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"

Beyond Nuclear watchdogs Davis-Besse Shield Building cracking at NRC ACRS meeting

Beyond Nuclear's Kevin Kamps attended the Nov. 4, 2015 meeting of the U.S. Nuclear Regulatory Commission (NRC) Advisory Committee on Reactor Safeguards (ACRS) at the agency's headquarters in Rockville, MD. Grassroots watchdogs from across the country, including in southern CA, Philadelphia, Chicago, southeast MI, Toledo, and beyond, also phoned in.

(See the Beyond Nuclear website entry immediately below, for more background information on this meeting and subject matter. And see the website entry immediately above, for Dave Lochbaum of UCS's insights on Davis-Besse Shield Building cracking.)

FirstEnergy Nuclear Operating Company (FENOC) brought a large team of Davis-Besse engineering staff and executive management officials, as well as public relations directors and attorneys. FENOC presented a power point. (FENOC back up slides, referred to during the meeting, and even projected onto the screen in the room, have not been provided to the public. They were neither available to pick up in hardcopy form in the room during the meeting, nor were they emailed out to the public by the NRC ACRS point of contact.)

NRC staff also presented a power point, and had back up slides. A very large number of NRC staff were also present at the meeting.

Beyond Nuclear's Kevin Kamps has prepared notes/commentary/analysis, regarding the ACRS meeting, as well as regarding the FENOC and NRC power point slides posted above.

NRC ACRS to discuss Davis-Besse Shield Building cracking, Nov. 4-7

The U.S. Nuclear Regulatory Commission's (NRC) Advisory Committee on Reactor Safeguards (ACRS) will discuss FirstEnergy Nuclear Operating Company's (FENOC) application for a 20-year license extension (2017-2037) at its problem-plagued Davis-Besse atomic reactor on the Lake Erie shore in Oak Harbor, OH. However, while the ACRS discussion with FENOC and NRC staff officials is to address the entire license extension application, and NRC staff's Safety Evaluation Report (SER), a major focus will be the severe and worsening cracking of Davis-Besse's concrete containment Shield Building.

On Wed., Nov. 4, from 1 to 4pm Eastern, and continuing from 4 to 6pm Eastern, the NRC ACRS will discuss Davis-Besse's license extension application, despite its Shield Building's severe, and worsening, cracking. The call-in number is 1-866-822-3032; Passcode 8272423. 

As shown on the NRC ACRS agenda for the meeting, Agenda Items 3.1 and 3.2, from 1-4pm Eastern, Wed., Nov. 4th, will be on the Davis-Besse license extension application. And during the latter part of the 4-6pm Eastern time block on Wed., Nov. 4th (Agenda Item 4.2), Davis-Besse's license extension will again be discussed. The severe, and worsening, cracking of the concrete containment Shield Building is a major stumbling block, and will be a major focus of the discussion.

Then on Thurs., Nov. 5th, during the 3-6pm Eastern time block, Agenda Item 8.2 will again be about Davis-Besse.

(The Fri., Nov. 6th session from 1-6pm Eastern could also involve a continuation of the Davis-Besse discussion, as could the 8:30am to Noon Eastern time block on Sat., Nov. 7th. Presumably, during all open-to-the-public sessions, the telephone bridge line should be functional.)

One or more public comment opportunities should be provided throughout the agenda at various times. Concerned citizens, as well as media reporters, are encouraged to listen-in, and to take advantage of the public comment opportunities, to let the ACRS know what you are thinking or to ask questions.

As you can see at this NRC posting, this ACRS multi-day meeting re: Davis-Besse is one of the very last check boxes, before NRC rubber-stamps the 20-year license extension, despite the Shield Building cracking. (Of course, environmental intervenors will continue to oppose the license extension at every turn -- including their Nuclear Waste Confidence court appeal, now before the second highest court in the land, the U.S. Court of Appeals for the District of Columbia Circuit.)

BACKGROUND

As official intervenors with legal standing before NRC's Atomic Safety and Licensing Board (ASLB), Beyond Nuclear and environmental coalition allies have raised official contentions in opposition to the license extension, regarding the containment cracking, beginning in January 2012, and continuing till now. These numerous major legal filings have fallen on deaf ears at ASLB.

However, after having denied our documented allegations along the very same lines, for four years, FirstEnergy made startling admissions on September 23, 2015 at an ACRS subcommittee meeting. Beyond Nuclear issued a press release the very next day about these significant revelations of the serious risks FENOC has now acknowledged regarding the worsening containment cracking.

For example, FirstEnergy admitted that collapse of large chunks of concrete from the Shield Building's exterior surface is a risk to safety-related systems, structures, and components below.

At Page 247, lines 21 to 23, the transcript from the 9/23/15 NRC Advisory Committee on Reactor Safeguards subcommittee meeting records the following passage:

(Mr. Byrd for FirstEnergy):

“…the answer is, yes, it could impact components that are safety related.”

Mr. Byrd of FirstEnergy's tesimony continues on Page 247, line 25, to Page 248, line 11:

"We have, first of all, the auxiliary building, which you can see clearly on this picture is safety related. And so having concrete falling on top of the auxiliary building is definitely impacting a safety related structure. We also, on that area to the left-hand side, we have our [borated] water storage tank, which is safety related. And obviously if we had large sections of concrete falling off the building, that would also effect the [borated] water storage tanks. We recognize that potential right in the beginning when we identified this condition.”

It must be pointed out that, if FirstEnergy "recognize[d] that potential right in the beginning when we identified this condition,” that is in October 2011, when the cracking was first revealed, they did not share or communicate that recognition with the pubilc, the media, or its own shareholders. In fact, FirstEnergy did quite the opposite, as by countering and denying, at every turn, such warnings made by environmental intervenors in the license extension proceeding, from January 2012 till this year.

Another highlight of the NRC ACRS subcommittee meeting on 9/23/15, was ACRS subcommittee members' repeated questioning of FirstEnergy as to why Impulse Response (IR) testing was not a part of its Aging Management Plan for the Shield Building cracking -- why it was not a requirement, instead of merely an option, as FirstEnergy kept insisting. This ACRS criticism echoed one made by Beyond Nuclear et al. for the past four years as well, that FirstEnergy has significant blind spots, when it comes to even knowing how bad the cracking is.

And given FirstEnergy's false assurance -- that its monitoring alone will prevent the worsening (a half-inch, or more, every time it freezes) cracking from coming to the point where actual chunks of concrete spall off the exterior, and crash down -- such blind spots are a serious problem.

Of course, there is also the potential risk of an earthquake -- another point that came up more than once during the ACRS subcommittee meeting on 9/23/15. Seismic risk seems to be the one they are most concerned about.

This also fits a pattern environmental intervenors have tried to call attention to since January 2012. During their multi-year intervention and numerous major legal filings, the environmental coalition repeatedly quoted two NRC safety engineers' late 2011 warnings, shortly after the cracking came to light, obtained in June 2012 via a hard won response by NRC to a coalition Freedom of Information Act (FOIA) request:

An NRC safety engineer inspects the cracking of the Davis-Besse Shield Building wall, shortly after it was first revealed on Oct. 10, 2011."I think the greater concern is will the SB [Shield Building] stay standing, and not whether or not the decorative concrete will fall off. Because the licensee has not performed core bores to see if there is cracking in the credited concrete, do they have a basis to say that the structural concrete will maintain a Seismic II/I condition?" ---Pete Hernandez, NRC, 11/4/11 (see FOIA document B/9, Page 1, bottom paragraph);

"I am concerned that the concrete will fail in this region due to bending in this region even under small loads." ---Abdul Sheikh, NRC, 11/22/11 (see FOIA document B/26, point #2, last sentence).

Although FirstEnergy has done a relatively small number of core bores since, given the size of the Shield Building, the testing has been woefully inadequate, as intervenors have warned countless times in the ASLB license extension proceeding. Impulse Response (IR) testing could well show where more core bores are needed, but FirstEnergy refuses to do such comprehensive IR testing, and NRC staff refuses to require it, despite the ACRS subcommittee members' strong questioning on 9/23/15 as to why not.

In fact, the first FOIA document released to the environmental coalition (undated NRC document B/1) showed that the ACRS had seismic concerns at Davis-Besse even "prior to operation" (that is, before April 22, 1977). 

The arrow marks the location of sub-surface laminar cracking at the outer rebar mat (layer), located three inches beneath the exterior face concrete of the Shield Building. Still image from NRC Office of Public Affairs video.That early concern, and NRC staff safety engineers Hernandez and Sheikh's 2011 warnings, were vindicated by FirstEnergy's admissions, and ACRS's documented concern, on 9/23/15. Such concerns are all the more serious now, that the Shield Building is known to be severely cracked, and worsening with every freeze-thaw cycle.

An earthquake -- or another tornado strike, like the one that happened in June 1998 (see Page 3 of this 2010 Beyond Nuclear backgrounder on the many near-misses at Davis-Besse over the decades) -- could be that additional "small load" that causes the Shield Building to fail and collapse, impacting safety significant systems, structures, and components below. Beyond Nuclear et al. have been making these arguments for four years, but they have been attacked by FirstEnergy and NRC staff, and have been ignored by the Atomic Safety and Licensing Board. As revealed on 9/23/15, it seems that FirstEnergy and ACRS are admitting these are -- and have been all along -- valid concerns.

For more information, see the 8/8/2012 Beyond Nuclear backgrounder "What Humpty Dumpty Doesn't Want You to Know: Davis-Besse's Cracked Containment Snow Job." (see photo, above left).

Edison Never Told Federal Regulators Of San Onofre Equipment Design Flaw

As reported by KPBS, a watchdog has called for a federal invetigation into Southern CA Edison's having hidden from the U.S. Nuclear Regulatory Commission (NRC), at a 2006 meeting, its knowledge of flaws in the San Onofre Unit 2 & 3 replacement steam generators. A radioactive steam leak from a failed steam generator tube in January 2012 ultimately led to the permanent shutdown of the two reactors in June 2013. Incredibly, Southern California Edison is seeking to charge ratepayers billions of dollars extra for its "lost profits" and other costs related the permanent shutdown, even though it already charged them for the replacement steam generators, that it knew were defective nine years ago!