Myths and Facts about Small Modular Reactors (SMRs)

Transcription

1 NUCLEAR ENERGY INSTITUTE Myths and Facts about Small Modular Reactors (SMRs) On June 7, 2011, the Senate Energy and Natural Resources Committee held a hearing on S. 512, The Nuclear Power 2021 Act, co-sponsored by committee chairman Jeff Bingaman (D-NM) and ranking member Lisa Murkowski (R-Alaska). The legislation would support development of small modular reactors (SMRs). Among the witnesses was Edwin Lyman, a staff member at the Union of Concerned Scientists. The UCS testimony contains a number of inaccuracies. The UCS statement seems to assume throughout that the Nuclear Regulatory Commission (NRC) will not discharge its statutory obligation to protect public health and safety. Such an assumption is insupportable and has no basis in fact. All the evidence over almost 40 years of operation demonstrates that NRC takes its statutory mandate and safety obligations very seriously. In addition, the UCS statement frequently uses hypothetical assertions to lead to a conclusion. For example, UCS observes: [N]ew reactor designs that have inherent safety features not present in current reactors may not actually end up being safer in the final analysis if designers compensate by narrowing safety margins in other areas [and] if the NRC allows SMR owners to reduce emergency planning zones and the numbers of operators and security officers per reactor. (Emphasis added.) There is no evidence that reactor designers are reducing safety margins; nor is there any evidence that NRC plans to reduce emergency planning requirements. The UCS comment is akin to saying that automobiles would be significantly less safe if they were not equipped with brakes or steering mechanisms. It is a true statement, but pointless. This paper identifies the major mistakes and misstatements in UCS testimony, and provides the facts.

2 UCS statement: If we want to reduce the risk of another Fukushima in the future, new nuclear plants will have to be substantially safer than the current generation. The Facts: This statement implies that the nuclear power plants now operating are not safe enough, which is not correct. The statement also reflects a lack of understanding about (1) the NRC s statutory mandate, and (2) the causes of the Fukushima accident: First, the current generation of nuclear power plants is safe and meet all NRC requirements and regulations which, taken together, provide assurance that public health and safety will be protected. NRC inspections since the Fukushima accident have confirmed this. It is also true that improvements and advances in reactor design over the last several decades have produced new nuclear reactor designs both large and small reactors that are significantly safer than operating nuclear plants. This does not mean the operating nuclear plants are unsafe. It simply means that the advanced designs offer even higher levels of safety. This is partly because the advanced reactor designs (including the SMRs) are simpler than the current generation of operating plants. They rely less on engineered safety features (so-called active safety systems like pumps and motors), and rely instead on natural safety features (so-called passive safety systems like gravity feed of cooling water in the event of loss of electrical power, and natural convection to carry away heat). Finally, the Fukushima accident was not caused by flaws in reactor design as much as by plant configuration and layout that would not be acceptable in the United States (e.g., failing to design for a tsunami that appeared to be a credible event; placing emergency diesel generators where they could be submerged and disabled; placing fuel oil tanks for emergency generators in areas where they could be washed away; placing vital electrical equipment and switchgear in areas susceptible to flooding that would disable the equipment). In addition, there are many differences between nuclear power in the United States and Japan. For example: 1. The United States has an independent regulatory agency with 4,000 employees and a $1- billion-a-year budget and resident inspectors at each U.S. nuclear power plant. Japan has no comparable institution or regulatory resources. 2. The United States has an industry-funded organization the Institute of Nuclear Power Operations (INPO) with a $100-million-a-year operating budget that is dedicated to excellence in nuclear power plant operations. Japan has nothing comparable to INPO. INPO was recognized by the President s independent commission on the Deepwater Horizon offshore oil accident as a model for achieving high levels of safety and excellence in operations. 3. After the terrorist attacks on September 11, 2001, the U.S. nuclear energy industry took steps to ensure that its nuclear power plants could be shut down safely and maintained in a safe condition, even during extreme events e.g., terrorist attacks using aircraft and loss of large areas of the plant due to fires and explosions. Japan did not take these steps. UCS statement: Unless they are carefully designed, licensed, deployed and inspected, SMRs could pose greater safety, security and proliferation risks than large reactors. Small Modular Reactors: Myths and Facts 2

3 The Facts: This statement appears designed to create alarm by raising the prospect of a situation that will never arise. Of course, SMRs (or any nuclear reactor) could pose greater risks if they are not carefully designed, licensed and deployed. SMRs will, however, be designed, licensed and built carefully in compliance with Nuclear Regulatory Commission requirements and regulations for design, licensing and construction. Those regulations and requirements, the most prescriptive of any regulatory authority in the world, ensure protection of public health and safety and the environment. UCS statement: Because nuclear reactor costs follow the principle of economies of scale, smaller reactors will begin with a large economic disadvantage. The Facts: UCS here implies that SMRs will not be economic, and cites a 2007 paper by Westinghouse scientists that allegedly supports this point. The paper cited by UCS does not conclude this, however. That 2007 paper found: This paper identifies and briefly discusses the various factors which, beside size (power produced), contribute to determining the capital cost of smaller reactors and provides a preliminary evaluation for a few of these factors. When they are accounted for, in a set of realistic and comparable configurations, the final capital costs of small and large plants are practically equivalent. (Emphasis added.) UCS statement: [T]he SMR industry is seeking to reduce operating and maintenance (O&M) costs by pressuring the Nuclear Regulatory Commission to weaken certain regulatory requirements for SMRs. For example, the industry argues that regulatory requirements for SMRs in areas such as emergency planning, control room staffing and security staffing can be weakened. The Facts: The nuclear energy industry is not pressuring the NRC to weaken regulatory requirements for SMRs. Small reactors will meet or exceed all of the NRC s safety and security goals and requirements. Today s regulations are designed to ensure that large, light water cooled reactors achieve these requirements. Tomorrow s small reactors may need new or modified regulations to ensure they also meet or exceed these safety and security goals and requirements. The industry and, presumably, other stakeholders are working with NRC to define the regulatory requirements for SMRs. This work is at a relatively early stage and no conclusions have been reached, either by NRC or the industry. The NRC and the industry have identified a number of generic regulatory issues including license fees, decommissioning funding assurance, emergency planning requirements, security, control room staffing, loss of large areas of the plant due to terrorist activity and a number of others that should be considered when developing the licensing framework for SMRs. The industry is developing position papers on many of these issues, and discussing them with NRC staff. These discussions between NRC and the industry are conducted in public meetings open to all. Based on these discussions and its own analysis, NRC staff will develop the licensing and regulatory requirements for SMRs that, in its view, would protect public health and safety. These Small Modular Reactors: Myths and Facts 3

4 requirements will be subject to review by (among others) NRC senior management, the NRC s Advisory Committee on Reactor Safeguards, and the NRC commissioners before they are finalized. Since these regulatory requirements will be promulgated as rules, they will also be subject to public review and comment before being finalized. The industry does believe that regulatory and licensing requirements should reflect the unique characteristics of SMR designs, to the extent they differ from the large thousand-megawatt-class plants. In the case of emergency planning, for example, the nuclear industry has not proposed any reduction in the size of the 10-mile emergency planning zone. The nuclear industry is developing a risk-informed framework to establish what actions must be taken within an emergency management zone based on the risk of a given SMR design. The risk of a given design would be based on many factors, including source term (simply put, the radioactive inventory associated with any given reactor); accident sequence; and design features that would delay and/or mitigate the amount of radioactivity available for release. Different designs might have different requirements within the zone. The nuclear industry is not seeking weaker requirements. Where appropriate, the industry is pursuing requirements that reflect the unique characteristics of SMRs. UCS statement: The Nuclear Regulatory Commission has a long-standing policy that new nuclear reactors, large or small, are not required to be safer than operating reactors. One consequence of this policy is that new reactor designs that have inherent safety features not present in current reactors may not actually end up being safer in the final analysis if designers compensate by narrowing safety margins in other areas, such as by reducing containment strength or the diversity and redundancy of safety systems. Any safety advantages will be eroded further if the NRC allows SMR owners to reduce emergency planning zones and the numbers of operators and security officers per reactor. (Emphasis added.) The Facts: NRC s statutory mandate is to ensure protection of public health and safety. That statutory obligation does not change with reactor design. Every reactor licensed to operate new or operating or not yet built, large or small must meet the NRC requirements and regulations appropriate to that design and necessary to protect public health and safety. That said, SMRs (and the advanced thousand-megawatt-class designs like the Westinghouse AP and the GE-Hitachi ESBWR ) being developed and deployed are safer, as UCS recognizes, because they have inherent safety features. UCS speculates that SMRs could be less safe if reactor designers reduce safety margins or if NRC fails to discharge its statutory mandate to protect public health and safety. There is no evidence that reactor designers are reducing safety margins; nor is there any evidence that NRC plans to reduce emergency planning requirements. UCS comment is akin to saying that automobiles would be significantly less safe if they were not equipped with brakes or steering mechanisms. It is a true statement, but pointless. UCS statement: One of the early lessons from Fukushima is that prevention of serious nuclear accidents requires significant margins of safety to protect against extreme events. After Fukushima the Small Modular Reactors: Myths and Facts 4

5 NRC should be strengthening nuclear safety requirements across the board, rather than weakening them for SMRs. The Facts: There is no evidence that NRC is weakening, or intends to weaken, safety requirements for SMRs. The relevant safety requirements and regulations have not yet been developed. U.S. nuclear plant designs and operating practices are designed to mitigate extreme events and severe accident scenarios such as aircraft impact, which include the complete loss of offsite power and all on-site emergency power sources and loss of large areas of the plant. U.S. nuclear plants are equipped to deal with these extreme events ( beyond-design-basis events ) and nuclear plant operations staff are trained to manage them. NRC has inspected all U.S. nuclear plants since the Fukushima accident and confirmed that they are safe to operate and prepared to deal with extreme events. There is no evidence to support UCS blanket assertion that the NRC should be strengthening nuclear safety requirements across the board. Safety requirements should be strengthened to the extent that analysis of the Fukushima accident demonstrates a need to strengthen them not across the board. The U.S. nuclear industry, the U.S. Nuclear Regulatory Commission, the Institute of Nuclear Power Operations and other expert organizations in the United States and around the world are conducting detailed reviews of the Fukushima accident, and identifying lessons learned (both in terms of plant operation and design). Those lessons will be incorporated into the regulation, design and operation of U.S. nuclear power plants, as necessary and appropriate. The U.S. nuclear energy industry routinely incorporates lessons learned from operating experience into its reactor designs and operations. UCS statement: The discussion we should be having today is whether current emergency planning zones need to be increased, not whether we can shrink them for SMRs. The Facts: The nuclear energy industry believes emergency planning requirements should be riskinformed and, based on that risk assessment, focus on the activities and requirements that might apply within the EPZ. The industry believes that EPZ requirements and activities should reflect the risks associated with reactor designs: If SMRs have a different risk profile than large, thousand-megawattclass reactors, it may be appropriate to have different EPZ requirements. That said, however, NRC has not proposed a new emergency planning regulation or requirements for SMRs. If and when it does so, there will be ample opportunity for stakeholder comment and input, as is always the case with NRC licensing actions. UCS statement: As we have seen in Fukushima, nuclear plants with multiple reactors that experience severe conditions present extreme challenges. At Fukushima, the need to manage multiple simultaneous crises resulted in what sometimes appeared to be a game of whack-a-mole as the plant operator was forced to shift limited resources from one unit to another as new problems cropped up. These considerations make multiple-reactor sites less attractive from a safety perspective. The Facts: The Fukushima accident was clearly exacerbated by plant layout and configuration failing to design for a tsunami that appeared to have been a credible event; placing emergency diesel generators where they could be submerged and disabled; placing fuel oil tanks for emergency generators in areas where they could be washed away by a tsunami; placing vital electrical equipment and switchgear in areas susceptible to flooding that would disable the equipment. Had these weaknesses in plant layout and configuration not existed, the course of the accident would have been significantly different. Small Modular Reactors: Myths and Facts 5

6 The light-water-cooled SMRs are being designed with separate, independent underground containments for each small reactor, as well as separate, independent safety systems protected within those underground containments. Combined with the smaller size of each unit, this configuration offers significant safety advantages. In addition, as SMRs are currently still in the design phase, lessons learned from Fukushima can be incorporated into their designs as appropriate. UCS statement: A well-planned and executed terrorist attack could cause damage comparable to or worse than the earthquake and tsunami that initiated the Fukushima crisis, potentially in even less time. And although Osama bin Laden is gone, the terrorist threat to domestic infrastructure may actually increase over time as al Qaeda seeks to retaliate. This is the wrong time to consider reducing security requirements for nuclear power plants, regardless of their size. The Facts: Neither the NRC or the nuclear industry are considering a reduction in security requirements. As with emergency planning, the industry does believe that security requirements should reflect and incorporate the design and operating characteristics of SMRs, to the extent those characteristics differ from the large plants. The chance of a terrorist attack on a U.S. nuclear power plant causing damage comparable to or worse than the earthquake and tsunami that initiated the Fukushima crisis is extremely remote, at best. Here are the facts about U.S. nuclear plant security: Nuclear plant security requirements are predicated on the need to protect the public from the possibility of exposure to radioactive releases caused by acts of sabotage, including cyberattacks. Intelligence information and incidents around the world are analyzed to ensure that plant protection regulations are updated to reflect potential threats. After the terrorist attacks of Sept. 11, 2001, the NRC ordered substantial security enhancements at all nuclear power plants. A rule issued in 2009 contains requirements similar to those previously imposed by order, as well as new requirements that evolved from experience in implementing the orders and in preparing to license new reactors. The NRC coordinates closely with other federal organizations. The agency coordinates with the Domestic Nuclear Detection Office, the National Counterterrorism Center and the U.S. Department of Homeland Security s Infrastructure Protection Office. The NRC also has agreements in place with the Federal Aviation Administration and the North American Aerospace Defense Command. In its 2008 report to Congress on security, released July 10, 2009, the NRC said: The commission is confident that nuclear power plants continue to be among the best-protected private sector facilities in the nation. Security measures at the 104 operating nuclear plants include: 1. physical barriers and illuminated detection zones 2. approximately 8,000 well-trained and well-equipped armed security officers at 65 sites who are on duty shifts all day, every day 3. surveillance and patrols of the perimeter fence Small Modular Reactors: Myths and Facts 6

7 4. intrusion detection aids (including several types of detection fields, closed-circuit television systems and alarm/alert devices) 5. bullet-resisting barriers to critical areas 6. a dedicated contingency response force. The threat against which the industry must defend known as the design basis threat is characterized as a suicidal, well-trained paramilitary force, armed with automatic weapons and explosives and intent on forcing its way into a nuclear power plant to commit radiological sabotage. Such a force may have the assistance of an insider, who could pass along information and help the attackers. The NRC s design basis threat provides a foundation for developing defensive response strategies that cover a variety of situations. The NRC determines the design basis threat using technical studies and information received from intelligence experts and federal law enforcement agencies. It is reviewed by the agency once a year. Since 2001, the NRC has twice raised the threat level against which nuclear plants must provide protection. In doing so, the NRC has assumed an increased number of possible attackers and weapons capabilities. UCS statement: The distributed deployment of small reactors would put great strains on licensing and inspection resources. Nuclear reactors are qualitatively different from other types of generating facilities, not least because they require a much more intensive safety and security inspection regime. The Facts: This is speculation that is not supported by any measure of NRC s past and present resources. NRC has consistently been appropriated sufficient resources, and licensees then reimburse the agency for all licensing and inspection costs, so there is no factual evidence that deployment of SMRs would place any strain on NRC resources. UCS statement: Congress should prohibit DOE from selecting designs with a business case that depends on a weakening of NRC safety and security regulations. The Facts: Congress does not need to provide such direction either to DOE or to NRC. It has already done so in the Atomic Energy Act and the Energy Reorganization Act of 1974, as amended. These laws confer on NRC a broad and unequivocal mandate to promulgate any regulations necessary to provide reasonable assurance that public health and safety will be protected. Small Modular Reactors: Myths and Facts 7