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Watts Bar Hokey Pokey is Not Okey Dokey

Fission Stories #200

The Watts Bar Nuclear Plant near Spring City, Tennessee has two pressurized water reactors (PWRs) like that shown in Figure 1. Water flowing through the reactor core gets heated to over 500°F, but does not boil because pressure of over 2,000 pounds per square inch prevents it. The heated water flows through tubes inside the steam generators. Heat conducted through the thin metal walls of the tubes boils water surrounding the tubes. The steam flows through a turbine that spins a generator to make electricity.

Fig. 1(

Fig. 1(Source: Nuclear Regulatory Commission)

PWRs feature emergency core cooling systems (see Figure 2) intended to provide makeup water should a pipe connected to the reactor vessel break and rapidly drain the pressurized water from the vessel. Accumulators located inside the containment building are metal tanks partially filled with water. The remaining space inside the accumulator above the water level is filled with nitrogen gas. The nitrogen gas is pressurized. If a pipe breaks, the pressure inside the reactor vessel will decrease as water jets out the broken pipe ends. When the reactor vessel pressure drops below about 600 pounds per square inch, the accumulator water will be “pushed” into the reactor vessel. The charging, safety injection, and residual heat removal pumps located outside containment will start up and supplement the water makeup function.

Fig. 2 (

Fig. 2 (Source: Nuclear Regulatory Commission)

The emergency core cooling (ECC) accumulators and pumps are designed to maintain adequate cooling of the reactor core for breaks of small, medium, or large diameter pipes connected to the reactor vessel. As shown in Figure 3, the size of the break determines how quickly the transition from the high head injection (e.g., charging pumps) systems to the low pressure systems.

Fig. 3 (

Fig. 3 (Source: Nuclear Regulatory Commission)

Each PWR at Watts Bar has two charging pumps. Each charging pump is powered by an electric motor and is designed to provide 150 gallons per minute of makeup flow at the high pressure conditions. The charging pumps are located within the auxiliary building that is adjacent to the reactor containment building. Because it gets warm in Tennessee during the summer and the running motors on the charging pumps give off more heat, air conditioning units called room coolers are installed in the auxiliary building to protect the charging pumps from overheating damage. (The irony is duly noted—the components installed to protect the reactor core from overheating damage are vulnerable to overheating damage themselves.)

Each room cooler consists of a bladed fan that blows air across metal tubes filled with cooling water. The air gets cooled down as it flows past the tubes. The fan is spun by an electric motor. A belt wraps around the motor shaft and fan shaft so that when the former rotates, the latter rotates too.

Revisions and re-revisions

On November 3, 1995, the shaft for a fan on one of the charging pump room coolers for Watts Bar Unit 1 was discovered to be damaged. Workers determined that the fan belt had been tightened too much, causing the fan shaft’s damage. The maintenance procedure for the room coolers was revised to include more guidance for properly installing and tensioning the fan belt. The procedure revision was a CAPR—corrective action to prevent recurrence.

And it did prevent recurrence, at least until 2011. A revision to the maintenance procedure in 2011 removed the guidance on proper tensioning of the fan belt.

Charging pump room cooler 1B-B was found broken on December 4, 2015. Workers disassembled the unit, repaired or replaced its broken parts, and reassembled it.

Charging pump room cooler 1B-B was found broken on August 3, 2016. Workers determined that the fan belt had been tightened too much which put more strain on the fan bearing causing it to degrade.

The corrective action was to re-revise the maintenance procedure to reinsert the guidance about properly installing and tensioning the fan belt. Workers also checked all other coolers at Watts Bar that had their fan belts tensioned during the 2011 revision to the maintenance procedure to ensure they were properly tightened.

Report to the Commission

The charging pumps provide high pressure makeup to the reactor vessel should a broken pipe cause a loss of coolant accident. If the pipe has a large diameter, the reactor vessel pressure will quickly drop down to the range where the accumulators and the residual heat removal pumps can supply the necessary makeup water. Following breaks of smaller diameter pipes, the reactor pressure will also decrease, albeit at a slower rate. An evaluation by Westinghouse, the vendor for the PWRs at Watts Bar, concluded that the charging pumps might be needed for up to 7.5 days during an accident.

An engineering evaluation by the owner concluded that a charging pump running without its associated room cooler would fail in about 74 hours due to overheating of its electric motor. Because the faulty room cooler could have prevented the charging pump from operating for the entire duration of its safety mission, the owner reported the problem to the NRC.

Our Takeaway

Workers at Watts Bar danced the nuclear hokey pokey. They started with the fan belt guidance out of the procedure, then took the step of putting the guidance into the procedure, back-stepped to remove the guidance, and re-took the step of placing the guidance back into the procedure. When it was in the procedure, the fan belt guidance seemed to protect against room cooler failures. Perhaps it’s time to stop the hokey pokey now that the useful guidance is once again in the procedure.

Right now, the nuclear industry seeks to significantly reduce costs through its Delivering the Nuclear Promise initiative while the Nuclear Regulatory Commission seeks to downsize through its Project AIM efforts. The lesson of this Watts Bar episode should not be lost upon the promisers and projectors. The workers who removed the fan belt tensioning guidance in 2011 were likely unaware of the reason it had been added back in 1995. Before the promisers and projectors discontinue this practice or eliminate that activity, they need to make really sure they are not undoing past fixes. Perhaps it is no longer necessary to do that thing, or perhaps it can be done more efficiently. But the reasons why practices were started need to be fully understood before they can be safely discontinued or streamlined.

In other words, put on the thinking caps and take off those hokey pokey dancing shoes.

Fission Stories” is a column by Dave Lochbaum. For more information on nuclear power safety, see the nuclear safety section of UCS’s website and our interactive map, the Nuclear Power Information Tracker.

Frazzled at FitzPatrick

Fission Stories #199

The James A. FitzPatrick nuclear plant near Oswego, New York has one boiling water reactor (BWRs) with a Mark I containment design. Water flowing through BWR cores is heated to boiling with the steam flowing through turbine/generator to make electricity. Steam exits the turbines and flows past thousands of tubes within the condenser. Water from the lake flowing inside the tubes cools the steam and transforms it into water. The condensed steam is pumped to the reactor vessel to make more steam.

Fig. 1 (Source: Nuclear Regulatory Commission)

The operators reduced the reactor power level on January 22, 2016, to 65 percent for scheduled maintenance. At 10:17 pm on January 23, the operators had increased the reactor power level to 89 percent on the way back to full power following completion of the maintenance. An alarm alerted them that the water level at the intake structure had dropped nearly two feet below normal. Environmental conditions formed chips of ice, called frazil ice, in the lake. Water being drawn into the plant caused ice to collect on the traveling screens at the intake structure. The traveling screens are metal mesh plates that rotate on rollers to prevent debris in the lake water from being drawn into the plant. Ice accumulating on the traveling screen partially blocked the incoming flow. As a result, the water level inboard of the traveling screens dropped lower than the lake’s level. If that level dropped too low, the circulating water pumps would pull in air instead of water (Fig. 2).

Fig. 2 (

Fig. 2 (Source: Nuclear Regulatory Commission)

By procedure, the operators responded to the alarm by reducing the reactor power level to 75 percent and turning off one of the three pumps that circulate lake water through the condenser (Fig. 3). Reducing the incoming water flow rate reduced the amount of ice drawn onto the traveling screens. But the water level at the intake structure continued dropping until it reached four feet below normal. Per procedure, the operators manually scrammed the reactor at 10:40 pm.

Fig. 3 (

Fig. 3 (Source: Nuclear Regulatory Commission)

Scramming the reactor caused control rods to fully insert within seconds to terminate the nuclear chain reaction. The rapid power reduction significantly reduced the amount of steam flowing to the turbine/generator, leading to the turbine being turned off and the generator taken offline.

With the reactor operating, electricity produced by the generator flowed out through the switchyard to the offsite power grid. Electricity from the generator also flowed through a transformer to supply power to equipment throughout the plant.

The plant’s design called for the power supply to swiftly transfer from the generator’s output to the offsite power grid through two other transformers. But the cold weather hardened the lubricating oil for electrical breaker 10042 in the switchyard, causing it to open more slowly than desired. The slowed breaker prevented the swift transfer. Instead, supply was transferred about three seconds later by a backup logic circuit. That momentary power interruption caused non-essential equipment throughout the plant to stop running; most notably, the other two circulating water pumps at the intake structure.

Fig. 4 (

Fig. 4 (click to enlarge) (Source: Nuclear Regulatory Commission)

With no lake water flowing through the tubes inside the condenser, the operators manually closed the two isolation valves in the main steam lines between the reactor vessel and the turbine/generator. Steam continued to be produced by the reactor core’s decay heat. This steam had no place to go and caused the pressure inside the reactor vessel to rise. When the pressure rose about 10 percent above normal pressure, safety/relief valves (SRVs) automatically opened to discharge steam through a pipe into the water of the suppression chamber (also called the torus due to his donut shape.) When the pressure dropped sufficiently low, the SRVs automatically reclosed. The SRVs cycled opened and closed to control reactor pressure (Fig. 5)

Fig. 5 (

Fig. 5 (Source: Nuclear Regulatory Commission)

HPCI Use and Misuse

By procedure, the operators started the High Pressure Coolant Injection (HPCI) system in pressure control mode. The HPCI system uses a turbine supplied with steam from the reactor vessel to spin a pump that transfers makeup water from the Condensate Storage Tank to the reactor vessel. The steam exiting the HPCI turbine flows into the suppression chamber water. HPCI system operation prevents the SRVs from cycling opened and closed. The SRVs have a nasty habit of sticking open, so minimizing the times they open lessens the chances they stay open.

The normal source of water for the HPCI system is the Condensate Storage Tank. But if this tank’s water level drops too low or the water level inside the suppression chamber rises too high, valves will automatically close and open to swap the supply from the Condensate Storage Tank to the suppression chamber.

More than an hour after the scram, the water level within the suppression chamber was approaching the swap-over setpoint. Procedures directed the operators to bypass the automatic swap-over for this plant condition. The control room supervisor recognized this need and directed the operators to take this step. But they failed to complete the task before the HPCI pump suction was automatically transferred over to the suppression chamber.

Procedures only permitted HPCI to be operated in pressure control mode when it took water from the Condensate Storage Tank. So, the operators had to shut down the HPCI system and revert back to the undesirable reliance on SRVs cycling to control reactor pressure.

The NRC issued a green finding, the least severe among its green, white, yellow, and red violation classification scheme, for the failure to properly implement procedures resulting in the avoidable need to rely on the unreliable SRVs for pressure control.

RHR Use and Misuse

More than twenty-four hours later, the operators sought to place the Residual Heat Removal (RHR) system in shutdown cooling mode. The RHR system is like a Swiss army knife—it can makeup water to the reactor vessel, cool water in the reactor vessel, cool the containment atmosphere, cool the torus water and airspace, and cool the spent fuel pool (Fig. 6).

 Nuclear Regulatory Commission)

Fig. 6 (Source: Nuclear Regulatory Commission)

The shutdown cooling mode uses one or two of the RHR pumps to take water from a recirculation system pipe connected to the reactor vessel, route it through heat exchangers where lake water cools it down, and return the cooled water to the recirculation system pipe so it flows into the reactor vessel (Fig. 7).

 Nuclear Regulatory Commission)

Fig. 7 (Source: Nuclear Regulatory Commission)

The procedure directed the operators to flush the RHR system piping before placing the system in shutdown cooling mode. The RHR system is normally in standby and stagnant water inside its pipes is “dirty” water compared to the nearly pure water circulating through the reactor vessel. Workers used the condensate transfer system to drain water from the RHR system pipes and replace it with “clean” water. Workers opened valve 10RHR-274 to perform this flushing activity.

The procedure directed operators to close 10RHR-274 before placing the RHR system into the shutdown cooling mode. But the operators failed to close this valve. When properly aligned, the RHR shutdown cooling mode merely circulates water from the reactor vessel through heat exchangers and back to the vessel, neither removing nor adding water inventory. With the improper alignment caused by the open valve, the RHR shutdown cooling mode added water to the reactor vessel. And not just a little bit of additional water.

The normal water level inside the reactor vessel is about 196 inches (16 1/3 feet) above the top of the reactor core. A rule-of-thumb is that about 200 gallons of water is needed to raise or lower the vessel level by one inch. So, nearly 40,000 gallons of water must drain out or boil off for the normal water level to drop to the reactor core’s level, even more to uncover the core.

Fig. 8 (

Fig. 8 (Source: Nuclear Regulatory Commission)

By running RHR shutdown cooling mode with the valve mistakenly open, the operators added water to the reactor vessel at FitzPatrick until water poured into the main steam lines. The main steam lines are located about 86 inches (over 7 feet) above the normal water level. It took nearly 17,200 gallons of water to increase the vessel level to the point of sending water down the main steam pipes.

As shown in Fig. 8, the level of the main steam line nozzles is above the upper scales of the Narrow Range and Wide Range water level instruments—the gauges the operators are trained to monitor frequently. Even if distracted, an alarm sounds in the control room when the vessel level rises just a few inches (not feet) above normal.

Sending water through the main steam lines could have disabled the HPCI system, the Reactor Core Isolation Cooling (RCIC) system (a smaller version of HPCI), and the SRVs. These systems and components are designed for steam, not water. Overfilling the reactor vessel could have taken away all of the high pressure safety systems for the reactor.

The NRC issued a green finding, the least severe among its green, white, yellow, and red violation classification scheme, for the failure to follow procedures resulting in loss of vessel level and potential impairment of multiple safety systems.

Our Takeaway

The HPCI swap-over miscue is a reminder of the trap one can fall into when given plenty of time to accomplish a short-term task. It did not take very long to install the bypass on the automatic swap-over. The operators had many tasks to perform besides installing the bypass. It was tempting to undertake seemingly higher priority tasks during the ample time before the swap-over point was reached. But time expired before the bypass was installed.

The RHR shutdown cooling miscue is a reminder about the importance of follow-up. Operators must maintain situational awareness, especially after the situation changes. In this case, placing the RHR system in shutdown cooling mode should have been followed by close monitoring of reactor water parameters to confirm that the temperature began decreasing and the level remained constant. Early awareness that something was wrong would have enabled intervention to minimize the consequences.

This one event revealed problems with the operators planning and implementing tasks. If operator performance is deficient when ample time is available and stress levels are low, how would the operators perform during an accident? The NRC’s Green findings would likely become Yellow or Red as the consequences of miscues become more significant.

So, the proper response to NRC’s slaps on the wrists is not to purchase wrist guards to lessen the sting of future slaps, but to take steps necessary to avoid future slaps, or worse.

Fission Stories” is a column by Dave Lochbaum. For more information on nuclear power safety, see the nuclear safety section of UCS’s website and our interactive map, the Nuclear Power Information Tracker.

Peter Navarro: Trump’s “China Policy Czar” ?

President-elect Trump named Peter Navarro to head the as-yet-uncreated White House National Trade Council. What does this portend?

Michael Wessel, a long-serving member of the US-China Economic and Security Review Commission (USCC), argued the United States government needs “to put somebody in charge” of US China policy “who looks at both the economic and national security implications of the US-China relationship and recognizes that they are inextricably intertwined.” Navarro definitely fits that description.

Navarro’s China: “The Planet’s Most Efficient Assassin”

It is not clear what this council will do or how it might influence US-China relations. What is clear is that Dr. Navarro believes that trade with China is a zero-sum game the United States is losing. Moreover, the Harvard-educated economist also believes that “an authoritarian and increasingly militaristic China” is using its supposed trade advantage to execute “a hegemonic agenda” that could lead to a nuclear war with the United States.


 Death by China.

Dr. Peter Navarro pictured next to a poster advertising a film based on his book: Death by China.

Dr. Navarro authored a trilogy of books that articulate his view of the “inextricably intertwined” relationship between the China trade and the possibility of nuclear war. In those books he argues that China is “the greatest single threat facing the United States” and that “every ‘Walmart dollar’ we Americans spend on artificially cheap Chinese imports” increases that threat. He describes China as a “budding colonial empire” with “lethal appetites” for energy and raw materials that are feeding “the extremely rapid and often chaotic industrialization of the most populous country on the planet.” Most importantly, he argues that China’s rapid modernization has “put it on a collision course with the rest of the world.”

Navarro writes that unless this course is altered the United States and China are “inexorably headed for conflict—and perhaps even a nuclear cliff.” He claims that China “now houses a rapidly growing arsenal of nuclear-tipped ballistic missiles” that are aimed at the United States and most of China’s neighbors, including non-nuclear weapons states like the Philippines and Vietnam. He suggests China may already have thousands of such missiles hidden in an “underground great wall.” Alarmingly, Navarro seems convinced that China’s leaders would “opt for nuclear war” and “ride things out in China’s many bomb shelters” if they cannot prevail in a conventional conflict with the United States.

Few economists would agree that all the benefits of the global China trade accrue to one side, or, in Navarro’s words, that “China has boomed at the expense of much of the rest of the world.” To the contrary, many believe China’s economic development is now the single greatest contributing factor to global economic growth.

Similarly,  Navarro’s characterization of China’s nuclear capabilities draws on a discredited analysis based on questionable sources and methods that are not accepted by US intelligence agencies or security experts.

Nevertheless, his appointment suggests he has the confidence of President-elect Trump, who seems to be using the transition period to signal a dramatic shift in US China policy.

Implications for US China Policy

Navarro’s prescription for change is a policy of economic and military containment. It is based on the following diagnosis from University of Chicago professor John Mearsheimer.

“What really makes China so scary today is the fact that it has so many people, and it’s also becoming an incredibly wealthy country so that our great fear is that China will turn into a giant Hong Kong. And if China has a per capita GNP that’s anywhere near Hong Kong’s GNP, it will be one formidable military power. So a much more attractive strategy would be to do whatever we can to slow down China’s economic growth – because if it doesn’t grow economically, it can’t turn that wealth into military might and become a potential hegemon in Asia.”

Navarro anticipates that US allies, and US consumers, will oppose containment because of the economic costs, which would be higher prices for US consumers and significant disruptions to Asia’s economy. But he believes he can eventually persuade the people of the United States and the policy-makers of Asia that trading with China is equivalent to “helping to finance a Chinese military buildup that may well mean to do us and our countries harm.”

Given this, it is not unreasonable to expect that Dr. Navarro will use the bully pulpit of the White House National Trade Council to make this case for an economic boycott of China.

On the military side Navarro imagines the United States can only keep the peace if it is able to work with its allies to “demonstrate a collective level of capabilities that, on the one hand, are not directly threatening to China, yet on the other hand are unassailable by any imaginable display of Chinese force.” He recommends “using attack submarines” to build an “undersea Great Wall” on China’s periphery. Navarro also supports the deployment of “substantially larger numbers” of “both the F-35 fifth generation fighter and the new Long-Rang Strike Bomber.” Most importantly, he argues that the Chinese leadership must be made to believe that the United States has the “will and resolve” to “use nuclear weapons if they must” to stop conventional Chinese aggression.

It is difficult to believe that China would not find these recommendations “directly threatening.” While the new trade council Navarro will lead is unlikely to deal with military issues, his views may still influence the thinking of others within the administration.

How Might China Respond?

Should the Trump administration act on Dr. Navarro’s recommendations for a policy of economic and military containment, it will most likely strengthen the credibility of China’s defense and foreign policy analysts who perceived the Obama administration’s “pivot to Asia”  as a means of containment. To them, Navarro’s recommendations are a logical acceleration of an already well established anti-Chinese drift in US policy.

Chinese voices who argue for greater engagement with the United States—and greater accommodation of US concerns— are more likely to be marginalized.

US exporters, especially those in the technology sector,  are likely to be effected by increased Chinese efforts to make their economy less reliant on the United States. Already substantial Chinese domestic investment in indigenous technical development is likely to increase.

The Chinese space program offers an interesting guide to the potential consequences. Many of the same US China analysts Dr. Navarro cites in his books were associated with US congressional efforts in the late 1990s to block US contact with the Chinese space community. The restrictive policies they enacted grew more severe over the past two decades. Yet, during that time China made dramatic advances in space science, technology and applications. It also expanded its relationships with other international partners, such as the European Space Agency. US efforts to “contain” the Chinese space sector arguably made it stronger than it otherwise might have been by stimulating the development of domestic Chinese capabilities and alternative international partnerships.

China is unlikely to be overly concerned about Navarro’s recommendations on credible US nuclear threats. For the time being, at least, Chinese strategists assign one and only one purpose to China’s nuclear forces, which is to prevent a nuclear attack on China. Traditionally they have believed that the requirements for preventing such an attack are rather low. Retaliation with as little as a single Chinese nuclear strike against one US city is believed to be enough to deter any US president from attacking China with nuclear weapons.

Navarro, and others around President-elect Trump, may put great stock in the strategic value of his unpredictably but this is unlikely to shake China’s faith in the deterrent effect of its potential to retaliate.

Chinese adaptations to any changes in the US nuclear posture will be focused on assuring the ability of its nuclear forces to survive a US first strike. That may include a modest increase in the size of Chinese nuclear force. But one of the more troubling proposals already under consideration is upgrading the alert status of China’s forces so they can be launched on warning on an incoming US attack. The early warning systems needed to implement such a policy are known to give false warning, especially in the early years of their operation.

Navarro’s recommendations, if acted upon, could cause Chinese leaders to expedite the development and deployment of an early warning system, increasing the risk of an accidental or mistaken Chinese nuclear launch against the United States.

End of the (Weekly) Line

It began on July 6, 2010, with commentary about a flood inside the Unit 2 containment building at Indian Point. Fission Stories were weekly commentaries about nuclear power plant problems. Fission Stories #198 ended the series on September 29, 2015.

In March 2013, the weekly Fission Stories were supplemented by Nuclear Energy Activist Toolkit (NEAT) commentaries. The NEAT commentaries were more educational than advocacy, seeking to explain technology and regulatory processes rather than critique them. NEAT #64 ended the series on September 22, 2015.

The Disaster by Design/Safety by Intent weekly commentaries began on October 6, 2015, with a summary of how U.S. nuclear plants are vulnerable to flooding.

After nearly 325 posts, UCS is retiring the weekly commentaries. Instead, we are reactivating the Fission Stories and Nuclear Energy Activist Toolkit commentaries to join the Disaster by Design/Safety by Intent. When we come across something that warrants commentary, we will use whichever of these templates fits best and post it. The result may be multiple postings in one week or multiple weeks between postings.

This change gives us the freedom of posting commentaries that are more timely and topical rather than finding topics that match the current theme. Hopefully, this will result in better use of our resources and, more importantly, better meet your needs.

We truly appreciate those who have read these commentaries over the years and look forward to sharing our perspectives with you in the future via this revised format.

You can sign up for an RSS feed and be notified of new AllThingsNuclear posts by clicking here. (Note: If you get a screen full of html code when you follow this link, try using a different browser.)

Reflections on the IAEA Nuclear Security Conference: More Participants, Less Focus

Last week I had the opportunity to attend the conference on nuclear security in Vienna sponsored by the International Atomic Energy Agency (IAEA). The conference was enormous, with 2,000 participants from 130 countries. The US official delegation alone had over 100 people. I heard (but have not substantiated) that the ministerial meeting that preceded the technical meeting attracted a larger number of national delegations than any other IAEA conference in its history. By one measure—inclusivity—the conference seems to have been a success.

However, that success came at a price: a reduction of focus on the most serious nuclear threat—the theft of fissile materials (highly-enriched uranium (HEU) and plutonium) that terrorists could use to make improvised nuclear weapons.

The greatest threat: Nuclear-weapon-usable materials


HEU (Source: DOE)

Addressing the threat of theft of these materials was the original purpose of the Nuclear Security Summits that began in 2010 under President Obama and ended in April this year. Countries attending these meetings were encouraged to reduce or eliminate their civil stocks of HEU (and to a more limited extent, plutonium) by shipping them to the US or Russia.

As there is little optimism that the incoming Trump administration will continue a comparable effort, many hope that a successor ­to these Nuclear Security Summits will continue under the IAEA’s mantle. The conference last week was the first to occur after the final Summit in April, and was regarded as the potential launching point for an enduring successor.

Only a relatively small number of countries possess significant quantities of weapon-usable uranium or plutonium (and the number has decreased as the result of the Nuclear Security Summits). Attendance at the Summits was limited to around 50 states that collectively possess 98% of the world’s civil fissile materials (if Russia, who declined to attend the final Summit in 2016, is included).

Radiological threats

However, many more countries have nuclear power plants and research and test reactors than stocks of fissile materials, and even more have radioactive sources for use in medicine and industrial applications. To get more member states actively involved, the IAEA had to broaden the scope of what it considered “nuclear” security to include what is more commonly referred to as “radiological” security. This would range from preventing the sabotage of nuclear power plants to preventing the theft and dispersal of radioactive sources, encompassing a wide spectrum of radiological consequences.

While the risk of radiological attacks is a significant concern, even the most severe radiological terrorism events would be less devastating than the detonation of a crude nuclear weapon, at least in terms of immediate deaths, injuries, and destruction of infrastructure. To lump all these issues together under the general rubric of “nuclear security” distracts from a focus on the greatest dangers.

Even worse, some nations used this broader agenda to divert attention from their greatest security problems. For instance, the French devoted their ministerial statement largely to radiological source security, and failed to address the risks associated with the large stockpile of plutonium within France, or France’s continuing efforts to promote spent fuel reprocessing (which produces plutonium) around the world.

Different threats need different venues

Nuclear terrorism, nuclear power plant sabotage and malevolent use of radiological sources are very different threats and require different measures to protect against them. Optimally they should be addressed in distinct venues.

On the other hand, the scope of the conference should not be so narrow that it excludes issues that do have an important nexus with fissile material security.

Consider one of the actions announced by the United States in its ministerial declaration at the conference: namely, the commitment to make 6 metric tons of excess plutonium that the United States had previously decided to directly dispose of available to the IAEA for monitoring and inspection. Since IAEA safeguards are not intended to protect material against terrorist theft, but to verify that the owner nation is not misusing the material for nuclear weapons purposes, some attendees questioned the relevance of this announcement to the purpose of the conference.

However, as UCS has long pointed out, direct disposal of excess plutonium poses fewer opportunities for theft than the main alternative approach, converting the plutonium to MOX fuel and using it in nuclear reactors. To the extent that the US declaration strengthens the political legitimacy of the direct disposal option, it will further diminish the prospects for the MOX approach and ultimately will avoid an increase in the risk of theft of US excess plutonium by terrorists. It could also provide a model for other countries, like France and Japan, who have accumulated worthless and dangerous stockpiles of plutonium.

Trump’s New China Policy: The Flynn Factor

In a recent interview, President-elect Trump confirmed what UCS anticipated in the first post of its China Transition Watch; that the Nixon-Kissinger era in US – China relations, established on the basis of the “one China policy,” is coming to a close. The question now is what comes next?

If the call is any indication of how President Trump intends to manage consequential decisions on US-China relations, his foreign policy advisors are likely to play a decisive role.

The Secretary of Defense, the Secretary of State and the National Security Advisor direct many of the human, technological and fiscal resources involved in the formation and execution of US foreign policy. Although it now appears that retired General James Mattis may become the Secretary of Defense and Exxon-Mobile CEO Rex Tillerson may become the Secretary of State, both prospective nominees need to be confirmed by the Senate before assuming office.

Lt. General Michael T. Flynn, Mr. Trump’s choice for National Security Advisor, does not. So it is worth examining his views on world affairs and how they might influence the course of US-China relations.

Lt. Gen. Michael Flynn (far right) greets Japanese Prime Minister Shinzo Abe with President-elect Donald Trump during the prime minister's visit to Trump Tower shortly after the US election.

Lt. Gen. Michael Flynn (far right) greets Japanese Prime Minister Shinzo Abe with President-elect Donald Trump during the prime minister’s visit to Trump Tower shortly after the US election.

“Informed” Intelligence ?

Mr. Flynn is a retired US intelligence officer who believes China is part of a “working coalition” of state and non-state actors composed of  “jihadis, Communists and garden variety tyrants.” He also believes the United States is engaged in “a world war” against this collection of bad actors, who Flynn believes are bound together by a shared hatred of “the West.”

China does not appear to play a major military role in this war. The principal enemy is something Flynn describes as “radical Islam” and he identifies Iran and Russia as its two most important sources of state support. He described China’s involvement as “more of an economic issue.” Flynn did write that his experience as a young military officer with the 25th Infantry Division brought him into contact with “a wide swath” of enemies in the Asia-Pacific who he believes are still out there. But these Asian enemies are unidentified and receive scant attention in his 2016 best selling book, The Field of Fight.

In a discussion of the book at the Heritage Foundation Flynn singled out the Beijing-based Shanghai Cooperation Organization (SCO) as a cause for concern. He described it as “a partnership that China and Russia just signed” that is “anti-American” and “anti-Western.” Flynn did not seem to realize it was officially founded by six nations more than 15 years ago and that eight other nations have varying degrees of semi-official representation as of 2015. There is no anti-Western or anti-American language in the SCO charter, which expresses support for the United Nations, international law, the prevention and peaceful resolution of international conflict, disarmament and arms control, cultural exchanges and global economic cooperation. Moreover, one function of the SCO is cooperation on anti-terrorism measures, which, presumably, would make the member nations of the SCO allies in combatting Flynn’s “radical Islam.”

Flynn also told the Senate Armed Services Committee that China has 800,000 “cyber warriors,” a figure that strains credulity. He also told the committee China was spending more than twice as much on its military as it publishes in its official budget—an estimate significantly higher than those published by the US Department of Defense and credible independent observers. Exaggeration is not a trait normally associated with a trained intelligence officer but Lt. Gen. Flynn does it quite often. During the campaign, for example, he warned an audience about the “strategic threat” of demographic changes in the US population, which he claimed had “tripled since 1950.” (It hasn’t.) This was not a slip of the tongue. He said it twice, just before arguing that the word “progressive” is a “politically correct way of saying socialist” and just after claiming Democratic Party state legislators tried to impose Islamic law on the citizens of Florida.

The Clash of Civilizations: Who is the Enemy?

Flynn makes repeated references to the Chinese military strategist Sun Zi (545-460 BC) in his book and in his public remarks, most frequently in regard to distinguishing friends from enemies. Flynn believes Sun Zi’s most important admonition was to “know your enemy.” Understanding who Flynn thinks he is fighting in his “world war” requires us to imagine what could possibly tie together Middle Eastern jihadists, the Chinese and US progressives.

Flynn explained to US journalist Charlie Rose that in his view the United States is facing a “moral, social and cultural” threat more than a military one. What ties Flynn’s disparate collation of adversaries together is their supposed rejection of “the West,'” a term Flynn uses interchangeably with both “American” and “Judeo-Christian” culture. Flynn, it seems, thinks the United States is in a global struggle to defend Western civilization from its enemies, both foreign and domestic.

Flynn’s conception of the world as an arena of competing cultures fits within a strain of US foreign policy analysis that emerged from Harvard Professor Samuel Huntington‘s seminal 1993 article in Foreign Affairs on The Clash of Civilizations. Huntington argued that “world politics was entering a new phase” where “the great divisions among humankind and the dominating source of conflict will be cultural.” In this new phase the “centerpiece” of international politics is “the interaction between the West and non-Western civilizations.” Huntington argued nations that did not join “the West” were coalescing around a “Confucian-Islamic connection that has emerged to challenge Western interests, values and power.”

In a best-selling book on the same theme Huntington broadened his analysis by connecting foreign policy to domestic politics. He warned that “the West” was going through “a universal stage of decay” characterized by “moral decline, cultural suicide and political disunity.” This decline was brought on by a “small but influential number of intellectuals and publicists” who advanced “a multicultural trend” in the wake of “the civil rights acts of the 1960s” that made “the encouragement of diversity one of its major goals.” This elite also promoted “multi-civilizational economic integration plans” like the North American Free Trade Agreement (NAFTA) and the Asia-Pacific Economic Cooperation (APEC) pact.

Huntington compared this liberal internationalist elite to Marxists for promoting a “universalist” ideology that sought to subordinate human cultures to the social, economic and political forces of globalization.

He believed this elite effort to promote multiculturalism at home and universalism abroad was doomed to fail, and if the United States continued to promote it Western civilization would inevitably fall to the more dynamic non-Western cultures resisting globalization. This is the same fear that animates Lt. Gen. Flynn, and is a fear that brought a surprising number of non college-educated whites, Christians and nationalists to the polls to support Mr. Trump, who ran on a zero-sum foreign policy that promised to put “America first.”

Implications for US China Policy

An important motivation for the US “one China policy” that Trump put up for negotiation was the expectation that “engagement” with China would eventually transform the communist regime into a “responsible stakeholder” in a US-centric international order. The Obama administration’s “pivot to Asia” was a hedge against a potentially irresponsible China seeking to upset that order. But the pivot policy also held on to the hope that change would eventually come to China.

In contast, Trump’s world view appears closer to Huntington’s. He may deal with China but he won’t engage it with the expectation or objective of changing it.

Flynn has little experience dealing with the “Confucian” members of the anti-Western, anti-American axis he believes he is fighting. One consequence may be that Flynn will be inclined to subordinate the economic and security needs of Japan and other US Asian allies to what he perceives to be more urgent concerns in other parts of the world. Trump has already signaled he expects Japan and other Asian nations to pay more to sustain the US military.

Neither man displays an understanding or special interest in Asian peoples or cultures. Nor do they see the need to keep Asians invested in the idea of global economic integration. The Trans-Pacific Partnership (TPP), a global trade agreement President Obama argued was needed to prevent China from controlling Asian commerce, will go forward under President Trump without US participation, if it goes forward at all.

The President-elect introduced his choice for National Security Advisor as “one of the country’s foremost experts on military and intelligence matters.” Flynn’s expertise in Asia, however, is clearly lacking.

Huntington predicted that the United States would be unable to prevent Chinese dominance in Asia. It is unclear if Flynn and Trump would agree. What does seem clear is that both see China as an implacable adversary in a divided world rather than a potential partner in the construction and maintenance of a global community.

That’s a seismic shift in US foreign policy that could force US Asian allies into choosing sides; a choice they’d rather not have to make. It could also increase animosities between the United States and China, and between Asian nations, that produce self-fulfilling prophecies and prevent them from working together.

Protecting Against Fatigued Nuclear Plant Workers

Disaster by Design/ Safety by Intent #62

Safety by Intent

The Nuclear Regulatory Commission (NRC) revised its regulations requiring nuclear plant workers to be fit for duty on March 31, 2008, to include measures intended to protect against mistakes made by workers impaired by fatigue. Specifically, Subpart I, “Managing Fatigue,” was added to 10 CFR Part 26, “Fitness for Duty Programs.”

The NRC issued its fitness for duty requirements in the late 1980s in response to Congressional concerns about reports of illegal drug use by nuclear plant workers. The original requirements instituted initial, random, and for-cause drug and alcohol testing of all workers granted access inside nuclear power plants.

On September 28, 1999, Barry Quigley, a worker at a nuclear power plant in Illinois, petitioned the NRC to revise its fitness for duty regulation to impose limits on the number of hours worked by nuclear plant staffers. Quigley proposed that the NRC revise its regulations to limit workers to 60 hours per week and 108 hours over al-two-week periods during normal operation with some relaxation of these limits when the plant is shut down.

The NRC convened a series of public meetings to discuss the working hour limits petition. I participated in many of the meetings on behalf of UCS. The matter interested a lot of groups and individuals with a range of viewpoints. Some, like the Professional Reactor Operator Society (PROS) and the International Brotherhood of Electrical Workers (IBEW), expressed concern that limits on working hours could reduce the amount of overtime pay earned by their members. They pointed out potential consequences from the working hour limits being sought—workers might obtain second jobs to replace the lost overtime wages.

The NRC invited specialists to the meetings to inform the discussions. For example, Dr. Gregory Belenky from the Division of Neuropsychiatry at the Walter Reed institute of Research presented insights from research on sleep and human performance.

Fig. 1 (

Fig. 1 (Source: Nuclear Regulatory Commission)

The differing perspectives by various stakeholders shaped by the insights from the specialists led to changes in the working hour limits proposed in Quigley’s petition. For example, the petition would impose working hour limits on all persons subject to the drug and alcohol provisions in Part 26. Industry representatives pointed out that many workers performed tasks that were very unlikely to contribute to a nuclear plant accident even if a worker was impaired by fatigue during their performance. An engineer calculating the power supply loads to be met by an emergency diesel generator could make a mistake due to fatigue. But that engineer’s work must be independently checked by another engineer and approved by a third individual, providing opportunities for any mistakes to be corrected. The scope of the fatigue management rule was therefore narrowed to only those workers with “hands on” tasks whose mistakes might more immediately and directly have adverse consequences—operators, maintenance personnel, and (after 9/11) security force personnel.

The Outcome

The final rule limits individuals to working no more than 16 hours during any 24-hour period, 26 hours during any 48-hour period, and 72 hours during any 7-day period.

The final rule also contained measures intended to address the situation where individuals are within the working hour limits but feel fatigued. For example, a worker may not have gotten a full night’s rest due to caring for an ill child. Under the final rule, that individual has the right to self-declare feeling fatigued without fear of reprisals. This provision explicitly addressed a problem that NRC identified in 2002 with some workers being compelled to work when impaired by fatigue or being fired for refusing to work.

The final rule contains another provision that had not been in Quigley’s petition that was added as a result of the insights provided by the specialists—the need for break periods. The specialists agreed that it was vitally important for individuals to have periodic opportunities for rest and relaxation. The final rule therefore requires that workers receive a 10-hour break between work periods and a 34-hour break every nine days. Individuals working 8-hour shifts must be given at least one day off per week, persons working 10-hour shifts must be given at least two days off per week, and individuals working 12-hour shifts must be given at least 2.5 days off per week when averaged over a shift cycle of six weeks or less.

The final rule recognized that situations could arise that required individuals to exceed the working hour limits. The rule contains a provision describing when management can authorize individuals to exceed the limits. The final rule also requires owners to submit annual reports to the NRC on the number of times when individuals exceeded the working hour limits.

The final rule adopted by the NRC was more compromise than consensus. No stakeholder got everything he or she wanted included in the final rule. I am not a fan of the provision allowing individuals to work longer hours when a reactor is shut down, particularly when that reactor is at a plant with multiple reactors and at least one other reactor is operating. But the NRC’s rulemaking process considered my viewpoints equally with the viewpoints of Barry Quigley, PROS, IBEW, the nuclear industry, and all other stakeholders. The NRC’s regulatory analysis supporting the final rule explained why some aspects were included in the final rule while others were not.

Many NRC staffers were involved in the multi-year process leading to the final rule. Among them, Dr. David Desaulniers played a key role as the efforts’ technical lead. In addition to the considerable education and experience he brought to the table, Dr. Desaulniers served as a calming influence when stakeholders passionate about their viewpoints disagreed on the problem and its solution. He effectively enabled open discussions while discouraging non-productive debates.

The final rule does not provide absolute protection against mistakes made by fatigued nuclear plant workers. But it provides significantly better protection than had existed.

Disaster by Design

The problem that happened yesterday is much easier to solve than the problem that might occur tomorrow.

Worker fatigue did not cause the Three Mile Island accident and did not contribute to the Davis-Besse near-miss. Worker fatigue was therefore a potential problem. Nevertheless, the NRC revised its regulations to better manage the risk from this potential problem.

No one can count the umber of accidents avoided by the NRC’s working hour limits rulemaking. But the NRC’s rulemaking makes it less likely for worker fatigue to account for one accident. That seems like a good deal.


UCS’s Disaster by Design/ Safety by Intent series of blog posts is intended to help readers understand how a seemingly unrelated assortment of minor problems can coalesce to cause disaster and how effective defense-in-depth can lessen both the number of pre-existing problems and the chances they team up.

Cuts to the Fissile Materials Stockpile

The Final Countdown

The United States maintains stockpiles of weapons-usable fissile materials—plutonium and highly enriched uranium (HEU)—that are much larger than needed. This material is a security risk, and is also expensive to store safely. Some of this fissile material has already been declared “excess to military needs” and is awaiting disposition. Even after that excess material is disposed of, however, the United States will still have far more material than it needs for its current or future arsenal. President Obama should declare additional material excess and schedule it for disposition as soon as possible. If done correctly, this would reduce opportunities for nuclear terrorism. It would also be a step toward making nuclear reductions more difficult to reverse.


The United States currently has just over 95 metric tons of plutonium. Of the original 99.5 metric tons of plutonium in the 1994 U.S. inventory, it declared 61.5 metric tons as excess to military needs. About four metric tons of this has already been disposed of,  and the U.S. is examining methods for disposing of the  other 57.5 metric tons of plutonium that was declared excess. Of the remaining 33.5 metric tons that is reserved for weapons use, some is in deployed and hedge weapons, and some is in plutonium pits removed from weapons that have been retired and dismantled.

U.S. nuclear weapons contain less than four kilograms of plutonium in their pits, which means that the current U.S. nuclear arsenal of roughly 4,500 deployed and reserve weapons contains no more than 18 metric tons of plutonium. Thus, President Obama could declare up to an additional 15 metric tons of plutonium excess to military needs while still maintaining the U.S. arsenal and hedge at its current size. Earlier this week the Department of Energy issued a press release saying that the United States “commits to IAEA [International Atomic Energy Agency] monitoring for the verifiable disposition of six metric tons of surplus plutonium.” But lest there be any confusion, this is not a commitment to declare any additional plutonium excess, it simply means that of the plutonium it has already declared excess, six metric tons will be made subject to monitoring and verification by the IAEA. The president should declare as excess the additional 15 metric tons of plutonium mentioned above.

However, disposing of this plutonium will only reduce the terrorism risk if it is done right. Until recently, the United States was planning to convert the plutonium into “MOX” fuel for nuclear power reactors. (MOX is a mixture of plutonium and uranium oxides.) It has been building a large facility at the Savannah River Site in South Carolina to produce the MOX fuel, but this project has run into cost and schedule problems and the Department of Energy is considering other options. At the top of its list is “dilute and dispose,” which involves mixing the plutonium with inert materials and placing small quantities of the mixture in waste drums, which would then be buried in a deep underground geologic repository—the Waste Isolation Pilot Plant in New Mexico. The Waste Isolation Pilot Plant is currently closed due to a 2014 accident, but the Department of Energy says it plans to resume operations by the end of 2016.

You know it’s going through your head now anyway

You know it’s going through your head now anyway

Disposing of the plutonium through MOX fuel, on the other hand, would entail converting it into an oxidized form, then mixing it with low-enriched uranium. The mixture would then be made into fuel rods for use in commercial nuclear reactors, and after the fuel is irradiated, the plutonium would become protected by the high levels of radiation in spent fuel. However, unused MOX fuel is not highly radioactive, and separating plutonium from MOX fuel requires only a straightforward chemical process. In addition, the fuel would be used in commercial reactors that do not have the security levels required for weapons-usable material. This means that the manufacture, transport, and storage of MOX fuel creates a greater security risk than would the dilute and dispose option.

Apart from security concerns, cost estimates for construction of the facility to fabricate the MOX fuel have jumped from $7.7 billion to more than $17 billion, and it is now not predicted to be operational until 2048more than 40 years behind schedule.

For all of these reasons, the United States should abandon the MOX approach to disposing of its excess plutonium and focus on the dilute and dispose option. In fact, the Obama administration is already trying to kill the MOX program because of the enormous increase in its costs. However, powerful supporters—including Senator Lindsey Graham of South Carolina—have prevented its demise. In the meantime, the most important priority is safe and secure storage of this material until the dilute and dispose program, which has already begun at a low level at the Savannah River Site, can be fully implemented.

Highly Enriched Uranium

In addition to its use in nuclear weapons, HEU is also used as a fuel for the nuclear reactors that power all U.S. submarines and aircraft carriers, though there are efforts to end this reliance on weapons-usable material. A 2014 report to Congress from the Office of Naval Reactors states that “recent work has shown that the potential exists to develop an advanced fuel system that…might enable either a higher energy naval core using HEU fuel, or allow using LEU fuel with less impact on reactor lifetime, size, and ship costs.” It is used in some U.S. research reactors as well, but this number is declining as more switch to low-enriched uranium (LEU), which is highly impractical for use directly in nuclear weapons.

The International Panel on Fissile Materials (IPFM) estimates that the U.S. stockpile of HEU is currently about 600 metric tons, with 253 tons of this in weapons or available for use in weapons. U.S. nuclear weapons contain about 15 kilograms of HEU in their secondaries, and some also contain another 10 kilograms of HEU in their primaries. If each weapon in the arsenal contains 15 to 25 kilograms of HEU, the current U.S. arsenal of 4,500 total weapons contains between 68 and 113 metric tons of HEU. This means that the president could declare an at least an additional 140 metric tons of HEU as excess while still maintaining the current arsenal and hedge size.

Over the last two decades, the United States has declared 374 metric tons of HEU to be excess to needs for nuclear weapons. Part of this—152 metric tons—has been set aside for use as fuel for naval nuclear reactors, and another 20 metric tons was reserved for space and research reactors. The remaining excess HEU is scheduled for disposal; most will be down-blended—mixed with natural or depleted uranium to turn it into LEU, which cannot be directly used in weapons but can be used to produce reactor fuel of the sort currently used. Another 22 metric tons that is in spent fuel will be disposed of in a geological repository.

According to the IPFM, by the end of December 2014 the United States had down-blended or shipped for down-blending 146.6 metric tons of HEU. The Department of Energy’s FY 2016 budget request indicates that all 186 metric tons of excess HEU that are scheduled for down-blending will be completed by the end of 2030. This is sooner than the previous target date of 2050, but still only requires down-blending about 2.5 metric tons of HEU per year to complete disposal of the 40 metric tons of HEU that is left, a much slower rate than in the past, when it was about 10 metric tons per year. The Department of Energy has said that this rate depends on “decisions regarding the U.S. nuclear weapons stockpile, the pace of warhead dismantlement and receipt of HEU from research reactors,” among other things. So far, speeding up the down-blending rate further does not seem to be a priority, but until all this excess HEU is down-blended, it remains a security risk.


Cuts to the Hedge

It’s Now or Never

One of the things President Obama could still do before leaving office is to cut the “hedge” force. These are nuclear weapons that the United States keeps in reserve for two reasons: technical and geopolitical. The argument for the technical hedge is that, if deployed weapons of one type experienced a problem, the U.S. could instead deploy weapons of another type from the hedge force. The geopolitical argument is that the international security situation could change, leading the United States to want to increase the number of deployed weapons.

In reality, both of these scenarios are extremely unlikely. The current nuclear stockpile is thoroughly understood and can be well maintained for decades to come by taking a sensible approach and minimizing warhead changes. It is also hard to imagine such a sudden change in the geopolitical situation that the United States would want to quickly deploy more nuclear forces. UCS and many others have long argued that the United States could reduce its arsenal to 1,000 warheads total, including hedge forces, and have more than enough warheads to ensure our security under any circumstance.

But setting that all that aside, let’s look at the current numbers in the hedge and how they could be reduced. The US keeps about 2,550 weapons (2,250 strategic and 320 tactical) in the hedge.

To comply with the New START treaty, the United States and Russia will each reduce their deployed accountable strategic weapons to 1,550 by 2018. For the United States, the actual number will likely be roughly 1,750. (This number is larger because of the way the treaty defines what counts as a weapon—bombers count as only one weapon even though they may carry multiple bombs or air-launched cruise missiles.) A study by my colleague Lisbeth Gronlund shows that the current U.S. hedge of 2,250 strategic warheads is almost twice the required technical hedge for an arsenal of that size with existing warhead types. Cutting the hedge would eliminate the costs of maintaining and storing these weapons, as well as reduce the overall U.S. arsenal and be a step toward eliminating nuclear weapons, as the United States is obligated to do under the terms of the Nuclear Non-Proliferation Treaty. President Obama could use his authority to order an immediate reduction in the size of the hedge, thereby transferring these weapons to the dismantlement queue.

Immediately Cut the Existing Hedge Maybe Obama could use a little Elvis.

Maybe Obama could use a little Elvis.

A 2013 administration report to Congress states that the Departments of Defense and Energy have re-examined their approach to determining the size of the hedge needed and concluded that a new, more efficient, strategy would allow the United States to “maintain a robust hedge against technical or geopolitical risk with fewer nuclear weapons.” It goes on to say:

A non-deployed hedge that is sized and ready to address these technical risks will also provide the United States the capability to upload additional weapons in response to geopolitical developments that alter our assessment of U.S. deployed force requirements.

In other words, a hedge that is large enough for one scenario (the failure of all weapons of one type) is also large enough to cover another scenario (a U.S. desire to quickly deploy more weapons for political reasons). That is actually significant progress, though it hasn’t led to any changes in the hedge yet.

Looking further ahead, the FY 2016 Stockpile Stewardship and Management Plan, which details plans for maintaining and upgrading U.S. nuclear warheads, states that the United States could eventually reduce the hedge by up to 50 percent. However, it specifies that this is only possible once the United States fully implements its ambitious “3+2” plan to replace its four types of ballistic missile warheads (two on land-based intercontinental ballistic missiles and two on submarine-launched ballistic missiles) with two sets of three newly-designed “interoperable” warheads—one set for use on ICBMs and the other on SLBMs. While the warheads themselves would not be interoperable (the ones for ICBMs would differ from those for SLBMs), the core of the weapon—the so-called nuclear explosive package—would be. Fully implementing the 3+2 plan will take decades, however, so this is irrelevant to current consideration of the hedge.

The same DOD document that talks about re-examining hedge requirements also discusses using “intra-leg hedging” to replace a failed weapon—in other words, replacing a failed SLBM warhead with another SLBM warhead, or a failed ICBM warhead with another ICBM warhead. Currently, it is not possible to do this with SLBM warhead types because while the arsenal includes two warheads for subs—the W76 and the W88—nearly all of the W88s are deployed, so none would be available as a backup if there were a problem with the W76. Instead, the United States would have to compensate for a problem with the W76 by deploying additional land- and air-based weapons, a strategy known as “inter-leg hedging.” While this would result in the same overall number of deployed weapons, fewer would be submarine-based. This has been the case with the U.S. arsenal for decades, and has not caused any problems. However, some DOD planners now see a chance to move toward their ideal “intra-leg” hedge force, and want to take it via the 3+2 program.

But there are a number of problems with building new warhead types to replace those in the existing arsenal. First, there are technical concerns. Using a nuclear explosive package that has not previously undergone nuclear explosive testing may reduce confidence in the reliability of the new warhead. This could lead some political and military leaders to push for renewed “proof testing” to demonstrate that the newly modified warheads will work as intended.

The unclassified executive summary of a study of the 3+2 plan by JASON, an independent group of scientists that advises the government, expresses skepticism about its benefits based partly on technical issues, noting that some of the program’s goals may compete with each other, and that some of the changes under consideration could “alter reliability or targeting accuracy.”

Second, on the political side, building new warheads could undermine U.S. nonproliferation goals by calling into question the U.S. commitment to the Comprehensive Test Ban Treaty and the Nuclear Nonproliferation Treaty. Finally, the 3+2 approach is almost certain to be more expensive than maintaining the existing stockpile through straightforward life extension programs. For example, the cost of the life extension program for the W76 warhead—the most common warhead in the U.S. stockpile—is around $4 billion. The cost estimate for the first warhead in the 3+2 plan is roughly twice that, and for far fewer warheads.

Moreover, as mentioned above, completing the 3+2 plan would take at least three decades. In short, the 3+2 plan is not the way to cut the hedge.

The good news is that the UCS study mentioned above finds that, for a New START-sized arsenal with existing warhead types, the hedge only needs to include 1,250 weapons to provide replacements in case of the technical failure of an entire class of weapon. And, as noted above, the DOD already concluded that there is no need for additional warheads beyond the technical hedge to meet its requirements.

In other words, rather than waiting decades to complete the 3+2 plan, the president could announce that the United States will immediately reduce the strategic hedge by 1,000 weapons—leaving 1,250.

In addition to strategic weapons, the hedge also contains 320 tactical weapons, all of which could be eliminated. These weapons are all B61 bombs, and would allow the US to add to the 180 tactical B61 bombs it currently deploys in Europe, or to deploy them elsewhere for “extended deterrence” purposes. The existing B61 bombs come in four versions, but are all in the process of being replaced with a single new variant—the B61-12—which will also serve as the U.S. strategic bomb. (The other existing U.S. strategic bomb, the B83, is planned for retirement.) Since there will no longer be a distinction between tactical and strategic bombs, there will no longer be a need for a separate tactical hedge.

Re-examine the Need for a Technical Hedge

More fundamentally, while immediately moving to cut the existing hedge, the United States should also reconsider the logic behind its decision to retain a technical hedge in the first place. Both Britain and France have significantly smaller and less diversified arsenals than the United States. Neither maintains a hedge in case of technical failures of their nuclear weapons. They also do not maintain multiple types of warheads for each delivery system. (France deploys one warhead type on submarines and another on aircraft. The UK deploys only one warhead type, on submarines.)

The failure of an entire class of weapons is highly unlikely, at least for existing weapon types, which have undergone nuclear explosive testing. The president should order a study to quantify the odds of such a failure and investigate whether it is necessary to maintain a technical hedge at all. Even if such a study finds that a technical hedge is advisable, it should not be necessary to employ three separate hedging strategies: keeping a technical hedge, deploying two types of warheads per delivery system, and deploying two types of ballistic missile delivery systems.

Trump’s Asia Advisors Want to Scrap the “Three Communiques” with China

My last post in this series ended with a video of President George W. Bush reiterating the U.S. commitment to a set of bilateral agreements known as “the three communiques.” Yesterday, two Asia experts advising the Trump transition, Randy Schriver and Dan Blumenthal, suggested the president-elect should scrap them. Both men are being considered for senior positions in the Trump administration. It now seems clear that Mr. Trump’s controversial outreach to Republic of China (ROC) President Tsai Ing-wen was not a simple “courtesy call,” but the first step in a coordinated effort by the Asia advisors on the Trump transition team to bring the Nixon-Kissinger era in US-China relations to a close. 

What are the “Three Communiques”?

The “three communiques” are a set of formal statements jointly issued by the the governments of the United States and the People’s Republic of China (PRC). The first communique, also known as the Shanghai Communique, was issued in February of 1972 during US President Richard Nixon’s historic trip to China. The second communique, also known as the Joint Communique on the Establishment of Diplomatic Relations, was issued on December 15, 1978 and became effective on January 1, 1979. The third communique, also known as the Joint Communique on Arms Sales to Taiwan, was issued on August 17, 1982.

President Richard Nixon and National Security Advisor Henry Kissinger meet with Chinese Premier Chou En-lai on the Shanghai Communiqué.

President Richard Nixon and National Security Advisor Henry Kissinger meet with Chinese Premier Chou En-lai on the Shanghai Communique.

All three communiques addressed US and PRC views on the sovereign status of Taiwan and their respective relations with the ROC government. In the Shanghai Communique China stated that the government of the People’s Republic of China is the sole legitimate government of China, that Taiwan is part of China and that unification was an internal affair. The US acknowledged “that all Chinese on either side of the Taiwan Strait maintain there is but one China and that Taiwan is a part of China” and reaffirmed the US interest in “a peaceful settlement of the Taiwan question by the Chinese themselves.”

In the Joint Communique on the Establishment of Diplomatic Relations the United States formally recognized that the government of the PRC is the sole legitimate government of China and that its continuing relations with Taiwan would be “unofficial” and conducted “within this context.” In The Joint Communique on Arms Sales to Taiwan, negotiated by President Ronald Reagan and Chinese Premier Zhao Ziyang, the United States declared it would not pursue a policy of “two Chinas” or “one China, one Taiwan.”

Schriver and Blumenthal questioned whether these three documents should still continue to govern US-China relations:

“There is, of course, a deeper and more complicated set of questions regarding the utility of communiqués drafted during the Cold War when an authoritarian Taiwan still claimed to rule “all of China.” A democratic Taiwan has long abandoned the claim that it represents “all Chinese across the Strait.” It is hard to think of another set of relationships still governed by joint communiqués from the Cold War era.”

The two prospective members of the Trump administration noted that the president-elect did not raise these questions during his call with ROC President Tsai. But should Mr. Schriver and Mr. Blumenthal be appointed to senior Asia-related positions in the US government, this “deeper and more complicated set of questions” is likely to be discussed.

Peter Navarro is another Asia expert advising the Trump transition who is being discussed as a nominee for a senior Asia-related position in the new administration. Like Schriver and Blumenthal, he also views the communiques pioneered by Nixon and Kissinger—and reinforced by every US president since—as a relic of the Cold War.  Moreover, he argues China is the now the most serious security challenge facing the United States, which must redefine its relationship with Taiwan in order to prevent the Chinese navy from gaining more open access to the Pacific Ocean.

Role for the Senate

The outlines of President-elect Trump’s China policy are taking shape under the direction of a new team of Asia experts who believe the United States needs a radical break with the past. The call to ROC President Tsai Ing-wen is just the first step in a series of significant changes these experts intend to make as senior officials in a new administration. Given the importance of the US-China relationship, and the potential consequences of a unilateral abrogation of official diplomatic agreements that have defined US-China relations for decades, Congress needs to exercise due diligence.

One of the most important powers Congress has over the conduct of US foreign and military policy is the power to examine, accept or reject executive appointments to key posts. Sub-cabinet nominations often move through the Senate on a voice vote. Congress needs to think seriously about the implications of the changes being proposed across a range of US interests, and must give President Trump’s nominees for Asia-related posts more careful scrutiny.

President Obama Can Still Reduce Stored Nuclear Weapons & Fissile Materials

It Ain’t Over ‘til It’s Over

During the summer and fall, reports appeared that President Obama was considering actions he could take to make a major impact on U.S. nuclear weapons policy before leaving office in January. While the situation has clearly changed since Trump became the president-elect, this still does not mean that Obama’s hands are completely tied. It does mean that major changes, such as declaring a no-first-use policy or taking nuclear missiles off hair-trigger alert, are unrealistic, as they would only serve to draw the ire of the incoming administration and likely be quickly reversed. However, most of these options were reportedly already off the table. There are other actions, less dramatic but still significant, that President Obama could take right now to improve the safety and security of all Americans.

Near the beginning of his term, the president gave a speech in Prague in which he pledged that “the United States will take concrete steps towards a world without nuclear weapons.” But despite initial success—the conclusion in 2010 of the New START arms agreement with Russia, in which each side agreed to limit its number of deployed strategic warheads to 1,550 by 2018—the Obama administration has made no further progress in this realm. In fact, of any Commander-in-Chief since the end of the Cold War, President Obama has so far presided over the smallest reduction in the U.S. nuclear stockpile.

In a different world, if Clinton had won the presidency, Obama might still be considering moves to change this, by announcing further cuts to U.S. deployed nuclear forces. After all, the Department of Defense has already said that the United States could safely reduce its deployed strategic nuclear forces by an additional third from New START levels even if Russia does not make similar reductions. An arsenal of this size would be more than enough to ensure a strong, stable nuclear deterrent. It would also reduce costs, a major consideration when it will take an estimated $1 trillion in spending to deploy, maintain and replace the entire nuclear triad (strategic bombers, land-based intercontinental ballistic missiles, and submarine-launched ballistic missiles) over the next 30 years. This is something Trump might want to keep in mind himself, since the Pentagon has already warned that it does not know where the money will come from to fund all the nuclear spending requirements that are on the books.

Lenny Kravitz, It Ain't Over 'til It's Over

This man knows.

Given the reality of the current situation, such a high-visibility and controversial cut has been ruled out. But President Obama could still make a difference by making some less controversial “housekeeping” type cuts in stocks that are not often thought about and would not adversely affect the U.S. deterrent: “hedge” weapons that are kept in reserve, and stockpiles of weapons-usable fissile materials (plutonium and highly-enriched uranium).

In addition to the roughly 1,950 nuclear weapons (1,750 strategic and 180 tactical) that the United States deploys, it also maintains a “hedge” force of about 2,550 weapons (2,250 strategic and 320 tactical). These are kept in reserve for two reasons: technical and geopolitical. The argument for the technical hedge is that, if deployed weapons of one type experienced a problem, the United States could instead deploy weapons of another type from the hedge force. The geopolitical argument is that the international security situation could change, leading the U.S. to want to increase the number of deployed weapons.

As I will discuss in detail in my next post, to reduce the role that nuclear weapons play in U.S. security policy, Obama could reduce the number of strategic weapons in the hedge, by almost half, to 1,250, and eliminate the existing hedge of 320 tactical weapons.

The United States also maintains stockpiles of weapons-usable fissile materials—plutonium and highly enriched uranium (HEU)—that are much larger than needed. Some of this fissile material has already been declared “excess to military needs” and is awaiting disposition. Even after that excess material is disposed of, however, the United States will still have far more material than it needs for its current or future arsenal. Obama could declare an additional 15 metric tons of plutonium and 140 metric tons of highly-enriched uranium as excess to military needs, which would be enough for more than 4,000 nuclear weapons. I will go into the details of these numbers in an upcoming post.

The Nuclear Safety Value of “What If?”

Disaster by Design/ Safety by Intent #61

Safety by Intent

Picture a driver distracted by tuning the car’s radio or reading a very clever roadside billboard and unknowingly traveling through a stop sign without even slowing down. Due to good fortune, the driver neither hits another vehicle nor gets hit.

Upon realizing the stop sign had been run, the driver could have two reactions. Based on the actual outcome, the driver could conclude that less time would be wasted in the future by simply not stopping at stop signs and red lights any more. Or, based on what could have happened, the driver could resolve to pay better attention to traffic safety signs.

Nuclear safety is best served when plant owners and the Nuclear Regulatory Commission (NRC) view things considering “what if” instead of “what was.” As evidenced by a problem recently reported to the NRC by the owner of the Peach Bottom nuclear plant in Pennsylvania, the nuclear industry typically considers the former rather than the latter.

What Was

On August 16, 2016, workers identified a small amount of water leaking from a one-inch diameter pipe going from the 18-inch diameter High Pressure Service Water (HPSW) system pipe downstream of the Residual Heat Removal (RHR) heat exchangers A and C to the radiation sampling system.

Fig. 1 (

Fig. 1 (Source: UCS adapted from NRC Plant Information Book (1994))

Following an accident, the HPSW system takes water from the Conowingo Pond, supplies it to the RHR system’s heat exchangers, and returns the warmed water to the pond. The RHR system provides cooling for the reactor core and the primary containment during an accident. By connecting to but being physically separate from the RHR system, the HPSW system discharges heat during an accident to the environment without also discharging radioactivity to it. The HPSW system features four motor-driven pumps each capable of supplying 4,500 gallons per minute flow.

The leak rate was approximately 120 drops per minute, well below the capacity of one HPSW pump, yet alone all four pumps. That small leak rate would not adversely affect the HPSW’s cooling role.

The leak’s location was downstream of the RHR heat exchangers. Thus, the leaked water would have already performed its intended safety function before it escaped from the pipe.

Based on what it was, the identified leak had zero safety implications.

What If

But the plant owner looked beyond “what was” to evaluate “what if.” Water leaked from a small crack in the one-inch diameter pipe going to a radiation sampling system. The engineering department evaluated the effect of that crack during a postulated design basis earthquake and concluded that the shaking movements could break the one-inch pipe. If so, approximately 77 gallons per minute could leak from the broken one-inch pipe.

The 77 gallon per minute leak was a very small fraction of the HPSW system’s flow. And the leak would occur after the water flowed through the RHR heat exchangers. If the pipe broke, the leaked water would go onto the floor instead of back into the pond.

The owner evaluated where the leaked water could go and concluded that it could enter the room housing RHR pump C and disable the pump. Because of this potential, RHR pump C was considered to be inoperable until the cracked pipe was repaired.

The RHR system has four motor-driven pumps. The accident studies show that reactor core and containment cooling can be accomplished by a single RHR pump.

The cracked one-inch pipe might have disabled RHR pump C after an earthquake but would not have affected RHR pumps A, B, and D.

The “what if” process assumed the earthquake occurred when the division 2 emergency diesel generators were out of service for maintenance. The unavailability of the emergency diesel generators and the loss of the offsite power grid took away RHR pumps B and D but would not have affected RHR pump A.

The NRC’s single failure criterion (defined in Appendix A to 10 CFR Part 50) further requires that safety studies assume a single failure of a safety component. Application of that criterion in this Peach Bottom case takes away RHR Pump A as justification for accepting the impaired RHR Pump C.

What Is

The discovery of a small amount of water leaking from the HPSW pipe downstream of the RHR heat exchangers could have been downplayed and tolerated for a long time before being fixed. Instead, workers determined that the little leak could, with help from an earthquake, cause a larger leak that could disable one of the RHR pumps.

The potential disabling of an RHR pump could have been downplayed and tolerated for a long time. Instead, workers recognized the challenge to the defense-in-depth approach to nuclear safety and quickly fixed the problem.

Disaster by Design

Bob Pollard, my predecessor at UCS, said he had no doubts that one could operate a safe nuclear plant and had no doubts that one could operate an economical nuclear plant. His doubts involved operating a safe reactor that was also economical.

Proper application of the “what if” process supports both safe and economical reactor operation. Misapplication of the process compromises safety and/or economics.

Proper application does not mean posing every conceivable “what if” question. For example, “what if anasteroid the size of the moon were to hit the plant?” can probably be left unanswered. But proper application entails asking, and answering, every credible question.

In this case at Peach Bottom, and many others elsewhere, the “what if” process served nuclear safety. Post-accident inquiries nearly always identify misapplications of this process.


UCS’s Disaster by Design/Safety by Intent series of blog posts is intended to help readers understand how a seemingly unrelated assortment of minor problems can coalesce to cause disaster and how effective defense-in-depth can lessen both the number of pre-existing problems and the chances they team up.

Origins and Implications of the Taiwan Call

Over the past few election cycles Congress passed a series of laws that enabled presidential candidates to begin preparing for transition immediately after obtaining their party’s nomination. This cycle a large number of Republican foreign policy professionals refused to support their party’s nominee, draining the pool of talent candidate Trump could draw upon to plan his transition. The Republican President-elect’s controversial decision to speak with Tsai Ing-wen, the President of the Republic of China (ROC), may be a consequence of these two developments.

Congress enacted significant changes to the laws governing the presidential transition process in  2004,  2010  and  2015 that gave presidential campaign staff access to classified information, US government facilities and the incumbent administration immediately after the nominating conventions. The legislation codified a general trend allowing the two major political parties to build and empower what essentially become two administrations-in-waiting before voters have a chance to decide which one will occupy the White House.

Candidate Trump’s language and behavior during the primary campaign alienated many of the Republican foreign policy professionals who normally would assume significant positions in a presidential transition. Three leading architects of Asia-related policy in past Republican candidacies and administrations; Richard Armitage, Michael Green and Aaron Friedberg, joined a large group of Republican foreign policy experts who denounced Mr. Trump as unfit for office.

“Mr. Trump lacks the temperament to be President. In our experience, a President must be willing to listen to his advisers and department heads; must encourage consideration of conflicting views; and must acknowledge errors and learn from them. A President must be disciplined, control emotions, and act only after reflection and careful deliberation. A President must maintain cordial relationships with leaders of countries of different backgrounds and must have their respect and trust. In our judgment, Mr. Trump has none of these critical qualities.”

Having taken themselves out of the running for a position in the Trump transition effort, which began shortly after the convention, the Republican foreign policy establishment left the door open for other aspirants. The people who filled the open positions related to Asia appear to be the ones who arranged the call with ROC President Tsai Ing-wen. Unfortunately, because the new laws Congress enacted did not require presidential campaigns to publicly disclose any information about the individuals it empowered to conduct transition-related activities on behalf of presidential candidates, we don’t yet know the names or the titles of many of the key people involved.

New Advisors Signal New Policies

Trump’s decision to speak with Tsai, and his decision to use her official title, violated the letter and the spirit of a series of agreements that both governments upheld as fundamental conditions of normalized diplomatic relations between China and the United States. Those agreements did not include an explicit US statement recognizing the island of Taiwan as a part of China. They did, however, formally state that the United States agrees that there is only one China: the People’s Republic of China (PRC).

Ms. Tsai is not the president of Taiwan, as she is often mistakenly described in the US press. She is the President of the Republic of China (ROC). This distinction matters, especially to the Chinese. The ROC constitution claims sovereignty over the whole of China, not just the island of Taiwan. It is a rival Chinese government. The last Republican administration sternly rebuked former ROC president Chen Shui-Bian’s efforts to change the ROC constitution in a way that would limit its claims of sovereignty to the islands it now controls. President George W. Bush, repeating the language of his PRC counterparts, interpreted Chen’s efforts as an unilateral attempt to change the status quo and advance calls for Taiwan’s independence (see video below). The PRC has explicitly threatened to use “non-peaceful means and other necessary measures ” to prevent such an outcome.

For the moment, Mr. Trump is still a private citizen. But should President Trump continue to take calls from Ms. Tsai when he is in the Oval Office, or continue to refer to her as “President Tsai,” it would not be unreasonable for Chinese leaders to assume that the United States had changed its policy on Taiwan’s independence. That change is highly likely to have a significant and lasting impact on the people of Taiwan, the people of China, and the people of every allied nation and territory hosting US military bases in Asia. The economic impacts could also be quite dramatic.

Given the potential consequences, the US public, and the peoples of the region, need to know a lot more about the individuals advising President-elect Trump on Asia policy. It is remarkable that Trump’s Asia transition team was allowed to set up a call that could dramaticly impact US-China relations—one of the most important foreign policy and defense issues facing the United States—before President-elect Trump selected his Secretary of State or his Secretary of Defense. This can be explained, in part, by the changing nature of the transition process and the unusual character of the man leading it.

But the press should now take a hard and sustained look at who will be guiding President Trump on Asia policy and what they believe.

US President George W. Bush rebukes Taiwanese leader Chen Shui-Bian for unilateral moves towards independence at White House press event with PRC Premier Wen Jiabao on 12/9/03. Complete video available at C-Span.


UCS’s “China Transition Watch” is a series of occasional posts that discusses how actions and statements during the Trump transition may affect US-China relations. While not intended to be comprehensive, the goal of the series is to provide insight on key issues.


The Trump Administration’s Opening Move to Disrupt US-China Relations


Former US Secretary of State Henry Kissinger met with Chinese President Xi Jinping hours before US President-elect Donald Trump’s controversial telephone call with Republic of China President Tsai Ing-wen.

President-elect Donald Trump has a reputation for being disruptive. But it was still surprising that he chose to break with convention and speak directly to Tsai Ing-wen, the President of the Republic of China (ROC) in Taiwan, despite the fact that the United States withdrew its official diplomatic recognition of the ROC in 1979 as a precondition for establishing diplomatic relations with the People’s Republic of China (PRC).

The call took place just hours after former Secretary of State Henry Kissinger, who brokered the deal that led to the establishment of diplomatic relations with the PRC, spoke with President Xi Jinping in Beijing. Kissinger met with President-elect Trump shortly after the election. The Chinese press reported that Kissinger told Xi he wanted to “play a positive role in enhancing communications between the two countries.” It would not be unreasonable for the Chinese leadership to assume that Dr. Kissinger was carrying a message from the US president-elect. Did Kissinger know Trump would speak with Tsai? Was he there to explain it to Xi? Or was Kissinger unaware that Trump would be shaking the foundation of the US relationship with China while the US diplomat who laid its cornerstone was in Beijing?

If Kissinger was out-of-the-loop on Trump’s decision to take the call, and did not warn Xi it was coming when they met, Trump may have shattered the Chinese leadership’s faith in Kissinger’s ability to continue to influence the course of US-China relations.

And that may not have been an accident.

The Taipei Times reported that Trump’s conversation with Tsai was arranged while Stephen Yates, who served in the White House as Deputy Assistant to the Vice President for National Security Affairs under Dick Cheney, was in Taipei to meet with ROC Minister of Foreign Affairs David Lee (李大維) and National Security Council Secretary-General Joseph Wu (吳釗燮). Yates was an advocate for better US treatment of the ROC government when he worked for the Heritage Foundation and is reportedly being considered for an appointment in the Trump administration.

It is difficult to know if Mr. Trump planned this interestingly choreographed set of events with the intention of undermining Dr. Kissinger and disrupting the US relationship with China. It is possible that Mr. Trump did not know Dr. Kissinger was in Beijing or didn’t understand the implications of the call. It is also possible that some members of Mr. Trump’s transition team decided to “go rogue” in an effort to advance their own agenda while the president-elect’s attentions are focused elsewhere.

Reporters should follow up with Dr. Kissinger, the President-elect and his transition team to clarify exactly how and why the US president-elect came to speak with ROC President Tsai. The Chinese leadership needs to be clear about Mr. Trump’s intentions. So does the American public, not to mention anyone considering taking a job in the Trump administration, especially Mr. Romney or General Mattis. Any perceived change in US policy on the status of the ROC government in Taiwan brings with it an appreciable risk of war, as the veteran Chinese diplomat Sha Zukang reminded a audience of US China-watchers earlier this fall.

Nuclear Plant Security

Disaster by Design/ Safety by Intent #60

Security by Intent

Nuclear Energy Activist Toolkits #32 and #47 described the emergency plan preparations required by federal regulations for every operating nuclear power plant. Other federal regulations require design features backed by testing and inspection protocols intended to minimize the chances of a nuclear plant accident that might result in the emergency plans being needed. That’s Safety by Intent.

The necessary companion is Security by Intent. The string of equipment malfunctions and worker miscues that could trigger a nuclear accident could also be pulled intentionally. Federal regulations seek to minimize the chances of a nuclear plant accident being triggered by sabotage.

Fig. 1 (Source: Nuclear Regulatory Commission)

The regulations protect against sabotage by people working at the plant and/or people breaking into the plant. After 9/11, the NRC revised the regulations to better protect against sabotage by insiders. Prior to 9/11, individuals could freely enter the security fences around a nuclear plant only after background checks revealed no criminal or trustworthiness histories. After 9/11, the NRC revised its regulations to require that the background checks be periodically revisited to ensure that the initial determinations remained valid.

The NRC also revised its regulations after 9/11 to better protect against sabotage by outsiders. Prior to 9/11, the regulations required protection against a modest number of outside attackers. After 9/11, the NRC revised its regulations to increase the number of potential attackers. In addition, the revised regulations assume the attackers may use more challenging tactics and more harmful weapons.

The revised regulations also upped the training and qualification requirements for security force personnel, which resulted in better protection against sabotage by insiders and outsiders.

Testing Security

Prior to 9/11, the NRC determined how effectively the various security elements (e.g., intrusion detection system, locked doors to areas housing vital equipment, defensive positions by security officers, etc.) fit together to deter sabotage through force-on-force tests that pitted mock attackers against the plant’s gates, guards, and guns. Real bullets were not used, so the tests employed people (controllers) who would judge who had yelled “Bang!” first. The controllers introduced delays as the players awaited rulings on who continued the fight and who retired to the sidelines. The security at each operating nuclear plant was checked by a force-on-force test about once every eight years.

After 9/11, the NRC increased the frequency and realism of the force-on-force tests. Each operating plant gets a force-on-force test about once every three years. And while the participants still don’t use real bullets, they use laser guns that provide more accurate and timely resolution of who-shot-whom questions.

Seeing a Security Problem

The passive defense provided by security fences around nuclear power plants is backed by active monitoring. Intrusion detection systems warn onsite security force personnel about unauthorized persons climbing over or cutting through a fence. The security force personnel can focus cameras to see whether a near-sighted deer wandered into the fence, a lazy bird landed on it, or ne’er do wells are entering the site sans invitation. Security force personnel need to discern foe from fawn to decide how to respond properly.

The periodic security checks conducted by the NRC included holding up cards at various spots along the fences to evaluate how good the cameras could “see” under various lighting and weather conditions—much like the eye-charts used by optometrists to check on their patients’ visual acuity. The NRC wanted to know if sun glare, darkness, fog or other factors could mask a section of the fence and take longer for security force personnel to detect intruders.

The NRC inspectors used the same small set of cards during these camera checks at the plants. Like memorizing the lines on an eye-chart, security folks at the plants communicated the symbols on the NRC’s card deck to the people monitoring the cameras. The question for the monitors changed from “what do you see?” to “does what you see look more like x, y, or z?”

The NRC figured out the game, too. They changed their card deck without telling the plant owners. The game was up the first time a monitor reporting seeing a symbol from the discarded card deck.

Evolving Security Measures

The NRC extensively revised its regulations and oversight practices after 9/11 to provide better protection against nuclear plant sabotage. But the NRC had made changes to security regulations and practices before 9/11 and has made further changes since the 9/11 revisions. The hazard environment evolves as new threats emerge and more harmful weapons are developed. The NRC strives to minimize the gap between evolving hazards and defenses against them.

Disaster by Design

Some reasonable and informed individuals contend that more should be done to improve nuclear plant security. It is undeniable that doubling the size of the guard force or installing an additional fence around the existing ones would make it harder to sabotage a nuclear plant.

Other equally reasonable and informed individuals contend that the post-9/11 security measures are more than sufficient and, with international terrorists preoccupied with other targets, it might be time to lessen some of the more costly security measures.

When the overwhelming majority of reasonable and informed individuals felt that security measures were more than adequate, it is time to slash here and there.

When the overwhelming majority of reasonable and informed individuals felt that security measures were woefully inadequate, it is time to beef up there and here.

When a sizeable subset of reasonable and informed individuals feel that existing security measures are overkill and another sizeable subset feel that much more must be done, it is time for case-by-case actions to plug gaps while removing unwarranted extraneous aspects.

I know which camp UCS is in and know many fellow campers. But I also know several people in the camp down the road. It therefore seems a bad time to slash and not a good time for beefing up. But it seems a swell time to shift security surpluses to seal shortcomings (and schedule a spectacular shindig with any surviving savings.)


UCS’s Disaster by Design/ Safety by Intent series of blog posts is intended to help readers understand how a seemingly unrelated assortment of minor problems can coalesce to cause disaster and how effective defense-in-depth can lessen both the number of pre-existing problems and the chances they team up.

Let’s Get a Better Deal on Plutonium Disposition

President-elect Donald Trump has promised to renegotiate international agreements to get “better deals” for the United States. A good place for him to start would be the U.S.-Russia Plutonium Management and Disposition Agreement (PMDA), which obligates each country to dispose of 34 metric tons of excess plutonium from their military stockpiles, so the dangerous material cannot easily be reused for nuclear weapons. Collectively, this plutonium is enough for more than 15,000 nuclear bombs.

The agreement was originally signed by the Clinton administration in 2000 and amended in 2010, partly in response to a request by Russia. The agreement is a bad deal, at least for the United States. It commits the U.S. government to dispose of the plutonium by converting it into “mixed oxide” (MOX) reactor fuel and burning it in commercial nuclear reactors—a program that is now estimated to eventually cost U.S. taxpayers more than $50 billion and last 50 years or more.

The Department of Energy (DOE) has proposed a feasible alternative that could be accomplished more quickly and at less than half the cost. The agency’s favored dilute-and-dispose approach would mix the plutonium with inert materials and place small quantities of the mixture in waste drums, which then would be buried in a deep underground geologic repository, the Waste Isolation Pilot Plant (WIPP) in New Mexico. Another benefit of the dilute-and-dispose method is it poses a smaller risk of nuclear terrorism than the MOX option, which would entail additional handling and transporting weapon-usable materials.

There’s a sticking point, however. Under the terms of the agreement, the United States would have to obtain Russia’s consent to change its plutonium disposal method, just as Russia needed to obtain U.S. consent in 2010 when it wanted to pursue use of its plutonium as fuel for fast reactors instead of light-water reactors. Because the United States accommodated Russia’s request, it was hopeful that Russia would reciprocate, but instead Russia has criticized the U.S. proposal to switch to the cheaper, faster approach. Russia claims the method is reversible, implying that the United States could easily recover the plutonium to increase its nuclear weapon stockpile. That objection has little technical basis, however, and there are ways to address Russian concerns.

In October, Russia suspended implementation of the plutonium agreement as part of a larger chill in U.S.-Russian relations. As a rationale, it cited in part the U.S. plan to reduce its compliance cost by switching to the cheaper dilute-and-dispose method.

Next steps

The United States could of course go it alone and dispose of its plutonium as it sees fit—and the DOE is proceeding with plans to use the dilute-and-dispose approach for six metric tons of excess plutonium that is not part of the 34 metric tons covered by the PMDA. However, there are benefits to doing so within the agreement, such as verification measures, and it would be best if the United States could persuade Russia to resume implementation.

Regardless, the United States should not be compelled to spend a vast sum of money on a failing project simply because that’s what Russia wants.

Fulfilling the agreement would require the United States to finish building and then operate the facility that would fabricate the MOX fuel, which has been under construction since 2007 at the DOE’s Savannah River Site in South Carolina. The plant is far behind schedule and its projected budget has ballooned beyond anyone’s expectations. The most recent DOE and U.S. Army Corps of Engineers estimate projected that the plant would not be finished before 2048 and would cost more than $17 billion, roughly 10 times more than initial estimates. Adding operating costs, other program expenses, and uncertainties, DOE estimates the lifecycle cost of the project could exceed $50 billion. The DOE-Army Corps of Engineers report also highlighted construction quality control problems that should raise red flags.

Some in Congress are putting up roadblocks to getting a better deal on plutonium disposition. The MOX program, warts and all, is being kept on life support by South Carolina Sen. Lindsey Graham, who wants to keep wasting federal government money on the project in his state. It’s time for Graham to stop putting parochial interests ahead of the interests of U.S. taxpayers.

President Trump will have the opportunity to use his negotiating skills—and his reportedly good relationship with Russian President Vladimir Putin—to persuade Russia to resume complying with its part of the agreement and secure approval for the United States to change its disposition method. Let’s hope the United States and Russia can end their stalemate on plutonium disposition and find a path forward that benefits both nations.

Friendly Answers Following Blowing of the Winds

Disaster by Design/ Safety by Intent #59

Safety by Intent

With ample warning, Hurricane Matthew made landfall in South Carolina coast on October 8, 2016, bringing along its heavy rainfall and high winds.

The Federal Emergency Management Agency conducted Disaster Initiated Reviews for nuclear plants in South Carolina, North Carolina and Florida to determine whether Hurricane Matthew adversely affected emergency planning measures within a 10-mile radius of each site.H.B. Robinson Steam Electric Plant (Hartsville, SC)

The Robinson nuclear plant was operating at 100 percent power on October 8, 2016, when perturbations on the electrical grid caused by Hurricane Matthew caused the automatic shutdown of the reactor. The onsite emergency diesel generators provided backup power to essential equipment onsite.

FEMA’s Disaster Initiated Review found that all 61 pole-mounted emergency sirens that notify the population in event of an accident at Robinson were operable, with about half (30 sirens) on battery backup power due to localized loss of electricity. FEMA verified that Duke Energy had a plan to replace the batteries before their 7-day capacity became depleted. FMEA further verified that the counties within 10 miles of the site had the resources to conduct alternate alerting if that need arose.

FEMA found that Florence Country opened six shelters to accommodate persons displaced by Matthew while Darlington and Lee Counties had opened one shelter. But FEMA’s consultations with county officials found that sufficient resources existed to handle additional needs in event of a nuclear plant accident. And FEMA verified that the storm had not degraded critical transportation routes and assets within the 10-mile emergency planning zone or depleted shelter and care facilities.

FEMA concluded that Matthew had not impacted its pre-storm finding that emergency planning measures for the Robinson plant remained adequate.

Brunswick Steam Electric Plant (Southport, NC)

The State of North Carolina and both Brunswick and New Hanover counties activated their emergency operations centers because of Hurricane Matthew. The two reactors at the Brunswick nuclear plant continued operating throughout the storm.

 Jocelyn Augustino/FEMA)

Fig. 1 Lumberton, NC, October 11, 2016. (Source: Jocelyn Augustino/FEMA)

FEMA’s Disaster Initiated Review found that all 38 pole-mounted emergency sirens that notify the population in event of an accident at Brunswick were operable on normal power with battery backup power available. The New Hanover County emergency operations center in Wilmington deactivated on October 10 while the Brunswick County emergency operations center in Bolivia remained activated due to flooding in the southern part of the county. FEMA found that state and local resources remained sufficient to handle a nuclear plant accident.

FEMA learned that the storm caused intermittent lapses of the primary communications links between the Brunswick plant and offsite emergency operations centers, but that the secondary satellite communications system functioned per design and a tertiary communications system remained available.

FEMA found that two shelters in New Hanover County and three shelters in Brunswick County had been opened to accommodate persons displaced by Matthew. All five shelters had been closed when no longer needed following the storm. FEMA found that state and local resources remained sufficient to handle a nuclear plant accident.

FEMA concluded that Matthew had not impacted its pre-storm finding that emergency planning measures for the Brunswick plant remained adequate.

Shearon Harris Nuclear Power Plant (New Hill, NC)

The Harris nuclear plant had just begun a scheduled refueling outage. Workers shut down the reactor the previous day. After Matthew’s landfall, the Duke Energy Control Center notified plant workers about perturbations on the electrical grid caused by the storm. Following this notification, outage-related activities were suspended and the plant was disconnected from the grid and placed on backup power from the onsite emergency diesel generators. After the storm subsided, workers reconnected the plant to the electrical grid and resumed refueling activities.

FEMA’s Disaster Initiated Review found that the 83 pole-mounted emergency sirens around the site that notify the population in event of an accident at Harris were operable. FEMA additionally determined that the state and local authorities had sufficient resources remaining to perform functions such as independent radiological dose assessments and field monitoring in event of an accident. And FEMA verified that the storm had not degraded critical transportation routes and assets within the 10-mile emergency planning zone or depleted shelter and care facilities.

FEMA concluded that Matthew had not impacted its pre-storm finding that emergency planning measures for the Harris plant remained adequate.

St. Lucie Plant (Jensen Beach, FL)

Hurricane Matthew impacted the emergency planning zone for the St. Lucie plant beginning on October 6 as it traveled off the eastern coast of Florida as a Category 4 storm. The State of Florida activated its emergency operations center on October 4; St. Lucie County and Martin County activated their emergency operations centers on October 6.

FEMA’s Disaster Initiated Review found that 90 emergency sirens around the site provided notification of the public in event of an accident at St. Lucie. The storm disabled one siren and caused 23 other sirens to rely on battery backup power. FEMA confirmed the plant owner’s plan to fix the broken siren within four days and to replace the batteries on the sirens without electricity supply within five days to ensure their continued operability.

Flagler, FL, USA-- Damage to roadway in Flaglar County following Hurricane Matthew. FEMA, state and local officials continue damage assessments along Florida eastern coast.

Fig. 2. Flagler, FL (Source: Steve Zumwalt/FEMA)

FEMA met with Brevard County officials on October 8 upon being notified that due to supporting persons evacuated due to Matthew, the county could not support additional evacuees in event of a nuclear plant accident. During that meeting, a contingency reception center was established with support from the State of Florida and Miami-Dade County emergency management officials should need arise until conditions in Brevard County returned to normal.

FEMA concluded that with the contingency plans in place, the emergency planning measures for the St. Lucie plant remained adequate.

Disaster by Design

Americans are all-too-accustomed to seeing local, state, and federal officials and non-governmental organizations like the American Red Cross respond promptly to help those harmed by a disaster.

Graphic provides an update on FEMA's support for Hurricane Matthew recovery as of October 10, 2016. Includes info on staff deployed, supplies, search and rescue, emergency communications, and incident management teams.

Fig. 3 (Source: FEMA)

FEMA certainly pitched in to help those in need following Hurricane Matthew (Fig. 3). Less evident, but no less important, was the effort undertaken by FEMA in parallel with their disaster response activities. FEMA checked whether Matthew damaged the infrastructure or depleted response resources such that the public might not be adequately protected in event of an accident at one of the nuclear plants in the region. Upon finding anything that might undermine public protection, FEMA ensured that contingency measures were in place to sustain the necessary protection levels.

Disaster response and disaster readiness are two side of the same coin. FEMA demonstrated capabilities in both areas following Matthew.


UCS’s Disaster by Design/ Safety by Intent series of blog posts is intended to help readers understand how a seemingly unrelated assortment of minor problems can coalesce to cause disaster and how effective defense-in-depth can lessen both the number of pre-existing problems and the chances they team up.

Look! Up in the sky! It’s a bird! It’s a plane! It’s, it’s … a nuclear reactor?

Episodes of The Adventures of Superman television series began with an announcer proclaiming “Faster than a speeding bullet! More powerful than a locomotive! Able to leap tall buildings in a single bound!” followed by a crowd of people on a city sidewalk with someone saying, “Look! Up in the sky! It’s a bird! It’s a plane. It’s Superman!”

The series ran between 1952 and 1958 before my time, but I did faithfully watch its re-runs during the early 1960s. (I understood why adults on the sidewalk were initially puzzled by the thing in the sky that turned out to be Superman, but couldn’t quite get their befuddlement week after week.)

About the same time, adults in the woods in northwestern Georgia could have looked up into the sky and been puzzled by something that was not a bird, or a plane, or even Superman. It was a nuclear reactor suspended on cables strung between towers. Really, a nuke on a wire.

Nuclear Aircraft Lab

Beginning in the late 1950s and continuing through its closure in 1971, Lockheed operating the Georgia Nuclear Aircraft Laboratory on a 11,000 acre site near Dawsonville, Georgia for the U.S. Air Force. A short video produced by Lockheed circa 1960 documents the construction and initial operation of the first reactor at the laboratory. A second reactor was later added to the laboratory.

The primary purpose for the facility was to test components and systems intended for use in nuclear propelled aircraft (likely the reason Lockheed was a contractor to the Air Force rather than the Navy, Army, or Coast Guard.) The facility also conducted research into the effect of nuclear radiation on non-aircraft components and wildlife to support atomic weapons consequences studies.

Fig. 1 (

Fig. 1 (Source: Department of Energy)

The laboratory had three major areas – the Nuclear Support Facility (NSF), the Reactor Equipment Facility (REF) and the Shielding Demonstration Facility (SDF) (Fig. 1).

Fig. 2 (

Fig. 2

The Nuclear Support Facility consisted of administration offices, a warehouse, and a large concrete bunker housing a hot cell (Fig. 2). Materials irradiated in the reactors could be transported via a special railcar to the hot cell. Workers manipulating equipment remotely examined the materials for the effects of exposure to radiation.

Fig. 3 (

Fig. 3 (Source: Dave Lochbaum)

The hot cell bunker remains today, but its remains are surrounded by a barbed wire fence dotted with frequent “No Trespassing” signs (Fig. 3).

Fig. 4 (

Fig. 4 (Source: Lockheed)

The Reactor Equipment Facility housed a 28-foot long reactor vessel that could be raised from its normal pit in the floor to test radiation effects on components staged within the building. Workers operated equipment and monitored conditions from its control room (Fig. 4).

Fig. 5 (

Fig. 5

The Shielding Demonstration Facility consisted of an underground concrete bunker for the control building, a water-filled concrete pool to store the reactor, and metal towers used to hoist the reactor nearly 200 feet into the air (Fig. 5).

Fig. 6 (

Fig. 6

The SDF had a tall pole topped by microphones (Fig. 6). During reactor operation, workers monitored audio channels for sounds of approaching aircraft. If an incoming plane was detected but not diverted in time, workers had instructions to shut down the reactors to avoid exposing passengers to potentially lethal amounts of radiation. Sounds like a safety plan, of sorts.

Bottom Line

If you ever folded a sheet of paper and sailed a paper airplane across the room or office, you accomplished more flight time and distance than the nuclear propelled aircraft. And it cost you less, way less, than it cost the U.S. government to demonstrate it could not get a nuclear propelled aircraft off the ground.

But the money spent on atomic airplanes was not entirely wasted. Some of the research paid off in other applications.

Does any of your clothing have zippers? If yes, it doesn’t matter. Zippers were invented outside of atomic airplane research space.

Do any of your appliances, gizmos, and gadgets use rechargeable batteries? If yes, it doesn’t matter. Rechargeable batteries were invented via other means.

Did you ever build a paper airplane? If yes, maybe we can fly our planes someday. I’ve given up looking for some useful byproduct from the atomic airplane projects.


Equity within the Nuclear Regulatory Commission

Disaster by Design/ Safety by Intent #58

Safety by Intent

As articulated in a recent posting by UCS’s Center for Science and Democracy, UCS believes science can and should be applied to reduce racial and economic inequity. Inequity can result when biases can, intentionally or not, put a segment of the population at a disadvantage. The staff of UCS has received training sessions and briefings over the past year on institutional and individual biases that result in racial and economic inequities.

With the information from these sessions and briefings in mind, I reflected on my dealings with the Nuclear Regulatory Commission (NRC) over the years. I have discussed many concerns and problems with NRC managers and staffers, but could not recall one where race or gender was named as a contributing factor. But this process wasn’t very sciency. It was more gossipy than sciency. So, I undertook a less-gossip, more-science approach to the matter. (Gossip has it that the more science we use, the more points we get.)

The NRC’s Office of Small Business and Civil Rights manages four major programs: (1) Affirmative Action, including the Federal Women’s Program and implementing a managing diversity process; (2) Civil Rights; (3) Historically Black Colleges and Universities (HBCU); and (4) Small Business. One of the procedures used by this office in administering these programs states that a primary objective of these efforts is to “Build and maintain a high-performing diverse workforce based on mutual acceptance and trust, and where the contributions of all employees are recognized and valued.”

Diversity Data

In spring 2016, the NRC reported that its workforce was 39% female and 61% male. According to the 2010 census, 51.25% of the U.S. population was female 48.75% was male.

27% of the NRC’s workforce was under the age of 40 and 29% was over the age of 55 (doing the math then, 44% of the workers are 40 to 55 years old.) According to the 2010 census, 61.7% of the U.S. population was under the age of 40 and 21% was over the age of 55.

15% of the NRC’s workforce was African-American, 9% was Asian Pacific American, 6% was Hispanic, less than 1% was Native American, and 67% was white. According to the 2010 census, the U.S. population was 12.6% African-American, 5.0% Asian Pacific American, 16.3 Hispanic, 0.9% Native American, and 72.4% white.

The data show the NRC’s workforce to be older, have more male representation, and have less Hispanic representation than the U.S. population. But the NRC’s objective was to have a diverse workforce rather than a mirror-image replication of the U.S. population. The data indicate the NRC met part of its objective.

Equal Employment Opportunity Complaints 2005-2015

Numbers alone comprise only part of the NRC’s objective. For insight to the other part, I looked at the equal employment opportunity complaints filed within the NRC between 2005 and 2015 (Fig. 1).

The good news is that the annual number of complaints is relatively small for a workforce of nearly 4,000 individuals. The bad news is that the number of complaints trended upward over the decade.

Fig. 1 (

Fig. 1 (Source: Nuclear Regulatory Commission)

In 2015, 24% of the complaints alleged age discrimination, 22% alleged discrimination by sex, and 20% alleged racial discrimination (Fig. 2).

Fig 2 (

Fig 2 (Source: Nuclear Regulatory Commission)

In 2015, 20% of the complaints alleged non-sexual harassment, 18% alleged that discrimination factored into not being selected for a promotion, and another 18% alleged that discrimination factored into performance appraisals (Fig. 3).

Fig. 3 (

Fig. 3 (Source: Nuclear Regulatory Commission)

I looked for data showing how many of the equal employment opportunity complaints had been substantiated. The closest I found to this information was the chart showing the number of complaints settled between 2010 and April 2016 (Fig. 4). Assuming that a settlement reflects at least some of the complaint had validity, the data show an average of more than one valid equal opportunity problem every month  this entire decade.

Fig. 4 (

Fig. 4 (Source: Nuclear Regulatory Commission)

Disaster by Design

In nuclear power plant design, diversity is an ally. For example, most nuclear power plants have a diverse array of emergency core cooling pumps—some motor-driven, some steam-driven, some powered from emergency diesel generators, and some powered from banks of batteries. This diversity helps assure that at least one pump survives to cool the reactor core despite whatever challenge is presented.

In nuclear safety decision-making, diversity is an ally, too. Decisions made exclusively by a contingent of marine biologists, gaggle of electrical engineers, hearty band of lawyers, convention of brain surgeons, swarm of accountants, team of gymnasts, or roomful of chefs won’t be as good as decisions considering the perspectives of a range of experts. The NRC’s diversity objective does right by its workers and also does right for the American public. Rather, the NRC’s meeting this objective accomplishes both these righteous outcomes.

The NRC has a diverse workforce. For the most part, the contributions of all members of the diverse workforce are recognized and valued.

But the equal employment opportunity complaint data over the past decade reveal a small and sustainable discrimination against NRC workers on the basis of age, gender, race, and other factors. That NRC’s biases and behaviors allow it to persistently discriminate against its own suggest that these attributes could also let it reach decisions that discriminate against the public.

Fairness for NRC’s worker and the American public dictates that the agency adopt and embrace a zero-tolerance for discrimination due to race, gender, age, religion, and other factors. A validation of one internal discrimination case per month must never be close enough for government workers.


UCS’s Disaster by Design/ Safety by Intent series of blog posts is intended to help readers understand how a seemingly unrelated assortment of minor problems can coalesce to cause disaster and how effective defense-in-depth can lessen both the number of pre-existing problems and the chances they team up.

Public Safety Improvements

Disaster by Design/ Safety by Intent #57

Safety by Intent

Continuing the series initiated with Disaster by Design #47, this commentary describes efforts that yielded public safety improvements. But this commentary approaches the subject from a perspective differing from prior commentaries. While still discussing improvements in public safety, this commentary focuses on safety improvements achieved by the public.

Fig. 1 (

Fig. 1 (click to enlarge) (Source: Union of Concerned Scientists)

Safety Second

More than a decade before I joined UCS, the organization published “Safety Second: A Critical Evaluation of the NRC’s First Decade” in February 1985. (f you cannot find this book in your local library, at Amazon, or on the web, send me an email and I’ll reply with a digital copy.)

Chapter Three of the book, titled “The Public as Adversary,” opened with a quote by NRC Commissioner James K. Asselstine—“It is absolutely amazing, the lengths to which the Commission with go to avoid finding that a party is entitled to a hearing on an issue.” After summarizing several confrontational nuclear plant licensing proceedings, the chapter had a subsection titled “Public Contributions to Safety and Environmental Protection.”

The subsection listed 13 safety improvements at individual nuclear plants achieved by the public’s interventions in licensing proceedings (Fig. 1). Several cases involved the public championing concerns raised by whistleblowers who had voiced these same concerns to owners and/or the NRC without success.

The subsection listed another 13 safety improvements achieved generically across the fleet of operating nuclear plants by the public’s efforts (Fig. 2).

Fig. 2 (click to enlarge) (

Fig. 2 (click to enlarge) (Source: Union of Concerned Scientists)

Considering that “Safety Second” examined only a single decade (1975-1984), 26 safety improvements achieved by the public is impressive—averaging nearly three improvements annually.

Those outcomes become even more admirable when you consider the situation faced by the public intervenors. Many have regular jobs and tackle the mind-numbing technical jargon, endless acronyms, and baffling legal lexicon on their own time and at their own expense. If their efforts prevail, their unselfish efforts return no compensation other than the satisfaction of making their communities safer and more secure.

Safety Improvements since Safety Second

Shortly after I joined UCS in October 1996, Ray Shadis of the Friends of the Coast invited me to serve on a panel at a meeting they planned in Wiscasset, Maine on November 19, 1996, to discuss the recent report issued by the NRC’s Independent Safety Assessment Team (ISAT). The NRC sent the ISAT to Maine Yankee at the request of then-Governor Angus King. The ISAT only examined four of the dozens of safety systems at the plant and chronicled many serious problems in their 70-plus page report before concluding the plant was operating safely. I accepted Ray’s invitation and went to Maine for what was my first public speaking role representing UCS.

The efforts by Friends of the Coast and several other public interest groups in Maine transformed the ISAT’s report into a To Do list of things to fix by the plant’s owner. It was a long and expensive list—in May 1998, the company announced its Board of Directors voted to permanently close Maine Yankee rather than pay for the safety fixes.

Over the years, I have had the pleasure of working with many citizens and representatives of local public interest groups. They consistently reminded me that the American form of democracy works best when it is not a spectator sport. They got off the couch and into the game, even though the game is seldom played on a level field and it’s often hard to discern the officials from the opposing teams. Despite the daunting challenges, they demonstrate absolutely amazing persistence and resilience.

I wish I could acknowledge all the safety improvements achieved by the public the past two decades. Instead, I will cite a small sampling to illustrate the results achievable with persistence and passion.

Paul Gunter

Fig. 3 (

Fig. 3 Paul Gunter (Source: Beyond Nuclear)

Paul Gunter, Director of the Reactor Oversight Project at Beyond Nuclear, probably showed the power of one person by single-handedly derailing a tentative agreement reached between the NRC and plant owners. In the wake of the March 1975 fire at the Browns Ferry Nuclear Plant in Alabama, the NRC adopted regulations intended to better protect against fire hazards. The regulations essentially required that owners step through their plants one room at a time postulating a fire that damaged all equipment and cables inside it. The owners’ evaluations had to show that enough equipment located outside the fire room survived to safely cool the reactor core. If not, owners had to relocate equipment or install additional equipment until it was true for all rooms of the plant.

In the late 1990s, NRC inspectors discovered that most of the nuclear reactors operating in the United States, including those at Browns Ferry, did not meet the fire protection regulations. Instead of using equipment that would not be damaged in a fire, owners took credit for workers racing to the end of burned electrical cables and manually operating equipment damaged by the fire. The regulations permitted such manual actions, but only after being formally reviewed and approved by the NRC. Most of the reactors relied on unapproved manual actions that had taken the agency decades to discover.

Meetings between the NRC staff and industry representatives revealed that hundreds, if not thousands, of exemption requests would have to be submitted to the NRC and approved by the agency for all of the illegal manual actions.

Fearful that it lacked the resources needed to process so many exemption requests, the NRC hatched a plan with industry to rapidly issue a new regulation that would permit manual actions that met certain criteria. Such a regulation would retroactively approve all manual actions satisfying the newly imposed criteria.

Paul attended a public meeting on November 12, 2003, between NRC and industry where the draft regulation was discussed. To say that the criteria in the draft regulation were vague would understate the situation. Basically, the draft language would permit any and all manual actions as long as it was “feasible” they could be successfully performed. The draft language would permit more than a dozen manual actions that had to be completed within 30 minutes as long as a dry run of those steps by someone who had rehearsed them many times was able to simulate taking all the steps in 29 minutes and 59 seconds. The draft language contained zero requirements to ensure that all workers who might someday be required to tackle the task was as fit, fast and rehearsed as Demo Worker.

Paul shot down this trial buffoon with this short statement: “It’s feasible that I could go out of this meeting and go out and become a nuclear engineer. I don’t think that that’s likely, but if offers up the same concerns of your choice of words.”

The NRC discarded the loosey goosey “feasible” criterion almost immediately. The NRC developed definitive criterion that appears in the final regulations. Thanks, Paul!

Fig. 4 (

Fig. 4 George Galatis (Source: TIME Magazine)

George Galatis

The efforts by George Galatis certainly resulted in significant safety improvements at Millstone (CT) and in how the NRC oversees safety. George raised concerns with how spent fuel was being handled at Millstone. When neither the company nor the NRC did anything about the concerns (unless shrugging and ignoring counts), George formally petitioned the NRC to keep the three reactors at Millstone shut down for 60 days—the equivalent of a time-out given to misbehaving children. Millstone’s owner contested the petition, but should have readily accepted it. Once George appeared on the cover of TIME magazine, the reactors were shut down. Unit 1 never restarted. Unit 2 restarted more than three years later. And Unit 3 restarted after more than two years. Thanks, George!

Ann Harris and Curtis Overall

Ann Harris and Curtis Overall worked at the Tennessee Valley Authority’s Watts Bar Nuclear Plant during its construction. While performing their assigned tasks, both found problems they reported to management as required by plant procedures. Both experienced harassment and intimidation—including death threats by phone and mail—for having done their jobs and following procedures. TVA fired both workers, allegedly as part of Reductions in Force and not for having raised safety concerns.

Ann and Curtis filed complaints with the U.S. Department of Labor (DOL) contending that TVA violated the Energy Reorganization Act. The DOL’s Administrative Law Judges ruled in their favor.

Ann and Curtis literally put their jobs, and arguably their lives, on the line for safety. Their efforts resulted in lots of safety improvements at Watts Bar that likely otherwise would not have happened. Thanks, Ann! Thanks, Curtis (posthumously)!

Nuclear Information and Resource Service

The Nuclear Information and Resource Service (NIRS) under the leadership of the late Michael Mariotte demonstrated the might of a small organization teaming with grassroots activists and environmental attorneys when they opposed the proposal by Louisiana Energy Services to build and operate a uranium enrichment plant in Louisiana. NIRS partnered with the Citizens Against Nuclear Trash (CANT) to win one of the nation’s first courtroom verdicts on environmental justice grounds. Thanks, NIRS!

Project on Government Oversight

The 9/11 tragedy questioned whether the nation’s nuclear power plants were adequately protected against sabotage attempts. The NRC held many meetings with plant owners about security vulnerabilities and upgrades to lessen them.

These meetings were closed to the public for legitimate concerns that public discussion of security capabilities and shortcomings could unintentionally aid those planning us harm.

The Project on Government Oversight (POGO) crafted a novel and effective way of putting a spotlight on security problems without also handing the bad guys a blueprint for nuclear nightmares. On September 12, 2002, POGO released “Nuclear Power Plant Security: Voices from Inside the Fences.” POGO interviewed security force personnel at more than a dozen nuclear plants and identified common themes: under-staffed, under-trained, under-equipped, and under-paid defenders.

The post-9/11 security regulations adopted by the NRC contained measures on security officer training and qualifications. In addition, a parallel rulemaking process resulted in a final regulation that limited the working hours of security force personnel as protection against impairment due to fatigue. Thanks, POGO!

Galaxy of Public Stars

These summaries illustrate a small sampling of the many times that efforts by the public resulted in nuclear safety improvements. The efforts of the following individuals and public interest groups could just as easily have been summarized (listed alphabetically):

Jessica Azulay of the Alliance for a Green Economy

Anna Aurilio of the Alliance for Nuclear Accountability

Rochelle Becker, David Weisman, and John Geesman of the Alliance for Nuclear Responsibility

Garry Morgan, Gretel Johnston, and Sandy Kurtz of the Bellefonte Efficiency & Sustainability Team

Linda Gunter, Kevin Kamps, and Cindy Folcker of Beyond Nuclear

Lou Zeller of the Blue Ridge Environmental Defense League

Debbie Grinnell and Sandy Gavutis of the C-10

Diane Turco of the Cape Downwinders

Deb Katz of the Citizens Awareness Network

Keith Gunter, Ethyl Rivera, and Jessie Collins of the Citizens’ Resistance at Fermi-Two

Dan Hirsch of the Committee to Bridge the Gap

Paul Blanch of Connecticut

Nancy Burton of the Connecticut Coalition Against Millstone

Michael Keegan of Don’t Waste Michigan

Howard Lerner of the Environmental Law and Policy Center

Maggie and Arnie Gundersen and Carolina Aronson of Fairewinds Associates

Damon Moglen of the Friends of the Earth

Jim Riccio of Greenpeace

Manna Jo Greene of the Hudson River Sloop Clearwater

Arjun Makhijani and the Institute for Energy and Environmental Research

Pine duBois of the Jones River Watershed Association

Dale Bridenbaugh of MHB Technical Associates

Jane Swanson of the Mothers for Peace

Tom Cochran, Geoff Fettus, and Matthew McKinzie of the Natural Resources Defense Council

Clay Turnbull and Ray Shadis of  New England Coalition on Nuclear Pollution

Mike Mulligan of New Hampshire

Mark Leyse of New York

Jim Warren and Mary MacDowell of the North Carolina Waste Awareness and Reduction Network (NC WARN)

Dave Kraft and Linda Lewison of the Nuclear Energy Information Service

Tim Judson, Mary Olson, and Diane D’Arrigo of the Nuclear Information and Resource Service

Glenn Carroll of Nuclear Watch South

Catherine Thomasson and Chuck Johnson of the Physicians for Social Responsibility

Mary Lampert of Pilgrim Watch

Allison Fisher and Tyson Slocum of Public Citizen’s Energy Program

Paul Gallay and Deborah Brancato of Riverkeeper

Tom Clements of the Savannah River Site Watch (and Savannah native)

Seacoast Anti-Pollution League

Susan Corbett of the Sierra Club’s South Carolina Chapter

Sara Barczak of the Southern Alliance for Clean Energy

Don Safer of the Tennessee Environmental Council

Eric Epstein and Scott Portzline of the Three Mile Island Alert

Norm Cohen of Unplug Salem

Vermont Public Interest Research Group

Marilyn Elie of the Westchester Chapter of the Citizens Awareness Network

Many thanks to many people for many safety improvements!

Disaster by Design

Nuclear safety is all about proper balancing.

Emergency core cooling systems are installed to restore the balance between the heat produced by the reactor core and the heat carried away by cooling water. An imbalance for too long results in reactor core overheating as Fermi Unit 1, Three Mile Island and Fukushima remind us.

Other emergency systems are installed to control the balance between neutrons released by atoms splitting in the reactor core. If this control is lost, the reactor power level can soar to disastrous levels as SL-1 and Chernobyl remind us.

Nuclear safety requires a similar balance between industry and public influence on the NRC. When the public’s thumb gets too heavy on the NRC’s regulatory scale, owners can spend money for measures that do not improve safety. Conversely, when the industry’s thumb tips the scale too much, necessary safety margins can be undercut.

This commentary shows that the public’s efforts have yielded nuclear safety improvements. Past commentaries have chronicled nuclear safety improvements achieved by industry’s efforts and other safety improvements gained through NRC’s efforts. Too much is at stake for all voices not to be heard and all perspectives not to be considered.


UCS’s Disaster by Design/ Safety by Intent series of blog posts is intended to help readers understand how a seemingly unrelated assortment of minor problems can coalesce to cause disaster and how effective defense-in-depth can lessen both the number of pre-existing problems and the chances they team up.