Remains to be seen

While it is comforting that the Energy Secretary, Dr. Steven Chu, has taken a bold position within the Obama position to promote nuclear energy as part of the mix, it remains to be seen what the President himself will support. Remember his speech in October 2008 in New Hampshire, where he described the "only" problem with nuclear energy, "that they might go boom and blow up, like a nuclear bomb."

Obama's own nuclear problem with Republican Senators is that his agenda for the future has already blown up. Given that Obama must find some common ground with his adversaries to build from, nuclear energy development is the only issue Republican's support (almost universally), with huge potential government program, already on the table, strategic in a geo-political world. Remember, even Iran is building new Russion nuclear plants, and the U.S. is sorely behind virtually every other Western country with new nuclear design development and licensing.

So for U.S. nuclear programs now the question is, will they be a June Bride in 2010 -- or left at the alter again as green steals the show for federal funding and support. Don't hold your breath. Instead, hang onto your pants.....

South Korea Consortium Steals UAE Nuclear Deal

UAE strengthens hand with nuclear deal/Sun Dec 27, 2009 10:28am GMT
DUBAI/SEOUL (Reuters) - South Korean firms Korea Electric Power Corp. (KEPCO), Hyundai Engineering and Construction, Samsung C&T Corp and Doosan Heavy Industries have won a deal worth around $40 billion to build and operate nuclear power plants in the United Arab Emirates, industry sources said today.
http://c.moreover.com/click/here.pl?t2427068707&f=10149

Were U.S. firms contenders? Probably not. Politics alone would have posed a barrier to GE. However, the broader issue is the dearth of U.S. commercial involvement. Although Westinghouse, owned by Toshiba, was one of the winning consortium, the plants are not AP-1000s. Most export income and profit from the project will go to Korea. The irony is that U.S. taxpayers, who footed the bill for commercial nuclear power development, will see no benefit accrue to U.S. companies, U.S. balance of payments, U.S. taxable income or other U.S. strategic concerns. Nor does the current crop of politicos in Washington on Capital Hill even care - they’re off chasing windmills.

The absence of a global U.S. nuclear strategy, as presented by President Dwight Eisenhower when he signed the Atomic Energy Act of 1954, has left the U.S. taxpayer's investments high and dry. Does the Obama administration care to change that picture?

Without a change of direction in Washington DC, the U.S. is headed towards third-rate status in world nuclear design, construction and operations. That should give all U.S. citizens pause for concern.

Will Westinghouse follow GE with its shield building design?

Via press release October 15, the Nuclear Regulatory Commission has said that Westinghouse’s new AP-1000 reactor design reactor shield building needs modification. Although Westinghouse said it would be no problem to comply with NRC’s request, this could slow down final AP-1000 design approval.

Insiders feel the NRC is frustrated with the Westinghouse shield building design, and that public release assures the NRC will slow the AP-1000 timetable. Some question whether utility loan guarantees that support the AP-1000 design should immediately stop, like DOE’s risk-ranking did when GE’s ESBWR design ran into similar licensing troubles.

Although rumors allege shield design problems, the details aren’t clear. Two stories relate them: (1) with modular construction of the Westinghouse shield structure design, and (2) NRC's design licensing approach. Both will affect new plant construction - the latter already has. With people who lack practical experience in design or construction, NRC is more into technical details than ever before. This story realizes everyone's worst fears, exactly. If the NRC won’t hold to a schedule, and dwells on technical details that may be beyond the technical skills of the staff, they can’t hold to a schedule. Furthermore, they‘ve never liked technical oversight of their work. Based on how the DOE evaluated the GE's ESBWR design for completion probability success, OMB should also hold up Congressional NP 2010 loan guarantees for the Westinghouse plants. That would put Areva's EPR design out front to construct, with multiple AP-1000 and lead plant Vogtle 3 owner Georgia Power (Southrern Nuclear) on hold. That would kill new nuclear construction momentum.

The bigger story is the NRC – and how they work. They aren't transparent like they claim, internally aligned, or objective. They don't follow schedules (how can safety be scheduled?) nor allow themselves to be held accountable for decisions. They worry eternally over technical details they can’t evaluate. Ironically, the loan guarantees were to protect against regulatory delay, but now they (loan guarantees) could exclude a "U.S." design from loan guarantees a second time. Loan guarantees are an essential prerequisite to funding. (GE’s case was the first.) Of course, now Toshiba owns most of Westinghouse. Although it’s a good time to get it out on the table, challenging the NRC and being delayed poses great risk.

Technical opinions on the validity of NRC claims against the AP-1000 speculate on this point; NRC experience is the best indicator. The AP-1000 containment approach is new. The US NRC does not do new well. They're still resolving digital IC controls, approved by the rest of the world 20 years ago. Since the NRC cannot work to a schedule, everyone must prepare for more cost. So much for Part 52's certified design risk-free development process. Converting a high-level design into construction is always complex. A tremendous amount remains ahead, for every design, constructing every plant even with a complete high-level design.

People have proposed more transparent methods to license new designs. So far, the NRC’s Commissioners, Executive Director for Operations and reactor venders have chosen to not raise the license process issue. Although we believe it would make the licensing more truly transparent and accountable, and speed it up, it would also take away power they currently hold.

If only based on what "others" said, Westinghouse has a problem. Going public NRC chooses an alternate path instead of resolving the technical issue directly. That's a bad sign - they're using their trump card. Prefabrication methods that accelerate construction in Japan are foreign to the US. The US NRC could delay licensing Westinghouse AP-1000 over them. Insistence on using modular construction techniques, including post-stressing systems, could be the focus of threats (under their owner, Toshiba that is) could delay approval of the Westinghouse AP-1000 recertification.

Scuttlebutt at a meeting in Washington DC asserted that in effect Westinghouse told the NRC, "Well, since the Japanese accepted the AP-1000 Shield Building design, it must be acceptable." The implication was that the Japanese regulator - with whom Toshiba presumably is in touch - was a tougher smarter or at least as qualified a regulator as the NRC. That’s hearsay, but if it happened, it would explain why the NRC would be upset. Of course, the Chinese are building four AP-1000’s today, with no specific concerns. (Remember, the US NRC already certified the early AP-1000 design in 2004.)

Should the NRC take Westinghouse to task - or visa versa? Calling press conferences for issues such as shield building modifications only foreshadows more problems. Many more are behind this one - digital controls, combustion turbine emergency backup power, Cyber Security, and others like them. Will this influence Westinghouse's marketing plans or stock price? It’s hard to tell now, but the worry is that it will. In the past, delays killed US nuclear programs. This threat realizes the banker’s worst fear, and emphasizes the role loan guarantees will have on retaining the US nuclear option - if it still exists.

Closing the RAP GAP for safety, cost and investment protection

September 25, 2009

Honorable Senator Thomas A. Carper
Chairman, Senate Environmental and Public Works
Subcommittee on Clean Air and Nuclear Safety
United States Senate 513 Hart BuildingWashington, DC 20510

Closing the RAP GAP for safety, cost and investment protection

Responding to Three Mile Island (TMI) learning twenty years ago, Part 52’s Combined License Quality Assurance Program (QAP) required certified designs provide a Reliability Assurance Program (RAP). Unfortunately, the nuclear industry failed to recognize that new plant RAPs are simply scheduled maintenance plans. Since introducing Boeing’s 747 in 1967, the FAA has only licensed new airplanes with certified scheduled maintenance plans. NRC should implement Part 52’s intent and letter by only licensing new designs with completed RAPs - the same way U.S. airframe suppliers have done the past 42 years.

Senator Carper:

Title 10 CFR Part 52[1] requires new nuclear plants to have reliability assurance programs (RAP) covering safety-related equipment. The difference between a new and operating plant reliability assurance programs - e.g., their scheduled maintenance plans - creates a RAP gap. Many nuclear plants started up under Part 50 with virtually no scheduled maintenance plans. Three Mile Island (TMI) was one. Few of those scheduled PMs. Surveillance test programs had major omissions, discovered only after industry-wide audits following TMI. New plant owners of that era assumed their operators could patch together various safety-related equipment maintenance and monitoring plans after startup once they completed the immediate startup goal to establish income flow. They did not.

TMI-2[2] demonstrated the huge risks that placed on the plant’s public, operators, and especially the nuclear industry and its financial backers. Those charged to develop plans were often woefully unprepared to do so, lacking formal training, qualification or effective tools. They deferred to operational needs. As a result, as late as 1995 many nuclear plants still ran with substantially incomplete reliability assurance plans.

Few financial lenders today would embrace placing their $8 billion dollar asset into operation without a scheduled maintenance program. Yet regardless of common sense, and rules that require RAP for nuclear safety-related equipment, we are poised to repeat that error again today - even on required, in-scope nuclear safety-related equipment. Although rules formally only cover a small fraction of overall plant equipment - the nuclear safety-related equipment - resistance developing programs before plants start up has emerged again. Regardless of what brokers or owners should expect to protect their huge investments[3] for purely economic reasons, addressing safety-related equipment’s planned monitoring and scheduled maintenance before startup remains unresolved.

Commitment today to implement Part 52’s NUREG-0800[4] and Regulatory Guide (RG) 1.206[5] RAP requirements remains unclear. Guidance remains suitably vague, confused by deterministic design considerations and engineering judgment. Completing the scoping of safety-related equipment classification is the only certain pre-startup requirement today. Thus, the same unprepared workers charged to develop Generation I plans, lacking in formal training, qualification and tools, are poised to do so again. Will they defer that task again to operational needs, and repeat the lessons of 1970’s and 80’s? Incomplete plans started up TMI, placing a huge risk on overall operations. The cumulative result of thirty years of nuclear operations indicates starting new plants with incomplete operating “software” causes confusion and introduces risk. Ignoring TMI, regulatory response the past thirty years has been many rules like as 50.49, Environmental Qualification of Class 1E Electrical Equipment for Nuclear Plants that specify nuclear maintenance programs. Guidance today now covers how to develop effective, comprehensive equipment scheduled maintenance and monitoring plans. For new nuclear construction, Part 52 specifies developing a reliability plan. Prospective licensees see providing the equipment scope covered by the rule, a safety-related MEL, meeting that requirement. Today, few anticipate providing scheduled maintenance plans required by the RAP at startup.

Industry should emulate the Federal Aviation Administration (FAA) and airline industry. FAA certifies new airframes with a preflight reliability assurance program as crew operational checks and scheduled maintenance[6] - before a licensed commercial plane ever leaves the ground! The advantages are many. Aside from having a complete startup plan from the onset, providing a systematic approach yields a structured plan. Plants can realize their design-based reliability, rather than let haphazard chance events determine outcomes. Reasons to develop embedded design-reliability programs include engineering completeness, along with forty-years operating experience. Financing requires realizing nuclear operations consistency from the start. Not only is it imperative not to repeat TMI, new nuclear generation economics require very high cost performance to repay construction loans. Cost-plus scenarios of Part 50 LWR licenses[7] are gone forever; they must meet public utility commission (PUC)-promised rate case projections. Predictable nuclear operating costs from reliability benefit safety directly as well as indirectly over a plants lifetime. Design-forward reliability benefits nuclear power consumers by not funding repetitive, haphazard design basis and scheduled maintenance reconstitution programs over and over, adding unnecessary or even detrimental requirements to maintenance processes. Everyone benefits from standardized operating plans licensed with plant designs.

Conclusion

Important strategic initiatives have hamstrung the nuclear industry in the past. While the industry should legitimately concern itself with the intrusion of regulation, existing safety statutes and rules are mandatory. Extending those sensibly to achieve common success on nonsafety related nuclear plant equipment should remain industry’s prerogative. However, the tools, methods and programmatic understanding to develop, implement and maintain effective, automated reliability programs have never been more available. If loan guarantees effectively make Congress the nuclear industry’s banker, it should require application of the very best methods and processes to protect its capital investment - not just nuclear safety-related equipment.

Given the substance, value and costs before us, as well as our safety interest, it is imperative that those who approve funds to develop safe American nuclear energy resources thoughtfully consider nuclear reliability and licensing. Congress should deliberate these matters as energy debates continue.

Sincerely,

J.K. August, PE
J.J. Hunter SRO
CORE, Inc.
303-425-7408/970-330-1411
[1] Licenses, certifications, and approvals for nuclear power plants
[2] The accident, a $2 billion loss.
[3] in nonsafety balance-of-plant equipment, constituting 80% of overall plant cost
[4] Review of Safety Analysis Reports for Nuclear Power Plants
[5] Regulatory Guide for Combined License Applications for Nuclear Power Plants
[6] See ATA MSG-3 (2001), Operator/Manufacturer Scheduled Maintenance Development, which provides an FAA-approved method for developing aircraft inspection/maintenance programs. Aircraft providers must certify airframes and power plants for commercial service applications.
[7] Under Part 50, most rate-based plants were allowed to recover “reasonable” ongoing construction costs.

Chairman Jaczko Remarks: Heritage Foundation

Gregory Jaczko, President Obama's new NRC head, outlined his priorities for the agency in a speech at the Heritage Foundation. He said little about new reactor applications, except that the agency would focus its limited application review resources on projects most likely to be built first. What does that mean?

What about DOE and the NP-2010 initiative, and Congress' Next Generation Nuclear Plant? What about new plant licensing? What about the high cost of new plants? What about operating plant performance improvements?

Chairman Jaczko needs to get the chance to firmly plant his feet. Then he should take off charging. If DOE's to have any impact on energy, NRC has to support their effort. They (the NRC) also need to support (coax, push, encourage and pressure) industry to get its act together. For thirty years there has been precious little new nuclear development of new U.S. nuclear application processes and thought. Yes, we have new LWR designs, but we're designing them like we did thirty years ago. And they really aren't new, they're evolutionary. Other than go to exhaustive extremes to prove the licensing cause under Part 52, precious little is new.

We need new thoughts, processes and challenges, and Chairman Jaczko must make that happen.

How we can boldly improve nuclear plant safety

June 26, 2009 rev June 14

Hon. Senator Thomas A. Carper, Chairman
Senate Environmental & Public Works Subcommittee on Clean Air & Nuclear Safety
United States Senate 513 Hart BuildingWashington, DC 20510

How we can boldly improve nuclear plant safety

Dear Senator Carper:

Removing nuclear plant safety concerns renews confidence in nuclear energy development. Improving nuclear plant safety requires reducing safety mistakes. Random safety errors like uncharged safety injection lines or reactor nozzle corrosion present near misses. Most nuclear safety errors randomly evolve from design process failures. Nuclear plant safety design anticipates all types of expected equipment degradation and provides the means to control their safety risks. Loss of safety design basis places errors deep into nuclear plant operational processes. Usually they only result in near misses. Rarely, something more happens than loss of defense-in-depth. Consequently, safety errors are unacceptable - particularly preventable ones. All non-random safety errors are preventable. Random factors should not determine nuclear safety when improved processes can entirely remove their threats. Most safety design losses come from failure to operationally integrate design. Aging equipment creates more safety design loss failure threats. Effective design basis integration preserves design-intended nuclear safety functions better - even with aging processes leading to equipment failure.

At Palo Verde, uncharged safety injection lines in both trains of the three units’ safety injection systems compromised capacity to supply emergency reactor cooling water. For a lengthy period, lost defense-in-depth substantially increased public safety risk. Though less risky (but more unnerving), Davis-Besse’s single reactor nozzle corrosion failure was another near miss. However, both presented the specter of direct nuclear fuel damage - a significant safety barrier loss. Direct fuel damage escalated into the calamity of an actual radiation release at Three Mile Island, creating the worst U.S commercial nuclear reactor accident. Persisting uncorrected for a lengthy period, in spite of multiple evident indications, uncharged safety injection was a “common-cause” failure - an especially insidious problem. Independently failing safety controls at Davis-Besse and Palo Verde reveal systemic industry problems - echoing Three Mile Island. Organizational behaviors powerfully influence common-cause failure risks. Training to improve nuclear safety awareness helps combat complacent cultures, but is not enough. Strengthening underlying safety processes provides additional needed assurance. Integrating safety design processes adds fundamental defense-in-depth. Integrating safety design with operations remains the most comprehensive way to improve error-prone nuclear safety.

Whether designing new plants or operating old ones, improving the design basis requires asking candidly how to correct the fundamental causes of design basis loss. Operating a three unit nuclear plant for many years with not just one but both safety trains inoperable in every unit does not generate public health and safety confidence. Flying in a commercial airliner with only one system to operate the plane controls, knowing all backup hydraulic controls were inoperable would also make the general public reluctant to fly - if in fact, they knew safety equipment was inoperable. People can personally assess flight risk from their own experience. After all, most of the general public flies today. However, few people today understand nuclear plants. They must trust others who do.

Commercial airline pilots cannot choose whether they do preflight instrument checks, leaving public flight safety to chance. Rules specify preflight system flight checks to assure safety performance. No plane leaves the ground with known, inoperable safety devices. However, commercial jet airliners integrate safety design into operations. Nuclear plants don’t. Discounting evident safety failures reveals safety weaknesses in the nuclear design process. While most of the time nuclear plants are safe, design basis integration would make them far safer. Ever so rarely, coincident multiple safety system failures randomly align, violating diversity, redundancy and principles of defense-in-depth. And once in a very great while, a nuclear accident happens. Overseas, in the military and at our National Labs nuclear accidents have killed people. Nuclear accidents can happen. Further reducing nuclear accident risk requires improving how we translate the underlying safety design basis into operational requirements. This requires integrating nuclear plant operations with plant nuclear safety design.

Nuclear safety performance improvement requires integrating the plant design basis. How can we justify not taking the next steps to further reduce nuclear safety risk? Three Mile Island, Chernobyl or the commercial airline industry have taught us nothing, if we have decided today that we are “safe enough.”

Sincerely,

J.K. August, PE / J.J. Hunter, SRO
CORE, Inc. 303-425-7408/970-330-1411

Terms: Design Basis (DB); Nuclear Safety Framework; Nuclear Safety Performance, Reliability Assurance Program (RAP); Systems Structures and Components (SSC), Component Part Aging; Next Generation Nuclear Plant NGNP; Failure; Failure Event; Failure Mechanism; Light-water Reactor (LWR); Actionable, Common-cause failure

Attachment: Strategic Nuclear Initiatives
Distribution:

US NRC
Gregory Jaczko (Chairman)
NRC Office of the Inspector General
Hubert Bell (Inspector General, US NRC)

Department of Energy
Steven Chu (Secretary, DOE)

House Committee on Energy and Commerce
Henry A. Waxman, CA, Chair
Subcommittee on Energy and Environment
Edward J. Markey, Chairman
Subcommittee on Energy and Air Quality
Rep. Perlmutter, CO Member

Senate Energy & Natural Resources CommitteeJeff Bingaman (Chairman)Lisa Murkowski (Ranking Member)

Senate Environment & Public Works Committee
Senator Barbara Boxer (Chair)
Senator George Inhofe (Ranking Member)
Matt Dempsey (Communications Director, Sen. James Inhofe Office)
Subcommittee on Clean Air and Nuclear Safety
Thomas R. Carper (Chairman)
Laura Haynes (Legislative Assistant, Senator Carper’s Office)
David Vitter (Ranking Member)
George V. Voinovich
Max Baucus
Benjamin L. Cardin
Bernard Sanders
Jeff Merkley
Christopher S. Bond
Annie Caputo, Senior Technical Staff

Government Accountability Office
Mark Gaffigan (Director, Natural Resources and Environment, GAO)

Nuclear Energy Institute
Marvin S. Fertel (President & Chief Nuclear Officer)

Institute of Nuclear Power Operations (INPO)
Jim Ellis (President & CEO)

Professional Engineering Societies & Consensus Standards Organizations
American Nuclear Society (ANS)
Jack Tuohy, Jr. (Executive Director, ANS)

American Society of Mechanical Engineers (ASME)
Kevin Ennis (Director Nuclear Codes and Standards, ASME)

Institute of Electrical and Electronic Engineers (IEEE)
John R. Vig (President and CEO, IEEE)



Industry
Westinghouse
Regis Matzie (Sr. Vice President/Chief Technical Officer)

General Electric (GE Hitachi Nuclear Energy)
Robert Brown (Senior Vice President, Regulatory Affairs GEH)

Areva NP
Tom Christopher (CEO & Vice-Chairman)

Mitsubishi Nuclear Energy Systems
Frank Gillespie (Senior Vice President, New Plant Technology, MHI)

Shaw
Steven Stamm (Vice President Business Development, Shaw)

Bechtel Power Corporation
Brian Reilly, Principal Vice President

Attachments sent to Senators/Representatives and others listed in red; letter only black.
For email or hardcopy copies of all materials, please send request via email with email address to:
jkaugust@msn.com
J.K. August
CORE, Inc.
P.O. Box 606
Arvada, CO 80001

Obama OK's Nuclear Power for Iran -- but rejects it in U. S.

Nuclear Power OK for Iran -- just keep it out of the U.S.

Obama said he "supported Iran's right to peaceful nuclear energy...." but worries about the same thing here in the U. S. (see previous post-- we promote wind and solar ) Perhaps the time has come to support nuclear power here in the U.S. too, if its so good for Iran (and Saudi Aradia, Egypt, the United Arab Emirates, Libya and Pakistan....) What gives, Mr. President?