From: Larry Criscione
Sent: Friday, September 14, 2012 5:51 PM
To: [email protected], [email protected],
[email protected], [email protected],
[email protected], [email protected],
[email protected], [email protected],
[email protected], [email protected], Marty Gelfand,
[email protected], Michal Freedhoff
Subject: NRC Concealing Concerns Regarding Oconee Nuclear Station
Attachments: Inspector General Letter.pdf
Flooding of Nuclear Power Plant Sites Following Upstream Dam Failures.pdf
The Oconee Nuclear Station (ONS) in South Carolina is situated 12 miles downstream of Jocassee
Dam. The site has three reactors, each housed inside a containment building. At the site is a Standby
Shutdown Facility (SSF) which contains support equipment necessary to remove decay heat from the
reactors in the event of a loss of the transmission lines to the plant. The SSF has a five foot high flood
wall around it to protect it in the event of severe flooding.
Just like the reactor vessels and containment building at the Fukushima Dai-ichi complex in Japan, the
reactors at ONS and their containment structures are build to withstand earthquakes and severe
flooding. However, just like at Fukushima, the reactors at ONS and their containment structures cannot
survive a sustained loss of offsite power.
And just like Fukushima, the flood wall at ONS is not adequately sized to prevent the loss of the
equipment at the SSF in the event of a failure of Jocassee Dam.
Duke Energy has known since 1992 that the flood wall at ONS is at least seven feet too short. The US
Nuclear regulatory commission has known this since 2006.
There are many people within Duke Energy and the US Nuclear Regulatory Commission who believe that,
were Jocassee Dam to fail, all three reactors at ONS would melt down in less than 10 hours. Duke Energy
predicts that if cooling cannot be restored following the recession of flood waters, the containment
buildings will fail within 60 hours of the dam break exposing the public to a significant dose.
The predicted annual failure rate for a dam of Jocassee’s construction is 2.8E-4/yr. That is, every year
there is a 1 in 3600 chance that Jocassee Dam will fail. Integrated over the 22 years which Duke Energy
has left on the renewed licenses of its Oconee reactors, this becomes a 1 in 163 chance. That’s better
than the odds of being dealt a straight or about 8 times better than the odds of rolling Yahtzee.
But of course, a 1 in 163 chance a dam will fail is a 163 in 1 chance that it will not. The odds are pretty
good (99.4%) that in the next 22 years the Jocassee Lake Dam will not fail. The Oconee Nuclear Station
is a vital part of the economy of Oconee County. Maybe it’s appropriate that, as a society, we can accept
those odds. I am not one to make that decision, however; that decisions is up to our elected
representatives. My role is to follow the NRC’s regulations as they currently exist. And currently, on an
annual basis the odds of a meltdown at ONS are about ten times higher than for a typical US reactor
There is another aspect to this issue though, and that is the survivability of the containment structures
around the reactors. It is well accepted that these structures can survive a flood resultant from a
Jocassee Dam failure. And it is well accepted that these structures, as at Fukushima, will eventually fail if
the utility cannot re-establish cooling. What is not known is the likelihood that, after the flood waters
recede, Duke Energy will be able to re-establish cooling to the containment buildings. If they cannot, then
a dam break at Jocassee Lake will cause a Fukushima-style accident in Oconee County, South
Carolina. Except instead of blowing out to sea as happened in Japan, depending on the winds the
radioactivity will be blown over Columbia or Charleston or Atlanta or Huntsville or Knoxville or
Charlotte. Whatever the winds, the radioactive fallout will occur over farmlands and not merely over the
The failure of the containment structure at a typical US facility is generically taken to be 1 in 100. That’s a
99% chance of survival. But does anyone really think there’s a 99% chance that Duke Energy employees
can make it through the devastation wrought by the flood and find a way to restore the cooling equipment
prior to the failure of the containment structures? It might be possible, but I would not put the odds at
anything better than 50%. That makes the annual probability of a Fukushima-style accident occurring at
ONS about 500 times more likely than at a typical US facility.
As a citizen I might be able to accept these odds, but as a regulator it is clear I cannot accept them under
the processes which are currently in place at the NRC. However, the NRC is accepting them and in a way
which I believe is unethically. The NRC keeps allowing Duke Energy to postpone the improvement of their
flood protections. The original date set was November 2011 but that has been moved to 2014 and now to
2017. Maybe it is best for the nation to tacitly accept the risk at Oconee, but that is not a decision the
NRC staff should be making. That decision is up to the actual commissioners and they should be debating
it and making it in full view of the Congress and the American public.
The attached letter is from Richard Perkins to the NRC Inspector General. Mr. Perkins was the lead author
on an NRC screening analysis concerning flooding hazards at US nuclear sites due to upstream dam
failures (also attached). Mr. Perkins wrote the Inspector General because he believes that his study is
being unlawfully kept from the public.
Many of the references in Mr. Perkins’ study are from documents stamped by the NRC as “Official Use
Only – Security-Related Information”. Unlike documents classified for national defense purposes, from a
legal standpoint “Official Use Only – Security-Related Information” is meaningless. I could release these
documents to the press or public and not face any jail time or fines. What I could face, however, is loss
of my job because releasing “Official Use Only” material is – and should be – a violation of NRC policies for
which one can get fired. I have no problems with that policy. My concern, and Mr. Perkins’, is the misuse
of the “Security-Related Information” stamp.
Nowhere in these “Security-Related Information” documents can be found the actual word “security” other
than in the stamp. Terrorism, sabotage, vandalism, etc. are not anywhere discussed. The documents
pertain entirely to safety issues concerning the failure of Jocassee Dam due to natural phenomena and
latent construction/engineering flaws.
Some might argue that knowing there is an extremely high chance the failure of Jocassee Dam will lead to
the meltdown and containment failures on three reactor plants is something that would benefit
terrorists. That may be true. But if there is a terrorist threat to Jocassee Dam, then it must be addressed
in some way other than merely suppressing the discussion of bonafide safety concerns about a dam
The Department of Homeland Security reviewed Mr. Perkins’ screening report as part of its routing and
review. The DHS assessment was that there was nothing in the report concerning Jocassee Dam and the
Oconee Nuclear Station that needed to be withheld from the public for security reasons. Yet the NRC is
continuing to withhold the unredacted version of the report from the public, citing FOIA exemption
7(F): Disclosure could reasonably be expected to endanger the life or physical safety of an individual.
Mr. Perkins’ concern is that the NRC is illegally using false security claims to withhold information on
Jocassee Dam from the public because they realize that their options regarding Oconee are to shut down
the site either temporarily or – quite possibly – permanently. My concern is that by withholding this
information from the public, the necessary oversight of the NRC – by both Congressional committees and
non-governmental watchdog organizations – with regard to ONS is being impeded. The decision as to
whether or not Duke Energy should continue to be allowed to operate ONS when its risk profiles are 500
times higher than other plants is a not a decision that should be made by NRC staffers – it is a decision
that should be made by the NRC Commissioners themselves in few view of the American public, the US
Congress, and the state and local governments of South Carolina.
Lawrence S. Criscione, PE