NRC dismisses GAO climate warnings for nukes

Hurricane Helene 2

On September 27, 2027, the US Nuclear Regulatory Commission’s (NRC) Chairman Christopher Hanson publicly provided the federal agency’s response and an attachment that dismisses the April 3, 2024 U.S. Government Accountability Office’s (GAO) report [GAO-24-106326], “Nuclear Power Plants: NRC Should Take Actions to Fully Consider the Potential Effects of Climate Change.” The GAO in its investigative report to Congress warns that NRC relies too heavily on historical climate data and neglects adequately incorporating science-based data projections on the impacts and destructive consequences of climate crisis on reactor operations and reliability.

The NRC Chairman  broadly responded that “…the NRC does not agree with the conclusion that the agency does not address the impacts of climate change.” In fact, the NRC’s new reactor licensing and aging reactor relicensing environmental reviews only look at the so-called “zero carbon emission” impacts of reactor operations on climate and not the climate change impacts on reactor safety and reliability  as a consequence of more severe and frequent storms, flooding, increasing sea level rise and more extreme temperatures that bring droughts and wild fires.

Chairman Hanson writes, “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.”  To the contrary, Beyond Nuclear is actively contending in its litigation before the Atomic Safety Licensing Board and now on appeal before the Commissioners in three separate NRC relicensing proceedings, that the nuclear industry and the NRC  in fact do not meet the agency’s legal standard of  “reasonable assurance of adequate protection” as required under the current Atomic Energy Act as Amended.

The NRC attachment briefly answers the GAO’s three recommendations in its report to the agency and Congress:

GAO Recommendation 1, “NRC should direct NRC staff to assess whether its licensing and oversight processes adequately address the potential for increased risk to nuclear power plants from climate change.”

A “…review of the Fifth National Climate Assessment (NCA5) and its supporting technical literature will be the starting point for the identification of any potential gaps relevant to the NRC’s licensing and oversight processes. NRC staff will determine if and how the updated information might inform the licensing and oversight of existing licensed power plants.”  However, Beyond Nuclear has  appealed an NRC licensing board decision to reject a hearing request for the stepped up environmental review of climate change for the 60 to 80 year operating license renewal of Virginia’s North Anna nuclear power station where where NRC documentation  identifies that the twin reactors’ turbine building  is already vulnerable to extreme flooding in the event of severe rand prolonged rainfall. These NRC documents acknowledge that  severe flooding of the North Anna site can overwhelm flood protection structures within the turbine building potentially disabling the reactors’ emergency core cooling system causing a severe  nuclear accident. The NRC is instead ignoring the nuclear accident risk of this climate change-related scenario. Moreover, nuclear power stations are operating below large dams where neither the dam infrastructures nor vulnerable nuclear power stations have been adequately evaluated for monstrous storms created by climate change like Hurricane Helene where unprecedented rainfall and flooding plunged far beyond coastal  Florida deep into Georgia, South Carolina, North Carolina and Tennessee.

GAO Recommendation 2, “NRC should direct NRC staff to develop, finalize, and implement a plan to address any gaps identified in its assessment of existing processes.”

Chairman Hanson states, the NRC “staff will assess the safety significance of any gaps, if identified.” However, the NRC staff filings have already  repeatedly identified in  site-specific license renewal proceedings for a second 20-year extension period (60 to 80 years) that they do not project any climate change analysis onto future operations because it is “beyond the scope of environmental reviews” for reactor relicensing. This includes the projected impacts of coastal sea level rise, hurricane storm surge and a re-evaluation of unprecedented probable maximum precipitation and probable maximum flooding farther inland on reactor operations and reliability.

GAO Recommendation 3, “The NRC should direct NRC staff to develop and finalize guidance on incorporating climate projections data into relevant processes.”

The NRC states, “The NRC staff is conducting a comprehensive review of relevant regulatory guides to determine whether any require an update or revision to address considerations related to climate change.” However, NRC staff presentations to the National Academies of Sciences (NAS) Committee for “Modernizing Probable Maximum Precipitation Estimation” identified that the agency does not plan to incorporate upgraded analysis for protecting nuclear power infrastructure from climate impacts and consequences including projected severe increases in rainfall and flooding.

[Photo: Hurricane Helene, September 24, 2024, NOAA]

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