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California wildfires: a warning to Nuclear Regulatory Commission on climate change

January 16, 2025,  https://beyondnuclear.org/ca-wildfires-are-a-warning-to-nrc-on-climate-change/
 US Government Accountability Office warnings to Nuclear Regulatory Commission go unheeded

For nuclear power plants, fire is considered a very significant contributor to the overall reactor core damage frequency (CDF), or the risk of a meltdown. Fire at a nuclear power station can be initiated by both external and/or internal events.  It can start with the most vulnerable external link to the safe operation of nuclear power plants; the Loss Of Offsite Power (LOOP) from the electric grid. It is considered a serious initiating event to nuclear accident frequency. Because of that risk, US reactors won’t operate without external offsite power from the electric grid.

The still largely uncontained wildfires burning in and around Los Angeles and Ventura Counties in southern California “are sure to rank among America’s most expensive.” The ongoing firestorms have now extended into a fourth period of “extremely critical fire weather” conditions and burned for more than a week an area the size of Washington, D.C., nearly 63 square miles. The estimated number is still being tallied for the thousands of homes and structures destroyed, the loss of life,  the evacuation of communities indefinitely dislocated and the threats to and impacts on critical infrastructure including electrical power .

There is no scientific doubt that global warming is primarily caused by the unquenchable burning of fossil fuels though politically motivated denial is entrenched in the US Congress. The increased frequency and severity of these wildfires—leading to suburban and even urban firestorms— are but one consequence of a climate crisis along with a range of other global natural disasters including sea level rise, hurricanes, more severe storms generally, extreme precipitation events, floods and droughts. This  more broadly adversely impacts natural resources and critical infrastructures to include inherently dangerous nuclear power stations.

At this particular time, it is important to reflect upon the April 2, 2024, report to Congress issued by its investigative arm, the United States Government Accountability Office (GAO), “Nuclear Power Plants: NRC Should Take Actions to Fully Consider the Potential Effects of Climate Change,” (GAO 24-106326).

The GAO warns that the US Nuclear Regulatory Commission (NRC) needs to start taking actions to address the increased risk of severe nuclear power plant accidents attributable to human caused climate change.

The NRC’s actions to address the risks from natural hazards do not fully consider potential climate change effects on severe nuclear accident risks. “For example, NRC primarily uses historical data in its licensing and oversight processes rather than climate projections data,” the GAO report said.

Beyond Nuclear has uncovered similar findings during our challenges to the NRC’s extreme relicensing process for extending reactor operating licenses, now out to the extreme of 60 to 80 years and talk of 100 years. We found that the agency’s staff believes and stubbornly insists that an environmental review for climate change impacts (sea level rise, increasingly severe hurricanes, extreme flooding, etc.) on reactor safety and reliability is “out of scope” for the license extensions hearing process.

The GAO report  points out to the NRC that wildfires, specifically, can dangerously impact US nuclear power stations operations and public safety with potential consequences that extend far beyond the initiating natural disaster. These consequences can include loss of life, large scale and indefinite population dislocation and uninsurable economic damage from the radiological
consequences:

“Wildfire. According to the NCA (National Climate Assessment), increased heat and drought contribute to increases in wildfire frequency, and climate change has contributed to unprecedented wildfire events in the Southwest. The NCA projects increased heatwaves, drought risk, and more frequent and larger wildfires. Wildfires pose several risks to nuclear power plants, including increasing the potential for onsite fires that could damage plant infrastructure, damaging transmission lines that deliver electricity to plants, and causing a loss of power that could require plants to shut down. Wildfires and the smoke they produce could also hinder or prevent nuclear power plant personnel and supplies from getting to a plant.”

Loss of offsite electrical power (LOOP) to nuclear power stations is a leading contributor to increasing the risk of a severe nuclear power accident. The availability of alternating current (AC) power is essential for safe operation and accident recovery at commercial nuclear power plants. Offsite fires destroying electrical power transmission lines to commercial reactors therefore increase the probability and severity of nuclear accidents.

For US nuclear power plants, 100% of the electrical power supply to all reactor safety systems is initially provided through the offsite power grid. If the offsite electrical grid is disturbed or destroyed, the reactors are designed to automatically shut down or “SCRAM”. Onsite emergency backup power generators are then expected to automatically or manually start up to provide
power to designated high priority reactor safety systems needed to safely shut the reactors down and provide continuous reactor cooling, pressure monitoring, but to a diminished number of the reactors’ credited safety systems. Reliable offsite power is therefore a key factor to minimizing the probability of severe nuclear accidents.

The GAO identifies a number of US nuclear power plant sites that are vulnerable to the possible outbreak of wildfires where they are located. “According to our analysis of U.S. Forest Service and NRC data, about 20 percent of nuclear power plants (16 of 75) are located in areas with a high or very high potential for wildfire,” the GAO report states. “More specifically, more than
one-third of nuclear power plants in the South (nine of 25) and West (three of eight) are located in areas with a high or very high potential for wildfire.” The GAO goes on to identify “Of the 16 plants with high or very high potential for wildfire, 12 are operating and four are shutdown.”

To analyze exposure to the wildfire hazard potential, the GAO used 2023 data from the U.S. Forest Service’s Wildfire Hazard Potential Map. “High/very high” refers to plants in areas with high or very high wildfire hazard potential. Those nuclear power stations described by GAO as “high / very high” exposure to wildfires and their locations are excerpted from GAO Appendix III: Nuclear Power Plant Exposure to Selected Natural Hazards.

Table 1: Potential High Exposure to “Wildfires” at Operating Nuclear Power Plants

–AZ / SAFER, one of two mobile nuclear emergency equipment supply units in the nation, “HIGH / VERY HIGH”
–CA / Diablo Canyon Units 1 & 2 nuclear power station, “HIGH / VERY HIGH”
–FL / Turkey Point Units 3 & 4 nuclear power station, “HIGH / VERY HIGH”
–GA / Edwin I. Hatch Units 1 & 2 nuclear power station, “HIGH / VERY HIGH”
–GA / Vogtle Units Units 1, 2, 3 & 4, nuclear power station, “HIGH / VERY HIGH”
–NC / Brunswick Units 1 & 2 nuclear power station, “HIGH / VERY HIGH”
–NC / McGuire Units 1 & 2 nuclear power station, “HIGH / VERY HIGH”
–NC / Shearon Harris Units 1 & 2 nuclear power station, “HIGH /VERY HIGH”
–NB / Cooper nuclear power station, “HIGH / VERY HIGH”
–SC / Catawba Units 1 & 2 nuclear power station, “HIGH / VERY HIGH”
–SC / H. B. Robinson Units 1 & 2 nuclear power station, “HIGH / VERY HIGH”
–WA / Columbia nuclear power station, “HIGH / VERY HIGH”

Table 2: Potential High Exposure to “Wildfires” at Shutdown Nuclear Power Plants

–CA / San Onofre Units 1 & 2, “HIGH / VERY HIGH”
–FL / Crystal River, “HIGH / VERY HIGH”
–NJ / Oyster Creek, “HIGH / VERY HIGH”
–NY / Indian Point Units 1, 2 & 3, “HIGH / VERY HIGH”

Wildfires can transport radioactive contamination from nuclear facilities

A historical review of wildfires that occur around nuclear facilities (research, military and commercial power) identifies that these events are also a very effective transport mechanism of radioactivity previously generated at these sites and subsequently released into the environment by accident, spills and leaks, and careless dumping. The radioactivity is resuspended by wildfires that occur years, even decades later. The fires carry the radioactivity on smoke particles downwind, thus expanding the zone of contamination further and further with each succeeding fire. The dispersed radionuclides can have very long half-lives meaning they remain biologically hazardous in the environment for decades, centuries and longer.

Here are a few examples of how wildfires increasing in frequency and intensity are also threatening to spread radioactive contamination farther away the original source of generation.

The Chornobyl nuclear catastrophe and recurring wildfires

The Chornobyl nuclear disaster that originally occurred on April 26,1986, initially spread harmful levels of radioactive fallout concentrated around the destroyed Chornobyl Unit 4 in northern Ukraine. The radioactive fallout was transported high into the atmosphere by the accidental reactor explosion. The days long fire and smoke transported extreme radioactivity from the expelled
burning nuclear fuel and its graphite moderator. Radioactive fallout then spread far afield in shifting winds, precipitated  with rainfall and was terrestrially deposited in its highest concentrations largely in northern Ukraine, Belarus and Southern Russia.

Additional atmospheric distributions of radioactive contamination fell across much of Europe, persisting in numerous hot spots, including in Scandinavia, and the United Kingdom, where it remains as a persistent toxin.

The Chornobyl ‘Exclusion Zone’ to restrict long term human habitation was established in the immediate aftermath in 1986 as an arbitrary 1,ooo square miles within an 18 mile radius around the exploded reactor in Ukraine and remains in place today nearly 39 years later.  The Bulletin of Atomic Scientists reports that seasonal wildfires continue to occur within the Chornobyl Exclusion Zone, routinely burning across already contaminated land and resuspending radioactivity via the smoke into the atmosphere. The radioactive smoke is borne on the wind, carrying the radioactive fallout farther out and increasing the size of what can be measured as potentially an expanding Exclusion Zone.

Contrary to claims, wildfires can threaten US nuclear facilities

The Los Angeles Times headlined in May 2024 “Sites with radioactive material more vulnerable as climate change increases wildfire, flood risks.”

The LA Times did a look back at several wildfires surrounding the government radiological laboratories and government nuclear weapons manufacturing sites including the 2018 Woolsey wildfire at the old Santa Susana Field Laboratory (SSFL). This facility specifically housed 10 nuclear reactors and plutonium and uranium fuel fabrication facilities located in the Los Angeles suburbs. SSFL was used for early testing of rockets and nuclear reactors for energy.  But decades of carelessness during experiments resulted in one of  the first nuclear reactor meltdowns in 1959, leaving acres of soil, burn pits and water radioactively and chemically contaminated. Boeing is the current operator of SSFL  now obligated to conduct the cleanup of the SSFL site.

“A 2018 fire in California started at the Santa Susana Field Laboratory, a former nuclear research and rocket-engine testing site, and burned within several hundred feet of contaminated buildings and soil, and near where a nuclear reactor core partially melted down 65 years ago,” reported the LA Times.

Over the years, NBC news has broadcast continuing coverage of the massive 2018 Woolsey fire at SSFL and the radioactive contamination from this event, found in several Los Angeles suburbs miles away.

Despite these events, federal authorities continue to issue vapid safety assurances that climate changes, including more frequent wildfires, will not increase the risks to public health and safety from contaminated commercial, military and national laboratory facilities and that there is no need to include environmental reviews that account for the impacts of climate change in the
regulatory environmental review process.

A recent example of the NRC resistance to factor in reasonable assurance for protecting the public’s health and safety from climate change risk and its potential impacts that increase the risk of a severe nuclear accident, including wildfire,  into its oversight and environmental reviews for licensing and relicensing is Chairman Christopher Hanson’s September 27, 2024 response to the GAO report:

“…the NRC does not agree with the [GAO] conclusion that the agency does not address the impacts of climate change. In effect, the layers of conservatism, safety margins, and defense in depth incorporated into the NRC’s regulations and processes provide reasonable assurance of adequate protection of public health and safety, to promote the common defense and security, and to protect the environment.”

Commission Chairman Hanson’s outright dismissal of the GAO report and its finding that the agency needs to take action runs contrary to one of agency’s own, Atomic Safety Licensing Board Judge Michael Gibson’s dissenting opinion to the similar blanket dismissal by the NRC to take a “hard look” climate change impacts  under the National Environmental Policy Act (NEPA) on extreme reactor relicensing.  In this case, the Judge Gibson supported Beyond Nuclear’s legal challenge to the Commission’s second 20 year license extension of its operating license of its commercially reactors and dissented from the licensing board’s majority denial of our hearing request on climate change’s contribution to the risk and consequences of severe nuclear accidents.

In Judge Gibson’s 23 page dissent of his colleagues’ decision to extend the nuclear plant’s operating license out to 2060 without a pubic hearing on climate change impacts on nuclear power plants, he went on the record,

“That is hardly the reception climate change should be given. As CEQ (the President’s Council on Environmental Quality), the federal government’s chief source for assessing the importance of climate change in environmental analyses under NEPA, has made clear, ‘The United States faces a profound climate crisis and there is little time left to avoid a dangerous—potentially catastrophic—climate trajectory. Climate change is a fundamental environmental issue, and its effects on the human environment fall squarely within NEPA’s purview.’ Sadly, the majority and the NRC Staff have failed to heed this warning.”

January 18, 2025 Posted by Christina Macpherson | climate change, Reference, USA | Leave a comment