Op Eds

Dear Editor:

Nuclear-Free, Carbon-Free Contingent to People’s Climate March
Second National Grassroots Conference Call
Monday, May 23, 2016 -- 7pm Eastern
May 11, 2016
Dear Friends,
Please contact Tim Judson at TimJ@nirs.org to join this call.
The March for a Clean Energy Revolution in Philadelphia on July 24, 2016 – right before the Democratic National Convention starts.
This march is our greatest chance to put a nuclear-free, carbon-free energy policy on the agenda in this year’s elections. Thousands of anti-fracking, climate justice, and clean energy activists are mobilizing for the march -- and we need to be there too!
NIRS is hosting the nuclear-free, carbon-free contingent at the march. We absolutely must put the dangers of nuclear power front and center in the national debate.
We will host the second national grassroots conference call on organizing the nuclear-free, carbon-free contingent on Monday, May 23 at 7pm Eastern.
Two years ago, thousands of us mobilized for the People’s Climate March in New York City, and made the nuclear-free, carbon-free message at the core of the largest climate mobilization in U.S. history. Ultimately, we got the EPA to take nuclear power out of the Clean Power Plan – and kept nuclear power out of the 2015 Global Climate Treaty in Paris!
We will bring you up-to-date with our latest information on the march itself, plus our activities. Buses and carpools are being organized from cities throughout the east coast and Midwest, which you can get plugged into.
Bring your updates, ideas, questions, thoughts and concerns to this call!
Thanks, and we’ll talk on Monday the 23rd,
Michael Mariotte and Tim Judson
P.S. Our Facebook group page for the nuclear-free, carbon-free contingent is being updated for the Clean Energy Revolution march: https://www.facebook.com/groups/nukefreeclimatefreemarch/  If you’re on Facebook, please join it and post your information.



Contact: Scott Portzline - Three Mile Island Alert 717-232-8863

Nuclear Watchdog Group Says the Results of a Hostile Action Drill at Three Mile Island are Grievously Misleading

A key element was missed during the hostile action drill at Three Mile Island (TMI). Specifically, emergency responders could be prevented from carrying out their responsibilities if the bridges at TMI are not under the control of the licensee. The control of approach routes was previously an NRC goal during the rule making process in which TMI Alert participated.


May 3, 2011:

Three Mile Island Alert


NRC’s Annual Assessment March 21, 2012

Eagle Building, Berwick, PA

May 3, 2011:

NRC to Mr. Timothy S. Rausch Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC,

“...Subsequent to the issuance of our March 4 letter, the NRC's review of Susquehanna Unit 1 determined that the Unplanned Scrams per 7000 Critical Hours performance indicator (Pl) has crossed the Green-to-white threshold (i.e., greater than three unplanned scram per 7000-critical hours) Specifically, Unit 1 had unplanned scrams on April 22,May 14, and July 16, 2010 as well as January 25, 2011. The first quarter of 2011 PPL was reported to the NRC on April 21, 2011.”

Therefore, beginning in the first quarter of 2011, the NRC has assessed the performance of Susquehanna Unit 1-to be in the Degraded Cornerstone column of the NRC's Action Matrix based on two White [findings] in the Initiating Events cornerstone. Consistent with the graded approach in the NRC's ROP, this results. In a corresponding increase in the NRC's inspection and assessment oversight of Susquehanna Unit 1. Specifically, we plan to schedule and perform a supplemental inspection

... [the] inspection will be conducted to provide assurance that the root causes and contributing causes of individual and collective risk-significant performance issues are understood, independently assess the extent of condition and extent of cause of individual and collective risk significant performance issues, and provide assurance that licensee corrective actions for risk significant performance issues are sufficient to address the root causes and contributing causes and prevent recurrence.

May 24, 2011

NRC to Mr. Timothy S. Rausch Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC

Dear Mr. Rausch:

By letter dated March 31,2011, PPL Susquehanna LLC, Inc. (PPL) submitted "NRC Decommissioning Funding Status Report, December 31, 2010" for the Susquehanna Steam Electric Station, Units 1 and 2.

The Nuclear Regulatory Commission staff has been reviewing the submittal and has determined that additional information is needed to complete its review.

RAI #1: Citation for real rate of returns: Provide the citation (e.g., an Order by the rate-regulatory authority) by the regulatory entity that allows for the for the assumptions used regarding rates of escalation in decommissioning costs, rate of earnings on decommissioning funds and rates of other assumed in your DFS report.

“PPL Susquehanna LLC is no longer under the jurisdiction of a rate making authority...” (PPL, June 22, 2011)

RAI #2: After-tax decommissioning funds as of December 31, 2010: Indicate if the amount of decommissioning funds identified within the DFS Report is the after-tax amount of funds accumulated through December 31, 2010. If not, provide the after-tax amount of decommissioning funds accumulated through December 31,2010.

“PPL paid all applicable federal, sate, and local taxes on trust fund activities directly front he fund balance including assets held as of December 31, 2010.” (PPL, June 22, 2011)

Sept. 1, 2011     The NRC completed its mid-cycle performance of Susquehanna Units 1 and 2

The NRC determined that the performance of Unit 1 during the most recent quarter ending June 30, 2011, was within the “degraded cornerstone column” of its oversight process. This was due to one finding having low to moderate safety significance and one performance indicator having low to moderate safety significance.

The one finding related to an internal flooding event on July 16, 2010, that required a plant shutdown. The performance indicator involved unplanned shutdowns occurring in 2010 on April 22, May 14, and July 16, and on Jan. 25, 2011.

The NRC found that the performance of Unit 2 was within the licensee response column of the oversight process.

Sept. 6, 2011

HARRISBURG, Pa. (AP) - Pennsylvania's Susquehanna nuclear power plant faces tougher scrutiny from federal regulators following a national review of plant safety.

The Nuclear Regulatory Commission said Tuesday all of the nation's 104 plants are operating safely, but that problems at Unit 1 of the Susquehanna plant in Luzerne County made it 1 of 5 with the worst recent safety performance. No serious problems were detected at Pennsylvania's four other nuclear plants in the latest assessment.

The low grades reflect four unplanned shutdowns at Susquehanna Unit 1 between April 2010 and January 2011, including one necessitated by a faulty gasket that caused 1 million gallons of river water to leak into the turbine building.

Copyright 2011 The Associated Press. All rights reserved. This material may not be published, broadcast, rewritten or redistributed


November 1, 2011

NRC to Mr. Timothy S. Rausch Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC,

“...once every 3 years, the NRC staff will audit a licensee's commitment management program.

On September 26-29, 2011, an audit of the commitment management program for PPL Susquehanna, LLC (PPL, the licensee) was performed onsite and in the NRC office. Based on the audit, the NRC staff finds that:

(1) While PPL had implemented most of the Regulatory Commitments on a timely basis; in the case of one commitment in the audit sample, item #3, in Table 1, the licensee neither entered the commitment in the system, nor did it track the implementation, and

(2) While PPL's program for managing NRC commitments, including the changes, is generally consistent with NEI 99-04, only the revised version of some regulatory commitments, related to license renewal, were entered in the system. The original commitments were not entered and subsequently revised, as described in its procedure NDAP-QA-0750, Revision 8, "Regulatory Commitment Management."

Also, as described in the enclosed audit report, the NRC audit team noted that the implementation of PPL's Commitment Management Program procedure varies depending on the user resulting in lack of consistent and uniform implementation. Therefore, the licensee's program document NDAP-QA-0750, needs considerable improvements, because it lacks specificity, clarity, consistency, and uniformity.”

Nov. 8, 2011, The NRC issued a severity level IV violation against the plant operator for failure to notify the NRC of the change in medical status of a licensed reactor operator. It was determined that the operator needed to wear eyeglasses as early as April 2009, but plant licensee PPL “did not inform the NRC or request an amended license” for the operator until August 2011.

“Therefore,” the NRC said, “the reactor operator performed license duties without an NRC-approved, amended license from April 2009 through August 2011, until the NRC identified the issue.”

The NRC noted that this is a “repetitive” issue. (See report dated Jan. 28, 2010, in which a senior reactor operator continued to conduct NRC-license activities after not meeting a specific medical prerequisite and there was no notification to NRC to ensure the person’s license was conditioned to require corrective lenses.) In that Jan. 28, 2010, report, the NRC noted that a civil penalty would not be proposed, but “significant violations in the future could result in a civil penalty.”

The latest NRC report does not mention any possible civil penalty.

The violation was found during an examination for the third quarter from July through September 2011. In the report, the NRC also found a non- cited security level IV issue and two NRC-identified and one self-revealing finding, all of very low safety significance. Additionally, the report said two PPL identified violations were determined to be of very low safety significance and were treated as non-cited violations.

The other level IV violation involved the recording of reactor coolant system leakage values under the performance indicators for Units 1 and 2.

“”PPL submitted inaccurate data for the affected performance indicators for Units 1 and 2 every quarter from April 2000 through its current submittal of June 2011,” the report said. “PPL’s failure to identify and correct the recurring errors over this period of time indicate the existence of a programmatic issue.”

Even though the data didn’t cross certain thresholds, “the inspectors concluded that PPL had reasonable opportunity to foresee and correct the inaccurate information prior to the information being submitted to the NRC,” the NRC report said. “The finding was not considered to be more significant since had this information been accurately reported, it would not have likely caused the NRC to reconsider a regulatory position or undertake a substantial further inquiry.”

The matter has been placed into PPL’s corrective action program.

On Dec. 6, 2011, personnel ascertained that a cylinder was not firing for the generator. It was determined that the loss of firing was likely the result of a diesel overhaul completed in September 2011, the NRC report said. The overhaul included disassembly of the fuel pumps to upgrade the o-rings to a material that was more compatible with ultra-low sulfur diesel fuel oil, the report said.

As part of the repair work, the cylinder was disassembled to inspect the delivery valve. The purpose was to verify that the delivery valve spring and stop had been installed correctly. When disassembled, the spring was found broken into several pieces. On Dec. 13, 2011, PPL decided to inspect the other fuel pumps to verify whether the springs were properly installed. It was determined that 11 of the remaining 15 delivery valves had their springs and stops inverted (installed incorrectly), and they were all broken into multiple pieces. Adding in the problem with the initial cylinder, 12 of 16 valve springs and stops were installed incorrectly,

The NRC said a root cause analysis determined that “work instructions to perform the modification were inadequate; workers proceeded with the work using the inadequate work instructions; and quality control hold point inspections were insufficient in both quality and performance to identify the error.

The finding was determined to be of very low safety significance. The NRC said a violation related to the finding is “currently under review.”

A second, self-revealing, finding of very low safety significance was identified when PPL personnel did not have adequate procedures to perform post-modification testing on the Unit 2 digital integrated control system (ICS). This led to a failure to identify an improperly terminated jumper that ultimately created a main turbine trip and automatic reactor scram (shutdown) during subsequent surveillance testing, the NRC report said.

PPL’s root cause analysis determined the direct cause of the main turbine trip on Aug. 19, 2011, “to be the improperly terminated connection in the ICS feed-water control panel,” the NRC report said. “This termination was installed in March 2009 as part of the ICS upgrade; however, the installation was not complete, to include post-modification testing, until May 2011. Despite review of documents and interviews with personnel performing the initial field installation, PPL was unable to positively determine that the improper termination was made during the 2009 initial field installation...Since the list of terminations that were required to be visually verified was not included in the work package, the visual check was not performed and the improper termination of the jumper that caused the event was not discovered”

“The wiring error ultimately led to a main turbine trip and automatic reactor scram during surveillance testing,” the NRC added. Inspectors evaluated the finding and determined that it “did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment of functions would not be available.” Consequently, the NRC issued a finding of very low safety significance.

An additional finding, a non-cited violation, occurred when the Unit 2 reactor core isolation cooling ramp generator signal converter failed during maintenance, but post-maintenance testing did not identify the failure. The failure went unrecognized for a three day period, from June 26, 2011 (when PPL commenced a reactor startup and transitioned to plant conditions when the reactor core isolation cooling was required to be operable) until June 29, 2011. The signal converter was replaced on July 1, 2011, and the isolation cooling unit was declared operable on July 2, 2011. (The reactor core isolation cooling provides makeup water to the reactor when normal supply is lost.)

Another non-cited violation occurred when PPL did not perform an adequate operability assessment for a failed suppression pool spray flow indicator, the NRC report said.

The NRC said one subsystem of the suppression pool was inoperable for 62.5 hours. “Since the finding was not a degradation of the barrier function of the control room against smoke or toxic gas, did not represent an actual open pathway of the physical integrity of containment, and did not involve an actual reduction in function of hydrogen igniters in the reactor containment, the finding was determined to be of very low safety significance,” the NRC said.

The three findings by PPL, the licensee, were all considered to be of very low safety significance. They are:

1) On Sept. 17, 2011,a worker in the Unit 1 recombiner room received a dose rate alarm of 683 millirem/hour, but the room was not posted and controlled as a high radiation area. “The issue was of very low significance because it was not an As Low as Reasonably Achievable issue, did not involve an actual or substantial potential for an overexposure, and the ability to assess the actual dose received was not compromised,” the NRC said.

2) PPL identified that a reactor operator was removed from the requalification program for a period of six months, and then was returned to licensed duties after three months of makeup training without obtaining NRC review.

3) On Nov. 2, 2011, PPL determined that the full scope of a control room emergency outside air supply system surveillance requirement was not being met due to procedural deficiencies.

The NRC also said it had opened an unresolved item relating to NRC requirements during a Dec. 5, 2011, transfer of a 1,100 curie Cs-137 sealed source and a source transfer into a Hopewell Design survey instrument calibrator. During the transfer, electronic dosimeters worn by the Hopewell Design contractor and the effluent technician immediately alarmed, indicating unexpected high dose rates. “The NRC had a number of issues related to this event, including adherence to radiological work practices in conducing the evolution and proceeding after the initial event, the adequacy of the radiological monitoring used, design control and vendor knowledge concerns related to the configuration of the source transfer assembly, and whether appropriate procedures were issued and followed for the evolution,” the report said.

The NRC also conducted a semi-annual review to identify trends that could indicate the existence of other safety issues. In the general work environment, the NRC noted that “actions taken to date to address the Safety Conscious Work Environment appeared to have had a positive impact” since the issuance of a chilling effect letter in January 2009. “Based on these results, the NRC will no longer formally document its assessments” of the safety work environment on a semi-annual basis, the NRC said.

Regarding human performance, the NRC observed that it had issued green, low-level, findings in each of the four quarters from July 1, 2010, through June 30, 2011 “pertaining to inadequate plant procedures.” It also noted that the plant’s human performance program “is not valued as a prevention method to reduce performance deficiencies. Numerous corrective actions were assigned to address the weaknesses, but had not been implemented at the time of this review.”

In addition, the NRC said, “Inspectors identified what appeared to be a potential trend in violations that were subject to traditional enforcement. Though many were of minor safety significance, the number of violations may be indicative of a trend requiring additional analysis and corrective action.”

It also listed concerns involving postings at radiation and high radiation areas, “as well as less than adequate radiation worker behaviors.” The report noted that PPL had developed a radiation protection recovery program “to track progress of numerous corrective action program products and manage corrective actions aimed at addressing the continuing trend.”

Jan. 6, 2012 The NRC issued a notice of violation to a senior reactor operator who failed to notify officials of the Susquehanna Steam Electric facility of a criminal violation filed against him by Indiana State Police prior to his return to work in July 2010.

The NRC said the senior operator had been issued a citation on July 10, 2010. The citation was for public indecency/indecent exposure, according to NRC records.

The senior operator did not report the legal action to his superior or any other PPL related official when he returned to work at the Berwick plant on July 18, 2010. He subsequently reported the legal action on July 21, 2010.

The senior reactor operator had unescorted access at the plant and was required by NRC regulations to promptly report legal actions issued to him by law enforcement agencies. The senior reactor operator was on vacation on July 10, 2010, and was scheduled to return to work on July 21, 2010. However, he reported back three days earlier to assist in a plant-flooding event, the NRC said.

The operator is no longer employed by PPL, the owner of the plant. He was issued a notice of violation, but no enforcement action is being taken against PPL, the NRC said.

Feb. 14, 2012 - The NRC issued its quarterly report for Units 1 and 2. The report covers the period from October through December, although it discusses and issues findings for events that happened prior to the quarter.

In the report, the NRC had four findings, two of them determined to be violations of NRC requirements. The plant’s licensee, PPL, also identified three violations that were determined to be of very low safety significance.

The NRC report also discussed some troubling trends regarding plant performance and procedures.


One finding involved PPL’s failure to properly plan and implement work instructions associated with a modification of an emergency diesel generator fuel pump assembly. The error resulted in the failure of the generator to continue running during surveillance testing on Dec. 6, 2011. It was subsequently determined that the generator had been inoperable from Sept. 19, 2011 following restoration from its maintenance outage.

NRC to Mr. Timothy S. Rausch Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC,

March 1, 2012

Dear Mr. Rausch:

On February 13, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed its end-of-cycle performance review of Susquehanna Steam Electric Station (Susquehanna) Units 1 and 2. The NRC reviewed the most recent quarterly performance indicators (PIs) in addition to inspection results and enforcement actions from January 1, 2011, through December 31, 2011. This letter informs you of the NRC’s assessment of your facility during this period and its plans for future inspections at your facility. This performance review and enclosed inspection plan do not include security information. A separate letter will include the NRC’s assessment of your performance in the Security Cornerstone and its security-related inspection plan.

The NRC determined that the performance at Susquehanna Unit 1 during the most recent quarter was within the Degraded Cornerstone Column of the NRC’s Reactor Oversight Process (ROP) Action Matrix because of one finding having low to moderate safety significance (i.e., white) and one PI having low to moderate safety significance (i.e., white), both associated with the Initiating Events Cornerstone. The White finding was related to an internal flooding event on July 16, 2010, which required the operators to insert a manual scram and isolate the normal heat sink. The White PI was related to the 1st quarter 2011 Unplanned Scrams per 7000 Critical Hours PI. Specifically, Unit 1 crossed the

green-to-white PI threshold following unplanned scrams on April 22, May 14, and July 16, 2010, and January 25, 2011. Although the 2nd quarter 2011 Unplanned Scrams PI returned to Green from White, Susquehanna Unit 1 will remain in the Degraded Cornerstone Column of the NRC Action Matrix until the associated supplemental inspection is completed satisfactorily.

...Therefore, the NRC plans to conduct ROP baseline inspections at Unit 2. The NRC evaluates cross-cutting themes to determine whether a substantive cross-cutting issue (SCCI) exists in a particular area and to encourage licensees to take appropriate actions before more significant performance issues emerge. Regarding Susquehanna, the NRC sustained an SCCI in the Corrective Action Program (CAP) component of the Problem Identification and Resolution (Pl&R) cross-cutting area. Specifically, there were six findings with a PI&R cross- cutting aspect of P.1(c) - Evaluation of Identified Problems - during this assessment period, one of which included the July 16, 2010 flooding event which has been held open since the associated supplemental inspection was not completed at the end of the assessment period. The P.1(c) theme was originally identified in the 2010 Annual Assessment letter (ML110620317), and an SCCI was assigned in the 2011 Mid-Cycle Assessment letter (ML112430469).

For the current assessment period, the NRC has determined that the exit criteria defined in the 2011 Mid-Cycle Assessment letter have not been met. Specifically, there has not been a notable reduction in the number of findings with a P.1(c) cross- cutting aspect and PPL has not demonstrated sustainable performance improvement in this area (ML111330523, 112220409, 113120409, and 12045A383).

Therefore, the P.1(c) SCCI will remain open until PPL has demonstrated sustainable performance improvement as evidenced by effective implementation of an appropriate corrective action plan that results in a notable reduction in the overall number of inspection findings with the same cross- cutting aspect, as well as no safety significant findings.

Because this letter is the second consecutive letter documenting an SCCI with the same cross-cutting aspect, in accordance with NRC Inspection Manual Chapter 0305, section 14.04.c, the NRC requests your staff provide a verbal response discussing your progress and future plans in addressing this SCCI during the 2011 annual public meeting. The NRC will continue to monitor your staff’s efforts and progress in addressing this SCCI through the baseline inspection program, the 95002 supplemental inspection, and the July 2012 biennial PI&R inspection.

The NRC also identified an SCCI in the Resources component of the Human Performance cross- cutting area. Specifically, PPL had four findings with a Human Performance cross-cutting aspect of H.2(c) - Documentation, Procedures, and Component Labeling, which included a green finding in each of the four quarters of the assessment period. This was originally identified as a cross cutting theme in the 2011 Mid-Cycle Assessment letter. For the current assessment period, the NRC has a concern with your progress in addressing and substantially mitigating this issue given that a reasonable duration of time has passed, findings with the same cross-cutting aspect continue to be identified as demonstrated by six consecutive quarters with an H.2(c) finding, and the delayed completion of a root cause analysis which resulted in limited implementation of corrective actions by the end of the assessment period. The PI&R H.2(c) SCCI will remain open until PPL has demonstrated sustainable performance improvement as evidenced by effective implementation of an appropriate corrective action plan that results in a notable reduction in the overall number of inspection findings with the same cross-cutting aspect, as well as no safety significant findings.

The NRC will monitor your staff’s efforts and progress in addressing this SCCI through the baseline inspection program, the 95002 supplemental inspection, and the July 2012 biennial PI&R inspection.


The NRC also identified a cross-cutting theme in the Work Practices component of the Human Performance cross-cutting area. Specifically, PPL had five findings with a Human Performance cross-cutting aspect of H.4 (a) -human error prevention techniques, which included two green findings and a greater-than-green finding issued in the 1st quarter(ML110871605 and ML111180742), and one green finding in each of the 3rd and 4th quarters of the assessment period (ML113120409 and ML12045A383). The NRC determined that an H.4 (a) SCCI does not exist because the NRC does not, at this time, have a concern with your staff’s scope of effort and progress in addressing the cross-cutting theme. Specifically, PPL recognized the H.4 (a) theme in the 3rd quarter 2011 and conducted analyses, including a root cause investigation, which were completed near the end of the assessment period.

Thus, the NRC concluded that more time is necessary for PPL to demonstrate the effectiveness of their corrective actions regarding human error prevention techniques in order for the NRC to evaluate the effectiveness and sustainability of these activities. The NRC will continue to monitor your staff’s efforts and progress in addressing the theme until the theme criteria are no longer met.

The enclosed inspection plan lists the inspections scheduled through June 30, 2013....The NRC will schedule and conduct IP 92723 when your staff has notified us of your readiness for this inspection. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes.


William M. Dean Regional Administrator 14



by Scott Portzline

The new steam generators at Three Mile Island have an unexpected flaw which is yet to be understood by Areva, the twice financially rescued French company (last year by US tax dollars) which built them, or by the engineers in the US nuclear industry. Fortunately, the engineers at TMI correctly determined that abnormal wear was occurring at unexpected locations on 257 steam generator tubes. Their observation caused Arkansas Nuclear to re-evaluate data which it had glossed-over indicating that the same thing was occurring at their reactor site.

These new "enhanced" steam generators were supposed to save money by decreasing maintenance and by increasing the amount of electrical power generated. The Nuclear Regulatory Commission (NRC) was so confident in the new metal alloys used in the steam generators that they would automatically extend inspection cycles to any licensee which requested it. But, now the NRC should mandate that the inspection of these new steam generators be more thorough and occur during each refueling outage. TMI will do this voluntarily.

The problem will probably be blamed on a design flaw which allowed steam tubes to bang against each other. Either the proximity of the tubes to each other, or inadequate stiffness can be blamed for the unexpected wear. The high temperatures of the pressurized water running through (and around) these tubes cause the tubes to expand and to bow sideways.

There are concerns that under abnormal conditions, when the temperatures can double or triple, additional tubes will bow even farther and then additional tubes may be compromised. Add to that the vibrations and shock waves caused by steam voids (which happened at TMI in 1979) and you have a large break loss of coolant accident on your hands as numerous tubes fail.

At the moment, there is still enough safety margin at TMI during normal conditions. Exelon claims that a "large break loss of coolant accident evaluation also demonstrates significant margin" as far as the steam generator tubes are concerned. Their report allows for tripled pressure differentials to support their analysis. However, there is no discussion of the temperature differences which allow the tubes to bow. During the 1979 emergency, temperatures in the reactor rose ten-fold. Steam generator "A" tore its guts apart.

The NRC's Advisory Committee on Reactor Safeguards, which conducted a review in 2001 stated that, "The NRC staff does not currently have a technically defensible analysis of how steam generator tubes, which may be flawed, will behave under severe accident conditions in which the reactor coolant system remains pressurized."

Additionally, there is a special manner in which tube failure can cause what is known at a guillotine rupture accident. If a high temperature jet rushes from a failed tube and cuts through an adjacent tube, the process can repeat itself in a rapidly cascading failure. A report on experiments by the Rockwell International states "[Damage] occurred on the surrounding tubes due to the high temperature reaction."

Knowing this, and despite the chances of its occurrence being very low, the NRC should address this as a Safety Issue. A spokesman for TMI stated that the newly found flaws are not considered a safety issue.

The problem reminds me of a fatal flaw that existed during the Apollo Moon Program. The original Saturn rockets had a vibration problem called "pogo." Liquid fuel slammed against the bottom of the fuel tank and then slammed against the top. The forces threatened to tear apart the rocket. Designers solved the problem by installing baffles to prevent the sloshing of the fuel.

Now back to nuclear thinking: For years the industry compared itself to "rocket science" and that ordinary citizens were unable to understand the complexities involved. Therefore citizens who worried about nuclear safety were viewed as ignorant, over-emotional pests. As the years went on and citizens became very sophisticated with their knowledge and familiarity of the regulatory process, citizens were accused of wanting to over-regulate the industry. New cries went up from the industry and even from the NRC's chairman Nils Diaz, "This is not rocket science."

The steam generator concerns are on the level of rocket science. These are new materials, higher pressures and temperatures may be involved, and new operational conditions and data; just like rocket science. No one should forget that experiments are still being thrust on the public in this nuclear realm.



by Scott D. Portzline

The good news for energy reliability is that wind and solar are stealing the show. Just last week, the North American Electrical Reliability Corporation testified to the Nuclear Regulatory Commission (NRC) that over the next 10 years 260,000 megawatts of new nameplate electrical capacity will be added. A whopping 96% of that will come from wind and solar. The NRC was told they might have to back down some of their nuclear plants during off-peak loads because of new wind-powered generation.

The claim by former NRC Commissioner Forrest J. Remick that nuclear power is “the most cost-effective way to boost capacity while meeting climate change goals” is hardly the truth. (Allentown Morning Call, Your View, 3/22/2010) The so-called nuclear renaissance is already on “life support” with taxpayer loans. Some proposed new plants are being canceled by utilities as costs double and even triple. Ratepayers in Florida are already paying for new nuclear plants that haven’t even begun construction let alone generate a watt.

In San Antonio Texas, the city-owned utility filed a $32 billion lawsuit against their nuclear construction partners alleging they had concealed rising cost information and thereby threatened the city’s credit rating. In South Carolina, the Public Service Commission ruled that the cost of proposed new nuclear plants does not have to be disclosed. How can anyone determine its cost effectiveness with a secret nuclear price tag? Meanwhile nuclear plant owners are suing the US over their current nuclear waste burden.

On the question of operating capacity, even if the new wind and solar generators were to operate at 20% capacity, that’s still double the output of the 26 proposed nuclear plants touted by Professor Remick. There’s no perpetual waste bill, no security force, no government subsidized catastrophic insurance, and no need for evacuation plans with these renewables.

The US is already ahead of schedule for the Department of Energy’s 2030 energy plan to have 20% of our electricity supplied by wind. Just last year 9,900 megawatts of new wind power came online. That increase in a single year represents 4 times the rate of growth provided by nuclear plant power uprates as calculated over a 15 year period. Best of all, it relieves us of the financial entanglement of 2 new nuclear plants. It should soon be obvious that Public Utilities and Wall Street favor these renewables and have all but closed the door on nuclear.

Scott D. Portzline
Harrisburg PA Security Consultant to Three Mile Island Alert


Comments of Eric J. Epstein,
January 6, 2010


On August 4, 2000 Governor Tom Ridge announced that electric competition would lead to job growth, economic expansion, and decreased rates. According to Governor Ridge, “Pennsylvania’s national leadership in electric competition continues to bring dramatic savings and economic benefits to Pennsylvanians.” Gov. Ridge added, "And, according to this new report, those savings and benefits will continue for some time to come!”

The Department of Revenue released "Electricity Generation Customer Choice and Competition” (August, 2000), and predicted free market nirvana. Secretary of Revenue, Robert A. Judge Sr., forecast reductions in retail electricity prices would lead to the following economic impacts in Pennsylvania by 2004:

The real gross state product will be $1.9 billion higher; overall employment will increase by 36,400 full-time and part-time jobs, nominal personal income will increase by $1.4 billion; the price index will decrease by .47 percent; and the population will increase by 51,400 people, as workers are attracted to job opportunities in Pennsylvania.

The Department of Revenue also reported that deregulation would result in greater sales tax and Personal Income Tax collections.

Could the deregulators have gotten it more wrong?

The reality is not so dreamy. Electric companies are collecting $11.4 billion in stranded costs, shifted taxes to hostage rate payers, and dumped customers at record rates.

Deregulation shifted power plants back to the local tax rolls under the assumption that utilities would pay at least the same amount had they been subject to real estate taxes.

By 2004 homeowners were paying an average of 30% more in property taxes than they did in 1997. PPL and the other electric utility companies are paying 85% less in taxes on their plants, down from about $120 million annually to about $20 million according to a Philadelphia Inquirer analysis.

Uncollectible accounts were supposed to decrease with the price of electric.

On November 19, 2004 - the last day of a “lame duck session” - the General Assembly passed “The Responsible Utility Customer Protection Act” (SB #677 or Chapter 14) at the behest of the energy industry. This legislation - passed in secrecy and without public comment - became Act 201.

Prior to this legislation, the PA Public Utility Commission prevented most winter time utility shut offs between November through March.

Deregulation’s “Consume Protection Act” has produced a 113% increase in terminations. In the first eight months of 2008, PPL cut electricity to 28,561 customers, which was an 111% increase over the number of customers whose power was shut off during the same period in 2007. The statewide average was 24%.

In 2004, about 70% of customers who received notices saying power could be shut off called the company and tried to arrange an alternate payment schedule according to PPL. Now only 28% of those who receive termination warnings try to arrange other payment plans.

But it got worse for Joe the Plumber.

A study published by Carnegie Mellon University's Electricity Industry Center found, “On average, power users in restructured states pay 2 to 3 cents per kilowatt hour more than customers in states that didn't restructure.” (Electricity Prices and Costs Under Regulation and Restructuring, 2008)

Future shock: The Office of Consumer Advocate, in a letter to Governor Rendell on April 20, 2008, estimated approximate increases in the overall rates of residential customers, comparing rates that were in effect and rates that would be expected to be in effect for each company after the rate caps have expired:

Met Ed -54%

PECO - 8%

Penelec - 50%

Allegheny (West Penn) - 63%

These numbers are staggering and coincide with the deteriorating health of Pennsylvania's shrinking middle class. The promise of deregulation leading to more capacity, more competition and lower prices has turned out to be a profitable illusion for a select few.


Patriot-News Op-Ed by David Hughes

December 29, 2009


Pennsylvania decision-makers’ poor understanding of the electricity industry led them into a big mistake 13 years ago: Giving up the state’s authority to control electricity-generation prices.

Consumers were promised a competitive retail electricity market that would restrain prices. The warnings that such a market would not develop went unheeded, but they turned out to be correct.


• PPL should implement a program for senior citizens on       

fixed incomes who will be forced into a “hardship class.”