Palisades 50

, former director, Nuclear Safety Project | July 7, 2015, 6:00 am EDT
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Fission Stories #192

Much has been said and written about the Fukushima 50—the workers who remained onsite during the height of the crisis at the Japanese Fukushima nuclear plant after senior managers ordered their co-workers to evacuate because of worsening conditions.

Less has been said and written about the Palisades 50—which involves worsening conditions and workers but not quite in the same way. Palisades 50 refers to the findings by the Nuclear Regulatory Commission (NRC) during a recent inspection at this nuclear plant five miles from South Haven, Michigan.

Inspections at Palisades

The NRC conducted a Component Design Bases Inspection (CDBI) involving seven inspectors at Palisades between September 8 and November 4, 2014. The CDBI is part of the NRC’s Reactor Oversight Process. According to the NRC’s inspection report for Palisades:

“The objective of the component design bases inspection is to verify the design bases have been correctly implemented for the selected risk significant components and the operating procedures and operator actions are consistent with design and licensing bases.”

Because risk studies assume that safety systems perform successfully to prevent and/or mitigate accidents, the CDBI seeks to verify this assumption is valid. When safety systems do not perform as assumed in the studies, the plant’s risk very likely increases.

For the CDBI at Palisades, the NRC inspectors selected 20 components. The NRC then examined engineering records (such as calculations and design specifications), maintenance records, operating procedures, testing and inspection records, system health reports, training documents, and other records for these 20 components.

The NRC identified 10 safety violations from their examination of 20 components—hence, the Palisades 50. On average, 50 percent of the components examined resulted in safety violations being identified.

The NRC did not select the 20 components at random from among literally thousands of candidates at the site.

The NRC did not select the components off the top, middle, or bottom of an alphabetical listing of components.

The NRC did not select the components from among the oldest, middle-aged, or newest components installed at the site.

The NRC selected the 20 components based upon their safety significance. The NRC deliberately selected components making the highest contribution to safety levels.

The NRC reviewed the owner’s risk study and the NRC’s Standardized Plant Analysis Risk (SPAR) model to identify a scenario having a high risk of resulting in reactor core damage. The NRC picked the large break loss of coolant accident. In this postulated accident, a large pipe forming part of the reactor vessel pressure boundary instantly snaps in two, allowing cooling water to escape from both broken ends. This scenario puts a severe challenge on standby emergency pumps to quickly start up and supply makeup water to the reactor vessel before the reactor core overheats and melts down. The NRC then selected 20 components with significant roles to play in mitigating the severity of this accident.

Inspections at other plants

In 2014, the NRC reported on 15 CDBIs conducted at other nuclear plants. The average CDBI examined 18 components and identified 3.6 violations. The Palisades CDBI involved about the same number of components but nearly three times as many violations. No other CDBI yielded as many, or more, violations that the one at Palisades. Two CDBIs—at Perry and Pilgrim—identified no safety violations at all.

Nuclear Plant Number of Components Examined During CDBI Number of Violations Identified During CDBI
Callaway (MO) 19 7
Duane Arnold (IA) 21 5
Farley (AL) 16 7
Nine Mile Point (NY) 24 3
Oconee (SC) 18 2
Palisades (MI) 20 10
Peach Bottom (PA) 17 2
Perry (OH) 20 0
Pilgrim (MA) 18 0
River Bend (LA) 19 5
Salem (NJ) 16 1
Shearon Harris (NC) 14 4
South Texas Project (TX) 22 7
Surry (VA) 13 2
Turkey Point (FL) 16 1
Vermont Yankee (VT) 14 1
Totals 287 57
Average CDBI 18 3.6


Our Takeaway

The NRC conducts a CDBI at each nuclear power plant every three years. Thus, if you can count to three, you know when the next CDBI team will arrive at your plant.

The NRC notified Palisades’ owner more than three months in advance of the CDBI team arriving at the plant. Again, if you can count to three, you know when the next CDBI arrives at your plant.

Because the components examined by the NRC during CDBIs have vitally important safety functions, they get tested and inspected more frequently and extensively than components of lesser importance. Thus, there are fewer excuses for plant workers not to have found and fixed the violations before the NRC identified them.

The silver lining at Palisades and nationally is that none of the 57 violations identified during these CDBIs was classified as being more serious than Green in the NRC’s color-coded classification system (Green, White, Yellow, and Red in order of increasing severity). But dark clouds accompany that silver lining—until the violations were identified and the safety impairments they introduced understood, no one could be certain that the safety implications were not greater.

Further shadowing this silver lining is this fact—the 16 plants have far more than 287 components with important roles to play in managing risks. Nearly 20 percent of the high safety value components examined by the NRC during 2014 yielded violations. There’s no reason to believe that the hundreds of high safety value components the NRC did not examine during 2014 are not equally afflicted with violations. And since these violations remain undetected and unevaluated, no one can honestly claim that the 57 Greens are the worst out there.

In theory, the NRC’s CDBIs should verify that all high safety value components are properly designed, maintained and operated.

In practice, the NRC’s CDBIs are verifying just the opposite.

The NRC must use the results from its CDBIs to force plant owners to figure out what is wrong with their testing and inspection programs that prevent them from finding and fixing safety violations. After all, that’s the primary purpose of doing all those tests and performing all those inspections. They are not an exercise program for workers or busy work to keep them occupied until lunch break. The testing and inspection programs are supposed to demonstrate that the public is adequately protected.

That’s not happening.

That must get fixed before impaired safety components contribute to the next nuclear disaster.


“Fission Stories” is a weekly feature 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.

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  • Richard Solomon

    How will the NRC go about ‘forcing plant owners to figure out what is wrong with their testing and inspection programs…..?’

    Who is going to make the NRC do this?!?

  • JohnGreenberg


    “In theory, the NRC’s CDBIs should verify that all high
    safety value components are properly designed, maintained and operated.”

    It’s a lovely theory.

    In actuality, however: “The NRC selected the 20 components
    based upon their safety significance. … The NRC conducts a CDBI at each nuclear
    power plant every three years. Thus, if you can count to three, you know when
    the next CDBI team will arrive at your plant. The NRC notified Palisades’ owner
    more than three months in advance of the CDBI team arriving at the plant.”

    And yet, there were 57 violations at US plants in just one
    year. (It’s worth noting, in passing,
    that that’s out of only 1/3 of the nukes, since 2/3 are not tested in any given

    If that year were around between, say, 1960 and 1975 when
    nuclear power in the United States was just coming on line, one could excuse
    the situation by claiming that these are just the mistakes of any relatively
    new technology. But the year was 2014, 55
    years after this infancy period.

    In a fantasy world, we could dismiss the actuality, and rely
    on the lovely theory above to find that nuclear power in the United States is safe.

    But in the real world, the obvious conclusion is precisely
    the opposite: even assuming that these facilities were properly designed in the
    first place – which Fukushima taught us is not the case (as 3 of the designers had
    already told us almost 40 years earlier) – the operators cannot maintain them
    adequately EVEN THOUGH they are warned in advanced about inspections of key

    I do not for a moment believe that nuclear operators are
    dumb. They can, as you put it, count to
    3 and I do not believe they are unaware of the safety violations at their
    plants. (If they are, what does THAT
    tell us??) They know the NRC inspectors
    will come; they know the inspectors will find problems, and STILL they prefer
    to continue operating WITH the problems, rather than to correct them.

    The obvious inference is pretty clear: plant owners find it preferable
    to pay fines (if any) for these safety violations rather than to actually fix
    the problems before inspectors can enumerate them. Isn’t that the very definition of a failed regulatory

    In an earlier column, you suggested that UCS would become
    anti-nuclear if “we could become unable to find appropriate solutions for
    nuclear power plant safety shortcomings. With benefits to be derived only at
    undue risk of costly consequences, nuclear power would likely be opposed by

    But we have just seen that, in any given year, there are
    dozens of violations involving key safety components at US nuclear plants, and
    that the existing regulatory structure (which is not likely to improve
    significantly in any foreseeable future) is incapable of prompting owners to
    fix them.

    Making the very best assumption, plant owners do not really
    believe these components will ever be needed and will therefore not bother to
    keep them working. (If they DO believe
    they will be needed, then what does their failure to maintain them tell
    us?) What does UCS think it can do that
    the NRC can’t to change their minds? And
    why, after decades of trying, does UCS believe that next time will be

    Accordingly, I find myself wondering at what point UCS
    will decide that, in the real world rather than the fantasy I invoked above, “appropriate
    solutions for nuclear power plant safety shortcomings” are not likely to be
    forthcoming in the US? At what point does the reality of the facts
    you yourself bring to the table overcome the idealistic, but baseless notion
    that, “if only” … will prevail?

  • grumpy

    When are we going to hold coal plants accountable to release no more radiation than is allowed at nuclear plants? At the moment coal plants release 1000x more radiation into our lungs than do nuclear plants. There is uranium in coal. And lots of other noxious things. Air pollution kills 7 million people per year according to the WHO. Nuclear power has killed less than 100 people in 60 years.

  • Dr. A. Cannara

    Wow, David is indeed no statistician — I’ve talked with him before — “10 out of 20” tested components failing inspections warrants the blanket denigration of the Palisades plant as “50%” off design bases? Really, David?

    I and my classmates never would have received our Statistics degrees if we’d been so casual with statistical analyses.

    Nuclear power should indeed be safer than any other form of power — oh yes, it is, even including illegal Chernobyl and unregulated Fukushima Dai-Ichi — remember, David?

    UCS would regain my respect and $ if it stopped pretending to be a good steward of nuclear safety and became a good steward of all energy safety, and an honest broker of energy sources in relation to their environmental impacts. Pictures of windmills on UCS pages detract from “honest-broker’ (look up OSHA reports on worker injuries & deaths from windmills, cell towers…)

    David may have bad memories of his conflicts with nuclear management individuals, but we all need to rise above such, if we want to contribute to our descendants’ rightfully safe futures.

    One way for Lochbaum & Lyman to start would be to rewrite some of their recent book (Fukushima) to expose facts they oddly avoided in their 1st writings, despite that being 3 years after 3/11/11. A modest start was given David when at the Commonwealth Club in SF last year. Remember, David? Remember leaving out inconvenient facts like the BAS report, Onagawa, Fukushima Dai-Ini…?

    The ‘design basis’ of your book missed a few journalistic targets. So here’s the freely-offered book cover again — it’s all about credibility, eh?…