UCS's Lochbaum's insights on RPV embrittlement risks at Entergy's Palisades atomic reactor

David Lochbaum, UCSDavid Lochbaum, Director of the Nuclear Safety Project at Union of Concerned Scientists (UCS, photo left), recently shared the following insights about reactor pressure vessel (RPV) embrittlement risks at Entergy's Palisades atomic reactor located in Covert, MI. And he gave us permission to share them:

"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. The NRC worked behind the scenes with the nuclear industry to revise the standards and now - magically - Palisades has ample margin.

So, the NRC colludes with industry to move the goal posts and then does not allow the coalition to contest the new location of the goal posts. Welcome to the Soviet Union of Michigan.

The NRC encourages public participation -- until the public seeks to participate.

To be fair (or less unfair) to the NRC, they don't have a clue where the embrittlement line is drawn. They are conducting an experiment in Michigan hoping that the redrawn line doesn't kill anyone. If no one gets killed in the experiment, the NRC might allow other reactors in other states to give it a try. Or maybe even redraw the line again.

Even if moving the goal posts was technically sound, doing it after conspiring with the industry while barring the public  moves the sleaze meter to 11. Someone really needs to take the NRC to the wood shed for antics like these. 

If no one gets killed in Michigan, it'll be due more to luck than the NRC working even-handedly with all its stakeholders to do the greatest good for the greatest number.

Thanks,

Dave Lochbaum

UCS

P.S. - I wonder which NRC senior manager will soon retire and find employment by Entergy at a very healthy salary?".

Beyond Nuclear hosted a MI and OH speaking tour featuring Lochbaum in April 2013, including southwest MI events focused on Palisades. Palisades had suffered three near-misses in just a two year time period, vying for worst such record in the entire country, as documented in Lochbaum's annual nuclear safety report that year, that year entitled Tolerating the Intolerable.

Lochbaum just published an "All Things Nuclear"/"Fission Stories" blog about yet another example of the abnormally high risks at Palisades.

NIW: "The Palisades Embrittlement Battle"

Entergy Nuclear's Palisades atomic reactor is located on the Lake Michigan shore in Covert, MI.Rosa Lin at Nuclear Intelligence Weekly (NIW) has written an article entitled "United States: The Palisades Embrittlement Battle" (reproduced here with permission from the publisher), about dueling appeals submitted to the full U.S. Nuclear Regulatory Commission (NRC).

Environmental intervenors, including Beyond Nuclear, have appealed an Atomic Safety and Licensing Board Panel's (ASLBP) rejection, on May 8th, of its contention against an Entergy Nuclear License Amendment Request (LAR) for regulatory relief regarding brittle fracture risk in Palisades' reactor pressure vessel (RPV) at colder temperatures. Entergy has just appealed the same ASLBP's granting of an evidentiary hearing, on June 18th, to the intervenors regarding an Entergy LAR for RPV ductile fracture risk at hotter temperatures.

NRC has recognized, on numerous occassions, that Palisades has the worst neutron radiation embrittled RPV in the U.S., but numerous other pressurized water reactors (including Point Beach, WI; Indian Point 3, NY; Diablo Canyon 1, CA; Beaver Valley 1, PA; and Davis-Besse, OH) are not far behind. Embrittled RPVs are at risk of pressurized thermal shock through-wall fracture, which would lead to core meltdown.

Lin quotes Beyond Nuclear, as well as Dave Lochbaum, Director of the Nuclear Safety Project at UCS:

Palisades "would not be allowed to operate if the standards applied to Yankee Rowe were applied" to it, said Dave Lochbaum of the Union of Concerned Scientists, referring to a plant shut down in 1992 due to embrittlement.

Another victory: ASLB denies Entergy request for document disclosure delay on brittle vessel fracture risk at Palisades!

NRC file photo of Entergy'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) that granted an environmental coalition's hearing on June 18th, has now denied Entergy Nuclear's request for a long delay in mandatory disclosure of documents in the proceeding. NRC staff has also been ordered to publish a hearing file sooner, rather than later.

The environmental coalition includes Beyond Nuclear, Don't Waste MI, MI Safe Energy Future--Shoreline Chapter, and Nuclear Energy Information Service of Chicago. Terry Lodge, a Toledo-based attorney, serves as its legal counsel. Arnie Gundersen, Chief Engineer at Fairewinds Associates, Inc. in Burlington, VT, serves as its expert witness.

The coalition's intervention concerns age-related degradation of Palisades' reactor pressure vessel (RPV), the worst embrittled in the U.S. Not only is Palisades' RPV at risk of colder temperature brittle fracture, but also to hotter temperature ductile fracture, or tearing. A through-wall fracture of the RPV would lead to a Loss-of-Coolant-Accident (LOCA), core meltdown, potential containment failure, and catastrophic release of hazardous radioactivity.

The environmental coalition has issued a press release about today's legal victory.

The ASLBP's July 9th ORDER is posted here.

The full docket of documents from this proceeding follows below, in chronological order:

(Entergy applied for regulatory relief under an "Equivalent Margins Analysis" under 10CFR50, Appendix G, because certain parts of its reactor pressure vessel at Palisades will fall below the Charpy V-Notch Upper Shelf Energy 50 foot-pounds screening criteria for metal degradation, as early as December, 2016. The risk is of through-wall ductile fracture, or tearing, at hotter temperatures):

On March 9, 2015 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." (The first front, re: colder temperature brittle fracture risk, is discussed in the final paragraph in this post, below.) 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 micro-cracking of RPVs in Belgium raises a red flag for similar cracking occurring worldwide. Greenpeace Belgium also issued a press release.

Beyond Nuclear posted a March 10 web entry about the March 9 filing.

On April 3, 2015 the NRC staff and Entergy filed oppositional responses to the environmental coalition's March 9 intervention petition.

Beyond Nuclear et al. filed a rebuttal to NRC's and Entergy's responses on April 10, 2015.

On June 18th, by a 2-1 split decision, the NRC ASLBP ruled in favor of environmental intervenors, granting an evidentiary hearing on the merits of its technical safety concerns. See the ASLBP ORDER AND MEMORANDUM, here.

On June 26th, the ASLBP published an ORDER Identifying Hearing Procedures and Scheduling Conference Call, posted here.

On June 29th, Entergy Nuclear filed a MOTION TO DEFER INITIAL DISCLOSURES, posted here.

On July 7th, on behalf of itself, as well as NRC staff and environmental intervenors, Entergy Nuclear filed a JOINT PROPOSAL ON MANDATORY DISCLOSURES AND SCHEDULE, posted here.

On July 8th, environmental intervenors filed a POSITION STATEMENT ON MANDATORY DISCLOSURES AND SCHEDULE, posted here.

On July 9th, the ASLBP issued its ORDER, denying Entergy's request for deferred mandatory disclosures, posted here.

The environmental coalition has also launched a separate and distinct, but parallel and overlapping, intervention proceeding regarding Palisades' colder temperature brittle fracture risk, due to neutron radiation bombardment embrittlement of the RPV, making it vulnerable to pressurized thermal shock. The Dec. 1, 2014 intervention petition was ruled against by the same ASLBP on May 8, 2015. The coalition appealed this ruling to the full NRC Commission on June 2, 2015. Links to the full docket of documents in this previous, ongoing proceeding are posted here.

Update on July 13, 2015 by admin

On July 13th, Entergy Nuclear appealed to the full NRC Commission, calling for the ASLBP's granting of the hearing to be overruled.

Environmental intervenors have 25 days to rebut Entergy's appeal, that is, by August 7th.

On July 14th, the ASLBP issued its Initial Scheduling Order, laying out the deadlines and due dates in the proceeding to come.

"Palisades 50," by Dave Lochbaum, UCS

Entergy Nuclear's Palisades atomic reactor, on the Lake Michigan shore in Covert, MIDave Lochbaum, Director of the Nuclear Safety Project at Union of Concerned Scientists (UCS), has penned another of his "Fisson Stories," entitled "Palisades 50," yet another installment in his watchdogging of Entergy Nuclear's problem-plagued atomic reactor.

Remarkably, during U.S. Nuclear Regulatory Commission CDBI (Component Design Bases Inspections) in 2014, 10 violations were discovered at Palisades, out of 20 components (with "vitally imporant safety functions") inspected. This was nearly three times the national average.

Lochbaum concluded: "The testing and inspection programs are supposed to demonstrate that the public is adequately protected.

That’s not happening.

That must get fixed before impaired safety components contribute to the next nuclear disaster."

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.

Fairewinds Energy Education has also produced a short, humorous educational video about RPV risks at Palisades.

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.

Update on June 24, 2015 by admin

Andrew Lersten at the Benton Harbor-St. Joe Herald-Palladium has reported on this story.

WSJM radio in s.w. MI has also covered this story.

WNDU/South Bend has also reported on this story.

Update on July 14, 2015 by admin

On July 13th, Entergy Nuclear appealed to the full NRC Commission, calling for the ASLBP's granting of the hearing to be overruled.

Environmental intervenors have 25 days to rebut Entergy's appeal, that is, by August 7th.