Environmental coalition filings on Davis-Besse Shield Building cracking issue
October 16, 2014 The environmental coalition challenging FirstEnergy Nuclear Operating Company's (FENOC) proposed 20-year license extension at the problem-plagued Davis-Besse atomic reactor, near Toledo on the Lake Erie shore, has been challenging Shield Building cracking since January 10, 2012. Below are the coalition's filings thus far, in chronological order, as well as associated coalition press release, FirstEnergy Nuclear Operating Company (FENOC) filings, U.S. Nuclear Regulatory Commission (NRC) staff filings, NRC Atomic Safety and Licensing Board Panel's (ASLBP) orders, etc.:
2011
June 15, 2011: ASLBP's Initial Scheduling Order (“ISO”).
October 10, 2011: "Laminar crack discovered in the shield building access opening during 17M (documented under CR 2011-03346)" (as put by Performance Improvement International in its 9/11/13 Full Apparent Cause Evaluation on ice-wedging crack propagation, not released by FENOC until ten months later, on 7/8/14. See PII FACE, p.26 of 98 on PDF counter. 17M refers to the 17th mid-cycle outage.)
October 31, 2011: Letter from R. Seeholzer, FirstEnergy, to the Investment Community (provided as Attachment 1 to FENOC’s Original Contention 5 Answer).
December 2, 2011: NRC Confirmatory Action Letter (CAL), permitting FENOC to rush the restart of the Davis-Besse reactor, despite the recently discovered cracking of unknown origin, extent, and safety significance (NRC ADAMS ML# ML11336A355).
2012
January 5, 2012: FENOC Presentation Slides, NRC Public Meeting (provided as Attachment 2 to FENOC’s Original Contention 5 Answer).
January 10, 2012: Environmental Intervenors' original cracking contention. (Motion for Admission of Contention No. 5 on Shield Building Cracking, 61 pages.)
January 31, 2012: NRC Integrated Inspection Report. 93 pages.
February 6, 2012: FENOC's Answer Opposing Intervenors' Motion for Admission of Contention No. 5 on Shield Building Cracking. 137 pages.
February 13, 2012: Intervenors' Combined Reply in Support of Motion for Admission of Contention No. 5. 110 pages. (Associated February 14, 2012 coalition press release)
February 27, 2012: Filing (Intervenors' first Motion to Amend 'Motion for Admission of Contention No. 5') based on U.S. Rep. Kucinich's (D-OH) revelation that the shield building's outer rebar layer was no longer structurally functional, due to the cracking. First contention supplement/amendment. (Associated coalition media release.)
February 27, 2012: Letter from B. Allen, Vice President-Nuclear, FENOC, to C. Pederson, Acting Administrator, NRC, Submittal of Shield Building Root Cause Evaluation (submitted as an enclosure to Letter from T. Matthews, FENOC Counsel, to Board, Notification of Filing Related to Proposed Shield Building Cracking
Contention (Feb. 29, 2012).
April 5, 2012: Letter from D. Imlay, FENOC, to NRC, Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application (TAC No. ME4640) and License Renewal Application Amendment No. 25, Attachment L-12-028 (provided as an enclosure to the Board Notification for April 2012 RAI Response); Letter from T. Matthews, FENOC Counsel, to the Board, Notification of Filing Related to Proposed Shield Building Cracking Contention
May 7, 2012: Davis-Besse Nuclear Power Station Reactor Vessel Head Replacement and Shield Building Cracking Inspection Report 05000346/2012007 (DRS) (provided as an enclosure to Letter from B. Harris, Staff Counsel, to Board (May 10, 2012)).
May 17, 2012: Revised Root Cause Evaluation (dated May 8, but not submitted till May 17, as an enclosure to Letter from T. Matthews, FENOC Counsel, to Board, Notification of Filing Related to Proposed Shield Building Cracking Contention), 131 pages. (In its September 11, 2013 Full Apparent Cause Evaluation (see below) -- not released by FENOC until July 8, 2014 -- PII refers to this document as RCA-1, Performance Improvement International Laminar Cracking Root Cause (Davis-Besse Condition Report 2011-03346)).
May 24, 2012: FENOC Davis-Besse nuclear power station, Unit 1, Submittal of Contractor Root Cause Assessment Report, Revised Root Cause Assessment Report, or RRCAR, from B.S. Allen, FirstEnergy Nuclear Operating Company, to Cynthia D. Pedersen, NRC, NRC/RGN-III/ORA, L-12-196, NRC ADAMS Accession No. ML12138A037, 257 pages. (Per immediately above, in its September 11, 2013 Full Apparent Cause Evaluation (see below) -- not released by FENOC until July 8, 2014 -- PII refers to this document as RCA-1, Performance Improvement International Laminar Cracking Root Cause (Davis-Besse Condition Report 2011-03346)).
June 4, 2012: Filing, (Intervenors' second Motion to Amend and Supplement Proposed Contention No. 5 (Shield Building Cracking)) in response to FENOC's woefully inadequate Aging Management Plan (AMP) for the shield building's cracks. Second contention supplement/amendment.
June 21, 2012: NRC Inspection to Evaluate the Root Cause Evaluation and Corrective Actions for Cracking in the Reinforced Concrete Shield Building of the Containment System 05000346/2012009(DRS). See page 3 of Attachment 2 (Page 35 of 46 on PDF counter) for a photo showing how severe the subsurface laminar cracking discovered on Oct. 10, 2011 actually was.
June 29, 2012: FENOC’s Answer Opposing Intervenors’ Motion to Amend and Supplement Proposed Contention No. 5 (Shield Building Cracking).
July 16, 2012: Filing (Intervenors' Third Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking)), in response to FENOC's revised root cause analysis report, which revealed that shield building cracking was first observed not in October 2011, but rather August 1976. Third contention supplement/amendment.
July 23, 2012: Filing (Intervenors' Fourth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking)), based on revelations in FENOC contractor Performance Improvement International's revised root cause assessment report, which revealed 27 areas of skeptical NRC questioning about FENOC's "Blizzard of 1978" theory of shield building cracking (the environmental Intervenors also posted documents supportive of this fourth contention supplement/amendment). NRC ADAMS Accession No. ML12205A507, 56 pages.
August 16, 2012: Contention supplement (Intervenors' Fifth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking)), on the severe shield building cracking, which cites U.S. Nuclear Regulatory Commission (NRC) documents revealed through a Freedom of Information Act (FOIA) request submitted by Beyond Nuclear. The coalition issued a media release about this contention supplementation.
2013
The environmental coalition (Beyond Nuclear, Citizens Environment Alliance of Southwestern Ontario, Don't Waste Michigan, and Sierra Club Ohio Chapter) intervention against Davis-Besse's steam generator replacement project included concerns about damage to the Shield Building. Arnie Gundersen, Chief Engineer of Fairewinds Associates, Inc., served as the coalition's expert witness. (Multiple filings)
See also:
September 3, 2013: NRC Safety Evaluation Report [SER] Related to the License Renewal of Davis-Besse Nuclear Power Station, available at ADAMS Accession No. ML13248A267. 895 pages. See particularly Section 3.0.3.3.9. NRC states in its April 15, 2014 RAI (see below): "Following review of the Shield Building Monitoring Program, responses to several rounds of follow-up Requests for Additional Information (RAIs), and an updated Shield Building Monitoring Program, the NRC staff found the Updated Shield Building Monitoring Program to be acceptable, as documented in Section 3.0.3.3.9. [of this SER]."
September 11, 2013: RCA-2, Performance Improvement International Laminar Crack Propagation Root Cause (Davis-Besse Condition Report 2013-14097). See Enclosure 2, beginning at page 17 of 98, of FENOC's July 8, 2014 (see below) letter to the ASLBP. Note that FENOC withheld this PII report for 10 months, despite its significance.
September 20, 2013: Preliminary Notification -- [NRC] Region III, Preliminary Notification of Event or Unusual Occurrence, PNO-III-13-007, Davis-Besse Shield Building Laminar Cracks, NRC ADAMS ML# ML13263A410, 2 pages.
November 1, 2013: Davis-Besse Nuclear Power Station NRC Integrated Inspection Report 05000346/20130004, available at ADAMS Accession No. ML13308A283. (Excerpts from the November 2013 NRC Inspection Report were provided as Attachment 2 to FENOC’s Answer to Contention 6.)
ASLB filing:
Exhibits: #1, NRC Preliminary Notice of Event or Occurrence (Feb. 19, 2014); #2, Toledo Blade article, “Davis-Besse Had Air Gap in Shield Building,” (Feb. 15, 2014); #3, Declaration of Victoria Clemons (April 14, 2014); #4, Minutes of Internal Meeting of Davis-Besse Oversight Panel (Oct. 18, 2001); #5, Minutes of Internal Meeting of Davis-Besse Oversight Panel (Oct. 29, 2002); #6, NRC Preliminary Notice of Event or Occurrence (Sept. 20, 2013); #7, NRC Request for Additional Information (April 15, 2014); #8, Expert Witness Report of Arnold Gundersen, 50-246-LA (2013).
DEIS comments:
1. Amory Lovins' "Nuclear power’s competitive landscape and climate opportunity cost," March 28, 2014 (TMI+35), Dartmouth College, NH
Amory Lovins on uncompetitiveness of old atomic reactors. At page 5 Lovin’s writes: "Reactors are promoted as costly to build but cheap to run. Yet as Daniel Allegretti ably described, many existing, long-paid-for U.S. reactors are now starting to be shut down because just their operating cost can no longer compete with wholesale power prices, typically depressed by gas-fired plants or windpower."
2. PJM Interconnect: 30% grid integration of renewables not a problem.
In fact, it was well known to PJM (Pennsylvania/Jersey/Maryland) Interconnect, covering 13 states and this nation's largest single electric grid, as published in this 2010 2010 ISO/RTO Metrics Report, posted at the website of the U.S. Federal Energy Regulatory Commission, that wind power and solar PV are available in abundance and that there is no disruption or destabilizing of "baseload grid" associated with their integration. Replacement power was available in 2010, and is available now, and certainly in 2017.
On Dec. 27, 2010, the environmental coalition -- with University of Toledo professor emeritus Al Compaan as its expert witness -- contended that wind and solar PV, combined with compressed air energy storage, could easily replace Davis-Besse's 908 megawatts of electricity during the 2017-2037 period. In 2011, the ASLB agreed to hear the contention. But on March 27, 2012, the five-member NRC Commission, responding to an appeal by FENOC, unanimously overruled the ASLB, rejecting the renewables-as-alternative-to-license-extension hearing. Interveners reassert their contention and call for the NRC Commissioners' order to be reversed, because they are simply wrong. The coalition reserves the right to appeal the rejection of its renewables contention to federal court, once the ASLB proceeding has concluded.
3. Beyond Nuclear's Radioactive Waste Watchdog, Kevin Kamps, also submitted five comments to NRC: #1, Jan. 10, 2012 SB cracking contention's relevance to DEIS; #2, four 2012 cracking contention supplements' (Feb. 27; June 4; July 16; July 23) relevance to DEIS; #3, fifth cracking contention supplement's (Aug. 16, 2012) relevance to DEIS; #4, Dec., 2010 backgrounder, "Davis-Besse Atomic Reactor: 20 MORE Years of Radioactive Russian Roulette on the Great Lakes Shore?!"; #5, Aug. 2012 SB summary report, "What Humpty Dumpty Doesn't Want You to Know: Davis-Besse's Cracked Concrete Containment Snow Job".
4. Joe DeMare's comments. Joe is a local resident near Davis-Besse. He is also an official intervener, as part of the environmental coalition, against the license extension. Joe is affiliated with the Ohio Green Party.
May 16, 2014: FENOC’s Answer Opposing Intervenors’ Motion for Admission of Contention No. 6.
July 3, 2014: FENOC filing "L-14-224," including: cover letter; Attachment L-14-224, "Reply to Requests for Additional Information for the Review of [LRA] Section B.2.42"; and Enclosure, Amendment No. 51 to the D-B LRA. NRC ADAMS ML# ML14184B184, 14 pages.
July 8, 2014: FENOC filing, "Notification of Documents Related to Davis-Besse Shield Building," including: Enclosure 1 (identical to July 3, 2014 post immediately above); and Enclosure 2, "Full Apparent Cause Evaluation, Shield Building Laminar Crack Propagation." NRC ADAMS Accession No. ML14189A452, 98 pages.
July 25, 2014: ASLB Memorandum and Order (Denying Intervenors' Motion for Admission of Contention No. 6 on Shield Building Concrete Void, Cracking and Broken Rebar Problems). 19 pages.