Watch-dogging embrittlement at Palisades
samples within the Palisades reactor cannot be traced solely to the impurity in its
weld metal. Even prior to Palisades’ start-up, the Atomic Energy Commission
(AEC) identified other potentially serious problems[3]. On January 27, 1970, Joseph
Hendrie, Chairman, Advisory Committee on Reactor Safeguards, wrote a letter to
Glenn Seaborg, Chairman, U.S. Atomic Energy Commission, in which he said,
first of the Combustion Engineering line currently licensed for
construction. A feature of the Palisades reactor is the omission of
the thermal shield. Studies were made by the applicant to show that
omission of the shield would not adversely affect the flow
characteristics within the reactor vessel or alter the thermal stresses
in the walls of the vessel in a manner detrimental to safe operation
of the plant… 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.
The results of annealing will be confirmed by tests on additional
surveillance specimens provided for this purpose.
[3] Joseph M. Hendrie, Chairman, Advisory Committee on Reactor Safeguards, letter to
Glenn T. Seaborg, Chairman, U.S. Atomic Energy Commission, “Report on Palisades
Plant,” January 27, 1970. (ML052720270, marked as “Exhibit 1A,” pages 3 to 6 of 129
on PDF counter)}
From: Kevin Kamps <[email protected]>
Date: Thu, Dec 7, 2023 at 2:39 PM
Subject: Palisades reactor pressure vessel embrittlement/pressurized thermal shock documents from past interventions
No. DPR-20; Palisades’ owner is Consumers Energy/CMS; Palisades’ operator is Nuclear Management Company, LLC]
A. Contention 1 (Regarding Embrittlement of Reactor Pressure Vessel) . . . . . . . . . . . . . 31
Status of Demetrios Basdekas as Petitioners’ Expert on Embrittlement…Page 2
March 20, 2006: NIRS and grassroots coalition letter to U.S. Senator Debbie Stabenow requesting General Accounting Office (Congress’s investigative arm) investigation into reactor pressure vessel embrittlement and pressurized thermal shock (PTS) at Palisades and reactors across the U.S. Also urges GAO investigate why — instead of protecting public health and safety and the environment against such risks — NRC has instead weakened embrittlement/PTS standards, allowing dangerously deteriorated reactors such as Palisades to continue operating.
March 20, 2006: NIRS and grassroots coalition letter to U.S. Senator Carl Levin requesting General Accounting Office (Congress’s investigative arm) investigation into reactor pressure vessel embrittlement and pressurized thermal shock (PTS) at Palisades and reactors across the U.S. Also urges GAO investigate why — instead of protecting public health and safety and the environment against such risks — NRC has instead weakened embrittlement/PTS standards, allowing dangerously deteriorated reactors such as Palisades to continue operating.
increasing the risk for Pressurized Thermal Shock, a condition caused by any number of system malfunctions which can result in a severe, sudden overcooling of
the reactor pressure vessel. This can lead to a loss-of-coolant accident, meltdown, and catastrophic release of radiation to the entire Great Lakes basin.
(11.) October 30, 2014: Annotated bibliography — about embrittlement in general, with a particular focus on Palisades; hundreds of entries dating from the 1940s to 2019 — although I began compiling this in October 2014, I kept updating it until early 2015, with projections made by NRC et al., dating out to 2019:
Beyond Nuclear warns NRC against weakening RPV embrittlement/PTS safety regulations at Palisades
A coalition of environmental groups and concerned local residents has intervened against Entergy Nuclear’s License Amendment Application (LAR) to the U.S. Nuclear Regulatory Commission (NRC) at its Palisades atomic reactor on the Lake Michigan shore in southwest Michigan (see photo, left). The LAR seeks to apply an alternate reactor pressure vessel (RPV) fracture toughness rule (10CFR50.61a, instead of the current 10CFR50.61). If successful, the intervention could force the permanent shutdown of the 44-year-old nuclear power plant.
The coalition cites the risk of catastrophic release of hazardous radioactivity to the environment due to Pressurized Thermal Shock (PTS) fracturing the embrittled RPV, causing a Loss-of-Coolant-Accident (LOCA), core meltdown, and containment failure.
See the coalition’s intervention filing here, including legal and technical arguments, as well as numerous examples of PTS regulatory rollbacks over the decades. See expert witness Arnie Gundersen’s declaration and CV here. See eyewitness affidavits re: NRC’s refusal to require metal samples to be analyzed here. See an extensive (yet still far from complete) compilation of Palisades’ PTS-related documents here. See the coalition’s press release here. See also a statement by Gail Snyder, President of the Board of Nuclear Energy Information Service of IL, and a local landowner near Palisades who has intervened against the LAR.
The coalition includes Beyond Nuclear, Don’t Waste Michigan, Michigan Safe Energy Future, and Nuclear Energy Information Service (Chicago, IL). Arnie Gunderden, Chief Engineer of Fairewinds Associates, Inc., serves as the coalition’s expert witness. Terry Lodge, Toledo-based attorney, serves as the coalition’s legal counsel.
(13.) December 22, 2014:
Nuclear Crack Down?
Did you know that embrittled nuclear reactors could shatter like glass? Watch Fairewinds Energy Education’s Nuclear Science Guy Arnie Gundersen (photo, left) demonstrate reactor embrittlement and imagine the shattering glass as a shattering nuclear reactor vessel. Learn more.
Arnie, Chief Engineer at Fairewinds Associates, Inc., serves as expert witness for an environmental coalition, including Beyond Nuclear, challenging Entergy Nuclear’s application to weaken reactor pressure vessel (RPV) embrittlement safety standards, yet again, at its Palisades atomic reactor in s.w. MI on the Lake Michigan shoreline. Palisades has the worst embrittled RPV in the U.S., at risk of pressurized thermal shock (PTS), fracture, Loss-of-Coolant-Accident, core meltdown, containment failure, and catastrophic release of hazardous radioactivity.
NRC rubber-stamped Palisades’ 20-year license extension in 2007, steamrolling an environmental coalition’s intervention in opposition. The primary technical safety focus of the coalition was RPV embrittlement and PTS risk. See the chronicle of this 2005-2007 intervenion, posted online at the NIRS website.
(14.) February 18, 2015: Not US, but partly related —
“Thousands more cracks found in Belgian nuclear reactors: Belgian regulatory head warns of global implications”
As revealed in a new report from Greenpeace Belgium, micro-cracking in Belgian atomic reactor pressure vessels (RPV) due to hydrogen flaking could be a global problem going undiagnosed, simply because nuclear utilities and government regulators haven’t done the needed testing. Belgium’s nuclear regulatory agency has issued “a statement confirming that the additional tests conducted in 2014 revealed 13,047 cracks in Doel 3 and 3,149 in Tihange 2,” as reported in Greenpeace Belgium’s press release.
Embrittlement can lead to RPV failure due to pressurized thermal shock (PTS) in pressurized water reactors (PWRs). Beyond Nuclear, in coalition with Don’t Waste MI, MI Safe Energy Future, and Nuclear Energy Information Service, has challenged the continued operation of Entergy Nuclear’s Palisades atomic reactor in s.w. MI on the Lake Michigan shore (photo, above left), due to its worst embrittled RPV in the U.S. As reported by Greenpeace Belgium, a RPV breach due to PTS could cause a Loss-of-Coolant-Accident (LOCA), core meltdown, containment failure, and catastrophic radioactivity release.
However, Greenpeace Belgium’s report warns that hydrogen flaking micro-cracking also impacts boiling water reactors (BWRs). Greenpeace Belgium’s experts call for comprehensive testing of all atomic reactors worldwide, a position echoed by Belgium’s top nuclear regulator. Belgium’s two suspect reactors are shut; Greenpeace demands they remain so till the concern is addressed. Meanwhile, Palisades operates at full power.
(15.) March 17, 2015:
Coalition to press its case against Palisades’ RPV safety rollbacks at March 25th NRC licensing board hearing
Entergy’s problem-plagued Palisades atomic reactor in Covert, MI, on the Lake Michigan shoreline.
A U.S. Nuclear Regulatory Commission (NRC) Atomic Safety and Licensing Board (ASLB) will hold an oral argument pre-hearing on Wednesday, March 25th beginning at 10am Eastern, regarding an environmental coalition’s intervention against further regulatory rollbacks regarding Entergy Palisades’ reactor pressure vessel (RPV), the worst embrittled in the U.S. The hearing will be held at ASLB chambers at NRC’s HQ in Rockville, Maryland, but a listen-in phone line is being provided. The hearing is scheduled to last two hours, till noon Eastern, but there is some chance it will run longer than that.
Palisades is located in southwest Michigan, on the shoreline of the Great Lakes, drinking water supply for 40 million people in 8 U.S. states, 2 Canadian provinces, and a large number of Native American First Nations (see photo, left).
We encourage environmental allies and the media to listen-in to the ASLB hearing, in order to watchdog this vital safety issue. RPV neutron radiation embrittlement, and consequent pressurized thermal shock (PTS) risks, are serious at many pressurized water reactors (PWRs) across the U.S. Any regulatory rollbacks rubber-stamped by NRC at Palisades would set bad precedents that could then be applied at other embrittled PWRs in the future.
According to Mr. Sachin Desai, ASLB law clerk: “The phone number for the oral argument is 800-857-9645. The passcode is 9568305. This will be a listen-only line.”
Mr. Desai has also communicated that “Members of the public interested in attending or listening to the March 25, 2015 oral argument must reach out to me, the Board’s law clerk, beforehand either by phone or e-mail. My phone number is 301-415-6523…[and] e-mail ([email protected]).” Mr. Desai asks that you RSVP with him by Monday, March 23rd, two days ahead of the hearing.
The hearing will allow the ASLB’s three administrative law judges (a.k.a. hearing examiners) to question the contending parties, in order to determine if the coalition’s intervention is worthy of an actual hearing on the merits. Both Entergy Nuclear and the NRC staff oppose the coalition’s intervention.
The coalition’s legal counsel, Terry Lodge of Toledo, filed the intervention petition on December 1, 2014, by NRC’s deadline. The filing included an extensive technical declaration by the coalition’s expert witness, Arnie Gundersen, who serves as Chief Engineer of Fairewinds Associates, Inc. in Burlington, Vermont.
Fairewinds Energy Education has published a humorous 6.5 minute video, “Nuclear Crack Down?”, shedding light on this serious subject matter.
On March 9, the coalition opened a second front in the safety regulation battle, filing an intervention petition and hearing request regarding the parallel issues of Entergy Palisades’ “Equivalent Margins Analysis.” This attempt by Entergy at yet another weakening of regulations is due to the “Charpy V-Notch Upper-Shelf Energy” of RPV plates and welds at Palisades falling below NRC’s 50 ft.-lb. safety screening criteria. In addition to refiling Gundersen’s December 1, 2014 expert witness declaration, Lodge also cited a recent Greenpeace International report, warning that extensive cracking of RPVs in Belgium raises a red flag for similar cracking occurring worldwide. Greenpeace Belgium also issued a press release.
This revelation from Belgium is a particular concern at such an already badly embrittled and degraded RPV as Palisades. Beyond Nuclear joins Greenpeace Belgium’s call for global testing for RPV cracks, starting with Palisades!
Entergy and NRC staff will almost certainly oppose this most recent intervention filing as well. It is not clear whether the ASLB panel will address this second intervention during the March 25th hearing.
The environmental coalition includes Beyond Nuclear, Don’t Waste Michigan, Michigan Safe Energy Future–Shoreline Chapter, and Nuclear Energy Information Service of Chicago.
Note that, in light of the ongoing Fukushima Daiichi nuclear catastrophe, the worst embrittled reactor in Japan — Genkai Unit 1 — is to be permanently shutdown. Writing in Citizens’ Nuclear Information Center-Tokyo’s newsletters No. 148 and No. 149 in 2012, Hiromitsu Ino identified Genkai Unit 1 as Japan’s atomic reactor most at risk of PTS.
NRC annual performance review, Thursday, April 9, Beach Haven Event Center, South Haven Twp., MI
In related Palisades news, NRC has announced it will hold its annual performance review on Thursday, April 9, beginning at 6pm Eastern, at the Beach Haven Event Center, 10420 M-140, South Haven Township, Michigan 49090. (Note that in a meeting announcement released on March 18, NRC announced that an open house, beginning at 5pm Eastern, will take place before the formal meeting begins at 6pm). Local concerned citizens and environmental watchdogs are urged to attend. A bone of contention will be the over-exposure of 192 workers to an average radiation dose of 2.8 Rem during a short, month-long project a year ago — the replacement of Control Rod Drive Mechanisms. Gundersen of Fairewinds charged Entergy with rushing the job, and thus knowingly exposing workers to such high doses, in order to return the reactor to operations, and profit-making, ASAP, despite the long-term risk to workers’ health. NRC has recently downgraded Palisades’ performance status because of the incident, and will increase its oversight of the problem-plagued reactor for the second time in the past few years.
“Pull the Plug on Palisades for Earth Day!”, Sunday, April 19, 2:30 to 5pm Eastern, Old Dog Tavern, downtown Kalamazoo, MI
On Sunday, April 19, a “Pull the Plug on Palisades for Earth Day!” fund-raiser will be held at the Old Dog Tavern in downtown Kalamazoo (402 E. Kalamazoo Ave.), Michigan, to support the interventions against Palisades. The free-will donation event will go from 2:30 to 5pm Eastern. Musical entertainment will be provided by The Duffield Caron Project with Friends. There will be a Silent Auction, and a Seed Exchange Table (so bring any seeds!). A panel of speakers from the local, state and national coalition behind the interventions will provide updates, and will available for Q&A and discussion at the info. tables afterwards. Speakers will include Kevin Kamps of Beyond Nuclear; attorney Terry Lodge; embrittlement researcher Michael Keegan of Coalition for a Nuclear-Free Great Lakes; Don’t Waste Michigan board member Alice Hirt; Michigan Safe Energy Future–Shoreline Chapter chairman Bette Pierman; and Nuclear Energy Information Service board chairman Gail Snyder. Michigan Safe Energy Future–Kalamazoo Chapter Team Coordinator Iris Potter is co-hosting the event. See the event announcement on MSEF–Kalamazoo Chapter’s “Palisades Shutdown Campaign” Facebook page.
Jim Hayden of the Holland Sentinel has reported on the March 25 ASLB hearing, the April 9 NRC performance review public meeting, as well as an ongoing lawsuit launched by a large number of Palisades security guards, seeking a significant amount of back overtime pay long owed to them by Entergy. The article quotes Beyond Nuclear’s Kevin Kamps: “It all boils down to the safety of the reactor vessel.”
In addition to that issue, a number of security guards that have been harassed and even fired at Palisades for simply doing their jobs (calling attention to problems) continue to press their wrongful termination lawsuit against Entergy, despite the company’s and NRC’s claims that the “safety culture” in the security department at Palisades has been restored to health. As documented by Beyond Nuclear and other groups, Entergy Nuclear is infamous for security breaches and harassment of security guard whistleblowers, not only at Palisades, but at other reactors in its fleet as well.
Nuclear Licesning Board examines vessel risks at Entergy’s Palisades atomic reactor; critics call for permanent shutdown
As reported by a press release, a coalition of environmental groups, including Beyond Nuclear, today testified before the U.S. Nuclear Regulatory Commission’s (NRC) Atomic Safety and Licensing Board (ASLB), at the agency’s HQ in Rockville, Maryland, just outside D.C.
The coalition, represented by Toledo attorney Terry Lodge, defended its intervention against an Entergy License Amendment Request (LAR) to further weaken reactor pressure vessel (RPV) embrittlement/pressurized thermal shock (PTS) safety regulations.
Palisades has the worst-embrittled RPV in the U.S., at risk of a PTS fracture, Loss-of-Coolant-Accident, core meltdown, and catastrophic release of hazardous radioactivity. A bad precedent at Palisades will then be applied by NRC to approve operations at other dangerously brittle pressurized water reactor (PWR) RPVs across the U.S.
The coalition intervened on Dec. 1, 2014. Entergy Nuclear and NRC staff counter-attacked on Jan. 12, 2015. The coalition rebutted the attacks on Jan. 20.
Today’s “oral argument pre-hearing” was essentially an ASLB exercise to determine whether the coalition’s intervenion is worthy of an evidentiary hearing on the merits of the contention. The ASLB is scheduled to rule on the admissibility of the intervenors’ contention within 45 days.
(17.) April 9, 2015 [not directly related but overlapping in part]:
Safety-significant reactor vessel flaws reported worldwide
A rash of potentially risk-significant flaws have been reported around the world recently, in reactor vessels old and new. The listing below is far from exhaustive, but merely shows news from recent days.
Age-degradation in old reactors
Beyond Nuclear is challenging reactor pressure vessel (RPV) degradation at Entergy Nuclear’s Palisades atomic reactor in Michigan (see photo, left). On Thursday, April 9th Beyond Nuclear’s Kevin Kamps will testify at the U.S. Nuclear Regulatory Commission’s (NRC) annual performance review at Palisades. The formal meeting begins at 6pm Eastern time, with public comments at the end. A call-in number has been provided for those who would like to listen-in, or even speak out during the public comment session: Teleconference Bridge Number: 888-989-4611; Pass code: 9165034.
The over-exposure of 192 Palisades workers to, on average, 2.8 Rem radiation doses during the short, month-long Control Rod Drive Mechanism (CRDM) replacement project at Palisades will be a hot topic for discussion, as that “White Finding” (of supposedly “low to moderate” safety significance, according to NRC) has resulted in increased NRC regulatory oversight for the foreseeable future.
On Friday, April 10th, Beyond Nuclear’s attorney at Palisades, Terry Lodge of Toledo, will also be filing yet another major legal brief in the ongoing environmental coalition legal intervention against any further weakening of safety standards regarding Palisades’ RPV embrittlement. Palisades has the worst neutron-embrittled RPV in the U.S., at risk of meltdown and catastrophic radioactivity release due to pressurized thermal shock (PTS).
Beyond Nuclear’s expert witness at Palisades, Arnie Gundersen, the Chief Engineer at Fairewinds Associates, Inc. in Burlington, Vermont, has prepared a short, humorous educational video about the most serious subject of RPV embrittlement and PTS risks, “Nuclear Crack Down?”.
On April 19th, a fundraiser will be held in Kalamazoo, Michigan to support the intervention.
See Beyond Nuclear’s media release for more details on activities around Palisades. (For an email version of this press release with functioning hot links, email [email protected] and he’ll send you a copy.)
In its RPV embrittlement legal filings, Beyond Nuclear and Lodge have raised warnings emanating from Greenpeace Belgium, and the Belgian nuclear regulatory agency, about extensive micro-cracking discovered in two Belgian atomic reactors. Greenpeace Belgium issued a press release in mid-February about these dire warnings. Belgium’s nuclear regulatory chief, and Greenpeace’s expert witness, have called for worldwide testing of all atomic RPVs. Beyond Nuclear has joined their call for this in the U.S., beginning at Palisades.
But Palisades isn’t the only reactor with CRDM or RPV penetration problems…
As reported in an NRC “Event Notification” on April 6th, the Braidwood Unit 1 atomic reactor in IL has an “indication” of degradation at a control rod drive mechanism on the reactor vessel closure lid.
On April 8th, another NRC Event Notification reported reactor pressure vessel closure lid degradation at the Shearon Harris atomic reactor in North Carolina.
Problems in proposed new reactors
Weak spots in the steel of the reactor vessel, and its closure lid, at the proposed new EPR (“European Pressurized Reactor”) at Flamanville, France, have been found, the French nuclear regulatory agency ASN has reported. The weak spots are due to a high concentration of carbon in the steel, which makes the vessels vulnerable to cracking.
Other EPR construction projects worldwide have been warned, such as the highly contentious one at Olkiluoto, Finland.
Both the Flamanville and Olkiluoto construction project were already in serious trouble due to major cost overruns and long schedule delays before this latest news. Areva, the EPR vessel manufacturer, was already in financial “meltdown” mode before this news, losing billions per year.
At one point, seven EPRs (the same design, but instead dubbed “Evolutionary Power Reactors” here, for some strange reason) were proposed to be built in the U.S. (and yet more in Canada, such as four at Darlington, Ontario), with the flagship at Calvert Cliffs nuclear power plant on the Chesapeake Bay in Maryland. But that proposal was stopped when the American partner, Constellation Nuclear of Baltimore, balked at the $880 million credit subsidy fee the Obama administration Office of Management and Budget, and Department of Energy, were requiring for a $7.5 billion federal loan guarantee. With the termination of Calvert Cliffs 3, the other EPRs proposed in North America were either outright canceled, or indefinitely postponed.
The Wall Street Journal has also reported on this EPR story.
(18.) April 10, 2015:
Environmental coalition rebuts NRC staff and Entergy attacks re: “ductile tearing” RPV risks at Palisades
The environmental coalition filed its Reply in support of its March 9 intervention petition, rebuttng NRC staff and Entergy attacks filed on April 3rd. The March 9 intervention regards Entergy’s application for regulatory relief, in the form of an EMA (equivalent margins analysis) in lieu of standard 10CFR50 Appendix G requirements, which it can no longer meet.
This second battlefront in the war over Palisades’ age-degraded reactor pressure vessel (RPV) overlaps with, and is parallel to, the intervention initiated by the same coalition on Dec. 1, 2014, re: Palisades’ application for regulatory relief against neutron irradiation embrittlement of its RPV, and consequent pressurized thermal shock (PTS) risks of a meltdown.
(19.) May 2, 2015:
“Environmentalists Threaten Palisades, NRC With Lawsuit”
As reported by Rebecca Thiele at WMUK (NPR at Western Michigan University), an environmental coalition, including Beyond Nuclear, is intervening against regulatory rollbacks at Entergy Nuclear’s Palisades atomic reactor on the Lake Michigan shore in southwest Michigan.
Thiele interviewed Beyond Nuclear’s Kevin Kamps (a native of Kalamazoo — just 35 miles downwind of Palisades — who serves on the board of directors of Don’t Waste MI), as well as the coalition’s attorney, Terry Lodge. At the top of the story, Bette Pierman of Benton Harbor, chairwoman of Michigan Safe Energy Future (MSEF)–Shoreline Chapter, is heard presenting during a panel discussion. The interviews took place at a fund- and awareness-raising event held at the Old Dog Tavern on April 19th in downtown Kalamazoo. Music performed by the “Duffield-Caron Project, with Friends” can be heard in the background of the interviews.
The intervention focuses on the risk of pressurized thermal shock (PTS). Palisades has the worst neutron radiation embrittled reactor pressure vessel (RPV) of any nuclear power plant in the U.S. Like a hot glass under cold water (and a ton of pressure per square inch!), PTS could fracture Palisades’ RPV, causing a loss of coolant accident, core meltdown, and catastrophic radioactivity release.
Arnie Gundersen, Chief Engineer at Fairewinds Energy Education, and the expert witness for Beyond Nuclear and the coaltion at Palisades, has produced a humorous short video about this serious subject, entitled “Nuclear Crack Down?”
(20.) May 9, 2015:
ASLBP issues split decision on vessel risks at Palisades, Beyond Nuclear vows appeal
A U.S. Nuclear Regulatory Commission (NRC) Atomic Safety and Licensing Board Panel (ASLBP) issued a ruling on May 8th that recognized an environmental coalition’s legal standing, but rejected its proferred contention, thus denying any further hearings on the matter.
Beyond Nuclear and coalition partners Don’t Waste MI, MI Safe Energy Future–Shoreline Chapter, and Nuclear Energy Information Service of Chicago, represented by Toledo attorney Terry Lodge, and expert witness Arnie Gundersen of Fairewinds Associates, Inc., filed an intervention on Dec. 1st against regulatory rollbacks on reactor pressure vessel (RPV) embrittlement/pressurized thermal shock (PTS) risks at Palisades, the most brittle RPV in the U.S. See the full docket of filings between the adversarial parties, here.
The coalition has issued a press release in response to the rejection of its contention. It has vowed to appeal the ruling within the next 25 days.
Lodge filed a second, related but separate intervention on behalf of the coalition on March 9. It challenges Entergy’s License Amendment Request to NRC for “equivalent margins analysis” regulatory relief from potentially disastrous “ductile tearing” (as opposed to brittle fracture) risks at Palisades, due to another form of age-related RPV metal degradation (loss of Charpy V-Notch Upper Shelf Energy below the 50 foot-pound screening criteria). The ASLBP has yet to rule on that intervention.
Beyond Nuclear comments on NRC move to weaken RPV fracture safety regulations
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 has submitted a dozen official public comments into the U.S. Nuclear Regulatory Commission’s (NRC) proceeding regarding the development of Draft Regulatory Guide 1299 (DG-1299), and its technical background document, NUREG-2163. Both DG-1299 and NUREG-2163 are part of NRC’s regulatory rollback, known as 10CFR50.61a, a weakening of (already weakened) safety standards contained in 10CFR50.61 (Title 10, Code of Federal Regulations, Parts 50.61 and 50.61a).
10CFR50.61a, or alternate fracture toughness rules for neutron radiation embrittled reactor pressure vessels (RPVs), would increase the risks of a pressurized thermal shock (PTS) through-wall breach, Loss-of-Coolant-Accident, core meltdown, containment failure, and catastrophic radioactivity release to the environment.
On Dec. 1, 2014, Beyond Nuclear and coalition partners Don’t Waste MI, MI Safe Energy Future–Shoreline Chapter, and Nuclear Energy Information Service of Chicago, intervened against Entergy Nuclear’s License Amendment Request for 10CFR50.61a regulatory relief at its Palisades atomic reactor in southwest MI. Terry Lodge serves as the coalition’s legal counsel.
Following are links to Beyond Nuclear’s dozen comments re: DG-1299 and NUREG-2163, as well as links to the documents on which they are based.
Comment 1: regarding NRC’s over-reliance on PRA (probabilistic risk assessement), or risk-informed regulation, in 10CFR50.61a, and its related DG-1299 and NUREG-2163.
Comment 2: regarding the coalition’s Dec. 1, 2014 intervention petition against 50.61a regulatory relief at Palisades.
Comment 3: DECLARATION OF ARNOLD GUNDERSEN, dated Dec. 1, 2014, part of the intervention petition mentioned immediately above. Gundersen serves as the expert witness for the coalition.
Comment 4: regarding DECLARATION OF PIERMAN, KAMPS AND KEEGAN CONCERNING COUPON AVAILABILITY FOR PTS TESTING, dated December 1, 2014.
Comment 5: regarding “PETITIONERS’ COMBINED REPLY IN SUPPORT OF AMENDED PETITION TO INTERVENE AND FOR A PUBLIC ADJUDICATION HEARING OF ENTERGY LICENSE AMENDMENT REQUEST FOR AUTHORIZATION TO IMPLEMENT 10 CFR§50.61a, ‘ALTERNATE FRACTURE TOUGHNESS REQUIREMENTS FOR PROTECTION AGAINST PRESSURIZED THERMAL SHOCK EVENTS’,” dated Jan. 20, 2015.
Comment 6: regarding NUCLEAR REACTOR PRESSURE VESSEL CRISIS: GREENPEACE BRIEFING (dated Feb. 15, 2015; 10 pages), and Greenpeace press release, “Thousands more cracks found in Belgian nuclear reactors, Belgian regulatory head warns of global implications,” dateline Brussels, Feb. 17, 2015 (2 pages).
Comment 7: regarding Official Transcript of Proceedings, NUCLEAR REGULATORY COMMISSION, Title: Entergy Nuclear Operations, Inc., Palisades Nuclear Plant, Docket Number: 50-255-LA, ASLBP Number: 15-936-03-LA-BD01, Location: Rockville, Maryland, Date: Wednesday, March 25, 2015 (135 pages).
Comment 8: regarding the June 1983 Popular Science article, “Thermal shock–new nuclear-reactor safety hazard?”, by Edward Edelson; the January 27, 1970, Advisory Committee on Reactor Safeguards (ACRS), chaired by Joseph M. Hendrie, “REPORT ON PALISADES PLANT,” sent to AEC Chairman Glenn T. Seaborg; and the MEMORANDUM and ORDER (Ruling on Petition to Intervene and Request for a Hearing), NRC Atomic Safety and Licensing Board Panel, In the Matter of: ENTERGY NUCLEAR OPERATIONS, INC. (Palisades Nuclear Plant), LBP-15-17, Docket No. 50-255-LA, ASLBP No. 15-936-03-LA-BD01, May 8, 2015.
Comment 9: regarding the 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 (specifically, the first contention, beginning on page 4, regarding “The license renewal application is untimely and incomplete for failure to address the continuing crisis of embrittlement”); the 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); the Petitioners’ Appendix of Evidence (129 pages), which accompanied its September 16, 2005 Reply; and the November 3, 2005: Transcript of oral argument pre-hearing before the NRC ASLBP, re: 20-year license extension for Palisades. The hearing was held in South Haven, Michigan. (See, specifically, the portions pertaining to PTS risks, including pages 34-80 (pages 17-63 of 206 on PDF counter), and following, as articulated by attorney Terry Lodge on behalf of intervening groups NIRS and Don’t Waste MI.)
Comment 10: regarding the 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, specifically pages 3 to 9, as well as portions of the conclusion relevant to PTS risks/RPV embrittlement).
Comment 11: regarding Spring 2006: Consumers Energy power point presentation to the Michigan Public Service Commission, highlighting “Reactor vessel embrittlement concerns” at Palisades.
Comment 12: Beyond Nuclear submitted for the record a June 2011 AP article, by investigative reporter Jeff Donn, entitled “US nuke regulators weaken safety rules.” It was the first installment in a four-part series entitled “Aging Nukes.” Beyond Nuclear pointed out that the weakening of RPV embrittlement/PTS safety standards was cited by Donn as a top national example of NRC’s collusion with industry to keep age-degraded reactors operating, despite the risks.
(22.) May 13, 2015:
Amidst worldwide warnings, Beyond Nuclear challenges regulatory rollbacks on reactor vessel risks
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.
Worldwide warnings about atomic reactor pressure vessel (RPV) risks have elicited little more than a yawn from the U.S. Nuclear Regulatory Commission (NRC). While the French nuclear establishment admits very serious fabrication flaws in brand new RPV components in France (with potential implications for new reactors under construction in China and Finland as well), and the Belgian nuclear regulatory chief warns about apparent age-related RPV degradation that should be guarded against globally, NRC is moving to further weaken already severely weakened RPV safety standards in the U.S.
In a major June 2011 exposé by investigative reporter Jeff Donn, the Associated Press cited RPV safety standard rollbacks as a top example of NRC complicity with the nuclear power industry to keep aging nukes operating, despite the increasing risks. In fact, Donn interviewed the NRC whistleblower who first brought RPV embrittlement/pressurized thermal shock meltdown risks to light more than 30 years ago. And Donn also identified NRC’s pat excuse for such regulatory rollbacks: supposedly unnecessarily- or over-conservative safety margins, that NRC chips away at, while continuing to express confidence that “reasonable assurance of adequate protection” of the public health, safety, and environment is being maintained.
A year later, the Japanese Parliament, in the first independent investigation in its history, concluded that the root cause of the Fukushima Daiichi nuclear catastrophe — the reason the atomic reactors were so very vulnerable to the natural disasters that destroyed them — was collusion between supposed safety regulator, nuclear power industry, and government/elected officials.
Beyond Nuclear, along with environmental allies, has challenged such attempted regulatory rollbacks at the worst embrittled RPV in the U.S., Entergy Nuclear’s Palisades atomic reactor, on the Lake Michigan shore in s.w. MI. Although an NRC licensing board rejected the groups’ intervention last week, the coalition has vowed to fight on. Its legal counsel, Toledo-based attorney Terry Lodge, has indicated an appeal will be forthcoming by the 25 day deadline.
Beyond Nuclear also just submitted extensive comments, based on years — and even decades — of past watch-dogging work, regarding brittle RPV fracture risks, in opposition to NRC’s latest moves to weaken standards yet further.
Beyond Nuclear’s expert witness in the Palisades proceeding, Arnie Gundersen, has prepared a short, humorous educational video about pressurized themal shock risks entitled “Nuclear Crack Down?” Gundersen serves as Chief Engineer at Fairewinds Energy Education.
The coalition also has a second RPV-related contention against Palisades still in process. On March 9th, Beyond Nuclear et al. intervened against Entergy and NRC’s collusion to also weaken RPV ductile tearing failure risks at the problem-plagued Palisades, as well.
(23.) June 4, 2015:
Coalition cites catastrophic risk of Palisades RPV fracture, appeals ASLB ruling to full NRC Commission
Citing the risks of reactor pressure vessel (RPV) fracture, core meltdown, and catastrophic release of hazardous radioactivity at Entergy’s Palisades atomic reactor in southwest Michigan, an environmental coalition (Beyond Nuclear, Don’t Waste MI, MI Safe Energy Future, and Nuclear Energy Info. Service of IL) has appealed an Atomic Safety and Licensing Board (ASLB) panel’s adverse ruling to the full U.S. Nuclear Regulatory Commission (NRC).
The coalition’s legal counsel, Toledo-based attorney Terry Lodge, filed the appeal on June 2nd.
Arnie Gundersen, Chief Engineer at Fairewinds Associates, Inc. in Burlington, VT, serves as the coalition’s expert witness on the risks of pressurized thermal shock (PTS) causing “brittle fracture” in the Palisades RPV. Gundersen and Fairewinds Energy Education have produced a short, humorous, educational video about PTS risks entitled “Nuclear Crack Down?”
NRC has admitted on numerous occassions that Palisades has the worst neutron radiation embrittled RPV in the country. Palisades first surpassed embrittlement safety standards in 1981, just ten short years into its operations. NRC, and/or the nuclear utilities owning and operating Palisades, have previously predicted various “End of Life” dates for the problem-plagued atomic reactor, the earliest being 1995. However, as reported by Jeff Donn of AP in 2011, NRC has weakened safety regulations time after time, to accommodate the age-degraded nuclear power plant, one of the oldest still operating in the U.S.
See updates on Beyond Nuclear et al.’s intervention against Entergy Palisades’ License Amendment Request for regulatory relief dating back to Dec. 1, 2014 at the Reactor Safety website section.
On June 29th, both Entergy Nuclear and NRC staff issued Answers to the environmental coalition’s June 2nd appeal.
(24.) June 22, 2015:
Nuclear Licensing Board Grants Evidentiary Hearing on Risk of Brittle Vessel Fracture at Entergy Nuclear’s Palisades Atomic Reactor
NRC file photo of Entergy Nuclear’s Palisades atomic reactor, located on the Lake Michigan shoreline in Covert, MIThe U.S. Nuclear Regulatory Commission (NRC) Atomic Safety and Licensing Board Panel (ASLBP) overseeing an intervention petiton filed by Toledo attorney Terry Lodge on behalf of an environmental coalition (Beyond Nuclear, Don’t Waste MI, Michigan Safe Energy Future, and Nuclear Energy Information Service) has granted an evidentiary hearing on the merits of concerns regarding the risks of a ductile tear, or fracture, of Entergy Nuclear’s severely embrittled Palisades atomic reactor pressure vessel (RPV), located in Covert, MI on the Lake Michigan shore.
Although Entergy’s Palisades has the worst embrittled RPV in the U.S., it is but the canary in the coal mine. As revealed in an April 2013 NRC document (see point #4, on page 5 of 15 on PDF counter), Next Era’s (Florida Power & Light’s) Point Beach Unit 2, also located on the Lake Michigan shore in Wisconsin, is nearly as bad. Following not very far behind in terms of RPV fracture risk are Entergy’s Indian Point Unit 3 near New York City, Pacific Gas & Electric’s Diablo Canyon on the California coast, and FirstEnergy’s Beaver Valley Unit 1 in Shippingport, Pennsylvania. FirstEnergy has also been required to have an Aging Management Plan for RPV embrittlement at its Davis-Besse atomic reactor on the Lake Erie shore near Toledo, an indication that this is a serious concern there as well.
As a safety precaution in the aftermath of the Fukushima Daiichi nuclear catastrophe, Japan’s nuclear power plant with the worst embrittled RPV — at Genkai 1 — was permanently shut down.
See the NRC ASLBP’s “MEMORANDUM AND ORDER” on the Palisades RPV hearing, here. The coalition has issued a press release on their legal victory.
See the coalition’s March 9, 2015 intervention petition here. Also see Entergy Nuclear’s and NRC staff’s opposition to the intervention petition here, and the coalition’s defense of its filing here.
The coalition’s expert witness declaration (prepared by Arnie Gundersen, Chief Engineer at Fairewinds Associates, Inc. in Burlington, VT), as well as an expert Greenpeace Belgium report on micro-cracking risks in Belgian RPVs that should be tested for at Palisades, were cited by the ASLBP as grounds for granting the hearing.
The same ASLBP had previously ruled against a related but distinct intervention petition concerning brittle fracture pressurized thermal shock risks at Palisades (see the ruling here). The coalition immediately vowed to appeal the adverse ruling, and its attorney Terry Lodge did do so, to the full NRC Commission, in early June.
Environmental intervenors have 25 days to rebut Entergy’s appeal, that is, by August 7th.
(25.) July 14, 2015:
“Nuclear Autopsies,” by Dave Lochbaum
In his blog entitled “Nuclear Autopsies,” David Lochbaum, Director of the Nuclear Safety Project at Union of Concerned Scientists, cites radiation impacts on reactor metal as his first example of the value of performing destructive testing on permanently shutdown nuclear power plant structures and components.
Regarding the baffle plate and core barrel materials “harvested” from the defunct Zorita reactor in Spain, he writes:
Metal specimens attached to the core barrel and other internal components are periodically removed during refueling outages over the reactor’s lifetime for laboratory analysis of radiation effects. The Zorita samples supplement those insights.
Radiation impacts on reactor metal are a grave concern for reactor pressure vessel (RPV) safety. Beyond Nuclear has intervened against any further regulatory weakening at the worst neutron embrittled RPV in the U.S., at Palisades in MI. Neutron bombardment of RPV walls and welds increases the risk of a pressurized thermal shock (PTS) RPV fracture (like a hot glass under cold water — and 2,200 pounds per square inch of pressure!), which would lead to Loss-of-Coolant-Accident (LOCA), core meltdown, and a high likelihood of catastrophic radioactivity release (see Fairewinds Energy Education’s short, humorous educational video about PTS risks, “Nuclear Crack Down?”).
Of deep concern is the industry and NRC practice of over-reliance on computer modeling, probabilistic risk assessment, and extrapolation from “sister plant” data, rather than requiring actual hard physical data from Palisades’ own RPV itself. NRC is allowing Palisades to go 16 years (from 2003 to 2019) without doing a single capsule pull/test, even though Palisades has four capsules available to extract and analyze.
Lochbaum’s “Nuclear Autopsies” blog concludes:
The nuclear industry and the NRC seek to expand those insights by harvesting materials from previously un-examined plant areas. These collections permit real data to replace positions established by extrapolating from other real data and/or by computer analyses. Hopefully, the real data reinforces previous positions. Either way, the real data supports better decision-making in the future.
Nuclear autopsies yield insights that cannot be obtained by other means.
This makes U.S. decisions to not do nuclear autopsies in the past all the more objectionable. For example, the Yankee Rowe RPV was not autopsied, but was instead simply buried in a leaking ditch in Barnwell, SC, even though neutron embrittlement of the RPV forced the reactor’s shutdown in the early 1990s. An autopsy on Yankee Rowe could have shed tremendous light on the RPV embrittlement concerns at Palisades. For, as Lochbaum himself recently observed:
“Embrittlement is the issue that compelled the owners of the Yankee Rowe nuclear plant to permanently shut it down in September 1991.
Palisades has the least embrittlement margin of any U.S. nuclear power reactor vessel. And it would not be allowed to operate if the standards applied to Yankee Rowe were applied to Palisades.”
This photo shows the initial leg of the shipment of Big Rock Point’s radioactive RPV, by heavy haul truck, before being loaded onto a train. The 25 foot by 13 foot cylindrical shell, Type B, transport container used to ship the Big Rock Point RPV from northern MI to Barnwell, SC for burial in Oct. 2003. The shipment was protested with a non-violent civil disobedience action in a Walbridge, OH railyard, resulting in two arrests. The 290-ton load damaged the rails in southeast MI, as well as in the Carolinas, resulting in the later derailments of other trains following on its wake.
(Citizens Awareness Network protested the environmental injustice of burying Yankee Rowe’s radioactive RPV in a leaking ditch in the predominantly African American community of Barnwell, SC. Citizens Awareness Network hauled a mock nuclear waste container from western Massachusetts, through numerous states, to SC, holding press conferences along the way to educate “transport route” communities of the risks.
Yankee Atomic, owner of Yankee Rowe, followed them. Yankee Rowe’s PR head attempted to rebut Citizen Awareness Network with follow on interactions with the news media along the route.
So too was Connecticut Yankee’s RPV.)
(26.) July 15, 2015
“Rickety & risky”: Applying RPV embrittlement lessons learned at Palisades to Diablo Canyon
In a post entitled NRC: ‘Diablo Canyon among ‘most embrittled plants in the U.S.,’ Mary Beth Brangan and James Heddle have posted an article at NoNukesCA.net applying the lessons learned about reactor pressure vessel (RPV) embrittlement at Diablo Canyon.
In a document dated March/April 2013 (see point #4, on p. 5 of 15 of PDF counter), the U.S. Nuclear Regulatory Commission listed Diablo Canyon Unit 1 as having one of the worst neutron radiation embrittled RPVs in the country, surpassing safety screening criteria by 2033. However, given that Palisades’ own End-of-Life dates have been predicted as early as the mid-1990s, or even the early 1980s, only to be postponed to 2017, with applications for regulatory relief out to 2031, Diablo Canyon’s “good to go” till 2033 NRC seal of approval must be subjected to critical scrutiny.
Pacific Gas & Electric has applied to NRC for 20-year license extensions at Diablo Canyon 1 & 2. Friends of the Earth recently won a hearing from the NRC’s Atomic Safety and Licensing Board for a hearing on earthquake risks. A similar legal victory in 2013 led to the permanent closure of San Onofre 2 & 3 in southern CA.
(27.) July 20, 2015
“Downstream,” by Arnie Gundersen, Fairewinds Energy Education
Arnie Gundersen, Chief Engineer at Fairewinds Energy Education, has posted a blog entitled “Downstream,” about the radioactive risks to the Great Lakes from dozens of atomic reactors located on their shorelines, in both the U.S. and Canada.
Gundersen has served as expert witness for Beyond Nuclear et al. in numerous challenges to continued operations at risky reactors on the Great Lakes, including Palisades and Fermi 3 in Michigan, as well as Davis-Besse in Ohio.
(Beyond Nuclear’s pamphlet, “Routine Radioactive Releases from U.S. Nuclear Power Plants,” also shows it doesn’t take an accident to cause contamination of surface fresh water supplies, nor coastal oceanic fisheries for that matter. A map is included, indicating which watersheds are impacted by each operating reactor in the U.S.)
(28.) July 21, 2015:
“Muhich: Testing must be done to ensure safety of nuclear power plant in Covert”
In an op-ed in the Lansing State Journal, the Chairman of the Sierra Club’s “Nuclear-Free Michigan,” Mark Muhich of Jackson, has urged that the U.S. Nuclear Regulatory Commission require Entergy to perform long-delayed physical tests to determine the severity of age-related degradation at its Palisades atomic reactor in southwest MI.
(29.) July 22, 2015:
“Flaw Indications Found In RPV At Switzerland’s Beznau”
As reported by NucNet, flaw indications — or micro-cracks — not unlike those found at two Belgian reactors in 2012, have now been discovered at the Beznau-1 reactor in Switzerland, revealed by ultrasonic tests.
The Western European Nuclear Regulators’ Association has communicated the findings throughout the nuclear power industry, given the potential safety implications for reactor pressure vessels.
The Belgian nuclear regulatory chief, as well as materials scientists cited by Greenpeace International, have warned that the Belgian micro-cracking could implicate RPVs worldwide, and have consequently called for global ultrasonic testing as a safety precaution.
Beyond Nuclear et al. have called upon the U.S. Nuclear Regulatory Commission (NRC) to require such ultrasonic testing in the U.S., beginning with the severely age-degraded Palisades atomic reactor in Michigan.
The Swiss nuclear regulator, ENSI, is requiring Beznau-1’s owner/operator, Axpo, to do additional tests, to determine the size and location of the flaw indications, and to assess their safety significance. Beznau-1 is 46 years old.
Beznau-2 will be similarly examined, beginning in August.
(30.) August 7, 2015:
Terry Lodge, Toledo-based legal counsel for the environmental coalition (Beyond Nuclear, Don’t Waste MI, MI Safe Energy Future, and Nuclear Energy Information Service) intervening against Entergy Nuclear’s Palisades License Amendment Request (LAR), has filed a brief in defense of the coalition’s hard-won hearing. The LAR, if approved by the U.S. Nuclear Regulatory Commission (NRC), would allow Palisades to continue operating, despite loss of fracture toughness in its thermally stressed, neutron embrittled, age-degraded reactor pressure vessel (RPV) below safety screening criteria by Dec. 2016.
The coalition intervened on the matter on March 9, 2015. The NRC’s Atomic Safety and Licensing Board Panel (ASLBP) ruled in the coalition’s favor on June 18, 2015, granting an evidentiary hearing on the contention. Entergy appealed the ASLBP’s ruling to the full NRC Commission on July 13, 2015. The coalition’s rebuttal was filed on August 7, 2015.
On July 30, 2015, the Mayor Grand Rapids, MI — George K. Heartwell — wrote a letter to NRC’s Chairman, Stephen Burns, urging that the hearing be allowed to proceed, and that physical safety tests be required to be conducted on the status of dangerous embrittlement of Palisades’ age-degraded RPV. The southwestern section of Grand Rapids — the biggest city in west MI — is located within the 50-mile Emergency Planning Zone (EPZ) downwind of Palisades.
On August 4, 2015, Brian Huffine, President of the Board of Directors of the Palisades Park Country Club, wrote to NRC Chairman Burns on behalf of the Board and members of the community. The more than century-old Palisades Park represents Entergy Palisades nuclear power plant’s nearest neighbors, with 205 cottages located immediately next door to the south (just to the right of the mechanincal draft cooling towers shown in this photo on the left). He urged that physical tests of RPV capsule samples be conducted, in order to assure the safety integrity of the worst embrittled RPV in the U.S. The June 18 ASLBP ruling held in favor of considering the need for additional capsule tests at Palisades, before the next scheduled one in 2019.
On August 7, 2015, Wallace Taylor, an attorney representing the Sierra Club, filed a friend of the court brief in support of the ASLBP ruling granting the environmental coalition a hearing. The Sierra Club’s Nuclear-Free Michigan, founded and chaired by Mark Muhich, has taken a very active interest in safety risks at Palisades.
On August 10th, Rosemary Parker reported on this story in the Kalamazoo Gazette.
Parker provided a link to the letter by Grand Rapids Mayor George Heartwell, and quoted Mark Muhich, founder and chairman of Sierra Club Michigan Chapter’s Nuclear-Free Committee:
“We felt compelled to weigh in on this case because a rupture of the Palisades pressure vessel due to embrittlement could kill thousands of western Michigan residents, ruin thousands of square miles of the best agricultural land in the state, and poison Lake Michigan, the source of drinking water for millions of people,” Muchich wrote in a news release announcing the club’s filing of an amicus brief last week.
WSJM Radio of St. Joe, MI has also reported on this story, including a short clip of an interview with Sierra Club Michigan Chapter Nuclear-Free Committee Chairman Mark Muhich.
The Sierra Club press release, including a link to the amicus brief, is posted online here.
(31.) October 19, 2015:
Environmental coalition urges Mayor and City Commission of Kalamazoo to take action on Entergy Nuclear’s Palisades atomic reactor
Agenda and slides for Oct. 20 NRC ACRS mtg. on reactor pressure vessel embrittlement/pressurized thermal shock risk
On Oct. 20th, the U.S. Nuclear Regulatory Commission (NRC) Advisory Committee on Reactor Safeguards (ACRS) THERMAL-HYDRAULIC PHENOMENA SUBCOMMITTEE will hold a meeting on reactor pressure vessel (RPV) embrittlement/pressurized thermal shock (PTS) risk, as well as other risks associated with age-related degradation of RPVs.
The agenda and slides (see links below) have just been provided. As they indicate, the nuclear power utilities involved (PWROG, Pressurized Water Reactors Owners Group), including Entergy Nuclear at the Palisades atomic reactor on the Lake Michigan shore in Covert, MI (the worst embrittled RPV in the U.S.), have invoked proprietary information privileges/trade secrecy. The only public portion of the meeting will take place from 8:30 to 9:30am Eastern time. A public comment opportunity will be provided at the end of the public portion of the meeting, from 9:30 to 9:45am Eastern.
Concerned citizens and environmental group representatives are encouraged to listen-in to the public portion of the meeting, and to provide oral public comments by phone during the allotted time. The Call-In Number is (866) 822-3032, Passcode: 8272423
The WCAP document has been declared proprietary, so NRC will not provide it to the public. Only the open, public portion of the presentation slides have been provided by NRC to the public.
Links to limited documents made available to the public:
WCAP-17788 Volume 1, Introduction, Gordon Wissinger, AREVA Inc., PWR Owners Group;
(33.) November 9, 2015:
NRC dismisses Beyond Nuclear et al. interventions against Entergy Palisades RPV risks; environmental coalition vows to fight on
An 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.
(34.) November 23, 2015:
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.
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.
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” <[email protected]>
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.
–End–
—
Radioactive Waste Specialist
Beyond Nuclear
7304 Carroll Avenue, #182
Takoma Park, Maryland 20912Cell: (240) 462-3216[email protected]
www.beyondnuclear.org
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