The environmental group has filed a contention saying the safety analysis is outdated
The Natural Resources Defense Counsel (NRDC), one of the nation’s leading environmental groups, told the NRC Nov 28 that the re-licensing application for Exelon’s Limerick nuclear power station has an out-of-date safety analysis.
The petition filed by NRDC challenges the relicensing process on the grounds that Exelon (NYSE:EXC) did not update a 1980s era safety analysis and that the NRC granted the utility an “inappropriate exemption” from the requirement to do one now.
Limerick is composed of two 1,200 MW BWR reactors. Unit 1 entered revenue service in 1986 and Unit 2 in 1990. Their NRC licenses expire in 2024 and 2029 respectively. The plants are located 21 miles northwest of Philadelphia.
“All U.S. nuclear plants are required to conduct a critical safety review known as a Severe Accident Mitigation Alternatives, or “SAMA,” analysis to determine potentially cost-beneficial operational safety upgrades at nuclear plants. The last analysis for Limerick, completed in 1989, relied upon population data from 1980 and therefore didn’t take into account evacuation planning and the health risk from radiation exposure for up to 1.4 million additional people now living downwind in the Philadelphia-Wilmington-Newark metropolitan area.”
He called the original SAMA “outdated” because it ignores population growth in the region. He cites a statement in NRDC’s press release about the contention.
“Some common sense planning is needed here. What was acceptable in 1989 is not good enough for the next 30 to 40 years.”
Not so fast says Exelon
Exelon disputes this view. April Schilpp, a spokesperson for Exelon, told this blog in an emailed statement that Limerick performed the required safety analysis in 1989 for initial licensing.
“The purpose of the analysis is to determine if there is cost effective mitigation for the environmental effects from a severe accident. It is required to be performed once, and Limerick, Watts Bar and Comanche Peak performed this analysis as part of initial licensing because of a court ruling in 1989. Since all other licensing was completed, the NRC required the analysis to be completed for other reactors during license renewal.”
She points out that NRC regulations require the analysis be performed for license renewal unless it was performed for initial licensing.
“We verified that there is no new and significant information that would alter the conclusion that the environmental effects remain low. Therefore no additional mitigation is necessary.”
And Exelon isn’t happy about the contention in general. Schilpp writes in an email, “The NRDC petition disregards everything else Exelon has done over the years to ensure safety and operational excellence.“
NEPA challenge at the heart of the contention
So why file a contention on these grounds?
McKinzie says the exemption is in conflict with the intent of the National Environmental Policy Act (NEPA). It appears to be a question of what is the “green footprint” of the plant.
“We want a ‘full-up’ and completely new SAMA. We think that new and materially significant information would result from one. Our contention is based on the plausible significance of this information,” McKinzie said.
He goes on to list seven reasons why the NRC should require a new SAMA for Limerick.
- additional accident scenarios analyzed for BWRs;
- real world information regarding reactor core damage frequency;
- population within 50 miles Limerick;
- economic consequences from accident scenarios at Limerick;
- evacuation speed assumed during accident scenarios at Limerick; and
- meteorology at Limerick.
Mc Kinzie says that “taken individually and especially in combination, this new information would plausibly cause a materially different result in the SAMA analysis for Limerick. This is why we think the current SAMDA analysis is incomplete.”
Again, Exelon isn’t buying it and not just because it wants to save money in the relicensing process.
“A great deal of investment has also been made to keep that analysis up to date since then, so it’s also not an “inadequate” study,” Schilpp says.
“In fact the Environmental Report itself (part of the application) lists the results of eight other safety analyses that were performed 1992 through 2009. Among other advances, these safety analyses show plant safety has improved over time (the calculated Core Damage Frequency (CDF) is lower),” Schilpp said.
Would a new SAMA make a difference?
With this back and forth from NRDC and Exelon in play, I turned to an expert third party for an opinion on whether a new SAMA would make a difference. This engineer, who also holds a Ph.D. in nuclear engineering, and has more than three decades of operational experience, told this blog via email;
A new SAMA analysis will basically be just be "more work for consultant firms"
While this sounds cynical, he said a new document would not be likely to produce much new information usable in day to day operations, “because it looks at additional hardware and tries to figure out if it has any additional benefits."
Does this mean NRDC has misunderstood the use of a SAMA? The consultant points out they may get it but also may be off the mark. He points out the knowledge of severe accident phenomenon has dramatically improved from what existed in the 1980's era and many of the safety issues which were addressed then are now recognized as obsolete.
“Some risks are reduced because of better knowledge of basic physics.”
"Some of the features incorporated voluntarily by the industry - such as hard pipe vents from the BWR suppression pool - have a huge impact on risk reduction. This would allow one reasonably sized fire pump and an open suppression pool vent to remove all decay heat from the core indefinitely."
The engineer concludes a number of major improvements have been added due to voluntary initiatives and for security measures. These include additional emergency diesel generators and fuel supplies.
He says, "It is difficult to see that re-evaluations in 2011 could come up any different."
The engineer is not quoted by name at his request due to contractual obligations with another nuclear utility which is not Exelon.
Watchdog group seeks leverage
NRDC’s contention has to pass some tests before it has an impact on the relicensing process for the plant. Even so, NRDC has to convince the NRC is has standing to file the contention and that it has raised a legitimate issue. The legal back-and-forth will take time so it could be mid-winter before the dust settles on this issue.
Exelon filed for relicensing in June of 2011 with an NRC calendar indicating a decision as early as April 2013. The plant license is good until 2024 so even if NRDC prevails on this issue, it won’t result in shutting down the reactor. Exelon has until the end of this month to file a legal response with the NRC.
What’s clear is that NRDC is seeking to overturn the exemption the NRC granted to Exelon. Whether a new SAMA would make a difference in over all plant safety isn’t clear based on a consultant’s expert observations. Then again, watchdog groups like NRDC seek leverage where they can find it so this may be an issue worth watching.
On the Web
- Exelon information on Limerick power station
- NRDC’s legal filings
# # #