NRC failing to enforce seismic regulations at California's Diablo Canyon reactors

[kristopher]

Seismic Shift: The NRC and Diablo Canyon
Dave Lochbaum, director, Nuclear Safety Project
November 13, 2013



The 2008 discovery of the Shoreline fault closely offshore from the Diablo Canyon nuclear plant again raised the question of whether its reactors conform to the NRC’s safety regulations governing seismic protection.

Depending on which NRC document you read, the “speed limit” at Diablo Canyon against ground acceleration caused by earthquake is 0.4g, 0.5g, or 0.75g. It’s tough to enforce a speed limit when you only know that it’s somewhere between stopped and the speed of light.



PG&E sought to answer this question by requesting that the NRC formally revise the safe shutdown earthquake (SSE) level to the level the company had evaluated for the Hosgri fault under its Long Term Seismic Program (LTSP) in the 1980s. PG&E believes the plant can withstand the ground motion caused by an earthquake on the Shoreline fault. But it has never performed a rigorous analysis of the Hosgri and Shoreline faults using the methods and assumptions required to legally re-define the seismic design basis. As a result, the NRC does not have the information it needs to determine that Diablo Canyon can operate safely.

Dr. Michael Peck, then an NRC resident inspector at Diablo Canyon, pointed out numerous deficiencies in PG&E’s evaluation of the Shoreline fault. Peck concluded that more analysis and likely additional modifications would be necessary before anyone could honestly claim that Diablo Canyon was adequately protected from an earthquake originating along the Shoreline fault.



Even if...

http://allthingsnuclear.org/seismic-shift-the-nrc-and-diablo-canyon/

[PamW]

1. For the record...

The following is from PG&E:

http://www.pge.com/myhome/edusafety/systemworks/dcpp/seismic/safety/

In November 2008, the U.S. Geological Survey (USGS), working in partnership with PG&E's Geosciences department, identified the Shoreline Fault zone and PG&E evaluated whether that new feature presented a safety risk to the plant. PG&E submitted its evaluation to the Nuclear Regulatory Commission (NRC) under the commitment of its current operating licenses. In 2012, the agency confirmed Diablo Canyon has adequate safety margin to withstand the maximum ground motions from faults in the region, including the Shoreline Fault.

and

An additional 3D high-energy offshore study proposed by PG&E did not receive approval by the California Coastal Commission in 2012.

As the above states, PG&E attempted to study the fault more closely but was blocked by the California Coastal Commission:

http://abclocal.go.com/kabc/story?id=8886271

A controversial plan for seismic surveys near a nuclear power plant on California's central coast has been rejected.

Earthquake faults would have been mapped by firing loud air cannons periodically over a four-year period near the Diablo Canyon Power Plant. Opponents feared that would harm thousands of sea mammals.

As for the NRC; the NRC staff did an analysis of the seismic design of Diablo Canyon and reports as follows:

http://www.sanluisobispo.com/2012/11/28/2310185/nrc-diablo-canyon-earthquake-study.html

The NRC study concurs with PG&’s conclusions that ground motion produced by a quake along the Shoreline Fault would be within the plant’s existing design limits, which are based on the larger Hosgri Fault farther offshore.

It doesn't appear that the NRC is ignoring anything; but rather that the results of the scientific studies are not to the anti-nukes liking.

The good thing about science is that it is true, whether or not you believe in it.
--Neil deGrasse Tyson

PamW

[kristopher]

2. "the Hosgri and LTSP evaluations used non-standard methods and non-conservative assumptions"

Based on its LTSP study, PG&E updated the Final Safety Analysis Report (PG&E 1988). According to PG&E:

The LTSP contains extensive databases and analyses that updated the basic geologic and seismic information in this FSAR Update. However, the LTSP material does not alter the design bases for DCPP [Diablo Canyon Power Plant] (PG&E 2010, page 3.7-1).

In other words, PG&’s evaluation concluded that the new seismic information did not require a value of SSE larger than 0.4g. It also concluded that the Diablo Canyon reactors could withstand earthquakes larger than SSE, and in particular could withstand seismic activity up to 0.75g.

However, while the NRC required PG&E to conduct the Hosgri and LTSP evaluations, these evaluations did not meet the high standards that the NRC requires of a rigorous analysis performed to determine the SSE value. The Hosgri and LTSP evaluations were performed to answer “what if” questions, but were not intended to officially determine whether the reactors met federal regulations. In particular, the Hosgri and LTSP evaluations used non-standard methods and non-conservative assumptions.

"Seismic shift: Diablo Canyon literally and figuratively on shaky ground" pg 6

You could put half the readers of DUEE in the hospital with shock if you ever made a relevant point. If you have actual evidence that the specific issue being raised by Lochbaum is invalid then you should post it. This vaudeville act where you rant and throw up a slew of irrelevant, off topic bullpucky lacks even entertainment value.

The well researched and written report is available for download here:
http://www.ucsusa.org/assets/documents/nuclear_power/diablo-canyon-earthquake-risk.pdf

[PamW]

3. More flotsam...

kristopher,

I should have guessed; more flotsam and jetsam from the "Union of Concerned Pseudo-Scientists.

When will you learn that UCS is NOT a scientific society like the National Academy of Sciences (NAS), or the American Physical Society (APS), the American Society of Mechanical Engineers (ASME)...

The UCS is an anti-nuclear activist group, and EVERY scientist I know considers the papers from the UCS unworthy for wiping excrement from their lower extremities.

The good thing about science is that it is true, whether or not you believe in it.
--Neil deGrasse Tyson

PamW

[NNadir]

4. "Well Researched and Written" is certainly in the eye of the beholder.

There are a lot of people - extremely well educated people - who don't think that anything coming out of the so called "Union of Concerned 'Scientists'" has any scientific merit at all, that it's simply another chanting dogma machine.

Jim Hansen, for instance, regards it as just another link in the self referential chain of anti-nukes.

http://pubs.acs.org/doi/abs/10.1021/es402211m

But let's cut to the chase:

How many people have died from Diablo Canyon and how does this number of deaths compare to the deaths caused by the burning of dangerous fossil fuels in order for people who know very little about anything to do with nuclear power complaining about it on the internet?

How about Fukushima, more deaths from radiation or more deaths from pollution caused by running servers to spread the anti-nuke propaganda?

According to Lancet, 4 million people die from the burning of "renewable" biomass each year.

http://www.thelancet.com/journals/lancet/article/PIIS0140-6736(12)61766-8/abstract

That works out to about 450 people an hour. (The World Health Organization figures - less well referenced than the Lancet paper - estimates a death toll of "only" 380 per hour.)

I often ask myself how many of those people might have lived through the next hour were it not for the fear and ignorance of anti-nukes.

I note that if one person, even one, had ever died from Diablo Canyon, millions of tons of carbon dioxide would be released by people carrying on about it, pretty much for eternity.

[PamW]

6. It sure is..

kristopher,

Take for example the last paragraph on page 6 of the CRAP from UCS

They talk about using "miniumum" values of strength for steel and concrete whereas PG&E used values from "tests"

They claim that PG&E used strength values that were greater than the minimums.

That's correct; PG&E used the ACTUAL values from actual tests.

If you don't know the value of a strength, then sound engineering practice is to use the minimum of what it could be if you don't know it.

But PG&E TESTED the strength. That's a MORE ACCURATE way of doing the calculation; by using the properties of the materials as actually measured.

This is more "sour grapes" from UCS; showing what PISS-POOR "scientists" they are when they want people to use a "minimum" instead of the ACTUAL values in a calculation. Lochbaum must have gotten a "D" in physics with that type of practice.

PamW

[kristopher]

5. If those pronuke replies had a kernel of relevance I didn't see it.

Three posts by defenders of nuclear power that attempt to discredit a fact based argument. No where in the body of those posts is there even a tangential point of connection to the facts or the fact based analysis presented by Lochbaum.

Not one.

[NNadir]

7. Would you care to compare the number of citations that the fool Lochbaum gets...

when he publishes a paper with the number of citation Hansen gets, or would you rather just offer your curious view of what is and what is not a "fact?"

Let me, um, um, um guess...

One can search "David Lochbaum" on Google Scholar and get a real sense of what passes in his purview as a "publication," and one can also search "James Hansen" and do the same.

If one searches the latter, on the very first page, listing ten papers one will find 8 papers cited by more than 500 other papers, with the other two being cited by more than 400.

No matter...

I see you have no interest whatsoever in comparing the "fact" that approximately 400 people will die in the next hour from "renewable" biomass burning with the death toll associated with the lifetime operations of Diablo Canyon.

Why am I not surprised?

[kristopher]

8. Your bluster and incoherent ravings are no substitute for sound reasoning

But you do a great impersonation of someone with nothing valid to say.

...For example, the differences between a rigorous SSE evaluation and PG&’s Hosgri and LTSP evaluations include (PG&E 1996):

- An SSE evaluation uses the minimum specified values for the material properties of concrete, support steel, piping, and other components whereas the Hosgri and LTSP evaluations used values obtained by tests. The Hosgri and LTSP evaluations thus assumed concrete and other materials were stronger and more resistant to earthquake forces than assumed in an SSE evaluation.
November 2013 6
- The Hosgri and LTSP evaluations assumed that the building’s foundation absorbed four to five percent of the ground motion energy while an SSE evaluation conservatively assumes that all this energy was applied to structures and components.
- An SSE evaluation assumes that vibrations caused by the earthquake would be dampened by two to five percent whereas the Hosgri and LTSP evaluations assumed seven percent damping. In other words, the Hosgri and LTSP evaluations assumed the plant had larger “shock absorbers” that lessened the duration and magnitude of shaking—and damage resulting—from the earthquake.
- An SSE evaluation assumes that steel supports and piping remained rigid during the event while the Hosgri and LTSP evaluations assumed that some components would bend. Rigid components transfer force to walls, floors, and whatever else to which they are connected. The force assumed to bend a component lessens the force applied on its neighbors.

So while PG&E’s Hosgri and LTSP evaluations concluded that the reactors could withstand ground motion up to 0.75g, these results are not reliable measures of Diablo Canyon’s ability to safely withstand such earthquake forces. And the NRC cannot officially rely on these results to gauge the regulatory compliance of the Diablo Canyon reactors.
Lochbaum Pg 7
...

[NNadir]

9. Whatever. How many citations does Lochbaum's nonsense statement gets in the...

...serious scientific literature, or would you simply care to cut and paste it indefinitely?

If I repeatedly post over and over again excerpts from a paper "proving" that cigarettes are harmless, for instance, I will not make them true.

I see rather than address the question related to cigarettes, specifically the carcinogenic properties of combustion gases, you'd rather engage in, um, smokescreen diversions from the question at hand.

Diablo Canyon has been operating for decades. Did it or did it not kill as many people as Lancet indicates will die in the next hour from air pollution.

[kristopher]

10. Whatever?

That is the crux of it, Nnads. You have absolutely nothing but empty rhetoric with which to sustain your beliefs.

Where does Lochbaum's analysis fail?

It doesn't.

I don't think I have ever, not even once, read a valid argument by you in defense of nuclear power.

Not one - Ever.

[NNadir]

11. So let's see if I have this straight.

You believe that I need to prove a negative in order to divert attention from a positive, the well known fact that the next 12 hours of air pollution will kill more people than the 60 year history of nuclear energy did?

One of the world's most respected and most cited scientists publishes a paper, the most widely read in the journal in question - a premier journal of environmental science, EST - over the last 12 months, showing that nuclear power saves lives.

And your response is what? A fantasy that something could happen and that therefore we should kill even more people with fear and ignorance?

Now, I have made it clear that I, like apparently the majority of the scientific community, have next to zero respect for Lochbaum, but if your point is that I should spend precious time going over his garbage to satisfy the ramblings of a person for whom I have even less respect than I have for that tiresome fool, this to address your silly vision of what a "valid argument" is, you're probably smoking something I wouldn't want my kids to use.

As Hansen's original paper shows, the data collected over more than half a century is clear: Anti-nuke ignorance kills people.

[kristopher]

12. Diversions and red herrings...

A refuge for those with nothing else to offer.

Dissent Within the NRC
Dr. Michael Peck, then the NRC senior resident inspector assigned full-time at the Diablo Canyon site, reviewed actions taken and planned by PG&E in response to the identification of the Shoreline fault. Peck disagreed with preliminary conclusions by PG&E and the NRC that Diablo Canyon could continue operating safely with these seismic issues unresolved. Peck initiated a non-concurrence report using the process within the NRC for individuals to formally disagree with NRC decisions (Peck 2012).

Peck enumerated several reasons why Diablo Canyon was not being operated safely within its legally defined design bases. He contended that the process PG&E used to determine whether its reactors could continue operating despite having a known non-conforming condition (the seismic gap)5 was inadequate because it:

... failed to demonstrate that the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code acceptance limits were met for reactor coolant pressure boundary components at the higher structural stress levels represented by the new seismic information.
... failed to demonstrate that all seismically qualified plant SSCs [structures, systems, and components] would continue to function at the higher vibratory motion associated with new seismic information in accordance with the [SSE] design basis (Peck 2012).

Peck basically contended that PG&’s initial assessment for the Shoreline fault indicated that it could produce ground motion at the Diablo Canyon site that could subject parts of the plant to more force than they were designed to withstand. As a result, the excessive force would damage equipment and structures needed to safely shut down the reactors and protect workers and the public from harm.

For example, Peck noted that PG&E’s evaluation did not show that the reactor vessel and piping attached to it (collectively the reactor coolant pressure boundary) would remain intact when subjected to forces from an earthquake along the Shoreline fault. If the reactor coolant pressure boundary is breached, water ends up on the floor instead of cooling the reactor core and preventing its meltdown. Peck’s non-concurrence report expressly pointed out that the NRC’s regulations and standards do not permit reactors to continue operating when information shows that equipment and structures would not be capable of performing this vital safety function. Yet Diablo Canyon’s reactors continue operating.

Lochbaum pg 10-11

http://www.ucsusa.org/assets/documents/nuclear_power/diablo-canyon-earthquake-risk.pdf

[PamW]

13. 100% WRONG as ALWAYS

kristopher states
An SSE evaluation uses the minimum specified values for the material properties of concrete, support steel, piping, and other components whereas the Hosgri and LTSP evaluations used values obtained by tests.

As always, kristopher and UCS have no idea of what they are talking about.

The SSE evaluation can use EITHER a minimum specified value OR the ACTUAL TESTED values.

If you want to understand this; consider the following analogy to your federal income taxes. Certain expenses are DEDUCTIBLE. The are two ways to compute your deductible expenditures. One way is to take the "standard deduction" and the other way is to "itemize deductions". The itemized deduction way is MORE ACCURATE in that it computes with your ACTUAL deductible expenditures; instead of an estimate which is what the "standard deduction" is. In my case, I itemize deductions because the sum of my actual deductible expenditures is greater than the "standard deduction" estimate.

Likewise, seismic calculations can either be made with a conservative "minimum value", or the MORE ACCURATE way is to use the ACTUAL TESTED values for material properties like the strength of the steel. PG&E has had the steel used in the construction of Diablo Canyon tested; and has the TESTED values for same. So in order to be as ACCURATE as possible, PG&E used the tested values of the material properties in their calculations.

UCS is like someone complaining because someone itemized deductions and paid less tax than if they took the standard deduction. If your deductions are high enough, it's true you pay less tax; but that's what the law allows, and you can't say someone is breaking the law by itemizing deductions instead of taking the standard deduction.

But it isn't just PG&E that says the plant legally meets the seismic requirements. It's the NRC staff. The NRC has its own cadre of seismic and structural scientists and engineers to evaluate licensee submissions, and to do their own evaluations of licensed reactors. In this case, the NRC staff scientists and engineers did their own seismic analysis of Diablo Canyon and concur with the PG&E analysis.

http://www.sanluisobispo.com/2012/11/28/2310185/nrc-diablo-canyon-earthquake-study.html

The NRC study concurs with PG&’s conclusions that ground motion produced by a quake along the Shoreline Fault would be within the plant’s existing design limits, which are based on the larger Hosgri Fault farther offshore.

“The Shoreline Fault has a low slip rate that is estimated to be an order of magnitude less than the Hosgri Fault, which implies that its overall contribution to the hazard is relatively limited,” the report concluded.

In terms of what is legal, the NRC makes its own rules about what standards are to be used, and Congress gave them that latitude to make their own rules, and the Supreme Court upheld that provision of the law when it said environmental groups and intervenors can't substitute their judgment for the Commission's judgment. It is the NRC that gets to make those determinations under law.

The Chair of the NRC is well versed in these issues because she is a geologist. The Chair of the NRC is Alison McFarlane:

http://en.wikipedia.org/wiki/Allison_Macfarlane

She has a doctorate in Geology from MIT, has served on the NRC Blue Ribbon Commission on spent fuel, and was nominated to be Chair of the NRC by President Obama.

Therefore, the regulation of seismic safety at our nuclear power plants is in good hands; we now have a real scientist in charge ( unlike the pretend pseudo-scientists at UCS ), and she is way more competent to handle the job than her predecessor who was merely a political anti-nuclear functionary from the staffs of Harry Reid and Edward Markey.

The good thing about science is that it is true, whether or not you believe in it.
--Neil deGrasse Tyson

PamW