By Mark Leyse
Dear Chairman Burns:
You and the Commissioners approved the publication of the Nuclear Regulatory Commission’s decision to deny proposed regulations on improving evaluations of spent fuel pool fires, provided that the Staff’s draft of the decision was “subject to the attached edits.”
But what were the “edits” that you insisted upon? The “edits” were the censoring of a few pages on the science of spent fuel pool fires. The censored pages discussed the fact that the nitrogen content of air would intensify a spent fuel pool fire.
Of course, the term “spent fuel pool fire” is informal. In a fire, strictly speaking, there wouldn’t be any nitriding, only burning (oxidation). What we call a spent fuel pool fire would occur if the highly-radioactive, discharged (spent) fuel assemblies stored in a pool were uncovered by cooling water and heated up enough (from decay heating, generated by fission products) to ignite. The zirconium cladding of the fuel assemblies would then chemically react with oxygen and nitrogen.
A spent fuel pool fire could expose millions of people to large doses of ionizing radiation, which damages human tissue. A recent study by Frank von Hippel and Michael Schoeppner of Princeton University found that a major fire could contaminate as much as 100,000 square kilometers of land and force the evacuation of millions.
In the petition for rulemaking (with proposed regulations) on spent fuel pool fire evaluations, I (the petition’s author) pointed out that the NRC’s computer model for evaluating spent fuel pool fires (MELCOR) is flawed because it doesn’t simulate the effects of nitrogen. I alleged that your MELCOR computer model under-predicts the severity of spent fuel pool fires. I asked that MELCOR be improved; mainly, that it simulate the effects of nitrogen.
Incidentally, a May 2016 National Academy of Sciences report, which discusses spent fuel pool fire evaluations, points out that MELCOR “cannot model nitriding reactions with zirconium.”
The NAS report recommends improvements to MELCOR, including: “Modeling the thermal and chemical behavior of spent fuel assemblies in partially drained pools.” I essentially asked for the same things when I submitted my petition in June 2014.
Among the sentences that you and the Commissioners redacted from the Staff’s draft was the simple statement: “The NRC recognizes that the phenomena discussed in the petition are important to realistically evaluate the initiation and progression of SFP fires in the unlikely event of a beyond design basis accident.”
Isn’t that something? The NRC recognized phenomena discussed in my petition are important to realistically evaluate spent fuel pool fires. So why did you deny the petition?
I would guess you denied it because you’d rather have unrealistic evaluations of spent fuel pool fires. A realistic evaluation would show that discharged fuel assemblies should promptly be removed from spent fuel pools and placed into dry cask storage (as the Union of Concerned Scientists has recommended for years). But the industry you appear to serve wouldn’t like that, as it’d cost millions.
Never mind that the US is particularly vulnerable to spent fuel pool fires because its storage pools are overpacked (almost as densely as reactor cores). Thinning out pools would help improve public safety. Germany started doing it 30 years ago; the US still doesn’t. And computer simulations that under-predict the severity of spent fuel pool fires help “justify” keeping US pools overpacked.
You and the Commissioners also redacted the following statement from the Staff’s draft: “Nitriding is most relevant when nuclear fuel is undergoing a severe accident in an air environment and oxygen-starved conditions develop because of rapid consumption of oxygen from the air.”
That censored statement sums up one of the primary reasons why I submitted my petition. I cited reports asserting that the cladding of fuel assemblies degrades quickly when oxygen isn’t present and the effects of nitrogen prevail.
Instead, of publishing scientific statements, you published dogmatic platitudes like: “The MELCOR computer code…represents the current state of the art in severe accident analysis.”
Meanwhile, back in 2000, Dana Powers, Chairman of the ACRS, wrote a letter to NRC Chairman Richard Meserve, complaining that the NRC’s evaluations of spent fuel pool fires didn’t consider the effects of nitrogen. Sixteen years ago, he said the evaluations “relied on relatively geriatric work.”
Chairman Burns, if you really think MELCOR’s so great, why did you resort to redacting information on the science of spent fuel pool fires when you denied my petition?
Why do you insist on censorship, when the NRC professes to embrace transparency and open government?
Chairman Burns, you undermine the NRC’s policy of public participation through your acts of censorship. As a member of the public, if you deny a petition, I expect it to be a science-based decision, not a decision based on saving industry money.
I have actually submitted a petition that the NRC accepted (PRM-50-84). In 2012, the NRC Commissioners voted unanimously to approve a proposed rulemaking—revisions to Section 50.46(b), which will become Section 50.46(c)—that is partly based on the safety issues I raised in PRM-50-84.
In her comments for the Commission Voting Record, Chairwoman Allison Macfarlane wrote: “Finally, I want to highlight that a portion of this proposed rulemaking…is the result of a petition for rulemaking submitted by a member of the public, Mr. Mark Leyse. I’m encouraged by continued public participation in our regulatory processes and I believe it’s particularly important that we highlight the contributions of members of the public to the agency’s mission.”
Chairman Burns, your predecessor encouraged public participation. You suppress it. As a member of the public, who spent weeks researching and writing the petition on spent fuel pool fire evaluations, I personally resent the way you disrespect science and the efforts of the public.
Even worse, much worse, your cynical actions undermine public safety. The NRC has used the results of unrealistic MELCOR simulations to justify not expediting the transfer of spent fuel from pools to dry cask storage. This endangers the very public that the NRC is congressionally mandated to protect.
About the author: Mark Leyse is a nuclear safety consultant who has written reports about nuclear power accidents for Natural Resources Defense Council as well as written enforcement action petitions against Indian Point Nuclear Plant on behalf of Riverkeeper and NRDC. Leyse also coauthored a paper on evaluations of reactor loss-of-coolant accidents that was presented at the American Nuclear Society’s 2009 Winter Meeting.
 The censored Federal Register notice is in the April 4, 2016 Commission Voting Record, SECY‑15‑0146, Denial of Petition for Rulemaking Requesting Amendments Regarding Spent Fuel Pool Severe Accident Evaluations (PRM-50-108; NRC-2014-0171). (available at: http://www.nrc.gov/docs/ML1610/ML16103A375.pdf : last visited on 08/29/16)
 Richard Stone, “Spent fuel fire on U.S. soil could dwarf impact of Fukushima,” Science, May 24, 2016. (available at: http://www.sciencemag.org/news/2016/05/spent-fuel-fire-us-soil-could-dwarf-impact-fukushima : last visited on 08/30/16)
 Mark Leyse, petition on spent fuel pool fire evaluations, PRM-50-108, June 19, 2014. (available at: http://www.nrc.gov/docs/ML1419/ML14195A388.pdf : last visited on 08/29/16)
 National Academy of Sciences, “Lessons Learned from the Fukushima Nuclear Accident for Improving Safety and Security of U.S. Nuclear Plants: Phase 2,” May 2016. (available at: http://www.nap.edu/catalog/21874/lessons-learned-from-the-fukushima-nuclear-accident-for-improving-safety-and-security-of-us-nuclear-plants : last visited on 08/29/16)
 Union of Concerned Scientists, “Safer Storage of Spent Nuclear Fuel.” (available at: http://www.ucsusa.org/nuclear-power/nuclear-waste/safer-storage-of-spent-fuel#.V8RLx5grLcu : last visited on 08/29/16)
 Robert Alvarez, “Spent Nuclear Fuel Pools in the U.S.: Reducing the Deadly Risks of Storage,” Institute for Policy Studies, May 2011. (available at: http://www.ips-dc.org/wp-content/uploads/2011/05/spent_nuclear_fuel_pools_in_the_US-final.pdf : last visited on 08/29/16)
 NRC, “Fuel-Cladding Issues in Postulated Spent Fuel Pool Accidents,” PRM-50-108, NRC-2014-0171, Federal Register, Vol. 81, No. 93, May 13, 2016 (available at: https://www.gpo.gov/fdsys/pkg/FR-2016-05-13/pdf/2016-11212.pdf : last visited on 08/29/16)
 Dana Powers’s letter to Chairman Richard Meserve, “Draft Final Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants,” April 13, 2000. (available at: http://www.nrc.gov/docs/ML0037/ML003704532.pdf last visited on 08/29/16)
 Mark Leyse, PRM-50-84, March 15, 2007. (available at: http://www.nrc.gov/docs/ML0708/ML070871368.pdf : last visited on 08/29/16)
 January 7, 2013 Commission Voting Record, SECY-12-0034, Proposed Rulemaking 10 CFR 50.46(c): Emergency Core Cooling System Performance during Loss-of-Coolant Accidents (RIN 3150-AH42). (available at: http://www.nrc.gov/reading-rm/doc-collections/commission/cvr/2012/2012-0034vtr.pdf : last visited on 08/29/16)
 NRC, “Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S. Mark I Boiling Water Reactor,” NUREG-2161, September 2014. (available at: http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr2161/: last visited on 08/29/16)
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