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ARTICLE ARCHIVE

Safety

Nuclear safety is, of course, an oxymoron. Nuclear reactors are inherently dangerous, vulnerable to accident with the potential for catastrophic consequences to health and the environment if enough radioactivity escapes. The U.S. Nuclear Regulatory Commission, Congressionally-mandated to protect public safety, is a blatant lapdog bowing to the financial priorities of the nuclear industry.

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Friday
Oct092020

Public Comment on D.C. Cook, Unit 1 request for relief from nozzle inspections, Code Case N-729

Submitted via email to the listed recipients:

Mssrs. Wall, Collins and Giessner:
Kindly review and respond to the attached letter from Beyond Nuclear, Don't Waste Michigan, Citizens Action Coalition, Michigan Safe Energy Future, Nuclear Energy Information Service, and Nuclear Information and Resource Service, opposing an emergency action request by IMPC, owner of D.C. Cook Nuclear Power Plant.
I have pasted the letter below and attached it as a .pdf. [linked here]


Thank you.
Terry J. Lodge, Esq.
(419) 205-7084
--------------------------------------------------------------------------------------------------------------

                            October 9, 2020

Scott Wall
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Via email only to scott.wall@nrc.gov

Jay Collins
Office of Nuclear Reactor Regulation
NRR/DNRL/NPHP
U.S. Nuclear Regulatory Commission
Via email only to jay.collins@nrc.gov

J.B. Giessner
Director of NRC Region III
U.S. Nuclear Regulatory Commission
Via email only to John.Giessner@nrc.gov

    RE: Public Comment on Indiana Michigan Power Company emergency request for D.C. Cook Nuclear Plant, Unit 1 for relief from ASME requirements, Code Case N-729, “Alternative Examination Requirements for PWR Reactor Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial Penetration Welds Section XI, Division 1”

Dear Mssrs. Wall, Collins and Giessner:

    The undersigned organizations, Beyond Nuclear (“BN”); Citizens Action Coalition (“CAC”); Don't Waste Michigan (“DWM”); Michigan Safe Energy Future; Nuclear Energy Information Service ("NEIS"); and Nuclear Information and Resource Service (“NIRS”), urge the Nuclear Regulatory Commission to deny Indiana Michigan Power Company’s (“IMPC’s”) request for emergency relief, excusing IMPC from performing immediately penetration weld inspections of the D.C. Cook, Unit 1, reactor pressure vessel head (RPV). IMPC’s request suggests a possibly serious threat to public health and safety from the continued operation of Unit 1, which is an aging and deteriorating nuclear power plant in its safety-significant systems, structures and components.  

    IMPC is balking at being required by ASME codes to inspect 18 penetration welds on the RPV because they are covered by insulation or visually blocked by equipment. Of 29 RPV penetration welds inspected so far, half showed boric acid crystal, corrosion, discoloration, staining, and streaming, evidently the result of borated reactor cooling water leaking onto the vessel. What is at risk is creation of a hole in the RPV, similar to what was discovered at Davis-Besse Nuclear Power Station in 2002, when boric acid ate a football-sized, jagged hole through over 6" of carbon steel of the RPV.

    But because of difficulty in accessing 18 penetration welds for inspection, IMPC now urgently seeks the NRC’s permission to skip mandated examinations of control rod drive mechanism nozzles for cracks, pleading hardship.

    The original RPV head for D.C. Cook, Unit 1 was replaced in 2006. The replacement head featured a new design for the thermocouple sealing assembly and reactor vessel head vent penetration.

    Sometime after the head replacement, IMPC reported recurring leakage from the thermocouple sealing assembly and reactor vessel head vent that resulted in boric acid residue collecting on the head. Such leakage sources were not present prior to the replacements. According to the well-known nuclear engineer and industry watchdog David Lochbaum, whose statement is attached, it appears that the new head designs introduced this mode of leakage. Mr. Lochbaum states, “The safety evaluations prepared for the head replacements apparently failed to detect this new failure mode, or the increased likelihood that a previously analyzed failure mode (i.e., unidentified leakage) would result.” Despite IMPC’s documented historical knowledge of leakage from the thermocouple sealing assembly and reactor vessel head vent line in the corrective action program, Mr. Lochbaum notes, “no apparent efforts were undertaken until very recently (circa 2018) to resolve the problems,” which IMPC now deems “unacceptable” despite being “acceptable to so many persons for so many years. Had IMPC fixed the problems then, it would not be in a self-induced dilemma now.”

    According to Lochbaum, the control rod drive mechanism nozzles, if cracked through- wall, may be the source of the boric acid residue found on the outer surface of the Unit 1 RPV. And, he says, “Leakage from the nozzles is not allowable  —  any leakage requires that the reactor be shut down within hours.”

    Lochbaum criticizes IMPC for arguing that the Unit 1 head was replaced in 2006 with a new and improved design, while not admitting that the new and improved design also featured new designs for the thermocouple sealing assembly and reactor vessel head vent penetration which have introduced the recurring leakage problems. He says IMPC “either ignores or improperly dismisses a lesson learnable from the Davis-Besse nozzle leakage case. The operational leakage monitoring program failed to detect years of nozzle leakage at Davis-Besse, raising very reasonable doubts as to why it might work now at Cook should a nozzle or two leak.”

    Lochbaum concludes that “It would be an undue burden on public health and safety for the NRC to approve the relief request sought by IMPC when the situation is self-inflicted by years of willful neglect by the company.”

    The undersigned organizations wholly agree. The nozzle inspections must occur now, without delay. FirstEnergy averted a loss of coolant disaster from the Davis-Besse hole-in-the-head by the narrowest of margins, a bulging 3/16" stainless steel liner in the RPV. There is plenty of energy available throughout the regional and electrical grid if Cook Unit 1 is taken out of service, now, for visual confirmation of the condition of the RPV. For the NRC to refuse stringent regulation, given the troubling history, will be gravely irresponsible. Load demand is down; electricity from Cook is unneeded now and will be unneeded for months to come.

    Please order IMPC to keep D.C. Cook, Unit 1 out of service and require the inspections immediately.  Thank you.

Sincerely,

/s/ Terry J. Lodge                       
Terry J. Lodge, Esq. (OH S.Ct. #0029271)
316 N. Michigan St., Suite 520
Toledo, OH 43604-5627
Phone (419) 205-7084
tjlodge50@yahoo.com
lodgelaw@yahoo.com
Counsel for Don’t Waste Michigan

Kevin Kamps, Radioactive Waste Specialist
Beyond Nuclear
6930 Carroll Avenue, Suite 400
Takoma Park, Maryland 20912
kevin@beyondnuclear.org
www.beyondnuclear.org

Michael J. Keegan, Convenor
Don't Waste Michigan
Monroe, MI
mkeeganj@comcast.net
(734) 770-1441

David Kraft, Director
Nuclear Energy Information Service
3411 W. Diversey #13
Chicago, IL 60647
(773) 342-7650
neis@neis.org
www.neis.org

Tim Judson, Executive Director
Nuclear Information and Resource Service
6930 Carroll Ave., Suite 340
Takoma Park, MD 20912
O: 301-270-6477
TimJ@nirs.org
www.nirs.org

Kraig Schultz
Michigan Safe Energy Future
kraig@schultzengineering.us
https://www.michigansafeenergyfuture.com/index.html

Kerwin Olson, Executive Director
Citizens Action Coalition
1915 W. 18th St., Suite C
Indianapolis, IN 46202
staff@citact.org
(317) 205-3535
Fax: (317) 205-3599
www.citact.org


Attachment: Lochbaum Summary [linked here]

Cc:

Paul Zurawski, Joe Mancuso
NRC Resident Inspectors D.C. Cook
U.S. Nuclear Regulatory Commission
Via email only to paul.zurawski@nrc.gov and joe.mancuso@nrc.gov

Michigan Governor Gretchen Whitmer
Via email only to  migov@exec.state.mi.us

Michigan Attorney General Dana Nessel
Via email only to miag@michigan.gov

Liesl Eicher Clark
Michigan Department of Environment, Great Lakes & Energy,
Via email only to EGLE-Assist@Michigan.gov

James Clift
Michigan Department of Environment, Great Lakes & Energy
Via email only to jamespclift@gmail.com and CliftJ@michigan.gov

R.J. Ancona
Michigan Public Service Commission
Via email only to MPSC_Commissioners@michigan.gov

Wednesday
Oct072020

Dave Lochbaum: 11-Page Summary Report on Donald C. Cook Unit 1's illegal Relief Request, with potential safety risk implications

Email from Dave Lochbaum, retired Union of Concerned Scientists Nuclear Safety Project Director, to Michael Keegan of Don't Waste Michigan:

From: David Lochbaum <davelochbaum@gmail.com>
Date: 10/07/2020 12:55 PM
Subject: Cook and leakage

Hello Michael:

Attached [linked here] is a short report I prepared on the Cook Unit 1 relief request.
 
I had a few hours this morning to followup on yesterday's response.
It seems clear that I&M's negligence at best or incompetence at worst created the situation that it now finds itself requesting NRC relief from. NRC should not condone or reward negligence and/or incompetence, particularly with public safety in the imbalance.
So, except for being unlawful and potentially unsafe, there's little wrong with I&M's request.
Feel free to distribute as you wish.

Thanks,
Dave Lochbaum
Wednesday
Sep302020

"Band-Aid" Reactor Vessel Head Repair Proposed at Palisades Nuclear Plant; NRC Asked to Approve Risky “Loophole” in ASME Code

NEWS FROM BEYOND NUCLEAR

For immediate release, Wednesday, September 30, 2020

Contact: 

Kevin Kamps, Beyond Nuclear, kevin@beyondnuclear.org, (240) 462-3216;
Michael J. Keegan, Don't Waste Michigan, mkeeganj@comcast.net, (734) 770-1441;
Terry J. Lodge, Legal Counsel for Beyond Nuclear and Don't Waste Michigan, tjlodge50@yahoo.com, (419) 205-7084
"Band-Aid" Reactor Vessel Head Repair Proposed
at Palisades Nuclear Plant

NRC Asked to Approve Risky “Loophole” in ASME Code

COVERT TOWNSHIP, MI -- Today Beyond Nuclear and Don’t Waste Michigan filed a Freedom of Information Act (FOIA) Request with the U.S. Nuclear Regulatory Commission (NRC), seeking documentation on the severely degraded reactor pressure vessel head at the half-century old Palisades nuclear power plant, located on the eastern shore of Lake Michigan, a few miles south of South Haven. 
 
On Monday, September 14, the NRC disclosed to the public this latest “Degraded Condition” at Palisades, in Event Report number 54897. This degradation is associated with a principal safety barrier, the reactor pressure vessel head.  One day later, on Sept. 15, NRC hastily and quietly announced a poorly noticed "Public Meeting," scheduled for Monday, September 21, to review this “Degraded Condition” with representatives from Palisades's owner, Entergy Nuclear.  At this September 21 meeting, Entergy Nuclear representatives presented NRC staff, from both the agency's national headquarters in Rockville, Maryland, as well as its Midwest/Region III headquarters in Lisle, Illinois, with an "emergent alternative request" to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, related to the repair of cracked Palisades reactor pressure vessel head penetrations.  Entergy is requesting a repair that will last only 1.82 years, instead of the industry-accepted standard repair that would last 27 years.
 
Entergy Nuclear has announced permanent closure of the Palisades atomic reactor in 1.7 years from now, by May 31, 2022. However, Entergy had previously announced, in December 2016, an October 2018 date certain closure for Palisades, only to later renege. NRC has rubber-stamped a 60-year operations license at Palisades, which does not expire until 2031.
 
"Entergy is looking for the NRC to approve a 'loophole' in the ASME code," stated Arnold Gundersen, nuclear engineer with Fairewinds Energy Education. Gundersen has previously served as Beyond Nuclear and Don't Waste Michigan's expert witness, regarding Palisades's reactor pressure vessel neutron radiation embrittlement pressurized thermal shock risks.
 
The ASME code is the national boiler and pressure vessel code. Any industrial application holding pressure must meet the ASME code. The ASME code is well thought out, and worked out, by experts, and dates back to the era of steam engines, but also applies to nuclear power plants.
 
In spite of the poorly noticed “Public Meeting,” several members of the public did attend the September 21 teleconference. The public watch-dogs and concerned citizens included: Kraig Schultz of Michigan Safe Energy Future (MSEF) in Grand Haven, MI: Michael Keegan of Don't Waste Michigan in Monroe, MI; Jan Boudart of Nuclear Energy Information Service (NEIS) in Chicago, IL; and Kevin Kamps of Beyond Nuclear in Takoma Park, Maryland.
 
MSEF's Kraig Schultz spoke out in opposition during the meeting, sharing his concern about undue, excessive risk being incurred by the public.  In a letter to NRC, dated Monday, Sept. 28, Mr. Schultz wrote: "On Monday, September 21, 2020, Palisades Nuclear Power plant operators announced that they are planning to skip important steps in repairing the cracks that have developed since 2018.  Palisades operators are asking the NRC to give it permission to skip these steps. …The NRC should not allow Palisades operators to bully it or force the approval of lower quality repair procedures.  Catastrophic failure events often do not happen in isolation.  They can result from cascading failures of seemingly tiny things that snowball into major events...”.
 
NEIS board member Jan Boudart expressed frustration with the NRC creating silos, and in doing so refusing to answer her questions, and avoiding meaningful dialogue on the extreme neutron radiation embrittlement of the Palisades reactor pressure vessel.  Her comments can be heard at the following link to an audio recording of the September 21 NRC-Entergy Palisades public meeting (the recording takes less than a minute to download and open): https://drive.google.com/file/d/17w2c2Elzi4t3Fnjqvx4Zf2wLIiqPI5Ki/view  
 
The comments by the four members of the public begin with Kraig Schultz at the 39 minute and 25 second mark on the audio recording. In addition to Schultz and Boudart, public comments also came from Kevin Kamps of Beyond Nuclear, and Michael Keegan of Don't Waste Michigan.  
 
"As we've documented for decades, Palisades has one of the worst neutron-embrittled reactor pressure vessels in the country, and in the world," said Kevin Kamps of Beyond Nuclear, based in Takoma Park, Maryland. "Activation of the emergency core cooling system, as due to failure of this 'Band-Aid' repair job proposed for the vessel head, could cause a pressurized thermal shock of the reactor pressure vessel, resulting in a through-wall fracture, and inevitable reactor core meltdown," Kamps added.
 
"Band-Aid" is not hyperbole, but an actual quote. It is the phrase that some workers at Entergy Nuclear Palisades are using, to refer to the proposed repair. The quote was overheard by an anonymous source in a position to know, and communicated to Kevin Kamps.
 
A 1982 report, commissioned by NRC, and carried out by Sandia National Laboratory in Albuquerque, New Mexico, estimated shocking casualty figures, and property damage, downwind and downstream of Palisades, in the event of a reactor core meltdown. The report is most commonly referred to as CRAC-II (CRAC is short for Calculation of Reactor Accident Consequences), but is also known as the Sandia Siting Study, or NUREG/CR-2239 (NUREG refers to Nuclear Regulation; CR is short for Contractor Report).The CRAC-II report estimated 1,000 "peak early fatalities" (acute radiation poisoning deaths), 7,000 "peak early [radiation] injuries," and 10,000 "peak cancer deaths" (latent cancer fatalities), to be expected downwind and downstream of a reactor core meltdown at Palisades, and consequent large-scale release of hazardous ionizing radioactivity into the environment. The CRAC-II study also estimated $52.6 billion in property damage downwind and downstream of a Palisades meltdown.
 
However, as reported by Associated Press investigative reporter Jeff Donn after the Fukushima nuclear catastrophe in Japan, in 2011, in a four-part series entitled "Aging Nukes," populations have soared around atomic reactors like Palisades since 1982, so casualty figures would be significantly worse in 2020. And when adjusted for inflation alone, the property damage figures, expressed in Year 2019 dollar figures, would surmount $141 billion. Donn also cited reactor pressure vessel neutron embrittlement safety standard rollbacks as a top example of NRC regulatory retreat, and capture of the so-called regulator by the industry.
 
Michael J. Keegan with Don’t Waste Michigan stated “This alternative repair amounts to an experiment that the NRC should not condone.  Entergy is a Limited Liability Company (LLC), and with tens of thousands of lives, all of Lake Michigan, and hundreds of billions of dollars in property damage on the line, the NRC must not approve this make-shift 'Band-Aid' repair.  This experiment must not be approved.”
 
For comprehensive documentation, please visit the Beyond Nuclear webpage at this link, http://www.beyondnuclear.org/safety/2020/9/26/documentation-re-entergy-palisades-request-to-nrc-for-permis.html, or reach out to the contacts listed above.

-30-

Beyond Nuclear is a 501(c)(3) nonprofit membership organization. Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic. The Beyond Nuclear team works with diverse partners and allies to provide the public, government officials, and the media with the critical information necessary to move humanity toward a world beyond nuclear. Beyond Nuclear: 7304 Carroll Avenue, #182, Takoma Park, MD 20912. Info@beyondnuclear.org. www.beyondnuclear.org.
Tuesday
Sep292020

FOIA Request, filed by Terry Lodge, legal counsel for Beyond Nuclear & Don't Waste MI

Monday
Sep142020

Documentation re: Entergy Palisades' request to NRC for permission to do a "Band-Aid" repair on a reactor vessel head penetration

On Monday, September 14th the U.S. Nuclear Regulatory Commission publicly disclosed the “Degraded Condition” at the half-century old Palisades atomic reactor in Covert, southwest Michigan, on the Lake Michigan shoreline.

The public disclosure took the form of Event Report Number 54897, posted at the NRC website, re: degradation of the principal safety barrier.

Here is the text of the Event Report, Number 54897 (note that the event -- discovery of degradation of the principal safety barrier -- actually happened on Friday, September 11th, when it was reported to the NRC by Entergy Nuclear; but NRC does not post Event reports over the weekend, so the public had to wait till Mon., Sept. 14th to learn of it):

DEGRADED CONDITION

"At 1930 EDT, on September 11, 2020, Palisades Nuclear Plant was conducting ultrasonic data analysis from reactor vessel closure head in-service inspections. During this analysis, signals that display characteristics consistent with primary water stress corrosion cracking were identified in head penetration 34. No leak path signal was identified during ultrasonic testing.

"The plant was in cold shutdown at 0% power and in Mode 6 for a refueling outage at the time of discovery. Repair actions will be completed prior to plant startup from the outage.

"This condition has no impact to the health and safety of the public.

"This report is being made in accordance with 10 CFR 50.72(b)(3)(ii)(A) for degradation of a principal safety barrier. This is the only indication that is currently present, however, if additional indications are found, they will also be repaired prior to the plant startup.

"The licensee notified the NRC Senior Resident Inspector."

In response to the discovery of degradation of the principal safety barrier at the Palisades atomic reactor, its owner, Entergy Nuclear, proposed a "Band-Aid" repair. "Band-Aid" is an actual quote, how some workers at Entergy Nuclear Palisades are referring to the proposed repair. The quote was overheard by an anonymous source in a position to know.

See below, for more information about this proposed "Band-Aid" repair job.