NRC rubber-stamps Entergy Palisades' operation till 2031, despite increasing risks of U.S.'s worst age-degraded reactor pressure vessel

A diagram describing pressurized thermal shock in a nuclear reactor. Credit: Japan Atomic Energy Agency. Japan's worst embrittled RPV, at Genkai 1, has been permanently closed in the aftermath of Fukushima.Beyond Nuclear and environmental allies responded to NRC staff's approvals (see below) with a press release (see the Word version for live links to relevant documents).

The Kalamazoo Gazette/MLive reported on this story, quoting the environmental coalition's attorney, Terry Lodge of Toledo:

"Once again, the NRC commissioners, and now staff, demonstrate that there is no way to thread the needle; the public remains excluded," said Terry Lodge, a Toledo attorney and legal counsel for the environmental coalition. "This is likely the public's last opportunity ever to question the absurdly embrittled and dangerous pressure vessel at Palisades. We can only hope the NRC's incurious facade and implacable public-be-damned attitude does not give rise to a spectacular radioactive catastrophe."

And the St. Joe-Benton Harbor Herald-Palladium reported:

Reaction from the anti-nuclear activist camp has been critical. Groups such as Beyond Nuclear have been pushing the NRC to force Palisades to shut down over safety concerns.

Kevin Kamps of Beyond Nuclear says the NRC keeps diluting the safety regulations for Palisades to keep allowing it to operate.

"They keep weakening the rules," Kamps said. "The NRC is a rogue agency and Entergy is a rogue corporation. The NRC has abandoned its conservative models. Palisades can't meet the old regulations, so magically there's a new regulation they can meet. They are shaving the safety margins. They're going right up to the cliff edge of risk."

Anti-nuclear organizations have been critical of the NRC for allowing Entergy to use data from metal samples from other nuclear plants' reactor vessels in its Palisades analysis.

WHTC reported:

The Nuclear Regulatory Commission’s decision to issue two license amendments involving the Palisades plant near Covert is coming under fire from anti-nuclear activist groups who continue to demand the closure of the 44-year-old facility. The NRC says that plant’s reactor vessel should remain safe for operation through 2031, when the Palisades’ license expires, and that staffers at the facility “successfully demonstrated the safety of the pressure vessel under current operating conditions.” Beyond Nuclear officials dispute these findings, claim that the NRC’s decision is based on greed, and vow to continue their high-visibility fight to close this plant.

WKZO reported:

A four-group coalition disputes these findings and claim that the NRC's decision is based solely on greed. U.S. House Energy and Commerce Committee Chairman Fred Upton of St. Joseph disagrees, however.

"There's no political arm-twisting," Upton said. "It's the science that determines the outcome."

Kevin Kamps of Beyond Nuclear accuses Upton of collusion with the NRC and Palisades' operator Entergy in a way that is "similar to the root cause of the Fukushima nuclear catastrophe in Japan."

The Detroit News also covered this story, reporting:

Longtime Palisades critic Kevin Kamps of the group Beyond Nuclear argues federal officials are putting the public at greater risk of an accident.

“NRC has custom-tailored weakened regulations to accommodate the severely age-degraded Palisades atomic reactor and to allow Entergy to run it into the ground until 2031,” Kamps said in a statement. “The collusion ... to keep Palisades operating is frighteningly similar to the root cause of the Fukushima Daiichi nuclear catastrophe in Japan. ...”

Beyond Nuclear is one of several groups involved in the Shutdown Before Meltdown campaign aimed at ending Palisades’ run as an active reactor.

NRC's approvals are but the latest instance of the agency ignoring warnings by environmental watchdogs and concerned local residents. For example, from 2012 to 2014, the coalition brought warnings from Japan to the attention of two NRC chairmen and another NRC Commissioner (Dr. Greg Jaczko, Dr. Allison Macfarlane, and William Magwood IV), at face to face meetings near Palisades after the officials had toured the problem-plagued reactor. The coalition shared articles, published by Hiromitsu Ino in the Citizens Nuclear Information Center-Tokyo newsletter (#148 and #149) in 2012, showing that Japanese nuclear power industry and nuclear regulatory agency models, regarding RPV embrittlement, were significantly non-conservative, as revealed when actual physical tests were finally performed at Genkai Unit 1. (See Figure 1 in newsletter #148, and Figue 2 in #149; also see illustration, above left).

The following email, sent by NRC Region 3 in Lisle, IL to news media, but not to concerned local residents or environmental groups, which have been officially intervening on reactor pressure vessel risks at Palisades for over a decade, was how Beyond Nuclear learned of NRC's approvals, when a reporter shared it:

"From: "Mitlyng, Viktoria" <Viktoria.Mitlyng@nrc.gov>

Date: November 23, 2015 3:38:50 PM GMT-05:00 

Subject: NRC approves two Palisades license amendments

NOTE TO MEDIA: NRC APPROVES TWO LICENSE AMENDMENT REQUESTS RELATE TO REACTOR VESSEL SAFETY

The NRC completed the review of and issued two license amendments which pertain to reactor vessel embrittlement under certain conditions for Palisades. The NRC granted these license amendment requests because they were found to maintain public health and safety The Pressurized Thermal Shock (PTS) amendment addresses the material behavior during a postulated accident event (PTS) and the Appendix G amendment addresses material behavior during normal operations.  While both are affected by embrittlement, they require examination and assessment of different data points.

PTS LAR

After 16 months and over 700 hours of independent review and verification, the NRC concluded that the probability of vessel fracture that could result from a PTS event at Palisades is so exceedingly low that it isn’t likely to present a danger to public health and safety.

The NRC granted Entergy permission to use an updated rule to assess the reactor vessel’s ability to withstand a certain type of accident. The original PTS Rule was published in 1985 while the Alternate PTS Rule was published in 2010. In the 25 years between the publishing of the two PTS rules, we acquired more data and a better understanding of embrittlement, as well as greater accuracy in computer modeling capabilities. Thus we are able to capture the details of a PTS event more accurately than was possible when the original PTS rule was adopted.

Both rules hold plants to the highest safety standards.

APPENDIX G LAR

After two years and over 800 hours of independent review, the NRC concluded that Palisades successfully demonstrated through fracture mechanics analysis the continued safety of the pressure vessel under current operating conditions.

Appendix G deals with NRC’s requirements for fracture toughness of the reactor vessel or the material’s resistance to fracture during normal operation.  The Appendix G regulations require that the reactor vessel maintain a minimum fracture toughness of 50 ft-lbs when measured by the Charpy test. The Charpy test is performed in a laboratory and measures metal fracture toughness.   If the tests shows that minimum fracture toughness will fall below the established value (50 ft-lbs), NRC regulations require the plant to perform fracture mechanics analysis to demonstrate that the reactor vessel will not develop significant flaws under normal conditions. This analysis is often referred to as an equivalent margins analysis (EMA). The NRC has reviewed this type of amendment and analysis for numerous reactors.  

The NRC staff has completed its review of the licensee’s EMA and determined that at the lower fracture toughness levels that have been predicted for the Palisades vessel, the likelihood of reactor vessel fracture remains extremely low under the conditions for which the reactor was designed through the end of the current license (March 24, 2031).

REACTOR CAPSULES

The NRC staff notes that the Palisades capsules contain test specimens from the reactor vessel, but not from the specific plates and welds which are the subject of the Palisades Appendix G submittal.  Therefore, when the next capsule withdrawal and test occurs, the capsules will provide embrittlement information for only certain reactor pressure vessel materials. They will not provide any additional information on the materials discussed in Entergy’s Appendix G submittal."

Attached to the email were the NRC's "Appendix G Approval" and "PTS Amendment Approval" documents.

Davis-Besse nuke license renewal challenged due to cracking issue

Matthew Bandyk at SNL has quoted Beyond Nuclear:

"The prospect of 22 more years of radioactive Russian roulette on the Lake Erie shore, with a cracked concrete containment, and paid for by a multibillion-dollar ratepayer bailout, is outrageous, and must be prevented," the group said in a Nov. 7 report following the hearings...

Beyond Nuclear pointed to testimony from a Sept. 23 NRC meeting, in which an NRC engineer said it was "possible," although "unlikely," that an earthquake could cause a cracked piece of concrete to "spall off." Concrete that fell off the shield building could damage the plant's auxiliary building, which is used to house safety features like emergency cooling systems...

In most cases, the NRC staff can complete a license renewal review in about two years, according to NRC spokesman Scott Burnell. But FirstEnergy submitted its application for Davis-Besse in 2010. It is typical for renewals that involve proceedings before the Atomic Safety and Licensing Board to take longer, he said. Beyond Nuclear and several other groups, such as the Ohio Green Party, filed multiple contentions about the cracking to try to block Davis-Besse's license renewal, but the board refused to grant them a hearing.

FirstEnergy President and CEO Charles Jones Jr. recently said that in early 2016 it expects a settlement with the Public Utilities Commission of Ohio that will resolve the proposed power purchase agreement. Beyond Nuclear called upon Ohio residents to oppose the agreement, saying it amounts to "$3 billion in ratepayer subsidies, to prop up [FirstEnergy's] age-degraded and uncompetitive Davis-Besse reactor" and that it would cost more than $3 billion to replace Davis-Besse's reactor containment if the cracks worsened.

NRC dismisses Beyond Nuclear et al. interventions against Entergy Palisades RPV risks; environmental coalition vows to fight on

NRC file photo of Entergy's Palisades atomic reactor on the Lake Michigan shore in Covert, MIAn environmental coalition (Beyond Nuclear, Don't Waste MI, MI Safe Energy Future, and Nuclear Energy Information Service of IL, represented by Toledo attorney Terry Lodge, and served by expert witness Arnie Gundersen of Fairewinds Associates) has been officially intervening against yet further regulatory rollbacks at Entergy's Palisades atomic reactor since Dec. 1, 2014. Entergy Nuclear has applied to the U.S. Nuclear Regulatory Commission (NRC) for weakened safety regulations, to accommodate Palisades' continued operations, despite having the single worst embrittled reactor pressure vessel (RPV) in the U.S., and other forms of severe, and worsening, RPV age-related degradation. Palisades has operated for nearly 45 years. It is located on the Lake Michigan shoreline in Covert, MI (see photo, left).

The NRC Commissioners have been considering dueling petitions filed by the environmental coalition and Entergy. On June 2, 2015, the coalition appealed an Atomic Safety and Licensing Board Panel (ASLBP) rejection of its contention regarding RPV embrittlement, and risks of pressurized thermal shock brittle fracture due to suddenly decreasing temperatures. On July 13, 2015, Entergy appealed the same ASLBP's granting of a hearing to the environmental intervenors on the technical merits of their contention, regarding other forms of RPV age-related degradation, and risks of ductile tearing failure even at hotter normal operating temperatures. Either form of failure of the RPV would lead to Loss-of-Coolant-Accident, and reactor core meltdown, and likely containment breach and release of catastrophic amounts of hazardous radioactivity.

Today, the NRC Commissioners ruled Entergy's way in both overlapping proceedings, denying the environmental coalition's appeal, while ruling in favor of Entergy's appeal.

The coalition, working in alliance with groups like the Sierra Club Nuclear-Free Michigan Committee, has vowed to fight on, to demand Palisades' shutdown, before it melts down. It has issued a press release. (See the word version for functional links to relevant documents.) Matthew Bandyk at SNL has reported on this story.

The NRC Commissioners' overruling of its own ASLBP grant of a hearing comes despite the environmental coalition’s efforts having garnered the support of the mayors of Grand Rapids and Kalamazoo. Grand Rapids (with a population of 200,000) and Kalamazoo (with 75,000 residents) are the two largest cities in southwest Michigan, both well within the 50-mile zone downwind of Palisades. On July 30, 2015, Grand Rapids Mayor George Heartwell wrote the NRC, urging that long overdue physical safety testing of Palisades’ RPV be conducted, and that the environmental groups’ intervention be allowed to proceed to a hearing. Echoing those calls, on November 6, 2015, Kalamazoo Mayor Bobby J. Hopewell went even further, urging “From the information presented…the requested regulatory relief should be denied to ENTERGY.”

Likewise, on August 4, 2015, the nearest residents to the Palisades atomic reactor, the Palisades Park Country Club, also demanded the long overdue physical safety testing, and called for the hearings to proceed.

On August 7, 2015, so too did the Sierra Club, “the nation's largest and most influential grassroots environmental organization -- with more than two million members and supporters.” The Sierra Club’s attorney, Wally Taylor, filed a Friend of the Court brief in support of the environmental coalition’s efforts, on behalf of its Nuclear-Free Michigan Committee, chaired by Mark Muhich of Jackson, MI.

Davis-Besse: A multi-billion dollar ratepayer bailout for 20 more years of radioactive Russian roulette is an outrage!

"Burning money," graphic art by Gene Case of Avenging AngelsBeyond Nuclear's Radioactive Waste Watchdog, Kevin Kamps, has published analysis and commentary on the NRC ACRS (U.S. Nuclear Regulatory Commission Advisory Committee on Reactor Safeguards) meeting that just took place about Davis-Besse's 20-year license extension. It is entitled FAUSTIAN FISSION, and argues that forcing ratepayers to fork over billions in bailouts to FirstEnergy to subsidize 20 more years of radioactive Russian roulette on the Great Lakes shoreline is an outrage, that must be stopped.

See the PDF version (or see the Word version, for live hyper-links to relevant documents).

The analysis and commentary touches on lessons learned over the past four years since severe, and ever worsening, cracking was first revealed in the safety-critical concrete Shield Building, on Oct. 10, 2011, at FirstEnergy's problem-plagued Davis-Besse atomic reactor.

Davis-Besse is located on the Great Lakes shore in n.w. OH. It thus puts the drinking water supply for millions of people downstream in the U.S. and Canada, as well as a large number of Native American First Nations, at dire risk.

The 5th anniversary of the launch of Beyond Nuclear et al.'s (Citizens Environment Alliance of Southwestern Ontario, Don't Waste MI, and OH Green Party) intervention against the 2017-2037 license extension at Davis-Besse will be Dec. 27, 2015. Toledo attorney Terry Lodge serves as the coalition's legal counsel.

The coalition's resistance to the license extension continues, as in the Nuclear Waste Confidence appeal to the U.S. Court of Appeals for the District of Columbia Circuit, spearheaded by D.C. attorney Diane Curran and Turner Environmental Law Clinic director Mindy Goldstein of Atlanta.

UCS's Lochbaum shares insights on Davis-Besse Shield Building cracking

Dave Lochbaum, director of the UCS Nuclear Safety Project, is one of the nation's top independent experts on nuclear power. On Nov. 4, 2015, David Lochbaum of the Union of Concerned Scientists (photo left) shared the following insights regarding the severe, and worsening, concrete cracking in FirstEnergy Nuclear Operating Company's Davis-Besse Shield Building. Lochbaum has granted Beyond Nuclear permission to reproduce his insights here.

"I happened just yesterday to skim through BOP (bunches of papers) that FENOC buried, I mean submitted to, ACRS. The BOP is online at https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML15280A293

There's a 16 page attachment to the letter transmitting the BOP to the ACRS that seems to lay out the landscape pretty well. This 16-pager is [linked here]. 

The first paragraph on page 1 includes nifty phrases like "...help facilitate a solid understanding of how Davis-Besse is currently managing the Shield Building laminar crack issue..." and "...how the Shield Building Monitoring Program will ensure that the identified aging mechanism will be managed...".

The remaining 15 pages reveal plenty of reasons to question whether the "solid understanding" will actually "ensure" anything good.

The third paragraph on page one explains that cracking was first identified in October 2011. The backgrounder kinda glosses over how the discovery was made when cutting through the shield building wall. Nor does it explain how the cracking -- blamed on a freak winter storm in the late 1970s -- hid itself when the shield building wall was cut open a decade earlier when the original degraded head was replaced. This knocks a few points off the "solid understanding." How did a crack allegedly formed in the late 1970s hide itself in 2002-2003 and then reveal itself in October 2011?

The first paragraph on page two explains that falling concrete could affect the Auxiliary Building and/or the Borated Water Storage Tank. The backgrounder does not explain the potential "affect" but it's safe to assume it won't be positive.

Section C on page three points out that "To establish a design basis calculation, two key pieces of information would be required: 1) The extent of laminar cracking had to be established...". Actually, the text leaves out an important adjective. One can establish a design basis calculation without a clue to the extent of laminar cracking. But one needs to know the extent of cracking to establish a CREDIBLE design basis calculation. It's not apparent that FirstEnergy has truly defined the extent of laminar cracking. Hence, it's not clear that they have a credible design basis calculation. 

Doubts about the extent of laminar cracking can be found in the text in the middle paragraph on page three -- "Impulse Response techniques were used to map the entire accessible areas of the exterior Shield Building..." and "The Impulse Response map completed in 2012..." and in the  text in the first two paragraphs under Section F on page eight -- "Based on the first root cause conclusions, the laminar cracking was considered passive" and "Monitoring in 2012 did not identify any changes in cracking. However, in 2013, a new crack was identified in a core bore that previously did not have indications of cracking."

Recurring surprises does not equate to a "solid understanding" that "ensures that the identified aging mechanism will be managed." The recurring surprises do equate to NOT knowing the extent of laminar cracking. And NOT knowing the extent of laminar cracking, per FirstEnergy's own statement, equates to NOT having a credible design basis calculation.

The last three paragraphs on page eight point out that FirstEnergy does not have their arms around this situation: "The Shield Building Monitoring Program was revised to increase the number of cores to be inspected to 23 core bores. These nine additional core bores were added to monitor the condition."  And "The Shield Building Monitoring Program was revised in 2015 to address changes in the Shield Building. Currently, the program is monitoring a total of 28 core bores. ... Five additional core bores were added to monitor the leading edges of areas of crack propagation."

"...the laminar cracking was considered passive" but requires more and more and more core bores "to monitor the leading edges of areas of crack propagation."

If these antics constitute having a "solid understanding" of the "extent of laminar cracking," what would merely guessing look like?

Recall that Section I on page three described the Impulse Response techniques used to develop a map that "shows the extent of laminar cracking." That section ends with the sentence "This Impulse Response map is used in subsequent analyses."

There's no mention of re-doing the Impulse Response process to re-map the extent of laminar cracking. Yet new cracks were said to have been found in 2013. So, is FirstEnergy still using a map known to be obsolete in its analyses?

The middle part of page nine describes "Fourteen areas of potential crack propagation" and various core bores planned to provide insights on the extent of laminar cracking.

Why not repeat the Impulse Response process to map out the current extent of laminar cracking?

If the Impulse Response map is not as useful as core bores in monitoring the extent of cracking, why use the old map in analyses?

The last paragraph on page nine states "In summary, the implementation of the Shield Building Monitoring Program will provide reasonable assurance aoerf fwih gsuhfsu [sorry, I couldn't type while I was laughing so hard] that the existing environmental conditions jusgfs uahas opsjha [sorry, another fit of laughter] will not cause aging effects that could result in a loss of component intended function."

So, the real question that ACRS should seek to answer is what has the largest crack?

A) The Shield Building at Davis-Besse

B) The Shield Building Monitoring Program for Davis-Besse

C) All of the above.

Even dead, Shakespeare knows the answer to be B.

If information is power, FirstEnergy seems powerless to understand the extent of laminar cracking and therefore properly manage aging effects.

Thanks,

Dave Lochbaum

Director, Nuclear Safety Project

UCS"