Part 3:Seismic Risks to CGS–What the NRC Doesn’t Want You to Know

Part 3: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.

The NRC Raises a Few Questions

On January 19, 2010, Energy Northwest presented the NRC with its application to
renew the operating license for the CGS reactor. On July 13, 2010, the NRC (following
up on the 2007 reevaluation of the WTP’s vulnerability) sent a letter requesting that
Energy Northwest address concerns that CGS’s 15-year-old seismic risk study failed to
foresee the dangers uncovered at the WTP site.

The letter had been preceded by an urgent conference call on June 28, 2010 in which
the NRC repeated its continuing concern that Energy Northwest had relied on old
seismic hazard estimates to measure ground movement. (Energy Northwest has
persisted in relying on two earlier findings — the 1981 WPPSS and 1994 Geomatrix
studies. The NRC has called both studies “incorrect and flawed.”) Citing the USGS and
PNNL studies of earthquake hazards that forced the DOE to make structural
improvements at the WTP, the NRC asked Energy Northwest to “assess whether
consideration of the more current” earthquake discoveries might “impact the results” of
the company’s Severe Accident analysis.

In response, Energy Northwest expressed concern that the impact of newer geological
studies “could not be addressed quantitatively.” Energy Northwest also insisted that
basalt and sediment bedrock at the WTP site were different from the geology beneath
the CGS. While it is true that there are different “soil structures” at the two sites, this
does not get the CGS off the seismic hook. As geologist Terry Tolan concluded in his
report on “Earthquake Risk Factors at the CGS,” the WTP and CGS sites are
“geographically and geologically linked and similar.”

In a follow-up letter, the NRC suggested that Energy Northwest’s failure to incorporate
the latest information about the location, size, and frequency of local faults was a
significant shortcoming.

The 1994 Geomatrix models assumed the faults in the Yakima Fold were “uncoupled”
and, thus, likely to produce only smaller magnitude 5 to 6 quakes. (In the Columbia
Basin, an uncoupled “thin skin” fault only penetrates the region’s surface basalt. It does
not extend downwards through the sedimentary layers and into the depths of the
crystalline basement.) By 2009, however, new data from deep hydrocarbon exploratory
drilling had produced what scientists at the USGS, the PNNL, the American
Geophysical Union, and the Geological Society of America concluded was “compelling”
evidence the YFTB’s major faults were, in fact, coupled, “thick skin” faults.

As USGS geologist Richard Blakey noted: “Generally speaking, long faults are
potentially more dangerous than short faults, and the through-going faults proposed
here would pose significantly increased seismic hazards if they would prove to be active
along their entire lengths.” USGS studies published in 2009 and 2011 also revealed the
eastward extension of the Umtanum Ridge-Gable Mount and Yakima Ridge faults
actually placed two “active” faults approximately 6.5 miles north of, and 2.3 miles south
of, the CGS reactor.

Energy Northwest Offers a Reply

Two months later, on September 17, 2010, Energy Northwest restated its position that
increased concerns about the earthquake safety of the WTP plant should have no
bearing on the CGS reactor. Energy Northwest continued to claim that there were
“distinct” geologic differences between the two sites and touted CGS’s “increased
distance from nearby seismic sources.” Company officials insisted its predictions of
peak ground motion were actually more conservative than required.

Energy Northwest’s fixation on dated data also freed the company to argue that any
faults near their atomic reactor were much farther away than the faults encroaching on
the Hanford’s troubled WTP. (This ignores the 2011 USGS finding that the reactor is
bracketed by two previously unknown “active” faults, one located only 2.3 miles to the

Still, the NRC appeared mollified. No new seismic structural upgrades were ordered at
the CGS.

A Litany of Shortcomings

On March 10, 2011, just a day before the Great Tohoku-Oki quake sent a tsunami
sweeping over Japan’s eastern coast, Energy Northwest received the latest in an
ongoing ebb-and-flow of letters related to its license renewal application. This NRC
missive challenged the sufficiency of the math the company had employed to assemble
its cost-benefit analysis of earthquake impact mitigations. The letter was in response to
several previous Requests for Additional Information (“RAI” in NRC-speak) all stemming
from a July 1, 2010 NRC request to review the company’s Severe Accident Mitigation
Alternatives (SAMA) planning for the CGS site.

Energy Northwest provided a partial response on September 17, 2010. The NRC then
sent two additional RAIs asking for clarification. Energy Northwest’s January 28, 2011
reply also left the NRC wanting. After months of back-and-forth correspondence, the
NRC fired of a letter on March 10, 2011 citing a litany of shortcomings in the renewal
application, including faulty tables, quantitative lapses and apparent inconsistencies.
The NRC asked the company to justify the calculations it had used to determine the
cost-benefit analysis of its earthquake preparations. The NRC noted that Energy
Northwest’s tables on fire and earthquake risks and remedies were unclear. A table on
handling severe accidents failed to “provide an analysis.” In an important section on
earthquake risks, “Neither seismically-induced failures nor random failures appear to be
addressed.” In three tables addressing “internal, fire, and seismic events,” the NRC
pointed out that “the percentage contributions presented… total to much less than
100%.” In another section of the application, the NRC criticized an assumption that
“could result in an underestimate of the estimated risk reduction for [Severe Accident
Mitigation Alternatives].”

An NRC ‘Walkdown’ Stumbles across Some Problems

In the summer of 2011, faced with the spectacle of three out-of-control GE reactors in
Japan spewing radiation into the planet’s oceans and atmosphere, the NRC announced
it was “requiring all power reactor licensees [to] reevaluate the seismic hazard and, if
necessary, update the design basis to protect against the updated hazards.”

On April 29, 2011, the NRC ordered all US reactor operators to provide updated
Seismic Reevaluations. But what looked like a swift response to a global tragedy was
undercut by the NRC’s timeline. Reactor operators were informed the reports would not
be due until March 12, 2015 — four years and a day after the Fukushima disaster.
In the meantime, the NRC directed its “resident inspectors” to complete post-Fukushima
safety surveys of all US reactor sites. The NRC’s initial inspection report on the CGS
was released on May 13, 2011. It noted a number of lapses, including a finding that the
Emergency Response Facilities, fire protection systems, floor drain isolation valves,
sump-valve switches, and the Tower Makeup “were not seismically qualified.” (The
“makeup” tower is designed to provide additional water to the cooling system to offset
any losses from evaporation, leaks or cooling system discharges. In the case of CGS,
this “make-up” cooling water must be drawn from the Columbia River, some three miles
away. Earthquakes would pose an additional threat to the pipes that carry CGS
reactor’s critical coolant more than 15,840 feet from river to reactor.)

The NRC also dispatched earthquake and flooding specialists to join resident inspectors
for post-Fukushima “walkdown” surveys of plant safety nationwide. (The “walkdown”
involves close physical inspections to determine if plant equipment is in good repair,
properly installed, and positioned to withstand damage during an earthquake.
Walkdowns are followed by less-rigorous “walkbys,” which rely on simple visual
inspection of the facilities.) The CGS Walkdown Report was completed on November
20, 2012 but the NRC refused to release the findings, citing “public security concerns.”

Under pressure from local activists (and other members of the public who had their own
“security concerns”), the government relented and released the report.

Out of 120 walkdowns conducted at the CGS, the NRC inspection documented “35
potentially adverse seismic conditions.” Additional “walk-by” inspections of 55 “unique
areas” identified 74 “potentially adverse seismic conditions.” (Remember, all of these
risk assumptions were based on the increasingly dubious 30-year-old premise that the
peak horizontal ground motion from a seismic shock was unlikely to top 0.25 g.)

Among the problems discovered during the inspections were:
• Missing concrete anchors from a surface-mounted support plate (only three of four
bolts installed);
• Improperly installed concrete anchors (crooked, with visible gaps between bolt heads
and plate surfaces);
• Bolts found missing nuts and washers;
• Serious corrosion on bolts and concrete anchors;
• Missing support clamps and bent flanges at bolted interfaces;
• Missing clamps on instrument tubing.

In a subsequent public relations blog dated July 31, 2012, the NRC gave some
examples of how the walkdowns worked to ensure that “protective features” were in
place to deal with earthquakes and floods. But, in at least one case, the inspectors
appeared to redefine a problem as a solution. “[C]onsider a watertight door protecting
against a flood,” the NRC blogged. “If a window two feet above the door could allow
floodwaters in, the site has two feet of available physical margin.” [Emphasis added.]
(This odd approach to flood safety seems as ill-advised as installing a window in a
seawall — on the theory that no waves would ever rise high enough to reach it.)

The History and Current Status of the CGS Reactor

Over the years, the CGS (like every other nuclear plant) has continued to experience
maintenance difficulties — some of which could prove problematic in the event of a
serious earthquake.

In 2001, the plant’s employees replaced 22 Westinghouse electric circuit breakers with
an incorrect model. Reporting on this slip-up more than a year later, an NRC inspection
report noted: “Sixteen of the breakers had important functions to play in power circuits
that operated four different safety systems at the plant, including emergency diesel
generators, standby service water pumps and emergency core cooling system pumps.”
The miss-matched breakers went undetected for nearly six months because, the NRC
reported: “No one noticed that the new breakers did not have the same dimensions as
the old breakers and didn’t fit properly in the power circuits.”

During an inspection in October 2002, the NRC was startled to find a seven-foot-tall
“man-lift” (a movable work platform similar to a cherry-picker) parked unattended near
the reactor vessel and a few feet from some control panels. The inspectors wrote that
the device “could have tipped against sensitive control room panels during a seismic
event” damaging the panel’s circuitry and necessitating an emergency reactor scram.

In March 2004, NRC inspectors discovered the nuts, studs or latches on 14 breakers
governing the plant’s safety systems were not properly secured and CGS’s operators
were cited for failure to verify “that all seismic restraints were properly configured.” The
NRC also expressed concern that CGS workers had missed several opportunities to
discover and correct the breaker errors between 2001 and 2004.

During a visit in August 2011, NRC inspectors found the control room was being used to
store rolling metal ladders, maintenance carts, unsecured bookcases and two 55-gallon
barrels, which were positioned dangerously close to a high-pressure core spray pump.
The barrels posed an “overturning hazard” that could have disabled the pump, which is
essential in handling the consequences of an earthquake. (The NRC called this an
example of one-of-many “long-standing issues” at the CGS reactor plant. Additional
instances of unsecured equipment found stored next to critical safety systems were
recorded in 2007, 2009 and 2011.)

And yet, as Paul Koberstein reported in the Cascadia Times, despite this history of
repeated, unattended and uncorrected errors, the NRC continued to permit Energy
Northwest to operate the CGS “at full power, under their clearly inadequate original
licensed earthquake standards.”

To Vent or Not to Vent

Fukushima also underscored the fact that the containment structure surrounding the
CGS Mark II reactor was too small to contain the buildup of extreme heat, pressure and
explosive hydrogen gas in the event of an incident. The NRC has acknowledged that
the Mark II containment capacity is only one-sixth the size of standard containment
structures in pressurized water reactors — like the PWR that suffered a partial
meltdown at Three Mile Island. (Note: The GE Mark I containment structure is even

Surprisingly, the NRC has been aware of this serious design flaw for more than 40
years — long before the Fukushima disaster – and these concerns eventually prompted
the NRC to recommend design modifications. In a February 1992 report on “Generic
Safety Issues,” the NRC expressed concern about the country’s Mark I and Mark II
containments. “Reactor pressure is anticipated to increase during a severe accident,
releasing steam and non-condensible gases into containment,” the report stated. With
this in mind, the NRC recommended the installation of hard pipe vents as a means of
“reducing risk” and avoiding “the probability of core-melt” in the event of a station

On March 19, 2013, in response to the potential threat of hydrogen gas explosions in
US-based Fukushima-style Mark I and Mark II containment structures, the NRC ordered
the operators of all 23 GE Mark I and eight Mark II boiling water reactors to install
“hardened” vents to help relieve internal pressures. Unfortunately, the NRC failed to
take the extra critical step of requiring radiation filters on these vents. While the NRC’s
own engineers recommended adding filters, the plan was opposed by nuclear
operators, who cited cost concerns.

The cost of adding filters to protect the public was estimated at $15 to $40 million per
reactor. “Given the added stress this places on the incumbent portfolio,” UBS Financial
Services concluded in a February 29, 2013 report, “the effort does not meet the usual
rigor of a quantitative cost-benefit analysis used to justify such investments.”

Paul A. Gunter of Beyond Nuclear, a Maryland-based nuclear watchdog group, called
the NRC’s decision not to require filters “would ‘firehose’ radioactive releases from an
accident into the local community and be a de facto violation of their own requirements
that all nuclear power plants have viable containment buildings” to protect public health
and safety against the uncontrolled release of radioactivity. The NRC’s General Design
Criterion specifically requires “an essentially leak-tight barrier against the uncontrolled
release of radioactivity to the environment.”

With this in mind, Beyond Nuclear called on the NRC to “shut down all GE BWR
reactors with Mark I and Mark II containments,” including Washington State’s CGS.
Under the NRC’s current rules, any future buildups of radioactive gases and “hot”
particles can be discharged into the atmosphere — and over downwind communities.
The containment design problem has been resolved by eliminating the requirement that
containment structures must actually contain explosive gases and nuclear radiation.

It’s something like promising to build an “escape-proof” prison and then overcrowding it
with rowdy inmates. When internal pressures threaten to erupt into a riot, prison
authorities rush to protect the prison structure by ordering the installation of escape
hatches for the prisoners.

NRC Commissioner Allison Macfarlane explained why she cast the lone vote to require
filters to keep radiation from pouring into the outside winds: “My decision reflects, in
part, my experiences during a recent trip to the Fukushima Daiichi plant in Japan. The
visit to the reactors required travel through deserted villages, full of abandoned homes
and businesses overgrown with weeds, and past fallow fields, and unused industrial
buildings, roads and railroad tracks, all of which emphasized the impact of the accident
from a nuclear plant that was over 10 kilometers [6.2 miles] away.”

In March 2013, the NRC ordered plant operators to install hardened vents at 31 US
reactors. The cost to Energy Northwest was estimated to range between $25 and $30
million. Energy Northwest says it plans to install the vents during the next fuel outage in
2015 or in 2017. The new vents will not have filters.

“It (Most Likely) Can’t Happen Here”

On March 12, 2012, the first anniversary of the Fukushima disaster, the NRC issued an
Order to Modify Licenses that required all nuclear plant operators to prepare plans and
safety improvements to deal with “Beyond-Design-Basis External Events.”

“The events at Fukushima Daiichi highlight the possibility that extreme natural
phenomena could challenge the prevention, mitigation and emergency preparedness
defense-in-depth layers,” the NRC wrote. This meant “additional requirements must be
imposed to mitigate beyond-design-basis external events.” But in the next breath, the
NRC decreed “continued operation does not pose an imminent risk to public health and
safety.” The NRC then declared: “additional requirements are needed to provide
adequate protection to public health and safety.” These statements stand in apparent

The NRC attempted to resolve the conundrum thusly: “A sequence of events such as
the Fukushima Daiichi accident is unlikely to occur in the US. Therefore continued
operation and continued licensing activities do not pose an imminent threat to public
health and safety.”

Former NRC Chair Gregory Jaczko took exception to this approach during an October
10, 2013 conference on the Fukushima catastrophe. “[Fukushima] is telling us that
severe accidents can and most likely will happen at some point.” Jaczko warned.
“Society does not ultimately find it acceptable to evacuate hundreds of thousands of
people, to have areas of land permanently contaminated, to spend half-a-trillion (or
more) dollars to deal with the aftermath of an accident at a facility that is simply
designed to generate electricity. For nuclear power plants to be considered safe…,
power plants should not be able to create accidents like this.”

The NRC concluded its March 12 memo by trumpeting the Commission’s “fundamental
regulatory objectives” — to wit: “Reasonable assurance of adequate protection of the
public health and safety.” [Emphasis added.] When it comes to protecting the public
from hydrogen explosions, core meltdowns and panicked evacuations to avoid clouds of
radioactive fallout, is “reasonable” and “adequate” assurance the best the NRC can
provide? One would hope the NRC’s overriding “regulatory objective” would be to
guarantee absolute assurance of the best protection of public health and safety.

The NRC ordered CGS’s operators to provide a list of strategies “to respond to extreme
natural events resulting in a loss of power” by February 13, 2013. Energy Northwest’s
plans remain a mystery since the NRC has withheld the report from the public citing
“security reasons.” The Oregon and Washington PSR chapters have filed a Freedom of
Information Act request to gain access to this plan.

CGS and GE’s Forgotten History of Fraud

(For More See Investigative Reports)

On April 3, 2013, an investigative team at Cascadia Times produced a stunning report
on “The Long Tragic Trail of Failed General Electric Nuclear Reactors.” The
investigation unearthed evidence of corporate cover-ups that extended as far back as
the 1950s. The article was based, in part, on court records from a 1985 lawsuit that
charged GE with intentionally selling boiling water reactors that GE knew contained
critical design flaws. Specifically, the reactor’s undersized containment shell was too
weak to prevent an explosion of hydrogen gas that might build up during a Loss of
Coolant Accident.

In 1985, four different nuclear operators sued GE for fraud, misrepresentation and
breach of contract, accusing the company of selling flawed reactor designs the
company knew were unsafe. One of the litigants was the Washington Public Power
Supply System and the reactor at the heart of its lawsuit was the Columbia Generating
Station. WPPSS sought $1.2 billion in damages.

During the disclosure process, GE was forced to turn over evidence that revealed the
company had been aware of potentially fatal flaws in the Mark I and II designs for at
least 10 years — and possibly since the very start of its reactor program dating back to

The evidence came in the form of numerous memos from GE’s own engineers who
repeatedly expressed concern that the reactors’ pressure containment shells were likely
to fail during an accident, leading to explosions that would pour dangerous clouds of
radiation over nearby lands and waterways. GE admitted it had a problem in 1974 when
officials confided to the industry journal Engineering News-Record that its Mark II
containment vessel “could be subjected to ‘newly discovered’ physical loads that could
structurally damage the steel containment and the equipment inside it.”

Documents disclosed during the trial revealed that GE had been assigning engineers to
try to fix the design problems since 1958. All the while, GE continued promoting sales of
its reactors to companies in the US and around the world.

How could General Electric justify such a practice? According to the Cascadia Times,
GE officials apparently assumed they would eventually find a way to fix the problematic
reactors. And, when they did, “the utilities would have to hire GE to fix them.”
Federal Judge Alan A. Anderson presided over the Washington State trial. After
reviewing the evidence, Anderson concluded that GE “hid serious doubts” about the
safety of the reactor it sold to WPPSS.

“The concealment constituted bad faith and nullified [a] contract provision limiting GE’s
liability,” Judge Anderson concluded. “The Court can only view [GE’s policies] as a fairly
sophisticated form of Russian roulette.”

The initial lawsuit ended in a mistrial, with Judge Anderson ruling that WPPSS could file
a subsequent complaint against GE charging “negligent misrepresentation” rather than
“fraud.” In 1992, GE opted to settle out-of-court with an offer of $134.9 million in “goods
and services.” To sweeten the deal, GE offered to provide WPPSS with $16.5 million
worth of extra electricity per year. And how would GE provide this bonus power? By
increasing the power output of its flawed CGS reactor by 50 megawatts.

Thirty-seven years after GE’s quiet, in-house admission to Engineering News-Record,
the very disaster its engineers had predicted, took place inside three GE reactors at

Taking it to the NRC

On March 12, 2012, with the Fukushima disaster clearly in mind, the NRC requested
that all nuclear plant operators provide detailed “Mitigation Strategies for Beyond Design
Basis External Events.” Energy Northwest was ordered to deliver an Overall Integrated
Plan by February 28, 2012. When the deadline came around, Energy Northwest
informed the NRC that its strategies were “preliminary,” “not yet finalized,” and “subject
to change as strategies, procedures, and modifications are finalized and equipment is
procured.” Energy Northwest promised to advise the NRC of any “significant changes to
the plan or the proposed schedule” in “subsequent status reports.”

So what plans did the company develop to prevent a Fukushima-scale disaster from
occurring at the CGS? That remains unknown because, as A. L. Javonik, Energy
Northwest’s Vice President for Engineering, informed the NRC: “Energy Northwest
believes that this submittal contains some information that should not be made publicly
available.” The company therefore requested that its plans for handling a Beyond
Design Basis challenge “be withheld from public disclosure.”

In an earlier letter dated October 25, 2012, Energy Northwest assured the NRC that the
“implementation” of its order would be completed prior to the reactor’s restart following a
refueling outage scheduled for May 1, 2015 — more than four years after the
Fukushima meltdowns.

As previously mentioned, on March 21, 2013, Beyond Nuclear, the Oregon and
Washington PSR chapters, and 22 other citizens’ groups filed a citizens’ petition with
the NRC demanding the revocation of operating licenses for all fatally flawed GE
reactors with Mark I and Mark II containments. It seemed a reasonable request. The
NRC’s Japan Lessons Learned Task Force had already concluded that the GE reactors
were prone to “early containment failure” in the event of “a severe nuclear accident.”

The first petition review board hearing was held on May 2, 2013.

At that meeting, a delegation of anti-nuclear experts filed a complaint that the NRC had
“rejected its own staff cost benefit analysis that the filtered containment vent was
justified.” (They also let the hearing officer know that their documentation had been
forwarded to the Office of the Inspector General.)

On June 17, 2013, the Petition Review Board announced that it saw no need to
entertain the call to revoke the licenses of North America’s 31 Fukushima-model GE
Mark I and Mark II reactors.

An Appeal to Macfarlane

On July 4, 2013, PSR’s Oregon and Washington chapters sent a letter to Commissioner
Macfarlane outlining their concerns about heightened earthquake risks at the Hanford
Nuclear Reservation and the potential implications for the CGS reactor.

The concerned activists were hopeful of a positive response, given some of
Macfarlane’s recent press statements. On March 19, 2013, Macfarlane criticized a costbenefit
analysis because NRC staff “did not include the potential costs of offsite
releases similar to those experienced by Japan after the Fukushima accident.” On
another occasion, Macfarlane observed: “We don’t know everything about how the
Earth behaves, and we must factor this into how we approach nuclear safety.”

Even more remarkable, according to a New York Times report, Macfarlane marked
Fukushima’s second anniversary with a speech on March 12, 2013, in which she
declared “the current generation of reactors has already outlived the theory of geology
that was prevalent when their sites were chosen…. They predate wide acceptance of
the theory of plate tectonics — the view that the Earth’s crust is made up of plates that
rub and slip against one another.”

Three months later, on October 1, Macfarlane sent a reply. In her letter, she simply
noted that the NRC “continues to conclude that CGS has been designed, built, and
operated to safely withstand earthquakes likely to occur in its region.” The PSR
chapters were naturally disappointed that Macfarlane failed to address the issue of
troubling geologic data, “some of which has been widely known to Washington state
geologists for over a decade.”

(It’s not as if the NRC doesn’t realized the dangers. In an email dashed off to colleagues
four days after the Fukushima quake, Brian Sheron, head of the NRC’s Office of
Nuclear Regulatory Research, referenced some of the alarming findings about new fault
hazards in Central and Eastern Washington. This data, Sheron wrote, demonstrated the
NRC “didn’t know everything about seismicity…. And isn’t there a prediction threat the
West Coast is likely to get hit with some huge earthquake in the next 30 years or so?
Yet we relicense their [nuclear] plants.”)

On November 23, 2013, Beyond Nuclear Director Paul Gunter reached out to
Washington State Representative Gerry Pollet to support a request for a formal inquiry
into the safety of the CGS plant. Pointing to the same “containment vulnerability
responsible for multiple catastrophic failures at Fukushima,” Gunter warned of a pattern
of pro-nuclear “regulatory protectionism” that pervades both Tokyo and Washington and
“places the public at undue and unacceptable risk.”

In written testimony to the NRC, Charles K. Johnson, director of the Joint Task Force on
Nuclear Power for the Oregon and Washington chapters of PSR, laid out a number of
critical concerns. These included:

(1) “Demonstrably inadequate containment structures” that had contributed to the
ongoing radioactive calamity in Japan. The meltdown of three GE-designed reactors
provided proof that continued operation of the flawed CGS plant violates the NRC’s
obligation that licensees guarantee “an essentially leak-tight containment against the
uncontrolled release of radioactivity.”

(2) An earthquake-triggered accident at the nearby Hanford Nuclear Reservation would
spawn a cloud of radioactive fallout that could spread to the CGS, causing the site “to
become so radioactively hot that operators might be at immediate health risk.”

(3) Failure of the Grand Coulee dam, due to a quake, would flood the region and cut
power to the reactor site. Flood damage to the reactor’s water-intake systems and
access roads would amplify the dangers and complicate the ability to respond. (The
CGS is one of 34 reactors — one third of the US fleet — at risk from the collapse of
upstream dams. A 41-page study that revealed the danger was suppressed by NRC
officials. It only came to light after two NRC whistleblowers leaked the report. In
September 2013, Public Employees for Environmental Responsibility sued the NRC to
force release of agency studies on the risks of dam failures. PEER argued that the
probability of a massive dam failure destroying a US nuclear plant “is higher than the
probability of the Fukushima tsunami.”)

(4) The failure to consider new seismic data during the May 2012 relicensing hearings
constituted another example of the NRC’s ongoing standard of lax “regulatory

(5) The NRC’s decision to ignore the “lessons of Fukushima” and the advice of its own
staff by requiring reactor operators to add hardened vents to Mark I and Mark II
containment structures but not requiring that the vents include filters to trap radioactive
gases and particles. Hardened vents equipped with filters have become the new post-
Fukushima standard in Finland, Germany, Japan, Switzerland, Sweden and Taiwan.

Refusing to be rebuffed, Beyond Nuclear, the PSR chapters and the other petitioners
subsequently utilized the NRC’s Management Directive 8.11 to gain one further
opportunity to argue its case. The NRC has yet to reply to the request.

Meanwhile, on December 14, 2013, the NRC announced that it would grant critics
calling for the shutdown of the CGS reactor the right to hearings as part of a formal
petition process before the NRC’s Petition Review Board.

The “breakthrough” was a necessary-but-not-sufficient step forward. “We didn’t ask for a
petition,” one activist lamented, “We asked for a shutdown based on the earthquake
information.” So, instead of a proactive response to a potentially grave threat, “the NRC
has decided to put us into a slow petition process.”

But if it’s a slow process to challenge the safety of a flawed and aging reactor built in the
midst of an earthquake haven, it’s another matter when it comes to expediting the
continued operation of the same facility.

NRC Relicenses CGS for another 30 Years

On May 22, 2012, the NRC relicensed the nearly 30-year-old CGS reactor to continue
operating for another 30 years. The new license was granted despite the fact that the
plant’s seismic evaluation was still in the works. Meanwhile, news coverage of
Fukushima’s three nuclear meltdowns provided a stark reminder of what fate might have
in store for the CGS General Electric Mark II reactor.

What was not reported in the media’s coverage was the fact that anti-nuclear activists in
Japan had repeatedly warned of the specific dangers posed by the Fukushima reactors.
Their complaints eerily foreshadowed the very problems that have given rise to
concerns about the CGS. AiIeen Mioko-Smith, the director of Green Action, Japan’s
leading anti-nuclear organization, noted that TEPCO’s reactors were “operating on 1978
earthquake-resistant guidelines” and ignoring more recent studies that revealed greater31
than-imagined seismic dangers. “Tokyo Electric’s analysis of the earthquake magnitude
potential at the Daiichi site was unscientific and grossly underestimated,” she charged.”The study’s main technique considered fault lines as short and separate threats when
they were clearly parts of a much larger system.”

At CGS, as at Fukushima, the facility was designed to store dangerously radioactive
spent fuel rods in a pool placed near the top the structure, 100 feet above the ground.
Pointing to the trouble-plagued Fukushima cleanup, Steven Gilbert, a toxicologist and
president of Washington’s PSR chapter, underscored the parallel risks at the CGS: “If
an earthquake cracked that spent-fuel facility, we could have a Fukushima-like scenario
on our hands.”

A collapse of the spent fuel pool atop Fukushima’s damaged Unit 4 building could spill
1,500 new and used fuel rods. The ignition of Unit 4′s 400 tons of radioactive fuel
assemblies could release 15,000 times the amount of radiation produced by the atomic
bomb that destroyed Hiroshima. All told, there are more than 11,000 fuel assemblies
scattered about Fukushima. Former DOE official Robert Alvarez estimates these fuel
assemblies contain more than 85 times as much lethal cesium as was released at

The CGS has 27 steel and concrete casks to store used nuclear fuel on site. Each cask
holds 68 fuel assemblies. The water-cooled spent fuel pool high up in the CGS
containment building was designed to accommodate 2,658 fuel assemblies. As of 2013,
the storage pool was reported to be two-third full. This would total more than 1,700 fuel
assemblies — more than are at risk at the Unit 4 site in Fukushima.

Unfortunately, the massive, ongoing (and still-uncontrolled) radiation spills seeping and
venting from the damaged Fukushima reactors appears not to have prompted an
“excess of caution” from officials at the NRC or Energy Northwest. In October 2013,
Dave Swank, vice president of engineering at Energy Northwest, assured the media: “I
don’t have any concerns.” Echoing the NRC, Swank explained there was no cause for
undue alarm because the “odds” of a major quake were low. Swank also quoted from
Macfarlane’s letter to PSR in which she maintained “the NRC continues to conclude that
CGS has been designed, built and operated to safely withstand earthquakes likely to
occur in its region.”

Unfortunately, these reassuring words don’t hold up when you look beneath the surface
— which is exactly what a team of citizens and scientists have done. On October 31,
2013, John Pearson, MD and Steven G. Gilbert, PhD, fired off an eight-page letter to
Macfarlane on behalf of the Oregon and Washington chapters of PSR.

“We need to know what data you are using as the basis for your conclusion,” they
wrote. “From what we can gather from your letter, the NRC, under your leadership, has
no intention of independently evaluating readily available geological evidence about the
increased seismic potential of the CGS-Hanford site until after receiving Energy
Northwest’s report.”

“All of this evidence leads us to urge you to fulfill your mandate as nuclear regulators
and put the safety of the public… above the utility’s interests,” Pearson and Gilbert
wrote. They concluded by calling on Macfarlane to shut down the CGS reactor “until it
can be shown that it meets adequate earthquake standards.”