Combustible Gas

As we observed in our prior blog post, the publication by the Union of Concerned Scientists of their new study of nuclear near misses would likely generate a combustible gas that could find some ignition sources, at least among like-minded nuclear critics.  Thus the March 22, 2011 article* in The Nation magazine was predictable, including the comments by Henry Meyers that the UCS study is evidence of a lack of “serious oversight for twenty years” by the NRC.  Evidence of this includes the reduction in NRC violations and fines in the late 1990s and the contention that then-Chairman Dr. Shirley Jackson caved to political pressure.  Disregarded are the facts that many nuclear plants underwent enormous performance improvement programs in that period and the consolidation of nuclear ownership under a small number of advanced nuclear enterprises.**  These nuclear operators had the significant management, technical  and financial resources to ensure operating excellence in their plants, resulting in much better regulatory compliance.

But it would be a mistake to dismiss lightly the direction that UCS and Christian Parenti of The Nation are taking the post-Fukushima discussion of nuclear safety.  Their thesis is that the current risky state of the nuclear industry in the U.S. (“a fleet of old nuclear plants and the 40,000 tons of nuclear waste they have created”) is due to the lack of strong safety culture, and that the NRC has been compromised through political pressure and the corrosive influence of an inadequate industry safety culture.  Thus,

“...it is imperative to overhaul the inadequate, industry-dominated safety culture that has developed over the past twenty years.  This eroded safety culture is a source of serious danger—and it must be fixed.”

Approaching the current state of nuclear safety from this direction has the potential to open a Davis-Besse size hole in the carefully constructed safety record of the nuclear industry.  By its essence safety culture is perhaps the most far ranging indictment of safety; far more extensive than any specific technical issues that have historically been the target of nuclear critics.  It targets an unprotected flank of both the industry and the NRC; including the recent process where consensus and stakeholder involvement has been emphasized by the NRC to the point that the above quote will gain traction.  The product, a safety culture policy statement by the NRC, something that is not even enforceable, will be framed as a continuation of a lack of “serious oversight” and serve well the newly energized anti-nuclear community. 

*  C. Parenti, "After Three Mile Island: The Rise and Fall of Nuclear Safety Culture," The Nation (Mar 22, 2011).

**  Nuclear industry consolidation was predicted and described in a paper I co-authored with NYPA's Bob Schoenberger, "Capturing Stranded Value in Nuclear Plant Assets," The Electricity Journal 9 (June 1996): 59-65.

Never Let a Good Crisis Go To Waste

“You don’t ever want a crisis to go to waste; it’s an opportunity to do important things that you would otherwise avoid.” So said Rahm Emanuel, memorably, several years ago.  Perhaps taking a page from the Emanuel book, the Union of Concerned Scientists took the opportunity last Thursday to release a report chronicling a series of problems it had investigated at U.S. nuclear plants.*  Apparently the events in Japan pumped plenty of fresh oxygen into the UCS war room in time for them to trot out their latest list of concerns regarding nuclear plant safety.

[UCS senior scientist Edwin] “Lyman was speaking in a conference call with reporters on the release of a report examining critical problems — known as “near misses” — at various nuclear facilities in the United States last year, and the N.R.C.’s handling of critical problems”

David Lochbaum, the author of the report and the director of the nuclear safety program for the organization, was quoted as:

[The report] “also suggested that federal regulators needed to do more to investigate why problems existed in the first place — including examining the overall safety culture of companies that operate nuclear power plants — rather than simply order them to be fixed.”

It could be that the UCS is aiming at the heart of the recent discussions surrounding the NRC’s new policy statement on safety culture.  It is clear that the NRC has little appetite to regulate the safety culture of its licensees; instead urging licensees to maintain a strong safety culture and and taking action only if “results” are not acceptable.  UCS would like specific issues, such as the “near misses” in their report, to be broadly interpreted to establish a more fundamental, cultural flaw in the enterprise itself.

Perhaps the larger question raised by the events in Japan is the dominance of natural phenomena in challenging man-made structures, and whether safety culture provides any insulation.  While the earthquake itself seemed fairly well contained at the nuclear plants, the tsunami easily over powered the sea wall at the facility and caused widespread disability of crucial plant systems.  Does this sound familiar?  Does it remind one of a Category 5 hurricane sweeping aside the levees in New Orleans?  Or the overwhelming forces of an oil well blowout brushing aside the isolation capability of a blowout preventer? 

John McPhee’s 1990 book The Control of Nature chronicles a number of instances of man’s struggle against nature - in his view, one that is inevitably bound to fail.  Often the very acts undertaken to “control nature” contribute to future failures of that control.  McPhee cites the leveeing of the Mississippi, leading to faster channel flows, more silting, more leveeing, and ultimately the kind of macro disaster occurring in Katrina.  Or the “debris bins” built in the canyons above Los Angeles communities.  The bins fill over successive storms, eventually leading to failures of the bins themselves and catastrophic mud and debris floods in the downstream valleys.

It is probably inevitable that in the aftermath of Japan there will be calls to up the design criteria of nuclear plants to higher levels of earthquakes and other natural phenomena.  The expectation will be that this will provide the absolute protection desired by the public or groups such as UCS.  Until of course the next storm or earthquake that is incrementally larger, or in a worse location or in combination with some other event, that supersedes the more stringent assumptions.

Safety culture cannot deliver on an expectation that safety is absolute or without limits. It can and should emphasize the priority and unflagging attention to safety that maximizes the capacity of a facility and its staff to withstand unforeseen challenges .   We know that the Japan event proves the former.  It will be equally important to determine if it also showed the latter.   

*  T.Zeller Jr., "Citing Near Misses, Report Faults Both Nuclear Regulators and Operators," New York Times, Green: A Blog About Energy and the Environment (Mar 17, 2011, 1:50 PM)