Monday

Real ISA, versus Faux ISA


The difference between the general public repeatedly being shown acceptable safety conditions by an alarmist press wrongly deeming them possible emergencies, and a truly degraded or dangerous nuclear plant , ...has not been made sufficiently clear.

Even an absolute collapse of local political confidence in NRC and its day-to-day oversight cannot be solved by re-inspecting all 104 nuclear plants whenever a local political figure gains traction for the idea in his/her constituency. Such a development can only result in the squandering of resources, funding, and effort into situations not warranting such activity. Taken to its extrapolated worst case, this strategy would flood all 104 nuclear plants with hordes of intrusive inspectors, impeding plant operations, and possibly inducing the very events they came to inspect against.

One of the first principles espoused in the international IAEA document 75-INSAG-3, "Basic Safety Principles for Nuclear Plants", in its preamble by nobel laureate Mohammed El Baradei, is that effort must be targeted to need. "It is important to avoid concentrating resources on efforts that have only marginal effects"..

With local governmental figures voicing ephemeral concerns brought to their attention from activist, intervenor, and opposer groups, outside of any indication that acceptable safety has truly been compromised, we see a clear need for a high level separation of fact and claim, perhaps by a national or international committee, establishing guidelines, and trip-points for the beneficial use of independent safety assessments, and likewise setting precise indicators barring the frivolous use of ISA as a political panacea.

The basic safety case for each of the 104 American nuclear plants has been set out in their Preliminary Safety Analysis Report and their Final Safety Analysis Report. Deterministic comparison of each plant's adherence to its written safety case is provided in real-time by the presence of resident NRC inspectors, and the NRC Reactor Oversight Program.

Probabilistic analysis of the major US plant types can be done by qualified researchers at any time, setting out the risks versus the probabilities in general, allowing guidelines to stand as required reading for those who would inspect, and re-inspect, frivolously, without knowing anything at all about the limits of mere inspection.

(Inspection as a tactic cannot predict an unforseen event. The very evening an ISA is completed at plant "X", a meteor could strike the containment dome, and breach the reactor core--- the inspection would have been a total waste of time).

Politicians ignorant of Probabilistic Risk Analyses seek an absolute "How Safe Is It?" answer , one that eternal inspection, by its very nature, cannot supply. PRA can provide that overview. Therefore politicians should direct the Congressional Research Service to commission a national PRA report on the 104 reactors, as their own internal legislative guide on how to avoid useless calls for repeat ISA's. In point of fact, politicians have been slyly misguided by intervenor and opposer public relations operatives posing as "technical experts", and given the Maine Yankee ISA & shutdown as the one and only way to find out if your local nuke is dangerous. Actually, the MY ISA found the plant was acceptable for further operation. It was a bereft conglomerate corporate culture that had no further interest in its nuclear asset, and bailed out. So even in the case of Maine Yankee, the public was never told how safe the plant was, or was not.

In the face of this impossibility to get blood from a stone, vis-a-vis the ISA tactic, politicians must be educated where to look for this information. I would challenge Senator Clinton and Congressman Hall to write up legislation empowering NRC or CRS to do a "PRA Constitutional Report" on each of the American reactors, with appropriate funding and a clear legislative charter., and to report the results in a high level national safety assessment.

After this report had scientifically charted the relative safety of all 104, then , and only then, would ISA become a useful tool, targeted at whatever specific need had been scientifically unearthed in the PRA Constitutional. This also has the benefit of closely following the IAEA methodology set out in 75-INSAG-3, the high-level agenda-free international document most trustworthy as an authority in these matters.

Without such a framework, any call for an ISA, without clearly demonstrated need, can rightly be called frivolous misuse of legislative priviledge. Within such a framework, established need can form the basis of any future calls for an ISA.

Reference Documents may be found at:

http://www-pub.iaea.org/MTCD/publications/PDF/P082_scr.pdf , links to the current international standard for safety at nuclear plants. "75-INSAG-3"

http://www-pub.iaea.org/MTCD/publications/PDF/Pub991e_web.pdf, is the IAEA publication setting the international standard for judging safety in nuclear plants built to earlier standards.
The document is named "INSAG-8"


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