With the score Nuclear Licensees 48, host communities 0, it seemed obvious that the fix was in and the NRC (Nuclear Regulatory Commission) was intent on bringing forth a Nuclear Renaissance by rubber stamping the License Renewal Applications of every aging, fatigued nuclear reactor in America, against the wishes of the 67 host communities who had agreed to host said reactors for a period of only 40 years. Contention after contention was shot down by the NRC, deemed speculative, or not properly and adequately defended and supported. How could this be, we all know about numerous problems from leaking steam pipes, failing weld joints, and untold numbers of radioactive releases into the environment. Time and again, brilliant legal minds and concerned citizens went down to heartbreak and defeat. The best contentions never raised as the Dark Lords shrewdly placed them out of scope with false claims that those items and issues were routinely in flux and being examined.It was only when the host community in and around Entergy's trouble plagued Indian Point began preparing their own Petition to Intervene, started looking for the documents necessary to support their contentions that the mist began to clear. The nuclear industry, NRC/DOE and NEI all needed a way to keep aging and other problems out of the public eye, needed a way to investigate known safety issues, while keeping grassroots environmentalists, opposing attorneys, and even state and local governments from getting their hands on damning documents, documents that would support the oppositions contentions. What the key nuclear players wanted, needed desperately, was another good old boy organization that could act as a repository for all these dirty documents, a corporate library where everything would be classified as proprietary, and fees for access would be deliberately price prohibitive to any one but their members. The per copy cost of each document price prohibitive for any one but the likes of Donald Trump or Bill Gates.
Imagine if you will, a impenetrable black tower of Electrical Industry learning and dark sinister secrets, it's reams of reports and studies off limits to all but the chosen few and the minions that serve them. Those allowed access paying handsomely (rumor has it the fee is $2 million a year) for unfettered corporate access. Imagine a dark tower of learning so well connected that the DOE funds research meant to protect NRC licensees interest, the studies and reports generated paid for by tax payer dollars, then secreted away, labeled proprietary and security sensitive and not eligible for export. Such an organization exists, and is known as EPRI (Electric Power Research Institute).
Hidden within the bowels of EPRI's vast document collection are the keys to stopping the wrongful relicensing of aged and failing nuclear reactors. Reports wherein it is admitted that welds are failing, leaks are occurring, and fatigue, corrosion and bacteria are eating away the stainless steel piping systems that are the guts of every reactor in the American Nuclear Fleet.
The NRC revision of the Maintenance Rule 10CFR50.65 (a) (4) implemented and to some great degree embraced Configuration Risk Management (CRM), which works hand in hand with what is known as PRA (Probalistic Risk Assessment) in addressing the risk issues associated with the operation of aged and failing nuclear reactors. Problem is, the entire CRM program allows each reactor site to create and write its own set of criteria, which means there is no industry wide standards that the NRC can enforce. What is interesting in knowing that each plant configuration is unique, is it brings into serious question, the generic relicensing EIS which eliminated (removed from scope) many nuclear plant internals.
Each plant it seems writes/establishes its own criteria in deciding what constitutes acceptable and undesirable levels of risk. One has to understand, that the use of, and the industry embracing of CRM was not about increasing public health and safety, but instead all about justifying configurations that would enable ever shorter refueling outages. It was this fact that saw EPRI, DOE, NEI and the nuclear industry insisting that the NRC adopt CRM when 10CFR50.65 (a) (4) was overhauled in 2000. It is no accident that said overhaul allowed a great deal of room and flexibility for each licensee to create SITE SPECIFIC approaches for CRM that fit into their plant management styles, that allowed companies like Entergy to put profits ahead of public health and safety. Despite what the industry might want you to believe, CRM is nothing more than a means to justify putting off, or ignoring needed repairs of reactor site internals. Too understand how CRM can be manipulated to justify delayed maintenance, one would need to play with a copy of EOOS, ORAM-Sentinel, Safety Monitor, or other simliar software created for this purpose.
Most plants use a four color system to identify their risk zones (green, yellow, orange and red), though some plants only have a three color code system, eliminating orange from the matrix. Even this deviation is alarming, as a four color system allows NRC licensees to provide themselves more wiggle room in pushing back repairs that could greatly impact human health and safety. Even more disturbing, no two plants have identical criteria for moving between the various color coded severity levels. One reactors red could be another reactors orange or yellow. This lack of uniformity is intolerable, and shows that the NRC is not properly enforcing the regulations they are sworn to uphold. Proves conclusively that there are no GENERIC relicensing issues for nuclear reactors, as each plant measures everything including risk in a different fashion, with a sliding scale of severity that is every changing from reactor site to reactor site.
The NRC, nor NEI and the nuclear industry want you, the general public to know this type of information. Instead, they want you to buy into the lie they have used in removing over 60 reactor plant internals from consideration in the license renewal application process, by claiming those internals were evaluated in a generic fashion, as said internals were all but identical from reactor to reactor, and thus did not need to be reconsidered, put in scope for reach license renewal application, as that would be a waste of funds and NRC time and energy. Problem is, the CRM process, and others that GNB has been studying show this to be untrue. Each reactor and their internals are different, as is the way each licensee weighs the risk of failing parts in their reactors.
Entergy's Indian Point, and other reactor sites will try to convince the public that their steam pipes are safe, and properly maintained...yet, EPRI has numerous documents hidden from public view that state otherwise. Even more troublesome, the NRC has full and complete access to these documents which outline failures, and presumably has read them, yet time and again the NRC has refused to order even one full and complete ISA (Independent Safety Assessment) of said steam pipe systems at a nuclear reactor. Leaking Butt Welds, thinning walls, and bacteria problems are not the exception in the nuclear industry, but instead the norm, with CRM being used to push back and delay repairs that are aimed at protecting human health and the environment, up time and electric generating capability superceding public safety as regulations meant to keep us protected are ignored, or set aside.
We have the power and ability to open the doors to the Dark Tower that is the EPRI library, we can force them to give the public access to the documents paid for fully or partially with tax dollars. Write and/or call your elected officials demanding investigations. Contact your Congressmen and Senators in Washington, DC demanding they pass a law that makes all documents, studies and investigations paid for, even partially with tax payer dollars be made publicly available in a central document repository similar to ADAMS. Dangerous, aging reactors are being wrongfully relicensed in the name of a Nuclear Renaissance. The documents that prove just how unsafe they are have been hidden behind the corporate veil of EPRI, and we must pierce their veil, gain access to the documents that prove our contentions.
