On December 18, 2012, the United States Nuclear Regulatory Commission (NRC) published a notice in the Federal Register (74788-74798 vol, 77, No. 243) announcing that it would consider in the rulemaking process the issues raised in a petition (Docket No. PRM-50-96: NRC-2011-0069) asserting that existing regulations for civilian nuclear power facilities are inadequate to assure pubic health and safety in the case of an electric power grid collapse lasting from 1-2 years.
The petition asserted that a combination of a loss of circulating flow and make up water for spent fuel pools in such a scenario would put the public at risk.
On June 10, 2011, I interviewed the petitioner, Thomas Popik of the Foundation for Resilient Societies, for the Atomic Show. I made the following statement at the time:
That proposed rulemaking would add backup power and cooling water source requirements for used fuel pools to enable them to operate unattended for at least two years following a loss of all offsite power. One of the proposed technologies advocated for this capability is a large array of solar panels with battery back up.
As you might imagine, I find the whole notion ridiculous and I told Tom that when I responded to his email. Used fuel pools are adequately supplied with cooling systems, there is no reason to think that any system should be able to operate without human intervention for 2 years, solar power systems have designed failures every 12 hours or so, and even if used fuel pools did lose their water, there would not be a risk to the public. Based on the results of the theory to practice event in the spent fuel pool of Fukushima unit 4, loss of water causes locally high radiation levels due to the loss of shielding, but that is about the extent of the real effects.
I was therefore disappointed to learn that the NRC has not only expended a large number of staff hours already, but it will also continue to spend hours (billed at the rate of $274 per professional staff hour to an unknown entity) for an indeterminate duration. The assigned people will perform detailed analysis to determine if US nuclear facilities are adequately protected in the case of a space weather event that is somehow severe enough to cause a complete electric power grid collapse AND the complete inability to deliver a small quantity of make up water to spent fuel pools during a response time span lasting from 1-2 years.
I’m sure that Ed Lyman would accuse me of a lack of imagination of what might be possible, but I do not believe that the radiological consequences of this scenario are worthy of any concern at all. The real truth is that I have a rather active imagination and believe that IF such a complete loss of capability occurred, one of the lowest concerns on my list would be an unhealthy exposure to radiation for any member of the plant staff or the public.
For your reading pleasure, here is a link to the 10 solid pages in the Federal Register devoted to explaining why the NRC has determined – during an evaluation that has already taken 20 months – to spend even more time and effort on this task. You can keep track of further NRC action on this issue by searching http://www.regulations.gov on Docket ID NRC–2011–0069.
And people wonder why investors are reluctant to put their money into an industry that is always at risk of someone creating another imaginary scenario specifically designed to require additional, unlimited expenditures.