Part 2:Seismic Risks to CGS–What the NRC Doesn’t Want You to Know

Part 2:Seismic Risks to CGS–What the NRC Doesn’t Want You to Know

A long but very well written article on the seismic risks of CGS which affects as we have seen in other posts, Hanford and the world. Please take the time to read this entire post by Gar Smith. We will post this into 4 parts to make reading easier and a bit less overwhelming regarding the enormity of the problem we face with CGS.

Second Thoughts

In 1983, the year before CGS reactor was placed in operation, the NRC decided to
question the plant’s seismic safety. WPPSS had assured Washington that all of its
planned reactors were engineered to ride out, if not the worst possible, at least the
worst “likely” earthquake. But this time, the NRC (an enforcement agency that routinely
invites its licensees to provide their own safety assessments and compliance
recommendations) decided to seek a “second opinion.” USGS scientist Tom Heaton
was hired to review Energy Northwest’s seismic research. After plowing through a
“decade’s worth of seismic studies,” Heaton was astonished at “how little was really
known about earthquake risks in the Northwest.”

“WPPSS reviewed the historical records, which went back 150 years,” Heaton reported.
And they reached “the logical conclusion: What’s past is prologue. The middling quakes
since settlers arrived in the mid-1880s were what the region could expect in the future.”
Drawing on the limited geological knowledge at the time, the WPPSS had assured the
NRC that “surface faulting is not a factor in the design of the plant” and that there was
no evidence that any “capable faults” existed within a five-mile radius of the proposed
reactor site. (The NRC defines a “capable” fault as one that has produced near-surface
ground motion at least once in the past 35,000 years or “movement of a recurring
nature” within the past 500,000 years.)

The WPPSS survey acknowledged the existence of several new “potential” seismic
sources but concluded they would most likely produce little more than an magnitude 4
to 6 quake, with an outside chance of a rare magnitude 6 to 7 earthquake.

The NRC reviewed the findings but issued no new safety requirements. (In 1988, the NRC invited all reactor operators to assess their potential risk from earthquakes beyond the parameters of the hypothetical “Safe Shutdown Earthquake.” Again, no seismic upgrades were made to the CGS plant, then in its fourth year of operation.)

Taking License

In 2011, during the CGS’s relicensing process, the NRC signaled its concern that
Energy Northwest was still relying on dated seismic studies from 1994, rather than the
most recent (and more alarming) research. But the NRC let the operators slide. Despite
protests from environmental organizations and citizen’s watchdog groups alarmed by
the spectacle of similar GE reactors reduced to smoking rubble by the Fukushima
quake and tsunami, the license-renewal process remained on track.

Hoping the Fukushima catastrophe would provide impetus for heightened safety
concerns, a coalition of Northwest activist groups petitioned the NRC on April 14, 2011,
asking that the Columbia Generating Station’s relicensing application be placed on hold
pending an assessment of the new findings of longer, more active and linked faults in
the area surrounding the reactor.

The NRC deliberated and announced it was rejecting the citizens’ petition because it
raised “issues that are outside the narrow scope of the NRC’s safety review for license
renewal.” According to the NRC’s ruling, the only issues of concern during the
relicensing process were those “limited to managing the effects of aging on certain
passive structures, systems and components.” Seismic reviews, by contrast, “are part of
the ongoing regulatory oversight process.”

This seems an odd standard. Not permitting an evaluation of new earthquake data
during a relicensing process seems as irresponsible as not allowing the submission of
new evidence during a murder trial.

There was another oddity about the relicensing process. The CGS’s operating authority
was not set to expire until the end of the reactor’s original “design lifetime” — in 2023.
Yet the NRC allowed Energy Northwest to apply for a new, extended operating license
in 2007, 16 years early. Five years and 2,200 pages later, the NRC approved Energy
Northwest’s renewal application on May 23, 2012.

John Pearson, a retired physician and president of Oregon Physicians for Social
Responsibility, notes that, out of nearly 200 applications, the NRC has only denied one
reactor operating license. In the case of CGS, Pearson argues: “What we received was
a rush job, 10 years before it was due, that did not consider all the evidence.”

The NRC’s decision seemed akin to the Department of Motor Vehicles granting a
license allowing a car built in 1979 to compete in a road race that’s scheduled to start in
2023. Picture, if you will, Energy Northwest arriving at the starting gate steering a
dilapidated vehicle operated by a steam pressure cooker pumping 14.7 million pounds
of steam per-hour, exerting 1,005 pounds-per-square-inch at 547 degrees F., and
powered with more than 500,000 pounds of nuclear fuel that keeps the engine
constantly revving — all day, all week, all year.

Hazards at Hanford: A Double Standard for CGS?

Ten miles northwest of the CGS, the Hanford Reservation’s $12.2 billion Waste
Treatment Plant (WTP) hunkers over 65 acres in the Pasco Basin, several miles below
a bend in the Columbia River. The controversial project is supposed to process 56
million gallons of Hanford’s radioactive and chemical wastes and encapsulate the toxic
residue in a glass-like state for storage inside stainless steel canisters. The plant,
dogged by costly design problems, has been under construction for more than 12 years.
The WTP project continues to experience delays, missed deadlines and shutdowns.
With federal budget cutbacks looming, DOE has announced plans to start laying off
construction crews in 2014.

While the NRC seems content with the situation at the CGS, the Department of Energy
was quick to take action after three USGS studies published in 2007 revealed a history
of larger-than-expected quakes that had battered the Hanford region over the past
millennia.

What the 2007 USGS studies uncovered was deeply troubling: there were more faults
than previously known and they all ran longer and plunged far deeper than suspected.
Instead of lying a mile or two beneath the ridge, the faults extended more than ten miles
into the Earth’s crust. The deeper the fault, the greater the potential shock when it
moves.

Faults that were thought to be unconnected with other, nearby faults, were found to be
part of a larger, common fault structure.

The report also warned that the size of many local faults had been underestimated.
Faults that were thought to run 40 miles turned out to extend more than 100 miles. The
Umtanum Ridge structure, once believed to extend 77 miles, was found to continue
more than 124 miles.

“Based on the length alone,” USGS paleoseismologist Brian Sherrod told the Seattle
Times, “you would estimate that some of the faults out there are capable of producing
magnitude 7.5 earthquakes.”

As recently as November 2013, Energy Northwest’s website was insisting the CGS
reactor was built to survive a magnitude 6.9 quake. Energy Northwest has offered no
seismic, scientific or engineering data to substantiate this claim. In any event, this
discussion of plant safety and “magnitudes” is immaterial because the NRC grants
operating licenses based solely on the ability of a reactor and its safety systems to
survive the effects of ground motion and g forces and (as earthquake scientists and the
NRC will tell you) you can’t translate ground motion into magnitude.

Although Hanford’s WTP is located fairly close to the CGS, its design-basis earthquake
safety margin (a ground motion of 0.5 g) was twice as great as that required for the
CGS nuclear reactor. Construction on the WTP began in 2002 but the Defense Nuclear
Facilities Safety Board (DNFSB) called a halt to work in 2005 and the project remained
shut down for a year pending new seismic studies. As Tolan noted: “The maximum
vibratory ground motion for this area has been dramatically increased based on the
WTP studies [and] … the presence of more (and longer) capable faults.” This raises a
question: Given the elevated concern for the WTP site, why was the CGS, located just
10 miles away — and with older seismic qualifications — not shut down as well?

When a new seismic response analysis for the WTP was delivered in 2007, it warned of
an increased level of seismic hazard — including the “violent” shaking and “heavy”
potential damage that could result from a magnitude 6 to 7 earthquake. The DNFSB
consequently recommended raising the ground-motion requirements at the WTP 30
percent to 0.6 g – or more than double the 0.25 g SSE design-basis protection level set
for the CGS reactor.

Hanford’s WTP is now being constructed to survive a quake that would rank 9 on the
USGS 10-point earthquake scale. Meanwhile, a 2011 USGS survey concluded that the
probability of large (magnitude 7 and greater) quakes could be much more likely in
eastern Washington. The fault associated with the Umtanum Ridge structure was found
to plunge deeply into the Columbia River’s “basement rock,” a clear sign that future
ruptures could produce much larger quakes than previously predicted. Tolan called the
latter discovery a “big revelation that has kind of shaken everything up…. These faults
appear to extend into the basement; they’re not just in the rug.”

In Tolan’s assessment, “Energy Northwest needs to develop a CGS site-specific model
for ground motion response spectrum based on borehole vertical seismic profile data
from the ground surface to the top of the Columbia River basalt. They then need to
integrate this data with the WTP shear wave velocity data for the Columbia River
basalt/Ellensburg Formation.” Once that is accomplished, Tolan adds, Energy
Northwest would still need to “reevaluate the maximum credible earthquakes … that the
revised model of the Yakima Fold can potentially generate.” This new seismic model
would also need to incorporate the latest findings on coupled faults, frequencies, length
and depth.

With questions about new seismic dangers gaining more media attention, Energy
Northwest’s posted a bold assertion on its homepage: “Columbia Generating Station
exceeds the Nuclear Regulatory Commission’s robust seismic design requirements, and
is capable of withstanding a massive earthquake.” The posting makes no mention of
specific findings (of new faults that are longer, deeper and connected). Instead, it refers
only to a single study that is still in progress — an investigation by Pacific Northwest
National Laboratory that Energy Northwest is co-sponsoring and funding.

In a letter to the Oregon/Washington chapters of Physicians for Social Responsibility
(OWPSR), the NRC stated “All of the issues raised in the letter from OWPSR are known
and are being evaulated as part of the seismic hazard reevaluation being conducted by
DOE and Energy Northwest” as part of the earthquake planning report that is due at the
NRC in March 2015.

The DOE’s next “seismic hazards analysis” is scheduled for 2014. Meanwhile, the DOE
has required the entire Hanford site to provide an up-to-date earthquake hazard
evaluation as part of a ten-year review. This reassessment is currently underway. Ivan
Wong, a board member at the Earthquake Engineering and Research Institute, is one of
the scientists who believe the record will show the seismic hazard in Eastern
Washington has probably been underestimated.

The DOE’s concern is not matched at the NRC, however. “The licensee conducted a full
probabilistic seismic hazard analysis for the region around the CGS plant, including an
evaluation of earthquake activity… including the Yakima fold belt and the Cascadia
subduction zone,” the NRC recently reported. No cause for alarm, the NRC continued,
since “the licensee evaluated the seismic capacity or ruggedness of the CGS plant and
determined that the risk of core damage from a seismic event is very low (0.00005 per
year).”

The NRC insists, “there is no immediate safety concern at CGS” and, come March
2015, the NRC has only promised to review the “evaluations conducted by Energy
Northwest for potential regulatory action.” (Emphasis added.)

Even if Energy Northwest’s “re-evaluation hazard evaluation” reveals additional,
heightened dangers, that does not guarantee the NRC is prepared to adopt the
Precautionary Principle. If new ground acceleration estimates are found to “exceed the
original design level,” the NRC has indicated it will simply require plant operators to
“conduct a seismic probabilistic risk assessment.” What happens if the risk is found to
exceed margins of design safety? “The NRC may determine that the plant must perform
modifications to strengthen equipment or anchorage based on the new higher ground
motion.” [Emphasis added.] And if the NRC does decide to act, it still would not deny a
license to operate. It would simply require that “a new ground motion level would be
added to the licensing basis of the plant.”

On its website, Energy Northwest has actually promised to be more diligent than its
supposed federal regulator: “Should the new PNNL analysis determine changes are
appropriate,” Energy Northwest states, “we will certainly make them.”

The disturbing element of this slow, bureaucratic approach is the issue of timing: While
you can schedule a safety review for March 2015, you can’t schedule an earthquake.

The Risk of Hanford Blowback

Once the pride of the Pentagon’s Cold War atom bomb program, the Hanford Nuclear
Reservation now resembles a “retirement community” for atomic artifacts — the home
of nine retired military reactors, four reprocessing plants, 53 million gallons of
radioactive wastes, and toxic ponds of hazardous chemicals stored in aging buildings,
concrete basins and underground tanks. In an assessment dating from 1999, the DOE
identified more than 1,600 waste sites at Hanford and slightly more than 500 facilities
built to store these wastes.

For more than 12 years, the DOE and its highly paid contractors (Bechtel and URS)
have been struggling to determine how to safely process and store the radioactive
waste produced by Hanford’s military reactors. The still-unfinished $12.3-billion Waste
Treatment Plant has been plagued with design problems, delays and cost overruns and
its fate remains uncertain.

The history of Hanford has not been pretty. Dumping of radioactive waste in the past was not exactly always done according to procedure...

The history of Hanford has not been pretty. Dumping of radioactive waste in the past was not exactly always done according to procedure…

More than 100,000 plutonium-filled used fuel rods from Hanford’s closed reactors are
stored in two shallow pools filled with about 1,000,000 gallons of water. Hanford’s
ancient tank farms (which contain enough plutonium to fashion 70 nuclear bombs) were
built in the 1950s with an anticipated lifetime of 20 years. Nearly seven decades on,
these containments are beginning to fail. If the pools were to crack and drain, the
exposed material could quickly ignite, creating a fallout hazard that would spread far
beyond the reservation.

In the 1990s, one of the pools was found to be releasing toxic sludge into the ground
only 300 feet from the Columbia River. In February 2013, inspectors reported that six of
Hanford’s 177 underground tanks were leaking. In October 2003, the DOE reported that
67 of the tanks “have leaked or are suspected to have leaked” a million gallons of
radioactive liquids into the ground. In 2013, six more tanks were found to be leaking and
the DOE now fears as much as 1.5 million gallons of contaminated water may have
been spilled into the surrounding soil.

But these pools are not just leaking radioactive fluids into the earth. On March 16, 2013,
a series of hydrogen gas releases were reporting escaping into the atmosphere from a
radioactive waste holding tank. Washington’s KING 5 News reported the releases
“lasted for several days, much longer than usual.” Plant operators were reportedly
concerned that “a single spark could have set off an explosive release of radioactivity.”
Hanford’s Waste Encapsulation and Storage Facility (WESF) holds 1,936 stainlesssteel,
20-inch-long capsules containing 130 million curies of radioactive cesium and
strontium (plus their decay products) in water-filled pools. Opened in 1979, the WESF
now holds the largest concentration of strontium-90 and cesium-137 on Earth. Over the
years, these deadly wastes have been left to simmer in an aging pool, beneath 13-feet
of water, with no overhead containment and no safety backups in the event of an
earthquake. In June, 2012, prompted by the Fukushima meltdowns, workers inside the
WESF’s cement-and-cinder-block warehouse were ordered to carefully rearrange the
spacing of more than 800 cylinders to reduce the chance of overheating.

Part of the Hanford nuclear reservation.

Part of the Hanford nuclear reservation.

The Hanford Nuclear Reservation holds two-thirds of the country’s stored high-level nuclear wastes — some 330 million curies of radioactivity that could be released in part or in toto by a severe earthquake or an on-site accident. The release of even a portion of these stored wastes could render the site a no-man’s land that could make recovery impossible and could compromise the safe operation of the nearby CGS plant, as well.

After a series of unusual hydrogen gas releases occurred at one of the Hanford storage
tanks in March 2013, KING 5 TV News reported that “State and federal officials have
long known that hydrogen gas could build up inside the tanks at the Hanford Nuclear
Reservation, leading to an explosion that would release radioactive material.”

The Defense Nuclear Facilities Safety Board immediately called for additional monitoring
and ventilation of the tanks. A major radiation release, whether the result of an
earthquake, a storage failure or human error, would require the evacuation and
relocation of approximately 300,000 people living within 50 miles of the CGS and the
Hanford site.

It wouldn’t even require a nearby earthquake to take out Hanford. If an earthquake (or a
terrorist attack) were to rupture the Grand Coulee Dam, a 65-foot-high wall of water
could inundate the nearby town of Richland and multiple disasters would befall
operators at the Hanford Reservation and CGS. (And it’s not just the Grand Coulee:
there are seven other dams on the Columbia between the Grand Coulee and the
Hanford Reservation.)

Meanwhile, at the same time the DOE is struggling to find a way to safely isolate the
military’s nuclear wastes, the CGS reactor has quietly churned out an additional
3,200,000 pounds of fresh nuclear waste — with a payload of 360 million curies.
According to nuclear expert Robert Alvarez, the amount of curies of radiation from the
atomic wastes at the CGS now surpass that of the toxic nuclear leftovers from nuclear
weapons production stored on the Hanford site.

Full Speed Ahead

Despite the Pasco Basin’s shaky geography and Hanford’s hellish hazards, Energy
Northwest continues to push ahead, arguing that there is no significant danger
associated with operating a power plant that has undertaken no structural safety
improvements for nearly 30 years. While the company has agreed to attend to more
than 100 internal up-grades demanded by NRC inspectors (i.e., reinforcing pipes,
strengthening tie-downs, upgrading equipment), Energy Northwest has undertaken no
structural/foundation modifications in response to the seismic hazards analysis. A
former CGS employee (who has requested anonymity) believes it would be “virtually
impossible to upgrade the foundation to meet the standards that we now know the plant
should have.” Moreover, the former employee confided, “it would be impossible to
upgrade the piping.”

In 2012, a coalition of citizens concerned about nuclear-safety asked the NRC to
provide the most recently completed Probabilistic Seismic Hazard Assessment for the
CGS reactor. The response was somewhat startling. “Currently, no probabilistic seismic
hazards assessment exists for Columbia Generating Station,” the NRC replied. The
NRC confirmed the “the original design of the facility” had not been changed in 30
years. However, as part of the NRC’s “Post-Fukushima Daiichi Lessons Learned”
response, an “update to the seismic hazards assessment is in progress.” The review
and recommendations will be provided, not by the NRC or by independent investigators,
but by the plant operators themselves.

In the meantime, don’t hold your breath: This review will not be due until March 2015.
But there should be no cause for concern, the NRC’s Lara Uselding offers, since “the
NRC knows of no significant changes to possible seismic hazards of the region.”

Antinuclear watchdogs are left to wonder why the NRC remains wiling to wait four years
before even beginning to assess the depths of North America’s potential “Fukushima”
problem. Can we afford to wait?

Imagine, if you can, the spectacle of an earnest entertainer heedlessly tap-dancing atop
a barrel of dynamite. The NRC’s position seems to be that such an activity can proceed
since it is statistically without any great, provable risk. But if you happen to be a member
of the audience, your appraisal might be somewhat different. Given the potential for a
serious disaster, why bother taking the risk in the first place?

The Channel-control Blade Problem

Another seismic safety issue involves the channel-control blades that help moderate the
atomic reaction inside the tightly packed fuel assemblies that power Boiling Water
Reactors. (In BWRs, these cruciform metal blades are inserted upwards from the
bottom of the reactor while in Pressurized Water Reactors, control rods are inserted
from above.) Designed to slide up and down between clusters of four fuel assemblies,
the blades are used to moderate the chain reaction and are essential to conducting an
emergency reactor shutdown (a “scram”).

The problem is that it might not be possible to shut down a BWR by fully inserting
control rods into these straight narrow channels while the reactor is undulating during an
earthquake. The channels may bow, bulge or twist, altering the clearance that allows
the control rods to move freely.

In a September 3, 2010 notification letter to the NRC, GE Hitachi Nuclear Energy (GEH)
noted that its previous “engineering evaluations… [did] not address the potential impact
of a seismic event on the ability to scram.” Furthermore, in the event of an emergency
shutdown, “scram capability is expected to be affected due to the added seismic loads,”
especially at low reactor pressures (i.e., below 900 pounds-per-square-inch gauge).
GEH notified the NRC that it had sent an alert to operators of 35 reactors in more than a
dozen states that the critical control rods could fail in an earthquake. One of the
potentially at-risk reactors was the Columbia Generating Station.

After “evaluating” the problem for more than a year, GEH sent an email on September
26, 2011 advising the NRC of its findings. The news was not good. GEH reported it had
“determined that the scram capability of the control rod drive mechanism in BWR/2-5
plants may not be sufficient to ensure the control rod will fully insert in a cell with
channel-control rod friction at or below the friction limits specified….”
GEH stated the expected impact of a Safe Shutdown Earthquake (SSE) on Mark I
reactors “may result in control rod friction that inhibits the full insertion of the affected
control rods during a reactor scram.” Similarly, Mark II reactors like the CGS, when
faced with either a Loss-of-Coolant Accident or a Safety Relief Valve problem during an
earthquake, might not be able to “fully insert” quake-damaged control rods “to perform
the required safety function.”

When GEH first notified the NRC in 2010, it took the position that the control-blade
issue was not a “Reportable Condition.” In the 2011 update, however, GEH was
compelled to admit that “a Reportable Condition… exists.”

Meanwhile, on October 11, 2013, the Nuclear Engineering Institute reported a related
problem. The fuel channels through which the control blades are supposed to slide can
be affected by bending and bowing, owing to the compounding impacts of heat,
pressure and radiation. The NEI reported: “More than half of the 35 BWRs in the United
States have reported control blade interference due to channel distortion since 2000….
Channels manufactured by all major BWR fuel suppliers have been affected.” According
to a December 2010 GHE evaluation report filed with the NRC, the CGS was one of the
plants warned about the possibility of blade failures during earthquakes.

These components were subjected to even greater stress in the 1990s, after the NRC
(bowing to the wishes of the nuclear industry) effectively permitted reactor operators to
double the amount of time nuclear fuel could be irradiated in their reactors. This “high
burn-up” policy also increased the percentage of uranium-235 contained in the fuels.

While this increased the profitability of old reactors, it also increased the stress on the
components inside the aging plants — including the critical control rods.

In September 2011, headlines broke the news that 35 of GE’s US reactors “may not
shut down properly during an earthquake.” GEH cautioned that, while “there is no
discussion of a recall of any control rods at this point,” it recommended testing to
determine “whether any modifications are necessary.” GEH admitted it had become
aware of the control rod problem “several months” before the Fukushima disaster and
the company now recommends that defective control rods be replaced when its reactors
are shut down for refueling. According to Energy Northwest’s FY 2014-16 Strategic
Plan, the company expects to begin preparations for replacing control blades in 2014,
with the actual work scheduled for 2015 and 2016.

But what if an earthquake strikes before the next refueling cycle? The position of GEH
and the NRC seems to be that running a reactor with defective control rods constitutes
a reasonable risk. For someone living near one of these reactors, however, the more
reasonable assessment might be the following: “If you can’t safety stop a reactor you
shouldn’t be allowed to start a reactor.”