In the retail business, the tactic is called “bait and switch.” It’s a tactic the Union of Concerned Scientists utilized recently at its blog “All Things Nuclear.”
UCS attempted to sway the Nuclear Regulatory Commission through a blog post to maintain certain engineering inspections as part of the commission’s Reactor Oversight Process rather than adopt the industry suggestion which is to use self-assessments for these inspections.
But in doing so, UCS not only erred, they omitted key facts in their example, which involves Energy Northwest’s Columbia Generating Station.
Energy Northwest installed seismic category I, environmentally qualified chillers (air conditioners) as required by Columbia’s original licensing basis. The chillers are safety-related and are designed to be manually operated for cooling the control room. This design has been reviewed by the NRC over the years.
It is factual that EN has received two violations on the emergency chillers. The first violation was in 2013 due to changes that had been made to the final safety analysis report in 1988 and 1989 when a change was made from temperature to effective temperature (or wet bulb temperature). This violation was for not obtaining proper NRC permission for the change, not for chiller performance. The issue was resolved by simply removing the term “effective temperature” from the report.
The second issue was due to the fact that no analysis existed for the period of time between the need for the emergency chiller and the manual start. Again this violation was for a lack of analysis, not for chiller performance. This was resolved by simply providing the analysis. The third violation mentioned in the UCS blog is for the service water cooling coil testing and is not related to the emergency chillers or the licensing basis.
Bait and switch
The title of the UCS blog is “Why NRC inspections are necessary” and specifically addresses NRC’s review of the “engineering inspections” performed as part of the ROP. But the three violations mentioned were identified by the NRC resident inspector, as a normal function of the resident program. The NRC maintains at least two resident inspectors on site for each operating U.S. reactor site. So the issues referenced in the UCS blog were identified by the onsite NRC resident inspectors as part of their normal plant inspection activities, which are not affected by or related to the NRC’s review of the engineering inspections.
Columbia Generating Station has had engineering inspections performed by teams of inspectors from the NRC regional office. So why did UCS not reference those? Because they did not provide the fodder UCS needed to push its agenda.
To wit, this year alone, the NRC performed three engineering team inspections at Columbia including Heat Sink Performance, Inservice Inspection Activities, and Evaluations of Changes, Tests and Experiments (10 CFR 50.59). No findings of more than minor significance were identified. The last five inspections of “Changes, Tests and Experiments” identified no violations of more than minor significance for 10 CFR 50.59. The Component Design Basis Inspection performed in 2016 identified one non-technical violation and also identified that Columbia’s performance was stronger compared to the industry.
Since those examples would not make the case the UCS wanted to make, they simply chose an unrelated issue and added the usual anti-nuclear flavoring.
For instance, Dave Lochbaum writes, “Owners are responsible for conforming with applicable regulatory requirements. In this case, the owner made a series of changes that resulted in the plant not conforming with applicable regulatory requirements for the air temperature within the control room.”
Sounds ominous. The truth is in September 1989, the revised FSAR to change the control room air temperature limit to 85°F was reviewed by an NRC regional team inspection and found to be satisfactory. It was later identified by the resident inspector in 2013 to be unsatisfactory. That’s all.
(Posted by staff)