BRIDGMAN, MI --
Last Friday a coalition of regional and national safe energy groups submitted public comment in opposition to the emerging dangerous approval and operation of the D.C. Cook nuclear power plant. Indiana Michigan Power Company (IMPC) has requested exemption from inspection of nearly one-third of the penetration welds going into the reactor.
The coalition urges the U.S. Nuclear Regulatory Commission (NRC) to deny IMPC’s request for emergency relief, excusing IMPC from performing penetration weld inspections of the D.C. Cook, Unit 1, reactor pressure vessel (RPV) head. IMPC’s request suggests a 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 Ohio’s Davis-Besse Nuclear Power Station in 2002, when boric acid ate a football-sized, jagged hole through six inches 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. What is at risk is a core melt accident.
David Lochbaum, retired nuclear engineer advising the coalition, states that when boric acid residue is discovered around a nozzle, the American Society of Mechanical Engineers (ASME) code requires that the inside of the nozzle, and its J-groove weld, be examined for signs of cracking and leaking. This way, it can be conclusively determined whether the nozzles are, or are not, the source of the boric acid. According to Lochbaum, "Davis-Besse found boric acid atop the reactor vessel head and attributed it to borated water leaking from where the upper ends of the CRDM nozzles are bolted to the drive motor assemblies. FirstEnergy contended that flange leaking caused borated water to rain down on the reactor vessel head. They were wrong and paid a high price for their extremely poor judgement -- a record NRC fine and an extended outage costing nearly a billion dollars."
"In 2001-2002, FirstEnergy spent thousands of dollars to literally lobby the NRC not to regulate, and the result was the nearest to a catastrophic nuclear accident the industry had come since Three Mile Island. D.C. Cook is Déjà-Besse all over again,” observed Toledo attorney Terry Lodge, who prepared the coalition's comments.
“Approval by the NRC of the D.C. Cook emergency exemption is tantamount to aiding and abetting criminal negligence in the operation of an increasingly degraded nuclear reactor. This was precisely the situation at the Davis-Besse ‘hole-in-the-head’ reactor in 2002. Lessons learned? The NRC is incapable of learning lessons,” stated Michael J. Keegan with Don’t Waste Michigan.
Kevin Kamps of Beyond Nuclear said: "The NRC-commissioned, and Sandia National Laboratory-conducted, 1982 CRAC-II report, short for Calculation of Reactor Accident Consequences, shows how catastrophic a reactor core meltdown at Cook Unit 1 would be. The CRAC-II report, also known as the Sandia Siting Study, or as NUREG/CR-2239, provides the following predicted casualty figures for a meltdown at Cook 1: 1,900 peak early fatalities, or acute radiation poisoning deaths; 80,000 peak early radiation injuries; and 13,000 peak cancer deaths (latent cancer fatalities). The report also estimated $91.9 billion in property damage downwind and downstream of a Cook 1 meltdown. But as Associated Press investigative journalist Jeff Donn reported in his 2011 series "Aging Nukes" after the Fukushima nuclear catastrophe in Japan had begun, populations have soared around nuclear power plants like Cook since 1982, so casualties would be significantly higher today. And adjusting for inflation alone, but not accounting for the significant economic development in the area since 1982, property damage would now surpass $246 billion, when expressed as Year 2019 dollar figures. And, as Fukushima has shown, domino effect meltdowns are possible. If Cook 1's meltdown led to a consequent meltdown at the co-located Cook Unit 2, the casualties and property damage would more than double, CRAC-II reported."
Link to the 22-page document made public 10/13/2020
(The photographs begin on page 5 of 22 on the PDF counter, and continue to page 22 of 22.)
The coalition consists of Beyond Nuclear, Citizens Action Coalition of Indiana, Don't Waste Michigan, Michigan Safe Energy Future, Nuclear Energy Information Service of Illinois, and Nuclear Information and Resource Service.
The coalition public comment letter on D.C. Cook, Unit 1's request for relief from nozzle inspection, Code Case N-727, as it was sent to the NRC via email on Friday, October 9, 2020 from Terry J. Lodge, is linked here, and includes Dave Lochbaum's Summary Report, attached. To go directly to Lochbaum's Summary Report, use this link below:
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October 16, 2020