Beyond Nuclear warns NRC against weakening RPV embrittlement/PTS safety regulations at Palisades
Entergy's problem-plagued Palisades atomic reactor, and the Great Lake and region of southwest Michigan it puts at dire, and increasing, risk.
Introduction
Nuclear watchdog groups have long been concerned about Pressurized Thermal Shock (PTS) risks due to the worst embrittled reactor pressure vessel (RPV) in the U.S., at Palisades, located on the Lake Michigan shoreline.
As described in a July 9, 1981 AP article (see below), "A severe overcooling and repressurization accident involving a weak vessel in one of the pressurized-water reactors could cause the reactor vessel--which contains the radioactive fuel rods used to produce heat and electricity--to crack like a hot glass jar thrust into cold water, officials of the Nuclear Regulatory Commission said in interviews this week."
A sudden decrease in temperature due to Emergency Core Cooling System activation, the consequent decrease in the intense pressure, followed by sudden re-pressurization (Pressurized Water Reactors, PWRs, operate at around 2,200 pounds -- or a ton -- of pressure per square inch) on the neutron radiation-embrittled metal of the RPV, could fracture it. A Loss of Coolant Accident (LOCA) would follow, then reactor core meltdown, risking containment failure and catastrophic release of hazardous radioactivity downwind, downstream, up the food chain, and down the generations.
The longer Palisades operates, the worse its risk of a breakdown phase accident, as due to PTS. (See Union of Concerned Scientists' "Bath Tub Curve" -- due to the curve's shape -- of break-in and breakdown phase risks, including nuclear power "data points," such as Three Mile Island Unit 2, Chernobyl, Davis-Besse's hole-in-the-head fiasco, and Indian Point's steam generator tube rupture.)
Relevant Regulations and Standards
See 10 CFR Part 50.61 (June 26, 1984), NRC's regulation on "Fracture toughness requirements for protection against pressurized thermal shock events." A link is also posted on NRC's website. (Page 929 to 933, or 98 to 102 of 212 on PDF counter) See also Part 50.61a (2010), "Alternate fracture toughness requirements for protection against pressurized thermal shock events." (Page 934 to 943, or 103 to 112 of 212 on PDF counter) A link is also posted at NRC's website.
See also 10CFR50 Appendix H, Reactor Vessel Material Surveillance Program Requirements. (Federal Register, Vol. 38, No. 136, July 17, 1973). In addition to Appendix H, 10 CFR 50.60, "Acceptance criteria for fracture prevention measures for lightwater nuclear power reactors for normal operation," requires that all lightwater reactors meet the fracture toughness and the material surveillance program requirements for the reactor coolant pressure boundary set forth in 10 CFR 50, Appendix G [Fracture Toughness Requirements]..." (as described by Entergy in its July 29, 2014 license amendment request).
In addition: NRC Regulatory Guide 1.43 regulates RPV forgings; Reg Guide 1.154, "Format and Content of Plant-Specific Pressurized Thermal Shock Safety Analysis Reports for Pressurized Water Reactors" (January, 1987) regulates annual through-wall crack risks; and RG 1.162 regulates annealing.
See also Section XI of the ASME Boiler and Pressure Vessel Code, Appendix G, Fracture Toughness Criteria for Protection Against Failure, 1989 Edition with no addenda, up to and including the 2007 Edition with the 2008 Addenda, American Society of Mechanical Engineers, New York.
See also Boiler and Pressure Vessel Code, Section III, Division 1, Subsection NB, Section NB-2300, "Fracture Toughness Requirements for Material," American Society of Mechanical Engineers, New York.
See also the following ASTM (American Society for Testing and Materials) standards:
ASTM E208, Standard Test Method for Conducting Drop-Weight Test to Determine Nil-Ductility Transition Temmperature of Ferritic Steels, in ASTM Standards, Section 3, American Society for Testing and Materials, Philadelphia, PA.
ASTM E185-82, Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels, E706 (IF), in ASTM Standards, Section 3, American Society for Testing and Materials, Philadelphia, PA, 1993.
ASTM E23-93, Standard Test Methods for Notched Bar Impact Testing of Metallic Materials, in ASTM Standards, Section 3, American Society for Testing and Materials, Philadelphia, PA, 1993.
ASTM A370-92, Standard Test Methods and Definitions for Mechanical Testing of Steel Products, in ASTM Standards, Section 3, American Society for Testing and Materials, Philadelphia, PA, 1993.
ASTM E8-94, Standard Test Methods for Tension Testing of Metallic Materials, in ASTM Standards, Section 3, American Society for Testing and Materials, Philadelphia, PA, 1994.
ASTM E21-92, Standard Test Methods for Elevated Temperature Tension Tests of Metallic Materials, in ASTM Standards, Section 3, American Society for Testing and Materials, Philadelphia, PA, 1993.
ASTM E83-93, Standard Practice for Verification and Classification of Extensometers, in ASTM Standards, Section 3, American Society for Testing and Materials, Philadelphia, PA, 1993.
Chronological History (timeline dates and citations in relevant AEC, NRC, Palisades, and/or environmental watchdog/intervenor documents)
January, 1948: R.D. Evans and R.O. Evans, "Studies in Self-Absorption in Gamma-Ray Sources," Reviews of Modern Physics, 20, 305-326.
March 14, 1967: Palisades receives its construction permit from the U.S. Atomic Energy Commission (AEC).
June 1967: E. Storm and H.I. Israel, "Photon Cross Sections from 0.001 to 100 MeV for Elements 1 through 100," Los Alamos Scientific Laboratory of the University of California, Los Alamos, NM, LA-3753, UC-34, PHYSICS, TID-4500.
January 27, 1970: The Advisory Committee on Reactor Safeguards (ACRS), chaired by Joseph M. Hendrie (later to chair the NRC during the Three Mile Island meltdown), "REPORT ON PALISADES PLANT" sent to AEC Chairman Glenn T. Seaborg (discoverer of plutonium during the Manhattan Project). Even more than a year before Palisades began operations, the ACRS was already concerned about RPV embrittlement, writing "Surveillance specimens in the vessel will be used to monitor the radiation damage during the life of the plant. If these specimens reveal changes that affect the safety of the plant, the reactor vessel will be annealed to reduce radiation damage effects...Prior to accumulation of a peak fluence of 10(19) nvt (> 1 Mev) on the reactor vessel wall, the Regulatory Staff should reevaluate the continued suitability of the currently proposed startup, cooldown, and operating conditions...". (emphases added) See this document at pages 3 to 6 of 129 on PDF counter in environmental intervenors' Exhibit 1A, September 16, 2005 (see below). Although annealing would be floated from time to time over the years and decades, it has never been done.
February 21, 1971: Palisades granted its operating license. As put by NRC staff in March 2013 (see page 8 of 15 on PDF counter): "Palisades implemented a surveillance program consistent with then-standard industry practice (i.e., implementation of the requirements of ASTM E185, "Standard Practice for Design of Surveillance Programs for Light-Water Moderated Nuclear Power Reactor Vessels." ASTM E185 has since been required by 10 CFR 50, Appendix H (see above).
April 1, 1971: Groeschel, R.C., Summary Report on Manufacture of Test Specimens and Assembly of Capsules for Irradiation Surveillance of Palisades Reactor Vessel Materials, CE Report No. P-NLM-019.
Summer 1975: American Physical Society report on light water reactor safety (Panofsky, Weisskopf, Bethe, Lewis, et al.), as cited in November 1981 Friends of the Earth newsletter article (see below).
1977: Regulatory Guide 1.99, "Radiation Embrittlement of Reactor Vessel Materials," Revision 1.
1977: NRC approves 15% power uprate at Palisades.
1977: As reported by NIRS in its 1988 report (p.22, see below), "...as early as 1977, test samples placed in B&W [Babcock & Wilcox] reactors were indicating that embrittlement was progressing at a faster rate than had been expected."
August 25, 1977: Perrin and Fromm, "Final Report on Palisades Pressure Vessel Irradiation Program: Unirradiated Mechanical Properties to Consumers Power."
1978: Palisades surveillance capsule pull, irradiated capsule ID# A-240, see "Final Report on Palisades Nuclear Plant Reactor Pressure Vessel Surveillance Program: Capsule A-240," ADAMS # for report 7907120344, according to NRC Commissioner Magwood response to Kraig Schultz of MSEF on May 28, 2013 (see below). Note, the ML# as provided by Commissioner Magwood does not work.
March 20, 1978: Severe overcooling accident at Rancho Seco, CA. (See also December 26, 1985 severe overcooling accident at Rancho Seco). As reported by NIRS in August 1988 (see below), "On March 20, 1978, the B&W designed Rancho Seco nuclear power plant experienced a PTS event precipitated by a control system failure. While replacing a light bulb in the integrated control system, an operator dropped the bulb into the control panel shorting out the control room instrumentation which eventually led to an overcooling of the reactor accompanied by repressurization of the vessel. The event is believed to represent the most severe and prolonged overcooling event to date with a change in temperature of 300 degrees F. per hour. [NRC safety engineer Demetrios] Basdekas was able to convince the NRC that control system failures were an unresolved safety issues, but the Commission continued to ignore these failures in their calculations on pressurized thermal shock."
March 13, 1979: Perrin, Fromm, Farmelo, Denning, and Jung, "Final Report on Palisades Reactor Pressure Vessel Surveillance Program: Capsule A-240 to Consumers Power," BCL-585-12.
Late 1970s and 1980s: As described in May 30, 2002 NRC doc (page 4 of 7), "large-scale experiments on prototypic RPVs subjected to pressure and temperature transients characteristic of PTS loadings were conducted at the Oak Ridge National Laboratory (ORNL) as part of the NRC-sponsored Heavy Steel Section Technology (HSST) research program." The experiments showed that a powerful PTS accident could cause "a crack [to initiate and propagate] through the vessel wall. In addition to large openings in the reactor vessel, this outcome involves significant additional deformation of the vessel," presenting "a potentially significant challenge to core cooling ad containment integrity."
1980: Severe embrittlement discovered during routine testing at the Maine Yankee atomic reactor, significantly worse than models had predicted (as reported by AP article on July 9, 1981, see below).
February 27, 1980: "Failure of Main Feedwater Control System Resulting in Unacceptable Overcooling of Reactor Vessel," memorandum from Demetrios Basdekas (NRC Office of Nuclear Regulatory Research) to Thomas Murley, US NRC, Washington, D.C. Documented (at Page 3-28, and Footnote #91) in "Systems Interaction and Single Failure Criterion, Phase 3, Final Report," prepared by MB Technical Associates, San Jose, CA, commissioned by Swedish Nuclear Power Inspectorate, October 1983.
Winter, 1980-1981: Oak Ridge National Laboratory report on severe 1978 overcooling accident at Ranch Seco, CA.
Early to mid-1980s: As reported by NIRS in 1988 (p.22, see below), "RTndt limits had originally been set at 200 degrees Fahrenheit. However, as these limits were reached in the early to mid 1980s, the NRC began developing new limits within the framework of the PTS rule."
April 1981: Letter from Demetrios Basdekas to Morris Udall, as cited in November 1981 Friends of the Earth newsletter article (see below). The July 9, 1981 AP article (see below) reported that Basdekas based his letter on the Rancho Seco accident of 1978, as well as the Maine Yankee revelation of 1980.
April 1981: Letters sent by NRC to 44 PWRs, requesting information, including recent test results, regarding RPV vulnerability to PTS (see July 9, 1981 AP article, below).
April 21, 1981: Thadani, NRC memorandum re: Frequence of Excessive Cooldown Events Challenging Vessel Integrity.
May 1981: Responses sent by 44 PWRs to NRC, re: RPV vulnerability to PTS. NRC evaluates responses to determine if any modifications to reactor operations necessary. (See April 1981 above, and July 9, 1981 below).
June 20, 1981: Science News, as cited in November 1981 Friends of the Earth newsletter article (see below).
June 11, 1981: Meeting held at NRC HQ in Washington, D.C., to discuss overcooling accidents at US PWRs in CA (Rancho Seco, March 20, 1978) and FL (Crystal River, 1979), as well as more severe embrittlement at the Maine Yankee atomic reactor than models had predicted (discovered during routine testing in 1980). NRC then ordered 44 PWRs to test the vulnerability of the RPVs to PTS, as reported by AP on July 9, 1981 (see immediately below).
July 9, 1981: Associated Press article, "Vessels becoming vulnerable: Some reactors are losing their toughness," by Maureen Dea.
September 27, 1981: "Steel turned brittle by radiation called a peril at 13 nuclear plants," by Matthew L. Wald, New York Times.
November 1981: "Radiation Weakens Pressure Vessels," Not Man Apart, Friends of the Earth's newsletter, pages 16-17 (Palisades and many other PWRs discussed).
1982: R.C. Weast and M.J. Astle, Eds., "CRC Handbook of Chemistry and Physics, 63rd Ed.," CRC Press, Boca Rotan, FL.
March 28, 1982: "The Risk of a Meltdown," March 28, 1982 New York Times op-ed by NRC reactor safety engineer Demetrios Basdekas.*
November 23, 1982: NRC SECY-82-465, "Pressurized Thermal Shock." This document summarized the technical basis for using RT(PTS) as an indicator of the ability of the RPV to withstand a PTS event; RT(PTS), which stands for Reference Temperature(Pressurized Thermal Shock), is a measure of the material ductile-to-brittle transition temperature at the end of the RPV's licensed life (see May 30, 2002 NRC document, below, footnote #1). Here is the full citation: Policy Issue from J.W. Dircks to NRC Commissioners, Enclosure A: NRC Staff Evaluation of Pressurized Thermal Shock, November 1982, SECY-82-465, November 23, 1982, Division of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, D.C.
1982: As reported by NIRS in 1988 (see below, Page 22), "In a briefing to its Advisory Committee on Reactor Safeguards in 1982, the NRC staff considered RTndt considered limits of 230 and 250 degrees F for longitudinal and circumferential welds respectively. However, by 1985..." (see below).
1983: Palisades surveillance capsule pull, irradiated capsule ID# W-290, see "Analysis of Capsules T-330 and W-290, Consumers Power Company, Palisades Reactor Vessel Radiation Surveillance Program," ADAMS # for report 8411200379, according to NRC Commissioner Magwood response to Kraig Schultz of MSEF on May 28, 2013 (see below). Note, the ML# as provided by Commissioner Magwood does not work.
Per Table 6-40 on Page 6-39 of EPRI's December 11, 2011 report below, Capsule W-290 was located at 290 degrees, was removed at End of Cycle 5 in 1983, the Removal taking place at 5.21 Effective Full Power Years, with a Fluence of 9.26 X 10(18) neutons/square centimeter.
1983: Palisades surveillance capsule pull, thermal capsule ID# T-330, see "Analysis of Capsules T-330 and W-290, Consumers Power Company, Palisades Reactor Vessel Radiation Surveillance Program," ADAMS # for report 8411200379, according to NRC Commissioner Magwood response to Kraig Schultz of MSEF on May 28, 2013 (see below). Note, the ML# as provided by Commissioner Magwood does not work.
1983: H.H. Hsu and E.J. Dowdy, "An Interpolation Technique for Gamma-Ray Attenuation Coefficients from 40 keV to 15 MeV," Nuclear Instruments and Methods, 204, 505-509.
June 1983: Edward Edelson, "Thermal Shock -- New Nuclear Reactor Safety Hazard?", Popular Science, pgs. 55-63.
January 1984: Sholly, "Pressurized Thermal Shock Screening Criteria," report prepared for Nuclear Information and Resource Service.
September 1984: M K Kunka and C A Cheney, "Analysis of Capsules T-330 and W-290 from the Consumers Power Company Reactor Vessel Radiation Surveillance Program," WCAP-10637.
1985: (continued from 1982, above) "...However, by 1985, the NRC sought to amend its regulations on pressurized thermal shock. The proposed amendments would establish an RTndt below which the risk from a PTS event is considered acceptable. These new reference temperatures established limits of 270 degrees F. for plate materials and axial welds and 300 degrees F. for circumferential welds." Reported in 1988 by NIRS, Page 22 (see below).
May 22, 1985: "There's No Room for Nuclear Utilities to Relax," Demetrios L. Basdekas, Letter to the Editor of the New York Times.
July 1985: As reported by NIRS in August 1988 (see below), "The NRC adopted the PTS rule in July 1985. In less than six months from the date of its adoption, control system failure had precipitated a severe overcooling event at the Rancho Seco facility [see immediately below]...Yet the NRC still failed to acknowledge control system failures in their analysis of embrittlement and pressurized thermal shock."
December 26, 1985: A second severe overcooling accident at Rancho Seco, CA (see March 20, 1978 above, as well). UCS published a backgrounder on this accident, and the earlier one.
1986: As described by the agency, NRC "established the PTS Rule in response to an issue concerning the integrity of embrittled reactor pressure vessels (RPVs) in Pressurized Water Reactors (RPVs)." That is, the original PTS Rule, 10 CFR 50.61, was promulgated by NRC.
August 7, 1986: Letter from K W Barry to NRC, "Response to Request for Additional Information - Pressurized Thermal Shock (PTS) Rule 10CFR50.61."
January 1987: NRC Regulatory Guide 1.154, "Format and Content of Plant-Specific Pressurized Thermal Shock Safety Analysis Reports for Pressurized Water Reactors" regulates annual through-wall crack risks. "Plants for which the computed RT(PTS) values, even with the neutron flux reduction, will still exceed the screening criteria are required, at least three years before exceeding the criteria, to submit a plant-specific safety analysis demonstrating that the risk associated with PTS events is acceptably low...[RG 1.154] describes one acceptable method for performing such safety analyses." (see May 30, 2002 NRC doc, page 2 of 7) RG 1.154 established a TWCF (Through-Wall Cracking Frequence) criterion, or limit, of 5 X 10(-6) per reactor year (see May 30, 2002 NRC doc, page 4 of 7). That is, a 5 in a million, or 1 in 200,000 risk of a TWC per reactor year.
June, 1987: Residual Life Assessment of Major Light Water Reactor Components--Overview, Volume 1, NUREG/CR 4731, EGG-2469, Volume 1, June 1987, Editors V.N. Shah and P.E. MacDonald (see Server, Odette, Ritchie re: Reference temperature for nil ductility transition increasing from 40 degrees F to 280 to 290 degrees F or higher in extreme cases, due to RPV embrittlement with age). See, for example, page 105.
November 20, 1987: Regulatory Analysis, Revision 2 to Regulatory Guide 1.99, Radiation Embrittlement of Reactor Vessel Materials.
1987-1990: Engineering "Analysis Package for PTS study, (sic) Reactor Engineering Department, Palisades Plant.
May 1988: Regulatory Guide 1.99, Revision 2, Radiation Embrittlement of Reactor Vessel Materials, U.S. NRC.
August 1988: Chapter IV, "Embrittlement of Reactor Pressure Vessels and Reactor Pressure Vessel Supports in Pressurized Water Reactors," in The Aging of Nuclear Power Plants: A Citizens Guide to Causes and Effects, James Riccio and Stephanie Murphy, Nuclear Information and Resource Service, Pages 19-26. Posted online as Exhibit 1D in environmental intervenors' September 16, 2005 Exhibits (see below, pages 18 to 27 of 129 on PDF counter). Pages 24 to 26 of the report address embrittlement risks associated with reactor pressure vessel supports.
October 1988: Experimental Assessments of Gundremmingen RPV Archive Material for Fluence Rate Effects Studies, NUREG/CR-5201, MEA-2286.
April 3, 1989: Consumers Power Company (CPC) provided a revised report on reactor vessel fluence at Palisades for Cycles 1-8. Letter from R W Smedley (CPCo) to NRC, "Docket 50-255 - License DPR-20 - Palisades Plant - Compliance with Pressurized Thermal Shock Rule 10CFR50.61 and Regulatory Guide 1.99 Revision 2 - Fluence Reduction Status (TAC No. 59970)."
August 29, 1989: Letter from J C Hoebel (Westinghouse) to R A Klavon (CPCo), "Interim Report of Westinghouse Review of Consumers Power PTS Calculations."
April 20, 1990: Telecopy of E.P. Lippincott (Westinghouse) to O.P. Jolly (CPCo), "Final Report on Westinghouse Review of Consumers Power PTS Calculations."
May 17, 1990: Cover letter and report, "Analysis of the Reactor Pressure Vessel Fast Neutron Fluence and Pressurized Thermal Shock Reference Temperatures for the Palisades Nuclear Plant," Reactor Engineering Department, Palisades Nuclear Power Plant, Consumer Power Company. (To access a copy of this document, see Pages 39 to 61 of 129 on PDF counter. This May 17, 1990 document was included as Exhibit 1I, in Petitioners' Appendix of Evidence, on September 16, 2005. See below.) Dated references in this documented are posted separately in this chronology. However, two references were not dated, and are posted here: RSIC Computer Code Collection DOT IV Version 4.3 (Report No. CC-429); RSIC Library Collection SAILOR DLC-76.
September 1990: End of Cycle 8 at Palisades.
Fall 1990: A replacement in-vessel dosimetry capsule, was to be fabricated and installed by Combustion Engineering, inserted into the W-290 capsule holder vacated following Cycle 5. Installation was to have occurred in the fall of 1990, according to a May 17, 1990 Consumers Power Co. document (Page 47; see below).
1992: As reported by Inside NRC on December 12, 1994 (see below), "The inability of Yankee Atomic Electric Co. to provide sufficient information about the integrity of Yankee's [Yankee Rowe's] reactor vessel, together with economic issues, prompted the Yankee (sic) to shut that unit permanently in 1992."
April 14, 1992: "Cheap and Abundant Power May Shutter Some Reactors," by Matthew L. Wald, New York Times. RPV embrittlement is listed as a concern that forced the shutdown of the Yankee Rowe reactor in MA. Palisades is also mentioned as vulnerable to permanent shutdown, due to the major investment required to deal with its embrittled RPV.
May 1992: Lippincott, E.P., "Consumers Power Company Palisades Nuclear Plant Reactor Vessel Fluence Analysis," WCAP-13348.
1993: Palisades surveillance capsule pull, irradiated capsule ID# W-110, see "Analysis of Capsule W-110 from the Consumers Power Company Palisades Reactor Vessel Radiation Surveillance Program," ADAMS # for report 9406270173, according to NRC Commissioner Magwood response to Kraig Schultz of MSEF on May 28, 2013 (see below). Note, the ML# as provided by Commissioner Magwood does not work.
Per the December 11, 2011 EPRI report below (in Table 6-40, on Page 6-39), Capsule W-110 was located at 100 degrees, was removed at End of Cycle 10 in 1993, the Removal being at 9.95 Effective Full Power Years, with a Fluence of 1.66 X 10(19) neutrons per square centimeter.
July 8, 1993: "Pressurized Thermal Shock Potential at Palisades: History of Embrittlement of Reactor Pressure Vessels in Pressurized Water Reactors," prepared by Michael J. Keegan (rekeyed August 3, 2005).*
March 9, 1994: NRC staff met with Consumers Power Company to discuss the licensee's program for further evaluation of the critical welds in their Palisades RPV. According to NRC, "the licensee planned to: gather additional materials properties data from its retired steam generators (welds fabricated using W5214 and 34B009 weld wire); institute an augmented surveillance program that would contain the limiting weld metal; evaluate annealing of the reactor vessel; consider instituting an 'ultra low leakage' fuel strategy. See page 9 of 129 on PDF counter of environmental intervenors' September 16, 2005 Exhibit, below.
May 1994: Peter, Lippincott, Wrights, and Madeyski, "Analysis of Capsule W-110 from the Consumers Power Company Reactor Vessel Radiation Surveillance Program," WCAP-14014.
June 21, 1994: Letter from D. Rogers (Consumers Power Company) to NRC, "Reactor Vessel Material Surveillance Capsule Test Report."
July 12, 1994: NRC staff issued an interim SER [Safety Evaluation Report] that stated: "based on previous nuclear industry data the Palisades reactor vessel was projected to reach the PTS screening criteria in 2004, prior to EOL [End of Life], 2007; staff SER noted that the PTS evaluation could change based on the information to be acquired from the SG [Steam Generator] welds." See also the related NRC staff-issued Commission Paper and NUREG Report on RPVs on October 28, 1994, as well as the December 9, 1994 NRC staff presentation to the ACRS (see immediately below). See page 11 of 129 on PDF counter in environmental intervenors' Exhibits, September 16, 2005 (see below).
October 28, 1994: NRC staff-issued Commission Paper and NUREG Report on RPVs. See July 12, 1994 entry immediately above, as well as December 9, 1994 entry below. See page 11 of 129 on PDF counter in environmental intervenors' Exhibits, September 16, 2005 (see below).
As reported by Inside NRC on December 12, 1994 (see below), "As recently as October 28th, when NRC staff issued Secy 94-267, "Status of Reactor Pressure Vessel Issues," the agency projected that Palisades would reach its PTS screening criteria in 2004. On November 18, Consumers Power submitted a revised evaluation of the PTS issue that indicated the vessel would reach the critical level in 1999."
November 1, 1994: Palisades' licensee Consumers Power Company informed the NRC "staff by telephone that the chemistry data from the W5214 welds indicated higher copper contents than previously assumed...evaluation of the steam generator weld material also indicated a higher initial RT(NDT) value than the mean generic value." See entries immediately above and below. See page 11 of 129 on PDF counter in environmental intervenors' Exhibits, September 16, 2005 (see below).
November 18, 1994: Palisades' licensee, Consumers Power Company, "submitted their assessment of the impact of these new data on the RT(PTS) value. This assessment indicates that Palisades reactor vessel would reach the PTS screening criteria in 1999." See entries immediately above and below. See page 11 of 129 on PDF counter in environmental intervenors' Exhibits, September 16, 2005 (see below).
November 21, 1994: NRC staff with the Palisades licensee, Consumers Power Company, "to discuss the new information." (see entries above and below; and page 11 of 129 on PDF counter in environmental intervenors' Exhibits, September 16, 2005 (see below))
November 30, 1994: NRC staff Request for Additional Information sent to Palisades' licensee, Consumers Power Company. (see entries above and below; and page 11 of 129 on PDF counter in environmental intervenors' Exhibits, September 16, 2005 (see below))
December 9, 1994: NRC staff presentation to ACRS, "Palisades Pressured (sic) Thermal Shock." See Pages 7 to 13 of 129 on PDF counter of environmental intervenors' September 16, 2005 Exhibits (see below). The NRC staff was still reviewing Consumers Power Company's November 18, 1994 submittal (see above). The NRC staff's evaluation was scheduled to be completed by January 31, 1995. As stated by the NRC staff, "Critical area[s] being assessed include: effect of thermal aging, heat treatment and test method on unirradiated reference temperature; best estimate chemical composition and nuclear industry data." The NRC staff went on to say, "Depending upon how the new data are used in the analysis the PTS screening limit could be reached before 1999. Staff will receive technical assistance from RES [NRC Office of Regulatory Research] contractor, ORNL [Oak Ridge National Laboratory]." The NRC staff concluded by noting these "Generic Implications of (the) New Data": (1) Review of Other RPVs with Palisades Weld Material (i.e. W5214 or 34B009 weld metal) -- other plants still satisfy PTS screening criteria and upper shelf energy criteria, and lower fluence or use of actual surveillance data; and (2) Other Plants that are Projected to be Near the PTS Screening Criteria Before End-Of-Life are being Assessed -- sensitivities being studied, and proactive measures may be appropriate.
December 12, 1994: "Palisades could reach its PTS screening limit earlier than expected," Inside NRC, reporting on a December 8, 1994 NRC Commissioners meeting. See Exhibit 1F in September 2005 exhibits, below, page 31 of 129 on PDF counter. Testimony revealed Palisades could reach its PTS screening limits by 1995, or 1999, not 2004 or even 2007, as had been reported by NRC staff as recently as late October 1994.
First Quarter of 1995: As reported by the 12/12/94 Inside NRC article immediatley above, "NRC wants to include the data [on reactor vessel weld integrity, that the vendor, ABB Combustion Engineering, wants to keep confidential] in a database called the Reactor Vessel Integrity Data Base, or RVID...RVID summarizes the properties or reactor pressure vessel materials for all plants; it is based on docketed information and is scheduled for public availability in the first quarter of 1995."
October 1995: Combustion Engineering report P-PENG-ER-006, Revision 0, "The Reactor Vessel Group Records Evaluation Program Phase II Final Report for the Palisades Reactor Pressure Vessel Plates, Forging, Welds, and Cladding," Combustion Engineering, Inc.
December 12, 1995: Letter from R. Smedley (Consumers Power Company) to NRC, "Preliminary Thermal Annealing Report, Thermal Annealing Operating Plan, Section 1.1, General Considerations, and Section 1.2, Description of the Reactor Vessel."
December 19, 1995: Code of Federal Regulations, 10 CFR 50.61, "Fracture toughness requirements for protection against pressurized thermal shock events," U.S. NRC, Washington, D.C., Federal Register, Volume 60, No. 243 (last updated on January 4, 2010).
June 21, 1996: SE-REA-96-122, "Transmittal of the Updated Palisades Reactor Vessel Fluence Submittal Response to NRC Request for Additional Information."
February 1996: Regulatory Guide 1.162, "Format and Content of Report for Thermal Annealing of Reactor Pressure Vessels."
1999: As described by Entergy on July 29, 2014 (Page 7 of 19 on PDF counter), "In 1999, the NRC undertook a project to develop a technical basis to support a risk-informed alternative to the existing PTS rule...".
2000: Surveillance capsule SA-240-1 removed from Palisades, the second most recent as of November 2014. As put by NRC staff in March 2013, this capsule "contained the limiting (that is, most embrittlement sensitive) weld from Palisades." (see #11, page 9 of 15 on PDF counter)
February 21, 2000: Consumers Energy letter to the NRC, "Palisades Reactor Vessel Neutron Fluence Reevaluation" (ADAMS Accession No. ML003686516). WCAP-15353, "Palisades Reactor Pressure Vessel Neutron Fluence Evaluation," dated January 2000, was submiitted to NRC by this letter dated February 21, 2000. The NRC approved the methodology described in WCAP-15353, by letter dated November 14, 2000 (see below).
June 23, 2000: NRC SECY-00-0140, "Reevaluation of the Pressurized Thermal Shock Rule (10 CFR 50.61) Screening Criterion."
November 14, 2000: NRC letter to Consumers Energy, approving the methodology described in WCAP-15353 (see February 21, 2000 entry above).
March 2001: Regulatory Guide 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence," describes methods for determining pressure vessel neutron fluence, per July 29, 2014 Entergy document (page 11 of 19 on PDF counter).
March 16, 2001: NRC SECY-01-0045, a periodic status report updating Secy-00-0140, "Reevaluation of the Pressurized Thermal Shock Rule (10 CFR 50.61) Screening Criterion" (see June 23, 2000, above).
May 2001: Framatome ANP report BAW-2398, "Test Results of Capsule SA-240-1 Consumers Energy Palisades Nuclear Plant."
September 2001: PWR and BWR Pressure Vessel Fluence Calculation Benchmark Problems and Solutions (NUREG/CR-6115). ("Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence")
October 5, 2001: NRC SECY-01-0185, another periodic status report updating SECY-00-0140, "Reevaluation of the Pressurized Thermal Shock Rule (10 CFR 50.61) Screening Criterion" (see June 23, 2000, above), and SECY-01-0045 (see March 16, 2001, above).
March 2002: Westinghouse report, WCAP-15805, Revision 0, "Analysis of Capsule X from the Carolina Power & Light Company H.B. Robinson Unit 2 Reactor Vessel Radiation Surveillance Program."
May 30, 2002: NRC SECY-02-0092, Status Report: Risk Metrics and Criteria for Pressurized Thermal Shock. This is "the third report of the [NRC] staff's progress in reevaluating the [50.61] rule's technical basis." (see also, above: June 23, 2000; March 16, 2001; and October 5, 2001.) Tellingly, NRC admits (on page 5 of 7) that an array of PTS RPV failure scenarios "have not yet been studied in detail. Consequently, the margins between TWCF [Through-Wall Cracking Frequency] and PTS-induced CDF [Core Damage Frequency] and PTS-induced LERF [Large Early Release Frequency], remain uncertain." (emphasis added) The NRC staff had scheduled discussion with ACRS on this in July 2002, and anticipated initiating a potential rulemaking via NRR by December 2002.
January 2003: Westinghouse report, WCAP-15958, Revision 0, "Analysis of Capsule V from Pacific Gas and Electric Company Diablo Canyon Unit 1 Reactor Vessel Radiation Surveillance Program."
March 28, 2003: Surveillance capsule W-100 removed from Palisades, the most recent surveillance capsule pull and test, as of November 2014. (See NRC staff, March 2013, #11, page 9 of 15 on PDF counter).
Also see NRC Commissioner Magwood letter to Kraig Schultz of MSEF on May 28, 2013 (see below), which describes Palisades surveillance capsule pull, irradiated capsule ID# W-100, see "Analysis of Capsule W-100 from the Consumers Power Company Palisades Reactor Vessel Radiation Surveillance Program," ADAMS # for report ML040910069 (see March 25, 2004, below).
February 2004: "Analysis of Capsule W-100 from the Nuclear Management Company Palisades Reactor Pressure Vessel Material Surveillance Program," Reactor Pressure Vessel Surveillance Capsule W-100 Test Report, BWXT Services, Inc. (See Attachment 1, Pages 6 to 296 of 312 on PDF counter in March 25, 2004 document below.)
February 11, 2004: "Fluence Analysis for Reactor Vessel Surveillance Capsule W100," Reactor Pressure Vessel Surveillance Capsule W-100 Test Report," Westinghouse (See Attachment 2, Pages 297 to 312 of 312 on PDF counter in March 25, 2004 document immediately below.)
March 25, 2004: NMC to NRC, "Reactor Pressure Vessel Surveillance Capsule W-100 Test Report."
July 7, 2004: Palisades, License Amendment Re Measurement Uncertainty Recapture Power Uprate.
July 2004: Westinghouse report, WCAP-16251-NP, Revision 0, "Analysis of Capsule X from Entergy's Indian Point Unit 3 Reactor Vessel Radiation Surveillance Program."
October 26, 2004 (Date Submitted; Revised December 14, 2004): Generalization of Plant-Specific Pressurized Thermal Shock (PTS) Risk Results to Additional Plants, Table 1. Plants with highest RTNDT, U.S. NRC.*
November 24, 2004: Internal NRC staff email written by Stephanie Coffin to Stephen Hoffman and cc'd to several others, re: a November 22, 2004 phone call with Consumers Power Co./Nuclear Management Co. officials re: Palisades RPV PTS risks. Coffin conveys that if NRC does not publish the new PTS rule "in time for them" -- Palisades "currently exceed[s] the screening criteria in 2014 -- "they will submit the Master Curve exemption in 2007." Instead of doing that now, Palisades will instead "be managing it in accordance with the May 27, 2004 guidance from Reyes to the Commissioners," and "They are following Point Beach and Beaver Valley closely." Coffin advised Palisades on the flux reduction requirements of NRC's current rule, and suggested Palisades review Point Beach's submittal, and NRC's associated SER [Safety Evaluation Report]. (In late 2012, Coffin would write to environmental watchdogs at Palisades that NRC Chairman Macfarlane was too busy to meet with them. This, soon after Macfarlane enthusiastically told the watchdogs that she wanted to meet with them about Palisades, and just to write her office to arrange a mutually agreeable date.)
December 1, 2004: ACRS (Joint Subcommittees: Materials and Metallurgy, Thermal Hydraulic Phenomena, Reliability and PRA), dialogue between ACRS Member, Dr. Wallis, and NRC RES staffperson Mark Erickson-Kirk, reveals that "This flaw distribution is based on rather skimpy evidence...". Yet another supposed basis for confidence in NRC PTS risk safety regulations is found to be seriously wanting. See pages 28 to 30 of 129 on PDF counter, in September 16, 2005 Exhibits (see below).
March 22, 2005: Palisades Nuclear Plant, Application for Renewed Operating License, (ADAMS Accession No. ML050940429).
April 5, 2005: Letter Transmitting Palisades Nuclear Plant Application for Renewed Operating License.
2005-2007: NRC rubberstamped Palisades' 20 year license extension in 2007, despite two years of widespread, determined grassroots resistance by a coalition of environmental groups and concerned local residents. Palisades' embrittled RPV, vulnerable to PTS, was a major concern raised during the intervention against the license extension. During the course of the intervention proceeding, environmental intervenors were assured by NRC that Palisades would have to have a plan for dealing with RPV embrittlement/PTS risks by 2011, or else the reactor would have to be permanently shutdown by 2014 (see Alice Hirt's letter to NRC Commissioner Magwood, March 25, 2013, below).
August 8, 2005: REQUEST FOR HEARING AND PETITION TO INTERVENE, submitted to the U.S. NRC ASLB, by attorney Terry Lodge, on behalf of Don't Waste Michigan and NIRS, in opposition to Palisades' 20-year license extension (the first contention, on page 4, regards The license renewal application is untimely and incomplete for failure to address the continuing crisis of embrittlement).*
September 16, 2005: PETITIONERS’ COMBINED REPLY TO NRC STAFF AND NUCLEAR MANAGEMENT COMPANY ANSWERS, submitted to the U.S. NRC ASLB, by attorney Terry Lodge, on behalf of Don't Waste Michigan and NIRS, in opposition to Palisades' 20-year license extension (pages 2 to 23 are regarding Contention 1, The license renewal application is untimely and incomplete for failure to address the continuing crisis of embrittlement).*
See also Petitioners' Appendix of Evidence (129 pages), which accompanied its September 16, 2005 Reply.
November 30, 2005: NRC Requests for Additional Information Related to License Renewal for the Palisades Nuclear Plant, RAI B2.1.16-2.
January 13, 2006: "NMC Response to NRC Requests for Additional Information Dated November 30, 2005 Related to License Renewal for the Palisades Nuclear Plant," RAI B2.1.16-2.
March 7, 2006: ASLBP, "Memorandum and Order, Ruling on Standing, Contentions, and Other Pending Matters," dismissing environmental coalition intervention against Palisades' 20-year license application. RPV embrittlement/PTS risk contention addressed from Pages 31 to 41 of 90 on PDF counter.
March 17, 2006: PETITIONERS’ NOTICE OF APPEAL FROM ASLB DENIAL OF HEARING, AND SUPPORTING BRIEF, submitted to the U.S. NRC ASLB, by attorney Terry Lodge, on behalf of Don't Waste Michigan and NIRS, in opposition to Palisades' 20-year license extension (Appeal of dismissal of Contention No. 1, The license renewal application is untimely and incomplete for failure to address the continuing crisis of embrittlement, pages 3 to 9).*
March 20, 2006: Environmental coalition letters, to U.S. Senators Carl Levin (D-MI) and Debbie Stabenow (D-MI), requesting they initiate a Government Accountability Office (GAO) investigation into embrittlement risks at Palisades in particular, but also into NRC weakening of PTS safety standards nationwide.*
Spring 2006: Consumers Energy power point presentation to the Michigan Public Service Commission, highlighting "Reactor vessel embrittlement concerns" at Palisades.*
May 18, 2006: "Halting 20 Extended Years of Risky Reactor Operations and Radioactive Waste Generation and Storage on Lake Michigan at Palisades Nuclear Power Plant: Comments on NUREG-1437, Supplement 27 to the Generic Environmental Impact Statement for License Renewal of the Palisades Nuclear Power Plant," submitted by an environmental coalition to NRC (see section XI., Plant Aging Increases Accident Risk, pages 26-27). See List of organizations opposing 20-year license extension at Palisades nuclear power plant.*
September 19, 2006: Revision to Reactor Vessel Surveillance Coupon Removal Schedule, Nuclear Management Company, LLC, to US NRC.
March 1, 2007: Recommended Screening Limits for Pressurized Thermal Shock (PTS), NUREG-1874.
March 2007: Branch Technical Position 5-3, "Fracture Toughness Requirements," Revision 2, contained in Chapter 5 of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LRW Edition."
August 2007: Technical Basis for Revision of the PTS Screening Limit in the Pressurized Thermal Shock (PTS) Rule (10 CFR 50.61): Summary Report (NUREG-1806, Volumes 1 and 2), Date Published August 2007, Manuscript Completed May 2006.
October 3, 2007: Federal Register Notice, 72 FR 56275, Alternative Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events.
June 2008: WCAP-16168-NP, Revision 2, Risk-Informed Extension of the Reactor Vessel In-Service Inspection Interval.
February 11, 2009: NRC letter, "Palisades Plant -- Issuance of Amendment RE: Change to In-Service Inspection Interval (TAC No. MD9266), ADAMS Accession Number ML090220442.
March 13, 2009: Draft Final Rule 10 CFR 50.61a, "Alternate Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events, NRC ACRS.
January 4, 2010: 10 CFR 50.61a published in Federal Register. Code of Federal Regulations, 10 CFR Part 50.61a, "Alternate fracture toughness requirements for protection against pressurized thermal shock events," U.S. Nuclear Regulatory Commission, Washington, D.C., Federal Register, Volume 75, No. 1. (See also No. 22, with corrections to part (g) dated February 3, 2010, March 8, 2010, and November 26, 2010.
As revealed on January 14, 2014 in an NRC RES staff briefing to an ACRS subcommittee (see page 230 of 292 on PDF counter), "Ongoing revision of current regulations and standards related to RPV integrity" -- specifically regarding 10 CFR 50.61a -- were "completed in 2010." At page 160 of 292 of the same document, NRC RES describes its 2010 activities vis a vis 10 CFR 50.61 (PTS) to "Improve quality & uniformity of submittals by providing Inspection and surveillance guidance." Current Activities by NRC staff listed include "DG-1299 developed, in NRR review." ORNL [Oak Ridge National Lab] is also listed as involved, with the note "All ORNL support is provided by project N6438." (see REAP -- Reactor Embrittlement Archive Project -- under 2012, below).
February 3, 2010: The effective date for the alternate PTS rule, which was included in the Federal Register in January 2010 (see immediately above). As described by Entergy on July 29, 2014, the alternative PTS rule "provides fracture toughness requirements for protection against PTS events for PWR pressure vessels that are less burdensome than the requirements of the PTS rule." (emphasis added)
March 2010: U.S. Nuclear Regulatory Commission, NUREG-1874, "Recommended Screening Limits for Pressurized Thermal Shock (PTS)."
April 20, 2010: Structural Integrity Associates, Inc., Report No. 0901132.401, Revision 0, "Evaluation of Surveillance Data for Weld Heat No. W5214 for Application to Palisades PTS Analysis."
November 12, 2010: Structural Integrity Associates, Inc., Report No. 1000915.401, Revision 1, "Revised Pressurized Thermal Shock Evaluation for the Palisades Reactor Pressure Vessel."
December 20, 2010: Entergy Nuclear Operations, Inc. letter, "Updated Palisades Reactor Vessel Pressurized Thermal Shock Evaluation" (ADAMS Accession No. ML110060692). Before this point, the Palisades RPV was calculated to surpass the PTS screening criterion limit by 2014. After this reevaluation, the Palisades RPV was deemed good to go, vis a vis PTS, till April 2017.
January 14, 2011: Updated Palisades Reactor Vessel Pressurized Thermal Shock Evaluation.
February 2011: Westinghouse report, WCAP-17341-NP, Revision 0, "Palisades Nuclear Power Plant Heatup and Cooldown Limit Curves for Normal Operation and Upper-Shelf Energy Evaluation."
March 7, 2011: Palisades Nuclear Plant, License Amendment Request for Primary Coolant System Pressure - Temperature Limits.
March 22, 2011: Palisades Nuclear Plant - License Amendment Request for Primary Coolant System Pressure-Temperature Limits.
June 2011: Jeff Donn of the Associated Press publishes a four-part exposé on nuclear power safety risks, entitled "Aging Nukes." In his first article, "US nuke regulators weaken safety rules," Donn pointed to rollbacks on PTS safety standards as the top example of this.*
July 12, 2011: NRC announces its upcoming July 26, 2011 meeting on 50.61a (see immediately below).
July 26, 2011: The U.S. Nuclear Regulatory Commission (NRC) held a meeting with the nuclear power industry regarding "technical discussions related to the evaluation of irradiation effects on RPV [Reactor Pressure Vessel] ferritic materials for operating plants, with particular focus on 10 CFR [Title 10, Code of Federal Regulations, Part] 50.61a and the NRC’s Embrittlement Database."
September 25, 2011: Yellow Finding Accident that came very close to testing Palisades' RPV embrittlement/PTS risks. The accident resulted in Palisades' safety status being lowered two columns by NRC, to "degraded cornerstone," requiring significantly enhanced oversight. Beyond Nuclear posted this on its website regarding the accident. The Detroit Free Press ran a major front page exposé about the accident. An NRC Special Inspection Team wrote a 101-page inspection report about the accident.*
November 29, 2011: Palisades Nuclear Plant - NRC Special Inspection Team (SIT) Report 05000255/2011014 Preliminary Yellow Finding (see September 25, 2011 accident, above).
December 7, 2011: NRC letter, "Updated Reactor Pressure Vessel Pressurized Thermal Shock Evaluation for Palisades Nuclear Plant (TAC No. ME5263)," ADAMS Accession No. ML112870050. According to NRC Commissioner Magwood's May 28, 2013 letter (see below), this licensee re-evaluation, reviewed and approved by NRC staff, "showed that the PTS screening criteria will not be exceeded till April 2017." Previously, the PTS screening criteria was predicted to have been exceeded by 2014.
December 11, 2011: EPRI Final Report, "Materials...PWR Coordinated RVSP [Reactor Vessel Material Surveillance Program]." See Palisades on Pages 38 to 39 of 94 on PDF counter, including Table 6-40, Palisades Current [Surveillance Capsule] Withdrawal Schedule," giving Capsule ID#, Location, Removed at End of Cycle X (Year), Removal (at Effective Full Power Year), and Fluence (in neutrons per square centimeter).
2012: Reactor Embrittlement Archive Project (REAP), database of RPV embrittlement data, posted online by Oak Ridge -- partially to entirely funded by NRC RES. (See page 161 of 292 on PDF counter in January 14, 2014 NRC RES briefing to ACRS subcommittee.)
Late February, 2012: Under direct questioning by Beyond Nuclear's Kevin Kamps (who took part in the meeting by phone), NRC Office of Regulatory Research's staffer Jennifer Uhle acknowledged that Palisades has the single worst embrittled RPV in the U.S. This took place at an NRC public meeting held at the Beach Haven Event Center in South Haven, MI.*
March 9, 2012: Letter regarding PTS risks at Palisades, sent to U.S. Senators Carl Levin and Debbie Stabenow (Democrats from Michigan), signed by numerous Don't Waste MI chapters across the state, as well as their attorney, Terry Lodge of Toledo, OH.
May 25, 2012: 25 concerned local residents and environmental group representatives met with NRC Chairman Greg Jaczko in South Haven, MI, near Palisades; RPV embrittlement and PTS risk was a top issue discussed. See Beyond Nuclear's webpost about this meeting.*
May-June, 2012: Nuke Info Tokyo (the newsletter of Citizens' Nuclear Information Center), No. 148, May/June 2012, including the Part I of the article "Aging Nuclear Power Plants focusing in particular on irradiation embrittlement of pressure vessels," by Hiromitsu Ino (pages 10 to 12, and continued in newsletter No. 149, below; the article in No. 148 also includes Figure: Genkai-1 Monitoring Test Sample Data and JEAC and 4201-2004 Prediction Curve).*
July-August, 2012: Nuke Info Tokyo, the newsletter of Citizens' Nuclear Information Center, No. 149, July/August 2012, including Part II of the article "Aging Nuclear Power Plants focusing in particular on irradiation embrittlement of pressure vessels," by Hiromitsu Ino (continued from the article in newsletter No. 148, above; pages 10 to 14, and concluded on page 5). Additional Tables and Figures were included in Hiromitsu Ino's articles.* (A July 2011 article by Ino, also translated by Phillip White, was submitted to NRC in Beyond Nuclear's October 30, 2014 comments.*)
February 2013: Westinghouse, WCAP-17651-NP, "Palisades Nuclear Power Plant Reactor Vessel Equivalent Margins Analysis."
February 2013: As revealed in January 14, 2014 NRC RES staff briefing to ACRS subcommittee, below (see Page 230 of 292 on PDF counter), NRC RES began working on the "emergent need" at Palisades re: RPV embrittlement.
March 19, 2013: Kevin Kamps of Beyond Nuclear's questions to NRC re: the agency Webinar on RPV embrittlement/PTS risks at Palisades.* On April 18, 2013, NRC released a summary of the Palisades embrittlement webinar it had held on March 19th.
March 25, 2013: Around two dozen concerned local residents and environmental group representatives met with NRC Commissioner William Magwood IV in South Haven, MI, near Palisades; RPV embrittlement and PTS risk was a top subject discussed. Letters containing questions and concerns from meeting attendees to Commissioner Magwood, and his responses, are posted under NRC ADAMS Accession No. ML13142A424. See Beyond Nuclear's webpost about this meeting.*
May 28, 2013: "Response to Concerns Raised in Letter Sent to the NRC by Ms. Alice Hirt," by NRC Commissioner William Magwood IV, to Alice Hirt, including: "Concerns regarding the embrittlement of the Palisades' reactor vessel and the extension of their operating license"; "Concerns with the predictability of assessing this irradiation embrittlement"; and a plot charting Embrittlement RT-PTS in degrees Fahrenheit versus Dates (Years of Reactor Operation). In addition to Magwood's correspondence with Alice Hirt, many of the other concerned local residents and environmental group representatives likewise raised RPV embrittlement/PTS risk concerns with Magwood (see associated links to documents on NRC website).
Commissioner Magwood's written follow up to MSEF's Kraig Schultz included (on pages 2-3) a table, Summary of surveillance capsules in the Palisades nuclear power plant.
June 25, 2013: Updated Palisades Nuclear Plant Reactor Vessel Fluence Evaluation, Entergy to NRC. (PNP 2013-046)
October 21, 2013: Palisades Nuclear Plant 10 CFR 50 Appendix G Equivalent Margins Analysis.
December 18, 2013: Entergy Nuclear sent its "UPDATED REACTOR VESSEL FLUENCE EVALUATION SUPPORTING A REVISED PRESSURIZED THERMAL SHOCK SCREENING CRITERIA LIMIT (TAC NO. MF2326)" to NRC, asserting its Palisades atomic reactor in Covert, Michigan on the Lake Michigan shoreline (see photo, left) is safe to operate till August 2017, despite having the worst embrittled RPV in the U.S.
January 14, 2014: ACRS subcommittee is briefed by NRC RES staff on such issues as RPV embrittlement (see pages 26 to 31, or 34 to 39 of 292 on PDF counter). At page 30 (or 38 on PDF counter), NRC RES compares "operating experience" or "emergent" issue at Palisades with the one at Doel in Europe. (Minutes/transcript published on March 12, 2014.)
January 19 (to March 16), 2014: 23rd refueling and maintenance outage, or Cycle 23, at Palisades.
January 22, 2014: Results of Periodic Review of Regulatory Guide (RG) 1.99.
February 2014: WesDyne ISI Report, "Entergy Palisades Unit 1 Nuclear Power Plant 10 Year Reactor Vessel Inserve Inspection.
June 2014: As described by Entergy on July 29, 2014 (on Page 7 of 19 on PDF counter), "The PNP alternate PTS rule evaluation is documented in the enclosed Westinghouse report WCAP-17628-NP, Revison 1, "Alternate Pressurized Thermal Shock (PTS) Rule Evaluation for Palisades," ML14211A525.
June 5, 2014: Meeting in Benton Harbor, MI, between more than a dozen concerned local residents and environmental group representatives, with Chairman Macfarlane; Palisades RPV embrittlement and PTS risk was a top subject discussed. See Barbara Pellegrini's letter to NRC Chairman Allison Macfarlane. As in late February 2012, NRC's acknowledgement that Palisades has the single worst embrittled RPV in the US also came out in this meeting. It happened under direct questioning by Michael Keegan of Don't Waste MI, and others. An NRC resident inspector at Palisades made the admission. See Beyond Nuclear's webpost about this meeting.*
July 24, 2014: Transcript, ACRS meeting at NRC Region III HQ in Lisle, IL (see Palisades PTS section).
July 29, 2014: Entergy Nuclear sent the U.S. Nuclear Regulatory Commission (NRC) a document entitled "License Amendment Request to Implement 10 CFR 50.61 a, 'Alternate Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events'" regarding its problem-plagued, age-degraded Palisades RPV. This license amendment would effectively enable Palisades to continue operating past August 2017, despite its violation of NRC embrittlement safety standards. This document is also labeled PNP 2014-049. Also see June 2014 entry, above, for "The PNP alternate PTS rule evaluation...documented in the enclosed Westinghouse report WCAP-17628-NP, Revison 1, "Alternate Pressurized Thermal Shock (PTS) Rule Evaluation for Palisades," ML14211A525.
Entergy Palisades posted this confident statement on its website, downplaying the risks of PTS, vis a vis 2014 so-called "inspections" and "analysis" of its worst embrittled RPV in the US.
August 2014: Appendix G briefing by NRC RES staff to ACRS.
August 29, 2014: In an email dated August 29, 2014, NRC confirmed that its "Acceptance Review" had determined that Entergy's application was sufficient for NRC to continue with a more in-depth technical review of the matter.
August 29, 2014: Also on this date, NRC published a copy of Entergy's July 29th application for Palisades, License Amendment Request to Implement 10 CFR 50.61a, "Alternate Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events," ML14211A520.
August 30, 2014: Letter from NRC Chairman Allison Macfarlane to Kevin Kamps of Beyond Nuclear, as follow up to June 5, 2014 meeting in Benton Harbor, MI, including regarding "reactor vessel embrittlement."
Summer 2014: As described on Page 230 of 292 on PDF counter in January 14, 2014 NRC RES staff briefing to ACRS subcommittee (see above), "DG-1299 to be released for public comment Summer 2014." Draft Reg Guide 1299 is alternate fracture toughness requirements for protection against PTS in PWRs.
September 30, 2014: Federal Register Volume 79, Number 189 (Tuesday, September 30, 2014), Notices, Pages 58812-58831, From the Federal Register Online via the Government Printing Office [www.gpo.gov], FR Doc No: 2014-23015, NRC publishes Entergy Palisades' application for 50.61a, setting the following deadline "DATES: Comments must be filed by October 30, 2014. A request for a hearing must be filed by December 1, 2014."
October 30, 2014: Beyond Nuclear submitted comments by NRC's arbitrarily short October 30th deadline regarding yet another request by Palisades for a weakening of RPV embrittlement/PTS safety regulations, in the form of a change of methodology to assess the problem. Such pencil whipping has occurred many times over the decades at Palisades, in order to enable ongoing operations, despite the RPV's seriously degraded condition.
October 30, 2014: Michael Keegan of Don't Waste Michigan in Monroe, MI also submitted comments on behalf of the statewide nuclear power watchdog coalition, by NRC's October 30th deadline.
November 6, 2014: NRC RES staff (Stevens and Kirk) brief ACRS on Draft Regulatory Guide 1299 (DG-1299), Regulatory Guidance on the Draft Pressurized Thermal Shock Rule, as well as NUREG-2163, the technical basis for DG-1299. See transcript, pages 1 to 60 of 268 on PDF counter.
November 12, 2014: Entergy Palisades to NRC, License Amendment Request for Approval of Palisades Nuclear Plant 10 CFR 50 Appendix G Equivalent Margins Analysis.
November 20, 2014: License Amendment Request for Approval of Palisades Nuclear Plant 10 CFR 50 Appendix G Equivalent Margins Analysis.
February 2015 (tentative): NRC to publish 50.61a draft final rule in Federal Register, beginning a 60-day public comment period. After that, NRC will take 60 days to review comments, then circulate Final Rule.
Summer 2015 (tentative): Publication of Final 50.61a Rule.
July 29, 2015: Per Entergy's July 29, 2014 letter (see Page 3 of 19 on PDF counter), it has requested that "To allow for normal NRC processing, ENO requests approval of the proposed license amendment by July 29, 2015. Also, an implementation period of 120 days following the effective date of the amendment is requested."
2019 (Planned): NRC Commissioner Magwood's letter to Kraig Schultz of MSEF on May 28, 2013 (see above), listed a planned Palisades surveillance capsule pull: installed, irradiated capsule ID# W-80. No title(s) for NRC documentation, nor ADAMS # for report(s), was provided by Commissioner Magwood.
Per Table 6-40 on Page 6-39 of EPRI's December 11, 2011 report above, Capsule W-80 is located at 80 degrees, will be removed at End of Cycle 27 in 2019, and will have a Fluence of 3.06 X 10(19) neutrons per square centimeter.
*This document was submitted to NRC as supporting documentation for official public comments by Beyond Nuclear on October 30, 2014. See immediately above.
August 8, 2013
