is always the “safe” approach.
In this case, the safe, technically informed course of action is not the “conservative” approach of doing everything possible to avoid any remote possibility of radioactive risk while ignoring all other risks. Of course, there are reliably antinuclear groups and individuals who are not only demanding that the reactors remain shut down for many more months, they are putting pressure on to force the plant to shut down permanently.
It is time for people who are worried about the risk of climate change, worried about the risk of power outages, worried about the negative economic impact of failing to produce reliable electricity and worried about the increased risk of natural gas explosions to put pressure on SCE and the NRC to get the plant up and running. The evaluation and the necessary corrective actions have been completed. There is no need to delay operations for additional analysis.
There is one more aspect of this situation that I do not fully understand, but I have some feelers out to try and obtain an adequate explanation. As far as I can tell, there was no initial justification for SCE accepting an NRC assertion that the company needed to get permission to restart the plant. This event did not include any safety violation and posed no risk to the public under the jurisdiction of the NRC. The plant’s sensors worked; the operators did their job; the public was protected and the plant owners correctly determined that they had purchased a equipment that needed more TLC than expected.
There is no technical safety reason why unit 2 could not have been restarted at full power after just a few weeks worth of inspections and no reason why unit 3 could not have started up at reduced power after a month or two. Until the company accepted the NRC’s Confirmatory Action Letter (CAL) and made voluntary, but binding, commitments in addition to their license conditions, I do not think there was any regulatory obligation to ask permission from the federal government to restart the plant. I will let you know if I have incorrectly interpreted the regulations. (Please remember that the NRC was, at the time of the CAL, led by Dr. Gregory Jaczko, who decided (perhaps with some strong encouragement) to resign more than a year before his term expired.)