Coalition challenges Davis-Besse AMPs re: propagating cracks in severely degraded Shield Building
September 3, 2014 
An NRC inspector examines severe cracking in the Davis-Besse Shield Building shortly after they were first revealed on Oct. 11, 2011. NRC file photo.Terry Lodge, Toledo-based attorney for an environmental coalition resisting FirstEnergy Nuclear Operating Company's (FENOC) proposed 20-year license extension at its problem-plagued Davis-Besse atomic reactor, has filed the 7th contention in the coalition's nearly 4-year long intervention. The coalition has issued a press release.
In addition to Beyond Nuclear, the coalition includes Citizens Environment Alliance of Southwestern Ontario, Don't Waste Michigan, and the Ohio Green Party.
The contention focuses on FENOC's admission that the cracking propagation, or worsening, is in fact aging-related, making it within the scope of the U.S. Nuclear Regulatory Commission (NRC) Atomic Safety and Licensing Board (ASLB) proceeding, and worthy of a hearing on the merits.
FENOC's admissions are to be found in a July 3rd document, containing modifications to its Shield Building Management Program Aging Management Plans (AMPs). The modifications represent amendments to its Davis-Besse License Renewal Application (LRA).
FENOC blames the new cracking, and worsening cracking, on "ice-wedging" ("freezing water at a pre-existing crack leading edge"), driven by regular freeze/thaw cycles that penetrate deeply into the Shield Building walls at the Lake Erie shoreline location. (See, for example, the second paragraph on page 13 of 14 on the PDF counter of the July 3rd document). The environmental coalition has previously documented the substandard concrete that allows such deeply penetrating freezing within the Shield Building walls.
The coalition warned that the summer 2012 "whitewash" (or weather sealant of the exterior, 40 years late) of the Shield Building would lock damaging water within the walls. FENOC has now admitted this is indeed the case. At page 13 of 14 on the PDF counter in the July 3rd FENOC document, FENOC admits that the cracking growth could be a startlingly high 0.4 to 0.7 inches per freezing cycle, due to the ice-wedging on the leading edge of the cracking.
The Lake Erie shoreline location is subjected to multiple freeze/thaw cycles per year, a number of which likely penetrate deeply into the Shield Building side walls, thus significantly worsening cracking each and every time. Although massive, the Shield Building is only so big: only 30 inches thick, 279 feet 6 inches tall, and with only a 436.5 foot inner circumference/452 foot outer circumference.
How long has such "ice-wedging" been worsening cracking? How much more cracking growth can the Shield Building withstand, before it ceases to fulfill its vital safety and environmental protection roles?!
FENOC's admission also proves that the coalition's objections to the "Snow Job of '78" were on target. FENOC concluded the Blizzard of 1978 was the root cause of the Shield Building's severe sub-laminar cracking, a theory NRC later endorsed, despite strongly questioning it at first. Intervenors have long maintained the Blizzard of 1978 is likely but one of numerous root causes of Shield Building cracking, which likely persist, and worsen, over time.
The contention challenges the inadequacy of FENOC's Shield Building Monitoring Program's Aging Management Plans (AMPs). Specifically, the intervenors have called for significantly more tests, utilizing a diversity of methods to avoid blind spots, carried out at a much greater frequency than FENOC plans during the 2017 to 2037 license extension period. If FENOC cannot reasonably assure adequate protection of public health, safety, and the environment, then Davis-Besse must be permanently closed, not granted a license extension, intervenors have long asserted.
The contention was prompted by a window of opportunity pointed out by the ASLB panel overseeing the Davis-Besse License Renewal Application (LRA) proceeding. In a July 25th ruling, rejecting a previous coalition cracking contention filed on Earth Day, the ASLB pointed out that FENOC's latest modifications to its Shield Building AMPs provide intervenors another contention opportunity, provided they file it within the arbitrarily short 60-day deadline allotted by the ASLB. The coalition has met that challenge.
Given the NRC Commissioners' unanimous vote on August 26th to approve the agency staff's "Continued Storage of Spent Nuclear Fuel" Generic Environmental Impact Statement (GEIS) and Rule, as well as its 4 to 0 vote to end the associated holds on final granting of license extensions, the Davis-Besse ASLB panel could be poised to approve FENOC's LRA. (In summer 2012, the NRC Commissioners placed final license extension decisions on hold, till resolution of the court-ordered "Nuclear Waste Confidence" policy re-write.) Once the "Continued Storage" (formerly called "Nuclear Waste Confidence") decision is published in the Federal Register later this month, then 30 days later, the Davis-Besse proceeding stay will end. The coalition's contention thus seeks to keep the intervention proceeding alive, and block the license extension. Davis-Besse's original 40-year license will expire on Earth Day (April 22), 2017.
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The Sandusky Register has reported on this story, with extensive quotes from Beyond Nuclear staffer Kevin Kamps.