ILLINOIS’ NUCLEAR POWER VULNERABILITIES:
Initially Prepared for a Meeting with Lt. Gov. Patrick Quinn
July 9, 2003, ELPC Offices, Chicago, IL; revised August 26, 2003
David A. Kraft, Director
Nuclear Energy Information Service
P.O. Box 1637, Evanston, IL 60204-1637; (847)869-7650; -7658 fx; neis@neis.org
NEIS has been Illinois’ nuclear power watchdog organization since 1981. The organization stands for the replacement of nuclear power by the planned, aggressive implementation of increased energy efficiency and greater use of renewable energy resources; and for the environmentally responsible management of all forms of radioactive waste.
NEIS would like to call to the attention of State Government the following nuclear power-related issues, and our recommended courses of action. NEIS also invites review of the issues found on its website ( http://www.neis.org ); and is prepared to discuss these issues in greater detail:
I. Nuclear plant “In-Security”
ISSUE: The 9/11 attacks on the World Trade Center and the Pentagon, as well as numerous lesser reactor threats and intrusions, amply demonstrate that nuclear reactors are clearly capable of being targets of terror or major accident (see NEIS report, “Here Today, THERE Tomorrow,” October 2001, on website at: http://www.neis.org ). Credible reports from national intelligence agencies have indicated that captured Al Qaeda members confirmed that nuclear reactors were considered as potential targets for assault. This means that each reactor represents a World Trade Center with 1,000 Hiroshima’s worth of radiation inside. Illinois has 14 such targets in state within flight-minutes of the world’s busiest airport at O’Hare Field, and several others out of state less than 100 miles from the airport.
PROBLEMS:
$ no reactors in existence or proposed can demonstrate that they can successfully withstand the impact of large commercial or military aircraft, and therefore in a post-9/11 world, represent a major terrorist threat, especially for Illinois which not only hosts 14 reactors (targets) already, but also the world’s busiest airport – O’Hare Field (weapons)
$ NEIS has calculated that NONE of the Illinois reactors (and additionally, the 3 reactors on the west coast of Michigan) is more than 30 minutes away from O’Hare Field for an aircraft traveling at normal takeoff and approach cruising speeds and altitudes. The nearest reactors – the two shuttered Zion reactors and their vulnerable, active spent reactor fuel pool – are only 8 minutes away at “normal” speed and altitude protocol, which in the event of a skyjacking, would not arouse suspicions of air traffic controllers or NORAAD until it was too late to intervene
$ historic evidence and recent news investigative reports strongly suggests that, in spite of claimed improvements in reactor site security, they remain unable to deter or repel “determined intruders” of the kind likely to currently exist in the 21st Century
$ recent criticisms within the last few months from both public (e.g., GAO) and private (e.g., Union of Concerned Scientists) sources find reactor security measures inadequate to deter or repel “determined intruders” of the kind likely to currently exist in the 21st Century
SUGGESTED ACTION: The state of Illinois should direct all levels of state government to call for and facilitate by all means in its jurisdiction and influence closure of any reactor incapable of withstanding a credible 21st Century threat; and it should urge the delegation to Congress to insist on NRC reform, and toughening of standards for safety and security at all U.S. reactors. No new reactors should be allowed to be built; and no license extensions for existing reactors granted unless these reactors can publicly and independently be proved to have such capability.
ISSUE: Apart from their already amply demonstrated vulnerability as terrorist targets, recent events indicate the ongoing operation of Illinois’ reactors are replete with other vulnerabilities which could cause operating reactors to sharply curtail output or shut down completely at times when then are most needed, thus endangering public health and safety, and severely damaging the Illinois economy:
PROBLEMS:
§ WEATHER ISSUES IN A PRE-GLOBAL WARMING WORLD: The recent heat-related disaster in France, the most heavily nuclear dependent nation on earth, illustrates a serious flaw in expecting nuclear reactors to either “help” reverse Global Warming, or even more immediately, be available when most needed during heat-related emergencies (when demand for electricity is greatest). During the French heat wave, 5,000 died from heat-related causes. The problem was so severe, and France so desperate for electricity to continue its economy and any modicum of cooling that the government allowed reactors to operate past known temperature safety limits, and discharge water into rivers in excess of allowable temperatures. In other words they risked nuclear accident and the thermal death of their rivers to keep electricity on. The reason for the problem was not only the recent record setting temperatures, but also the fact that the accompanying drought had drastically reduced river water volumes and flow-rates. The hot discharge water was not able to dilute either heat or “allowable levels” of radionuclides, as per operating regulations.
NEIS documented a similar situation in Illinois during the summer of 1988, when over 90 reactor-days of power output at several Illinois reactors were either limited to no more than 30% capacity or entirely eliminated because Illinois’ reactors would have similarly thermally polluted our rivers. Then-ComEd later had to install expensive cooling baffle systems at Dresden and elsewhere to meet EPA limits for thermal discharges. The choice in 1988 was either: cut power output, or kill the rivers with excess heat and higher radionuclide concentrations (a function of water volumes).
In a real Global Warming world, river volumes and flow rates may even be less than what they are today, or than what we have experienced in France this year and in Illinois in 1988. To depend on nuclear power reactors which need copious amounts of water for BOTH intake and discharge will either kill the rivers and threaten public health and safety; or will add prohibitive costs to reactors. Better solutions exist to meet legitimate energy needs (see Section V. below).
§ REACTORS AND GRID VULNERABILITY – THE NORTHEAST POWER BLACKOUT: Numerous lessons about reactor vulnerability and the dangerous situations they create should be learned from the August 2003 Northeast power blackout:
§ The blackout forced the closure of all 8 affected U.S. reactors – at a time when then were needed most. This was due to the regulatory requirement that offsite electric power must be available to operate safety systems at the reactors. No offsite power existed during the widespread blackout.
§ Had their onsite emergency diesel generators not been functional (as has been documented so many times by the NRC, which has done nothing to require adequate corrections for this problem), a radiological emergency could have been added to the already problematic blackout
§ Because of lack of power, the emergency warning sirens sited around the reactors were inoperable, in violation of emergency planning procedures. Had a radiological emergency resulted, the surrounding public would not have been able to warned or instructed on what to do. Until national grid issues are resolved, this will remain an ongoing problem for every U.S. reactor
§ ONGOING REACTOR OPERATION: QUALITY ASSURANCE PROGRAM VIOLATIONS:
§ Serious allegations of quality assurance violations existing at several Illinois reactors relating to the recent Exelon “power upgrades” and the construction of Holtec “dry-cask” storage modules have been brought by former Exelon engineer Oscar Shirani. These allegations mean that we have reactors operating that cannot be proven to be within regulatory standards
§ The official public NRC position has been that no problems exist; yet, a former NRC staff member has publicly corroborated Shirani’s conclusions
§ A floppy-disk with a Power Point presentation summarizing Shirani’s allegations was given to Lt. Governor Patrick Quinn at a meeting at the office of the Environmental Law and Policy Center (ELPC) in Chicago on July 7, 2003.
§ Until these allegations are thoroughly investigated in public, and by independent reviewers, it must be assumed that many if not all Illinois reactors may be operating in violation of many standards they are required to meet in the Code of Federal Regulations
SUGGESTED ACTIONS:
§ Nuclear reactors will be undependable at best, totally nonfunctional at worst during conditions of severe drought, or in a “Global Warming” world – i.e., when they are needed MOST. They should not be expected or relied on to function under these circumstances; alternative energy resources should be planned to meet these future and emergency needs for electricity.
§ Nuclear reactor operation will continue to be vulnerable to national grid disruptions, the sources of which are outside Illinois borders and jurisdiction. Plans should be made in-state to move away from such centralized power sources and transmission in favor of more flexible and redundant “distributed energy” solutions.
§ Allegations of quality assurance violations at Illinois reactors (accounting for 60% of electricity production in Illinois) should be made a prime target of investigation by Illinois government. The Governor’s office should use all power and influence at its disposal to get the Illinois delegation to Congress to force the NRC to conduct a public and independent investigation of the quality assurance violations brought to light by former Exelon senior Nuclear Lead Auditor and now Nuclear Safety Whistleblower, Oscar Shirani
§ Illinois risks severe economic disruption and environmental and public health degradation should it continue present reliance on or expansion of nuclear power in Illinois. See Section V. below for alternatives
>III. New nuclear reactor construction
ISSUE: Exelon Corporation seeks to build new nuclear reactors in Illinois at the site of the Clinton reactor, west of Champaign/Urbana
PROBLEMS:
$ no reactors in existence or proposed can demonstrate that they can withstand the impact of large commercial or military aircraft, and therefore in a post-9/11 world, represent a major terrorist threat, especially for Illinois which not only hosts 14 reactors already, but also the world’s busiest airport – O’Hare Field.
$ additional nuclear capacity will add to the already enormous high-level radioactive waste (HLRW) storage and transportation problems Illinois already faces if and when a national HLRW repository opens
$ adding additional nuclear capacity will skew the already glutted Midwest electricity market against renewable energy resources, which have none of the security, terrorism, accident, or waste problems nuclear reactors inherently possess
SUGGESTED ACTION: The state of Illinois should direct all levels of government to oppose by any and all means at their disposal the construction of any new nuclear capacity in Illinois.
IV. License extension proposed for existing reactors
ISSUE: Exelon corporation has announced intentions to ask for 10-20 year extensions of the operating life for several of its reactors in Illinois
PROBLEMS:
$ older reactors already are showing signs of aging, and, at best, will either require increases in operation and maintenance costs (which utilities are reluctant to allocate in the “de-regulated” electricity market), or attempt to have safety margins and standards relaxed, which threatens public safety and the environment
$ recent credible allegations by a former Exelon employee (see above) indicate a marked and significant erosion of quality assurance and control at Exelon reactors within the last five years; and blatant disregard for existing and required safety margins, especially critical for the older (and historically troubled) Exelon reactors; Exelon has already successfully petitioned the federal Nuclear Regulatory Commission for increased power production ratings at some of the oldest and most troubled reactors in the US (Dresden, Quad Cities, Clinton); such increases will only put more mechanical stress on the already aging and historically troubled reactors
$ no existing reactors can successfully and publicly demonstrate their ability to repel “determined intruders” (terrorists), and no reactor containment or spent fuel pool in Illinois can successfully demonstrate its ability to withstand impact from today’s operating commercial and military aircraft
SUGGESTED ACTION: The state of Illinois should actively oppose the extension of license for any reactor that cannot publicly demonstrate through independent validation and public hearings its ability to survive the threats and problems listed above.
V. Expansion of renewable energy resources
ISSUE: Legislation implementing a Renewable Energy Portfolio Standard (RPS, SB-25) had been introduced but defeated in the State Legislature. It had been opposed by Exelon Corporation, which simultaneously is making plans to build new reactors, and to extend the operating lifetimes of its older reactors
PROBLEMS:
$ expansion of nuclear power without AT LEAST passage of a state if not federal RPS will doom renewable energy to the role of little more than a marginal eccentricity, without a proper market share to enjoy economy of scale cost reduction benefits.
$ Continued reliance on nuclear power subjects Illinois people, environment and economy to all the costly risks summarized above
RECOMMENDED ACTION: No new reactors should be permitted to be built in Illinois, and no reactor operating licenses extended for Illinois reactors without prior passage of a RPS with mandatory targets, and penalties for failure to comply. The State ICC should be instructed to use its regulatory authority to certify energy producers to withhold certification of a provider and prevent operation of any new nuclear reactors constructed without prior implementation of such a RPS for a period of at least five years.