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1. The lack of safety culture results from the agency prioritizing industry profits over public safety. For example, NRC consistently proposes radiation protection standards well below those proposed by EPA. Closer to home: Pilgrim installed the Torus Vent system to fix an identified design flaw – the containment was too weak to withstand pressure that would build up in an accident scenario. A vent was installed to relieve excess pressure. The vent should have gone into a filter bed deep into the ground; instead a cheaper fix was allowed whereby the vent would spew contaminated steam directly into our neighborhoods.

2. Enforcement and safety inspections are based on risk analysis calculations – they in turn rest on overly “rosy” assumptions that do not jibe with reality.

In Nuclear Plant Risk Assessments Studies: Failing the Grade,” David Lochbaum of the Union of Concerned Scientists, August 2000, outlined the problems:

  • Nuclear plant risk assessments are really not risk assessments because potential accident consequences are not evaluated. They merely examine accident probabilities -- only half of the risk equation. Moreover, the accident probability calculations are seriously flawed. They rely on assumptions that contradict actual operating experience:

  • The risk assessments assume nuclear plants always conform to safety requirements, yet each year more than a thousand violations are reported.

  • Plants are assumed to have no design problems even though hundreds are reported every year.

  • Aging is assumed to result in no damage, despite evidence that aging materials killed four workers.

  • Reactor pressure vessels are assumed to be fail-proof, even though embrittlement forced the Yankee Rowe nuclear plant to shut down.

  • The risk assessments assume that plant workers are far less likely to make mistakes than actual operating experience demonstrates.

  • The risk assessments consider only the threat from damage to the reactor core despite the fact that irradiated fuel in the spent fuel pools represents a serious health hazard.

  • The potential vulnerability of reactors and spent fuel pools in the event of a deliberate terrorist attack is almost completely ignored. The results from these unrealistic calculations are therefore overly optimistic.



ITEM: Pilgrim - NRC 2004 Annual Assessment


The Nuclear Regulatory Commission came to Plymouth on March 24, 2004 to give Pilgrim its annual report card. To nobody’s surprise, NRC presented them with all “A’s.”

Clearly NRC’s tool, grading system, for assessing safety at nuclear reactors is broken.

For example, Pilgrim received an “A” for emergency planning, which included methods to notify the public in the event of an emergency. However, we know that the siren system was broken six times since 2003 – yes, six times. The last failure was in January 2004 after they installed new sirens. The NRC justified their grade by stating that siren failures occurred, “only during tests.” Does this mean a bad score would be given only if a failure occurs during an accident?

NRC’s failure to evaluate Pilgrim is not an isolated example. The infamous Davis-Besse nuclear reactor in Ohio received all “A’s” from NRC and shortly after a hole in its reactor head was discovered – a hole nearly through that would have resulted in a catastrophe.

NRC was properly embarrassed by the David-Besse fiasco and vowed to fix 49 items that needed fixing in their reactor evaluation system. To date, 2/3 of those items have not been fixed to prevent the next Davis-Besse. Maybe that is why Pilgrim received all A’s despite glaring safety flaws.

The public concluded that our safety depends not on the NRC - but instead on luck.

ITEM: NRC’s Response to Independent Experts Study on Spent Fuel Storage Hazards

A study that appeared in the spring issue of Science and Global Security, a publication edited at Princeton University confirmed 25 years of past science and concluded that spent fuel pools are particularly vulnerable to terrorist attacks and could generate a pool fire and corresponding contamination of hundreds of square miles around a nuclear plant.

The Science and Global Security study lays out a solution - secured dry casks (also referred to as Hardened On-Site Storage, HOSS) and a low density pool. This is far safer than a densely packed fuel pool and an important interim solution until all the rods can be shipped to Yucca or some other federal repository.

The NRC responded to the new study simply by asking staff to deep-six it. Specifically NRC Commissioner Edward McGaffigan ordered his subordinates to produce “a hard-hitting critique … that sort of undermines the study deeply” (U.S.NRC, Briefing On The Status Of Office Of research (RES) Programs, Performance, And Plans, March 27, 2003, page 44).

This directive within the NRC to develop a conclusion-driven critique to undermine a scientific study is yet more evidence that, in many cases, the NRC acts an advocate for the industry, and without regard to the public safety.

ITEM: NRC Adopted A Rule in Mid-February 2004 That Would Reduce the Public’s and States’ Ability to Be Granted Hearings in Utility Licensing Requests.

This would, for example, directly affect citizens and the States ability to file legal challenges to license renewal applications at Pilgrim, VT Yankee and Seabrook. This new rule is being appealed by the Citizens Action Network in the 1st Circuit Court of Appeals.