Entergy's problem-plagued Palisades atomic reactor, and the Great Lake and region of southwest Michigan it puts at dire, and increasing, risk.
Introduction
Nuclear watchdog groups have long been concerned about Pressurized Thermal Shock (PTS) risks due to the worst embrittled reactor pressure vessel (RPV) in the U.S., at Palisades, located on the Lake Michigan shoreline.
As described in a July 9, 1981 AP article (see below), "A severe overcooling and repressurization accident involving a weak vessel in one of the pressurized-water reactors could cause the reactor vessel--which contains the radioactive fuel rods used to produce heat and electricity--to crack like a hot glass jar thrust into cold water, officials of the Nuclear Regulatory Commission said in interviews this week."
A sudden decrease in temperature due to Emergency Core Cooling System activation, the consequent decrease in the intense pressure, followed by sudden re-pressurization (Pressurized Water Reactors, PWRs, operate at around 2,200 pounds -- or a ton -- of pressure per square inch) on the neutron radiation-embrittled metal of the RPV, could fracture it. A Loss of Coolant Accident (LOCA) would follow, then reactor core meltdown, risking containment failure and catastrophic release of hazardous radioactivity downwind, downstream, up the food chain, and down the generations.
The longer Palisades operates, the worse its risk of a breakdown phase accident, as due to PTS. (See Union of Concerned Scientists' "Bath Tub Curve" -- due to the curve's shape -- of break-in and breakdown phase risks, including nuclear power "data points," such as Three Mile Island Unit 2, Chernobyl, Davis-Besse's hole-in-the-head fiasco, and Indian Point's steam generator tube rupture.)
Relevant Regulations and Standards
NRC Regulations
"Alternate Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events," Federal Register, Vol. 75 p. 13 (75 FR 13). Washington, D.C. January 4, 2010.
U.S. Code of Federal Regulations (CFR) Title 10 "Energy," Part 50, "Domestic Licensing of Production and Utilization Facilities," U.S. Nuclear Regulatory Commission, Washington, D.C.
See 10 CFR 50.60. See also 10 CFR Part 50.61 (June 26, 1984), NRC's regulation on "Fracture toughness requirements for protection against pressurized thermal shock events." A link is also posted on NRC's website. (Page 929 to 933, or 98 to 102 of 212 on PDF counter) See also Part 50.61a (2010), "Alternate fracture toughness requirements for protection against pressurized thermal shock events." (Page 934 to 943, or 103 to 112 of 212 on PDF counter) A link is also posted at NRC's website. (Prior to final issuance of 50.61a, Entergy referred to proposed 50.61a, 72 FR 56275 -- see Entergy, 7/29/14, p.16 of 19 on PDF counter)
10CFR50 Appendix A, "General Design Criteria for Nuclear Power Plants," General Design Criterion (GDC) 1, "Quality Standards and Records," requires the structures, systems, and components important to safety to be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed. Where generally recognized codes and standards are used, they shall be identified and evaluated to determine their applicability, adequacy, and sufficiency and shall be supplemented or modified as necessary to assure a quality product in keeping with the required safety function.
GDC 31, "Fracture prevention of the reactor coolant pressure boundary," requires that the reactor coolant pressure boundary be designed with sufficient margin to assure that when stressed under operating, maintenance, testing and postulated accident conditions (1) the boundary behaves in a non-brittle manner and (2) the probability of rapidly propagating fracture is minimized. The design shall reflect consideration of service temperatures and other conditions of the boundary material under operating, maintenance, testing, and postulated accident conditions and the uncertainties in determining (1) material properties, (2) the effects of irradiation on material properties, (3) residual, steady state and transient stresses, and (4) size of flaws.
GDC 32, "Inspection of the reactor coolant pressure boundary," requires components that are part of the reactor coolant pressure boundary be designed to permit (1) periodic inspection and testing of important areas and features to assess their structural and leak tight integrity, and (2) an appropriate material surveillance program for the reactor pressure vessel. (The 10CFR50 Appendix A GDCs above are as described by Entergy on July 29, 2014; see page 10 of 19 on PDF counter)
See also 10CFR50 Appendix H, Reactor Vessel Material Surveillance Program Requirements. (Federal Register, Vol. 38, No. 136, July 17, 1973). As described by Entergy in its July 29, 2014 license amendment request (see page 11 of 19 on PDF counter), 10CFR50 Appendix H "ensures that changes in fracture toughness properties of ferritic materials in the reactor vessel beltline region of light water nuclear power reactors which result from exposure of these materials to neutron irradiation and the thermal environment are monitored. Under the program, fracture toughness test data are obtained from material specimens exposed in surveillance capsules, which are withdrawn periodically from the reactor vessel."
In addition to Appendix H, 10 CFR 50.60, "Acceptance criteria for fracture prevention measures for lightwater nuclear power reactors for normal operation," requires that all lightwater reactors meet the fracture toughness and the material surveillance program requirements for the reactor coolant pressure boundary set forth in 10 CFR 50, Appendix G [Fracture Toughness Requirements]...". (see Entergy, July 29, 2014, page 11 of 19 on PDF counter)
NRC Office of Regulatory Research (RES) staff also claim that the 2010 50.61a "Acceptance Criterion for TWC [Through-Wall Cracking] Frequency" was established consistent with RG 1.174 (see p.117 of 168 on PDF counter). See Revision 1 of RG 1.174 (Nov. 2002).
Regulatory Guide 1.154, "Format and Content of Plant-Specific Pressurized Thermal Shock Safety Analysis Reports for Pressurized Water Reactors" regulates annual through-wall crack risks. "Plants for which the computed RT(PTS) values, even with the neutron flux reduction, will still exceed the screening criteria are required, at least three years before exceeding the criteria, to submit a plant-specific safety analysis demonstrating that the risk associated with PTS events is acceptably low...[RG 1.154] describes one acceptable method for performing such safety analyses." (see May 30, 2002 NRC doc, page 2 of 7) RG 1.154 established a TWCF (Through-Wall Cracking Frequence) criterion, or limit, of 5 X 10(-6) per reactor year (see May 30, 2002 NRC doc, page 4 of 7). That is, a 5 in a million, or 1 in 200,000 risk of a TWC per reactor year. (See January 1987 in chronology below.)
Regulatory Guide 1.161, "Evaluation of Reactor Pressure Vessels with Charpy Upper-Shelf Energy Less Than 50 Ft.-Lb.," June 1995.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.162, "Format and Content of Report for Thermal Annealing of Reactor Pressure Vessels," dated February 1996, ADAMS Accession No. ML003740052).
Regulatory Guide 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence," March 2001, describes methods for determining reactor pressure vessel neutron fluence. (see Entergy, July 29, 2014, page 11 of 14 on PDF counter) (ADAMS Accession No. ML010890301.)
Draft Regulatory Guide DG-1299 (Proposed New Regulatory Guide), Draft Guidance on the Pressurized Thermal Shock Rule was released by NRC in late February/early March 2015. Here is the Regulatory Analysis re: DG-1299. Public comments are due May 12th.
(In addition: NRC Regulatory Guide 1.43 regulates RPV forgings; Reg Guide 1.154, "Format and Content of Plant-Specific Pressurized Thermal Shock Safety Analysis Reports for Pressurized Water Reactors" (January, 1987) regulates annual through-wall crack risks; and RG 1.162 regulates annealing.)
NUREG-0800, Revision 2, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," Branch Technical Position 5-3, dated March 2007 (ADAMS Accession No. ML070850035).
NUREG-1806, "Technical Basis for Revision of the Pressurized Thermal Shock (PTS) Screening Limit in the PTS Rule (10 C.F.R. 50.61): Summary Report," August 2007. (ADAMS Accession No. ML072830074.)
NUREG-1807, "Probabilistic Fracture Mechanics -- Models, Parameters, Uncertainty Treatment Used in FAVOR Version 04.1, Computer Code: Theory and Implementation of Algorithms, Methods, and Correlations," August 2007. Also see ORNL/TM-2012/566, "Fracture Analysis of Vessels -- Oak Ridge FAVOR, v12.1, Computer Code: User's Guide," Oak Ridge National Laboratory, Oak Ridge, TN, November 2012 (ML13008A016).
U.S. Nuclear Regulatory Commission, NUREG-1871, "Safety Evaluation Report Related to the License Renewal of Palisades Nuclear Plant," dated January 2007 (ADAMS Accession No. ML070600578).
NUREG-1874, "Recommended Screening Limits for Pressurized Thermal Shock (PTS)," March 2010. (ADAMS Accession No. ML 15222A848.)
NUREG-2163, Technical Basis for Regulatory Guidance on the Alternate Pressurized Thermal Shock Rule (10CFR50.61a), Draft Report for Comment, ML15058A677. Although variously November 2014 (as in DG-1299 immediately above) or Feb. 28, 2015, the document was not made publicly accessible (docketed) for public comment until March 2, 2015.
NUREG/CR-6817, PNNL-14268, "A Generalized Procedure for Generating Flaw-Related Inputs for the FAVOR Code, March 2004.
ASME (American Society of Mechanical Engineers) Standards
See Section XI ("Rules for Inservice Inspection of Nuclear Power Plant Components," NY, NY, various Editions, including 2013, and the following) of the ASME Boiler and Pressure Vessel Code, Appendix G, Fracture Toughness Criteria for Protection Against Failure, 1989 Edition with no addenda, up to and including the 2007 Edition with the 2008 Addenda, American Society of Mechanical Engineers, New York. Appendix VIII describes qualified examinations. See especially Category B-A and B-D reactor vessel weld inspections (per Entergy 7/29/14, p.16 of 19 on PDF counter). Re: the 2001 Edition with the 2003 Addenda, see the modification contained in NRC's regulation 10CFR50.55a(b)(2)(xiv, xv, and xvi) (per Westinghouse June 2014 WCAP, p.30 of 47 on PDF counter, see below).
See also Boiler and Pressure Vessel Code, Section III, "Rules for Construction of Nuclear Facility Components," (1998 Edition, or earlier), and Division 1, Subsection NB, Section NB-2300, "Fracture Toughness Requirements for Material," American Society of Mechanical Engineers, New York, NY.
ASTM (American Society for Testing and Materials) Standards
ASTM E208, Standard Test Method for Conducting Drop-Weight Test to Determine Nil-Ductility Transition Temmperature of Ferritic Steels, in ASTM Standards, Section 3, American Society for Testing and Materials, Philadelphia, PA.
ASTM E185-82, Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels, E706 (IF), in ASTM Standards, Section 3, American Society for Testing and Materials, Philadelphia, PA, 1993.
ASTM E23-93, Standard Test Methods for Notched Bar Impact Testing of Metallic Materials, in ASTM Standards, Section 3, American Society for Testing and Materials, Philadelphia, PA, 1993.
ASTM A370-92, Standard Test Methods and Definitions for Mechanical Testing of Steel Products, in ASTM Standards, Section 3, American Society for Testing and Materials, Philadelphia, PA, 1993.
ASTM E8-94, Standard Test Methods for Tension Testing of Metallic Materials, in ASTM Standards, Section 3, American Society for Testing and Materials, Philadelphia, PA, 1994.
ASTM E21-92, Standard Test Methods for Elevated Temperature Tension Tests of Metallic Materials, in ASTM Standards, Section 3, American Society for Testing and Materials, Philadelphia, PA, 1993.
ASTM E83-93, Standard Practice for Verification and Classification of Extensometers, in ASTM Standards, Section 3, American Society for Testing and Materials, Philadelphia, PA, 1993.
ASTM's Standard E509-86 "posits that re-embrittlement occurs at the same rate as before annealing but that embrittlement restarts from a point of greater ductility--a 'lateral shift' in the embrittlement curve," as reported in 1994 on Pages 11-12 (37-38 of 129 on PDF counter) in "Outlook on Life Extension" (see below).
Chronological History (timeline dates and citations in relevant AEC, NRC, Palisades, and/or environmental watchdog/intervenor documents)
January, 1948: R.D. Evans and R.O. Evans, "Studies in Self-Absorption in Gamma-Ray Sources," Reviews of Modern Physics, 20, 305-326.
1966: Mark Kirk of NRC RES, on April 2, 2013 (see below), stated that the "Program" -- presumably, the program to monitor Palisades' ever worsening RPV embrittlement -- "complies with ASTM-185 (1966)," adding that "10 CFR 50 Appendix H [was] not in force when Palisades was licensed."
March 14, 1967: Palisades receives its construction permit from the U.S. Atomic Energy Commission (AEC). Palisades' original 40-year operating license extended from 1967 to 2007.
June 1967: E. Storm and H.I. Israel, "Photon Cross Sections from 0.001 to 100 MeV for Elements 1 through 100," Los Alamos Scientific Laboratory of the University of California, Los Alamos, NM, LA-3753, UC-34, PHYSICS, TID-4500.
January 27, 1970: The Advisory Committee on Reactor Safeguards (ACRS), chaired by Joseph M. Hendrie (later to chair the NRC during the Three Mile Island meltdown), "REPORT ON PALISADES PLANT" sent to AEC Chairman Glenn T. Seaborg (discoverer of plutonium during the Manhattan Project). Even more than a year before Palisades began operations, the ACRS was already concerned about RPV embrittlement, writing "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...Prior to accumulation of a peak fluence of 10(19) nvt (> 1 Mev) on the reactor vessel wall, the Regulatory Staff should reevaluate the continued suitability of the currently proposed startup, cooldown, and operating conditions...". (emphases added) See this document here.
Or, see it below (on pages 3-6 of 129 on PDF counter), as environmental intervenors' Exhibit 1A opposing Palisades' 20-year license extension, filed September 16, 2005. (Note the ACRS's mention of annealing, as an option to address embrittlement. Although annealing has been floated any number of times over the past 45 years at Palisades, it has never been done.)
February 21, 1971: Palisades granted its operating license. As put by NRC staff in March 2013 (see page 8 of 15 on PDF counter): "Palisades implemented a surveillance program consistent with then-standard industry practice (i.e., implementation of the requirements of ASTM E185, "Standard Practice for Design of Surveillance Programs for Light-Water Moderated Nuclear Power Reactor Vessels." ASTM E185 has since been required by 10 CFR 50, Appendix H (see above).
April 1, 1971: Groeschel, R.C., Summary Report on Manufacture of Test Specimens and Assembly of Capsules for Irradiation Surveillance of Palisades Reactor Vessel Materials, CE Report No. P-NLM-019.
Summer 1975: American Physical Society report on light water reactor safety (Panofsky, Weisskopf, Bethe, Lewis, et al.), as cited in November 1981 Friends of the Earth newsletter article (see below).
1975: John G. Fuller's book, We Almost Lost Detroit, about the Fermi 1 partial meltdown in Monroe County, MI on Oct. 5, 1966, is published. At Page 243/297 on PDF counter, Fuller wrote:
A senior AEC [Atomic Energy Commission] engineer at the Oak Ridge Laboratory told Robert Gilette, who was writing a series of articles for Science, the prestigious publication of the American Association for the Advancement of Science: "What bothers me most is that after 20 years we are still making purely subjective judgments about what is important and what is not in reactor safety. Purely by decree some things, like the rupture of a reactor pressure vessel, are ruled impossible. To decide these things without some objective measure of probabilities is, to me, almost criminal." (emphasis added)
1977: Regulatory Guide 1.99, "Radiation Embrittlement of Reactor Vessel Materials," Revision 1.
November 1, 1977: NRC rubberstamps a 15% power uprate at Palisades. See NRC's cover letter and "Amendment to Provisional Operating License (Amendment No. 31)," approving the uprate to 2,530 Megawatts-thermal (MWt).
1977: As reported by NIRS in its 1988 report (p.22, see below), "...as early as 1977, test samples placed in B&W [Babcock & Wilcox] reactors were indicating that embrittlement was progressing at a faster rate than had been expected."
August 25, 1977: Perrin and Fromm, "Final Report on Palisades Pressure Vessel Irradiation Program: Unirradiated Mechanical Properties to Consumers Power."
1978: Palisades' first surveillance capsule pull, irradiated capsule ID# A-240, see "Final Report on Palisades Nuclear Plant Reactor Pressure Vessel Surveillance Program: Capsule A-240," ADAMS # for report 7907120344, according to NRC Commissioner Magwood response to Kraig Schultz of MSEF on May 28, 2013 (see below). Note, the ML# as provided by Commissioner Magwood does not work.
See also the second slide presented by Mark Kirk of NRC RES in South Haven, MI on April 2, 2013 (see below).
March 20, 1978: Severe overcooling accident at Rancho Seco, CA. (See also December 26, 1985 severe overcooling accident at Rancho Seco). As reported by NIRS in August 1988 (see below), "On March 20, 1978, the B&W designed Rancho Seco nuclear power plant experienced a PTS event precipitated by a control system failure. While replacing a light bulb in the integrated control system, an operator dropped the bulb into the control panel shorting out the control room instrumentation which eventually led to an overcooling of the reactor accompanied by repressurization of the vessel. The event is believed to represent the most severe and prolonged overcooling event to date with a change in temperature of 300 degrees F. per hour. [NRC safety engineer Demetrios] Basdekas was able to convince the NRC that control system failures were an unresolved safety issue, but the Commission continued to ignore these failures in their calculations on pressurized thermal shock."
March 13, 1979: Perrin, Fromm, Farmelo, Denning, and Jung, "Final Report on Palisades Reactor Pressure Vessel Surveillance Program: Capsule A-240 to Consumers Power," BCL-585-12.
Late 1970s and 1980s: As described in May 30, 2002 NRC doc (page 4 of 7), "large-scale experiments on prototypic RPVs subjected to pressure and temperature transients characteristic of PTS loadings were conducted at the Oak Ridge National Laboratory (ORNL) as part of the NRC-sponsored Heavy Steel Section Technology (HSST) research program." The experiments showed that a powerful PTS accident could cause "a crack [to initiate and propagate] through the vessel wall. In addition to large openings in the reactor vessel, this outcome involves significant additional deformation of the vessel," presenting "a potentially significant challenge to core cooling and containment integrity."
1980: Severe embrittlement discovered during routine testing at the Maine Yankee atomic reactor, significantly worse than models had predicted (as reported by AP article on July 9, 1981, see below).
February 27, 1980: "Failure of Main Feedwater Control System Resulting in Unacceptable Overcooling of Reactor Vessel," memorandum from Demetrios Basdekas (NRC Office of Nuclear Regulatory Research) to Thomas Murley, US NRC, Washington, D.C. Documented (at Page 3-28, and Footnote #91) in "Systems Interaction and Single Failure Criterion, Phase 3, Final Report," prepared by MB Technical Associates, San Jose, CA, commissioned by Swedish Nuclear Power Inspectorate, October 1983.
Winter, 1980-1981: Oak Ridge National Laboratory report on severe 1978 overcooling accident at Ranch Seco, CA.
Early to mid-1980s: As reported by NIRS in 1988 (p.22, see below), "RTndt limits had originally been set at 200 degrees Fahrenheit. However, as these limits were reached in the early to mid 1980s, the NRC began developing new limits within the framework of the PTS rule."
April 1981: Letter from Demetrios Basdekas to Morris Udall, as cited in November 1981 Friends of the Earth newsletter article (see below). The July 9, 1981 AP article (see below) reported that Basdekas based his letter on the Rancho Seco accident of 1978, as well as the Maine Yankee revelation of 1980.
April 1981: Letters sent by NRC to 44 PWRs, requesting information, including recent test results, regarding RPV vulnerability to PTS (see July 9, 1981 AP article, below).
April 21, 1981: Thadani, NRC memorandum re: Frequency of Excessive Cooldown Events Challenging Vessel Integrity.
May 1981: Responses sent by 44 PWRs to NRC, re: RPV vulnerability to PTS. NRC evaluates responses to determine if any modifications to reactor operations necessary. (See April 1981 above, and July 9, 1981 below).
June 20, 1981: Science News, as cited in November 1981 Friends of the Earth newsletter article (see below).
June 11, 1981: Meeting held at NRC HQ in Washington, D.C., to discuss overcooling accidents at US PWRs in CA (Rancho Seco, March 20, 1978) and FL (Crystal River, 1979), as well as more severe embrittlement at the Maine Yankee atomic reactor than models had predicted (discovered during routine testing in 1980). NRC then ordered 44 PWRs to test the vulnerability of the RPVs to PTS, as reported by AP on July 9, 1981 (see immediately below).
July 9, 1981: Associated Press article, "Vessels becoming vulnerable: Some reactors are losing their toughness," by Maureen Dea.
September 27, 1981: "Steel turned brittle by radiation called a peril at 13 nuclear plants," by Matthew L. Wald, New York Times.
November 1981: "Radiation Weakens Pressure Vessels," Not Man Apart, Friends of the Earth's newsletter, pages 16-17 (Palisades and many other PWRs discussed).
1982: R.C. Weast and M.J. Astle, Eds., "CRC Handbook of Chemistry and Physics, 63rd Ed.," CRC Press, Boca Rotan, FL.
March 28, 1982: "The Risk of a Meltdown," March 28, 1982 New York Times op-ed by NRC reactor safety engineer Demetrios Basdekas.*
November 23, 1982: NRC SECY-82-465, "Pressurized Thermal Shock." This document summarized the technical basis for using RT(PTS) as an indicator of the ability of the RPV to withstand a PTS event; RT(PTS), which stands for Reference Temperature(Pressurized Thermal Shock), is a measure of the material ductile-to-brittle transition temperature at the end of the RPV's licensed life (see May 30, 2002 NRC document, below, footnote #1). Here is the full citation: Policy Issue from J.W. Dircks to NRC Commissioners, Enclosure A: NRC Staff Evaluation of Pressurized Thermal Shock, November 1982, SECY-82-465, November 23, 1982, Division of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, D.C.
1982: As reported by NIRS in 1988 (see below, Page 22), "In a briefing to its Advisory Committee on Reactor Safeguards in 1982, the NRC staff considered RTndt limits of 230 and 250 degrees F for longitudinal and circumferential welds respectively. However, by 1985..." (see below).
October 31, 1982: As stated by NRC on February 28, 1984 (see below): "As of October 31, 1982, the [Palisades] licensee indicates that Capsule A-60 had accumulated approximately 8.7 X 10[(18)] n/cm2 (E>1MeV) neutron fluence. Since the neutron fluence accumulated by the Capsule is significantly greater than the predicted EOL [End of Life] fluence for the Palisades reactor vessel and Capsule A-240 has provided material properties that can be utilized to predict the EOL material properties of the Palisades reactor vessel, Capsule A-60 will provide no useful fracture toughness data and may be deleted from the surveillance program." Environmental intervenors' expert witness, Arnie Gundersen of Fairewinds Associates, Inc., cited this NRC passage in his December 1, 2014 declaration (see point #42 on page 16 of 40 on the PDF counter, below).
November 23, 1982: Dircks, W., U.S. Nuclear Regulatory Commission, Policy Issue (Notation Vote) to NRC Commissioners, SECY-82-465, "Pressurized Thermal Shock (PTS)," dated November 23, 1982 (Legacy Accession No. 8212060419).
1983: Palisades' second surveillance capsule pull, irradiated capsule ID# W-290, see "Analysis of Capsules T-330 and W-290, Consumers Power Company, Palisades Reactor Vessel Radiation Surveillance Program," ADAMS # for report 8411200379, according to NRC Commissioner Magwood response to Kraig Schultz of MSEF on May 28, 2013 (see below). Note, the ML# as provided by Commissioner Magwood does not work.
Per Table 6-40 on Page 6-39 of EPRI's December 11, 2011 report below, Capsule W-290 was located at 290 degrees, was removed at End of Cycle 5 in 1983, the Removal taking place at 5.21 Effective Full Power Years, with a Fluence of 9.26 X 10(18) neutons/square centimeter.
See also the second slide in Mark Kirk of NRC RES's presentation at an NRC public meeting in South Haven, MI on April 2, 2013.
1983: Palisades surveillance capsule pull, thermal capsule ID# T-330, see "Analysis of Capsules T-330 and W-290, Consumers Power Company, Palisades Reactor Vessel Radiation Surveillance Program," ADAMS # for report 8411200379, according to NRC Commissioner Magwood response to Kraig Schultz of MSEF on May 28, 2013 (see below). Note, the ML# as provided by Commissioner Magwood does not work.
1983: H.H. Hsu and E.J. Dowdy, "An Interpolation Technique for Gamma-Ray Attenuation Coefficients from 40 keV to 15 MeV," Nuclear Instruments and Methods, 204, 505-509.
June 1983: Edward Edelson, "Thermal Shock -- New Nuclear Reactor Safety Hazard?", Popular Science, pgs. 55-63.
January 1984: Sholly, "Pressurized Thermal Shock Screening Criteria," report prepared for Nuclear Information and Resource Service.
February 28, 1984: The NRC authorized deletion of metal surveillance sample coupon/capsule SA-60-1 at Palisades, from any further consideration, because its measured neutron exposure value exceeded/violated the allowed 1 sigma (20%) data variation level. See page 8 of 9 on PDF counter in NRC document ML020800206.
But as expert witness Arnie Gundersen of Fairewinds Associates, Inc. wrote on December 1, 2014 (see point #42, on page 16 of 40 on PDF counter, below): "Simply put, this particular sample was discarded precisely because it gave an answer that would have required Palisades to be shut down. It follows that the analytical basis for continuing operation is distorted, and since specific sample data has been disregarded, Entergy may be putting the public at risk by operating Palisades under unsafe conditions." See also October 31, 1982, above.
September 1984: M K Kunka and C A Cheney, "Analysis of Capsules T-330 and W-290 from the Consumers Power Company Reactor Vessel Radiation Surveillance Program," WCAP-10637.
1985: (continued from 1982, above) "...However, by 1985, the NRC sought to amend its regulations on pressurized thermal shock. The proposed amendments would establish an RTndt below which the risk from a PTS event is considered acceptable. These new reference temperatures established limits of 270 degrees F. for plate materials and axial welds and 300 degrees F. for circumferential welds." Reported in 1988 by NIRS, Page 22 (see below).
May 22, 1985: "There's No Room for Nuclear Utilities to Relax," Demetrios L. Basdekas, Letter to the Editor of the New York Times.
July 23, 1985: Analysis of Potential Pressurized Thermal Shock Events, 50 Fed. Reg. 29,937.
As reported by NIRS in August 1988 (see below), "The NRC adopted the PTS rule in July 1985. In less than six months from the date of its adoption, control system failure had precipitated a severe overcooling event at the Rancho Seco facility [see immediately below]...Yet the NRC still failed to acknowledge control system failures in their analysis of embrittlement and pressurized thermal shock."
December 26, 1985: A second severe overcooling accident at Rancho Seco, CA (see March 20, 1978 above, as well). UCS published a backgrounder on this accident, and the earlier one.
1986: As described by the agency, NRC "established the PTS Rule in response to an issue concerning the integrity of embrittled reactor pressure vessels (RPVs) in Pressurized Water Reactors (PWRs)." That is, the original PTS Rule, 10 CFR 50.61, was promulgated by NRC.
NRC Office of Regulatory Research (RES) staff also claim that the 2010 50.61a "Acceptance Criterion for TWC [Through-Wall Cracking] Frequency" was established consistent with the 1986 NRC Commission safety goal policy statement (see p.117 of 168 on PDF counter). See also p.160 of 168 on PDF counter of same document, re: 51 FR 28044, Safety Goal Policy (1986). RES summarizes this policy as: "QHOs < 0.1% of the total public risk (prompt & latent)." See also March 30, 2000, for "Modifications to Safety Goal Policy Statement" (SECY-00-0077).
August 7, 1986: Letter from K W Barry to NRC, "Response to Request for Additional Information - Pressurized Thermal Shock (PTS) Rule 10CFR50.61."
1986: See, Lorion v. U.S. Nuclear Regulatory Comm’n, 785 F.2d 1038, 1043 (D.C. Cir. 1986) (affording NRC’s
assessment of “[t]he susceptibility of steel reactor vessels to pressurized thermal shock” the “highest level of deference”).
January 1987: NRC Regulatory Guide 1.154, "Format and Content of Plant-Specific Pressurized Thermal Shock Safety Analysis Reports for Pressurized Water Reactors" regulates annual through-wall crack risks. "Plants for which the computed RT(PTS) values, even with the neutron flux reduction, will still exceed the screening criteria are required, at least three years before exceeding the criteria, to submit a plant-specific safety analysis demonstrating that the risk associated with PTS events is acceptably low...[RG 1.154] describes one acceptable method for performing such safety analyses." (see May 30, 2002 NRC doc, page 2 of 7) RG 1.154 established a TWCF (Through-Wall Cracking Frequency) criterion, or limit, of 5 X 10(-6) per reactor year (see May 30, 2002 NRC doc, page 4 of 7). That is, a 5 in a million, or 1 in 200,000 risk of a TWC per reactor year.
June, 1987: Residual Life Assessment of Major Light Water Reactor Components--Overview, Volume 1, NUREG/CR 4731, EGG-2469, Volume 1, June 1987, Editors V.N. Shah and P.E. MacDonald (see Server, Odette, Ritchie re: Reference temperature for nil ductility transition increasing from 40 degrees F to 280 to 290 degrees F or higher in extreme cases, due to RPV embrittlement with age). See, for example, page 105.
November 20, 1987: Regulatory Analysis, Revision 2 to Regulatory Guide 1.99, Radiation Embrittlement of Reactor Vessel Materials.
1987-1990: Engineering "Analysis Package for PTS study, (sic) Reactor Engineering Department, Palisades Plant.
May 1988: Regulatory Guide 1.99, Revision 2, Radiation Embrittlement of Reactor Vessel Materials, U.S. NRC.
August 1988: Chapter IV, "Embrittlement of Reactor Pressure Vessels and Reactor Pressure Vessel Supports in Pressurized Water Reactors," in The Aging of Nuclear Power Plants: A Citizens Guide to Causes and Effects, James Riccio and Stephanie Murphy, Nuclear Information and Resource Service, Pages 19-26.
See this section of this document, posted online here.
Also see it posted online as Exhibit 1D in environmental intervenors' September 16, 2005 Exhibits (see below, pages 18 to 27 of 129 on PDF counter).
Pages 24 to 26 of the report address embrittlement risks associated with reactor pressure vessel supports.
October 1988: Experimental Assessments of Gundremmingen RPV Archive Material for Fluence Rate Effects Studies, NUREG/CR-5201, MEA-2286.
April 3, 1989: Consumers Power Company (CPC) provided a revised report on reactor vessel fluence at Palisades for Cycles 1-8. Letter from R W Smedley (CPCo) to NRC, "Docket 50-255 - License DPR-20 - Palisades Plant - Compliance with Pressurized Thermal Shock Rule 10CFR50.61 and Regulatory Guide 1.99 Revision 2 - Fluence Reduction Status (TAC No. 59970)."
August 29, 1989: Letter from J C Hoebel (Westinghouse) to R A Klavon (CPCo), "Interim Report of Westinghouse Review of Consumers Power PTS Calculations."
April 20, 1990: Telecopy of E.P. Lippincott (Westinghouse) to O.P. Jolly (CPCo), "Final Report on Westinghouse Review of Consumers Power PTS Calculations."
May 17, 1990: Cover letter and report, "Analysis of the Reactor Pressure Vessel Fast Neutron Fluence and Pressurized Thermal Shock Reference Temperatures for the Palisades Nuclear Plant," Reactor Engineering Department, Palisades Nuclear Power Plant, Consumer Power Company.
This document is filed on the NRC ADAMS system under ML# ML052720270.
This document is also posted online as part of environmental intervenors' Exhibit collection opposing Palisades' 20-year license extension. See Pages 39 to 61 of 129 on PDF counter. This May 17, 1990 document was included as Exhibit 1I, in Petitioners' Appendix of Evidence, on September 16, 2005. See below.
As Arnie Gundersen wrote in his December 1, 2014 expert declaration (see below, in the "Palisades Embrittlement End of Life Chronology" in point #44 on page 18 of 23 (or 18 of 40 on PDF counter)), the Palisades Engineering Department (see page 4) projected the reactor pressure vessel's End of Life date as September 2001:
"With flux reduction incorporated in Cycle 9 and beyond, the PTS limit would be exceeded at the axial welds again, but not until about September, 2001. These predicted dates are far short of the assumed nominal plant operating license expiration date of March 2011."
Dated references in this document are posted separately in this chronology. However, two references were not dated, and so are posted here: RSIC Computer Code Collection DOT IV Version 4.3 (Report No. CC-429); RSIC Library Collection SAILOR DLC-76.
June 1990: NRC Office of Regulatory Research (RES) staff claim that the 2010 50.61a "Acceptance Criterion for TWC [Through-Wall Cracking] Frequency" was established consistent with the June 1990 SRM (see p.117 of 168 on PDF counter).
September 1990: End of Cycle 8 at Palisades.
Fall 1990: A replacement in-vessel dosimetry capsule, was to be fabricated and installed by Combustion Engineering, inserted into the W-290 capsule holder vacated following Cycle 5. Installation was to have occurred in the fall of 1990, according to a May 17, 1990 Consumers Power Co. document (Page 47).
October 1991: As reported by a consortium of nuclear-related publications, "Yankee [Rowe] had been 'voluntarily' shut down the previous October [1991] after the NRC staff recommended that it be laid up until questions regarding the degree of embrittlement of its reactor pressure vessel (RPV) could be resolved. They never were." See "Yankee Effort Foundered on Vessel," in "Outlook on Life Extension," Special Report to the Readers of Nucleonics Week, Inside N.R.C., and NuclearFuel, 1994, Page 11, posted online as Exhibit 1H (see September 16, 2005, below), page 37 of 129 on PDF counter.
February 26, 1992: As reported by Inside NRC on December 12, 1994 (see below), "The inability of Yankee Atomic Electric Co. to provide sufficient information about the integrity of Yankee's [Yankee Rowe's] reactor vessel, together with economic issues, prompted the Yankee (sic) to shut that unit permanently in 1992."
As reported by Nucleonics Week, Inside N.R.C., and NuclearFuel, "On February 26, 1992...the [Yankee Atomic Electric Co.] board voted to permanently close the unit. See "Yankee Effort Foundered on Vessel," in "Outlook on Life Extension," 1994, Page 11, posted online as Exhibit 1H (see September 16, 2005, below), page 37 of 129 on PDF counter.
March 6, 1992: NRC issued GL [Generic Letter] 92-01, Revision 1, "to obtain information necessary to assess compliance with requirements regarding RPV integrity in view of certain concerns raised in its review of RPV integrity for the Yankee Nuclear Power Station," as stated by NRC on May 19, 1995 (see below). "All licensees submitted the information requested by July 2, 1992." (see below)
April 14, 1992: "Cheap and Abundant Power May Shutter Some Reactors," by Matthew L. Wald, New York Times. RPV embrittlement is listed as a concern that forced the shutdown of the Yankee Rowe reactor in MA. Palisades is also mentioned as vulnerable to permanent shutdown, due to the major investment required to deal with its embrittled RPV. (See this article reproduced here, as well.)
May 1992: Lippincott, E.P., "Consumers Power Company Palisades Nuclear Plant Reactor Vessel Fluence Analysis," WCAP-13348.
July 2, 1992: "All licensees submitted the information requested by July 2, 1992," in response to NRC's GL 92-01, Revision 1, issued on March 6, 1992 (see above). The NRC staff completed its review of licensee responses in the fall of 1994 (see below).
1993: Palisades' third surveillance capsule pull, irradiated capsule ID# W-110, see "Analysis of Capsule W-110 from the Consumers Power Company Palisades Reactor Vessel Radiation Surveillance Program," ADAMS # for report 9406270173, according to NRC Commissioner Magwood response to Kraig Schultz of MSEF on May 28, 2013 (see below). Note, the ML# as provided by Commissioner Magwood does not work.
Per the December 11, 2011 EPRI report below (in Table 6-40, on Page 6-39), Capsule W-110 was located at 100 degrees, was removed at End of Cycle 10 in 1993, the Removal being at 9.95 Effective Full Power Years, with a Fluence of 1.66 X 10(19) neutrons per square centimeter.
See also slide 2 on Mark Kirk of NRC RES's presentation at the April 2, 2013 NRC public meeting in South Haven, MI.
July 8, 1993: "Pressurized Thermal Shock Potential at Palisades: History of Embrittlement of Reactor Pressure Vessels in Pressurized Water Reactors," prepared by Michael J. Keegan (rekeyed August 3, 2005).*
1994: "Outlook on Life Extension" published, a Special Report to the Readers of Nucleonics Week, Inside N.R.C., and NuclearFuel, 1994.
This document is also posted online as Exhibit 1H (see September 16, 2005, below), pages 33 to 38 of 129 on PDF counter, filed by environmental intervenors against Palisades' 20-year license extension.
RPV embrittlement is discussed, including its impact on license extension, the potential for annealing, etc. A chart on Page 10 (page 36 of 129 on PDF counter) lists Palisades as the first PWR in the US that would reach PTS screening criteria, between 1997 to 2005 -- years, or even an entire decade, before its then-current, original 40-year operating license expiration date of 3/14/2007.
March 9, 1994: NRC staff met with Consumers Power Company to discuss the licensee's program for further evaluation of the critical welds in their Palisades RPV. According to NRC, "the licensee planned to: gather additional materials properties data from its retired steam generators (welds fabricated using W5214 and 34B009 weld wire); institute an augmented surveillance program that would contain the limiting weld metal; evaluate annealing of the reactor vessel; consider instituting an 'ultra low leakage' fuel strategy. See page 9 of 129 on PDF counter of environmental intervenors' September 16, 2005 Exhibit, below.
May 1994: Peter, Lippincott, Wrights, and Madeyski, "Analysis of Capsule W-110 from the Consumers Power Company Reactor Vessel Radiation Surveillance Program," WCAP-14014.
June 21, 1994: Letter from D. Rogers (Consumers Power Company) to NRC, "Reactor Vessel Material Surveillance Capsule Test Report."
July 12, 1994: NRC staff issued an interim SER [Safety Evaluation Report] that stated: "based on previous nuclear industry data the Palisades reactor vessel was projected to reach the PTS screening criteria in 2004, prior to EOL [End of Life], 2007; staff SER noted that the PTS evaluation could change based on the information to be acquired from the SG [Steam Generator] welds." See also the related NRC staff-issued Commission Paper and NUREG Report on RPVs on October 28, 1994, as well as the December 9, 1994 NRC staff presentation to the ACRS (see below). See page 11 of 129 on PDF counter in environmental intervenors' Exhibits, September 16, 2005 (see below).
Fall of 1994: Following receipt and review of licensee supplements responding to [NRC] requests for additional information, the [NRC] staff completed its review of licensee responses to GL 92-01, Revision 1, in the Fall of 1994. (See March 6, 1992 and July 2, 1992 entries, above).
October 28, 1994: NRC staff-issued Commission Paper and NUREG Report on RPVs: "Status of Reactor Pressure Vessel Issues," SECY-94-267. See July 12, 1994 entry above, as well as December 9, 1994 entry below. This same document is also posted, at page 11 of 129 on PDF counter, in environmental intervenors' Exhibits, September 16, 2005 (see below), as Exhibit 1K.
As reported by Inside NRC on December 12, 1994 (see below), "As recently as October 28th, when NRC staff issued Secy 94-267, "Status of Reactor Pressure Vessel Issues," the agency projected that Palisades would reach its PTS screening criteria in 2004. On November 18, Consumers Power submitted a revised evaluation of the PTS issue that indicated the vessel would reach the critical level in 1999."
November 1, 1994: Palisades' licensee Consumers Power Company informed the NRC "staff by telephone that the chemistry data from the W5214 welds indicated higher copper contents than previously assumed...evaluation of the steam generator weld material also indicated a higher initial RT(NDT) value than the mean generic value." See entries immediately above and below. See page 11 of 129 on PDF counter in environmental intervenors' Exhibits, September 16, 2005 (see below).
Week Ending November 4, 1994: NRC Office of Nuclear Reactor Regulation, Items of Interest, Week Ending November 4, 1994, SECY-94-267, "Status of Reactor Pressure Vessel Issues." This document was also included as Exhibit 1L by environmental intervenors' opposing the Palisades 20-year license extension, on September 16, 2005. Remarkably, this document indicates the Palisades RPV would reach the PTS screening criteria by May, 1995! But, as indicated in the next entry immediately below, Palisades instead claimed the RPV was good to go till 1999!
November 18, 1994: Palisades' licensee, Consumers Power Company, "submitted their assessment of the impact of these new data on the RT(PTS) value. This assessment indicates that Palisades reactor vessel would reach the PTS screening criteria in 1999." See entries immediately above and below. See page 11 of 129 on PDF counter in environmental intervenors' Exhibits, September 16, 2005 (see below).
November 21, 1994: NRC staff met with the Palisades licensee, Consumers Power Company, "to discuss the new information." (see entries above and below; and page 11 of 129 on PDF counter in environmental intervenors' Exhibits, September 16, 2005 (see below))
November 30, 1994: NRC staff Request for Additional Information sent to Palisades' licensee, Consumers Power Company. (see entries above and below; and page 11 of 129 on PDF counter in environmental intervenors' Exhibits, September 16, 2005 (see below))
December 1994: NUREG-1511, "Reactor Pressure Vessel Status Report," U.S. Nuclear Regulatory Commission, Washington, D.C. (See: March 6, 1992; July 2, 1992; and fall of 1994 entries, above; and May 19, 1995 entry below.)
December 9, 1994: NRC staff presentation to ACRS, "Palisades Pressured (sic) Thermal Shock." See this document here.
Or, see Pages 7 to 13 of 129 on PDF counter of environmental intervenors' September 16, 2005 Exhibits (see below).
The NRC staff was still reviewing Consumers Power Company's November 18, 1994 submittal (see above). The NRC staff's evaluation was scheduled to be completed by January 31, 1995. As stated by the NRC staff, "Critical area[s] being assessed include: effect of thermal aging, heat treatment and test method on unirradiated reference temperature; best estimate chemical composition and nuclear industry data." The NRC staff went on to say, "Depending upon how the new data are used in the analysis the PTS screening limit could be reached before 1999. Staff will receive technical assistance from RES [NRC Office of Regulatory Research] contractor, ORNL [Oak Ridge National Laboratory]." The NRC staff concluded by noting these "Generic Implications of (the) New Data": (1) Review of Other RPVs with Palisades Weld Material (i.e. W5214 or 34B009 weld metal) -- other plants still satisfy PTS screening criteria and upper shelf energy criteria, and lower fluence or use of actual surveillance data; and (2) Other Plants that are Projected to be Near the PTS Screening Criteria Before End-Of-Life are being Assessed -- sensitivities being studied, and proactive measures may be appropriate.
December 12, 1994: "Palisades could reach its PTS screening limit earlier than expected," Inside NRC, reporting on a December 8, 1994 NRC Commissioners meeting.
This document is also posted online as Exhibit 1F in September 2005 exhibits, below, page 31 of 129 on PDF counter.
Testimony revealed Palisades could reach its PTS screening limits by 1995, or 1999, not 2004 or even 2007, as had been reported by NRC staff as recently as late October 1994, just six weeks earlier.
As Arnie Gundersen wrote in his December 1, 2014 expert declaration (see below, in the "Palisades Embrittlement End of Life Chronology" in point #44 on page 18 of 23 (or 18 of 40 on PDF counter)), this article documents a "downward revision [of projected End of Life Date for Palisades RPV] from 2004 to 1999."
First Quarter of 1995: As reported by the 12/12/94 Inside NRC article immediately above, "NRC wants to include the data [on reactor vessel weld integrity, that the vendor, ABB Combustion Engineering, wants to keep confidential] in a database called the Reactor Vessel Integrity Data Base, or RVID...RVID summarizes the properties of reactor pressure vessel materials for all plants; it is based on docketed information and is scheduled for public availability in the first quarter of 1995."
March 2, 1995: NRC to Palisades, "Issuance of Amendment Re: Pressure-Temperature Limits." NRC changes to Technical Specifications [TS], accommodating "reactor vessel fluence for an additional 4 effective full power years." How?! By revising "primary coolant system (PCS) pressure-temperature limits, power-operated relief valve setting limits, and primary coolant pump starting limits," and also by revising "the emergency core cooling system TS to render two high-pressure safety injection pumps incapable of injecting into the PCS when the PCS is below 300 [degrees] F rather than rendering both inoperable below 260 [degrees] F." It also "revises the pressurizer heatup to achieve consistency between design assumptions and TS limits."
May 19, 1995: NRC Generic Letter 92-01, Revision 1, Supplement 1: Reactor Vessel Structural Integrity, sent to PWR licensees.
This document is also posted here as a PDF.
And this document also posted as Exhibit 1J, in Exhibits, September 16, 2005, below, pages 62-64 of 129 on PDF counter.
This document is posted on the NRC's ADAMS system as ML# ML031070449.
Here is an excerpt from p.3 of 9:
"Recent NRC Staff Evaluations of RPV Structural Integrity Data for PTS Events
The staff issued a safety evaluation report to the licensee for Palisades on the variability of reactor vessel weld properties for the Palisades reactor vessel on April 12, 1995 [Ref. 2]. The staff agreed with the licensee's best estimate analysis of the chemical composition of the reactor vessel welds and concluded that continued operation through Cycle 14 (late 1999) was acceptable. As discussed previously, while performing the evaluation, the staff noted larger variability in the chemical composition of the welds compared to that assumed for the development of the PTS rule. The staff evaluated the implications of this larger variability on the PTS rule generic margins for the Palisades vessel using the same analytic methods as those used in formulating the rule. The staff has reviewed the other PWR vessels and, based upon currently available information, believes that the Palisades vessel will reach the PTS screening criteria by late 1999, before any other PWR." (emphases added)
As Arnie Gundersen wrote in his December 1, 2014 expert declaration (see below, in the "Palisades Embrittlement End of Life Chronology" in point #44 on page 18 of 23 (or 18 of 40 on PDF counter)), this documented NRC admission acknowledged a projected End of Life Date for the Palisades RPV of late 1999.
October 1995: Combustion Engineering report P-PENG-ER-006, Revision 0, "The Reactor Vessel Group Records Evaluation Program Phase II Final Report for the Palisades Reactor Pressure Vessel Plates, Forging, Welds, and Cladding," Combustion Engineering, Inc.
December 12, 1995: Letter from R. Smedley (Consumers Power Company) to NRC, "Preliminary Thermal Annealing Report, Thermal Annealing Operating Plan, Section 1.1, General Considerations, and Section 1.2, Description of the Reactor Vessel."
December 19, 1995: Code of Federal Regulations, 10 CFR 50.61, "Fracture toughness requirements for protection against pressurized thermal shock events," U.S. NRC, Washington, D.C., Federal Register, Volume 60, No. 243 (last updated on January 4, 2010). (per Westinghouse WCAP, June 2014, p.46 of 47 on PDF counter)
February 1996: Regulatory Guide 1.162, "Format and Content of Report for Thermal Annealing of Reactor Pressure Vessels."
June 21, 1996: SE-REA-96-122, "Transmittal of the Updated Palisades Reactor Vessel Fluence Submittal Response to NRC Request for Additional Information."
1998: As described by NRC RES staff, briefing the ACRS Subcommittee on Oct. 16, 2014 (see below), work began in earnest in 1998 to revise the PTS rule, leading eventually to 50.61a in 2010.
The way they described it is "Problem Identified & project started." This "Planning & Model Building" phase would take 3 1/2 years, till June 2001. (See p.114 of 168 on PDF counter) The "problem identified" was the fact that PWRs like Palisades would have to close "prematurely," before their operating license expired, due to PTS risks, under the 50.61 rule.
July 1998: Combustion Engineering Owners Group, CE NPSD-119, Revision 1, "Updated Analysis for Combustion Engineering Fabricated Reactor Vessel Welds Best Estimate Copper and Nickel Content," dated July 1998 (ADAMS Accession No. ML15103A309).
1999: As described by Entergy on July 29, 2014 (Page 7 of 19 on PDF counter), "In 1999, the NRC undertook a project to develop a technical basis to support a risk-informed alternative to the existing PTS rule. Realisitc input values and models and an explicit treatment of uncertainties were used to develop the alternative PTS rule, which was approved by the NRC and included in the Federal Register with an effective date of February 3, 2010." (see below; see also the publication of NRC's revised PTS rule on August 31, 2007, below)
2000: Surveillance capsule SA-240-1 removed from Palisades, the second most recent as of November 2014. As put by NRC staff in March 2013, this capsule "contained the limiting (that is, most embrittlement sensitive) weld from Palisades." (see #11, page 9 of 15 on PDF counter)
January 2000: Westinghouse, WCAP-15353, Revision 0, "Palisades Reactor Pressure Vessel Neutron Fluence Evaluation," dated January 2000 (ADAMS Accession No. ML003686582).
February 21, 2000: Consumers Energy letter to the NRC, "Palisades Reactor Vessel Neutron Fluence Reevaluation" (ADAMS Accession No. ML003686516). WCAP-15353, "Palisades Reactor Pressure Vessel Neutron Fluence Evaluation," dated January 2000, was submiitted to NRC by this letter dated February 21, 2000. The NRC approved the methodology described in WCAP-15353, by letter dated November 14, 2000 (see below).
In this Feb. 21, 2000 document, "The limiting RV [Reactor Vessel] welds, which are the beltline axial welds fabricated with weld wire heat no. W5214, were projected to reach the 10 CFR 50.61 PTS screening criterion limit in 2014." (as described by Entergy on July 29, 2014 -- see page 2 of 19 on PDF counter).
March 2, 2000: Letter forwarding overview of changes incorporated into WCAP-15353, Revision 0, with respect to previous fluence submittal dated April 4, 1996 (WCAP-14557, Revision 1) and copy of WCAP-15353, Revision 0 for review and approval.
March 30, 2000: "Modifications to Safety Goal Policy Statement" (SECY-00-0077). Mentioned by NRC RES in briefing to ACRS subcommittee on Oct. 16, 2014 (see p.160 of 168 on PDF counter in transcript/power point), as part of the "Linkage of PTS [Pressurized Thermal Shock] Limits on TWCF [Through-Wall Cracking Frequency] to CDF [Core Damage Frequency] & LERF [Large Early (Radioactivity) Release Frequency] Policy Decisions." RES staff summarized these modifications as: "CDF<1X10(-4)/ry" [Core Damage Frequency less than 1/10,000 per reactor-year]; "CDF & QHO limits for generic decisions." [Does QHO stand for Quantatitive Health Objectives?]
June 23, 2000: NRC SECY-00-0140, "Reevaluation of the Pressurized Thermal Shock Rule (10 CFR 50.61) Screening Criterion."
November 14, 2000: NRC letter to Consumers Energy, approving the methodology described in WCAP-15353 (see February 21, 2000 entry above). NRC effectively blessed Palisades as adequately safe, vis a vis PTS risks, not just till 2007, but till 2011, to correspond with an NRC rubberstamped "mini" license extension -- so that Palisades could "re-capture" its four-year construction period, from 1967 to 1971, and stick it onto the end of its initial 40-year operating license (1967-2007). Thus, Palisades would now be approved to operate till 2011, including vis a vis PTS risks. See the NRC's approval of the "mini" (4 year) license extension, immediately below.
December 14, 2000: NRC approves Palisades' requested "mini" license extension (see immediately above).
2001 to 2002: On Oct. 16, 2014, Mark Kirk of NRC RES, in a briefing to an ACRS subcommittee, said that an operable code in the development of what would become 50.61a was achieved (see p.19 of 168).
2001: Light Water Reactors: Overview, "Embrittlement of Nuclear Reactor Pressure Vessels," G.R. Odette and G.E. Lucas, JOM [Journal of Metallurgy], 53 (7), 2001, pp. 18-22.
March 2001: Regulatory Guide 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence," describes methods for determining pressure vessel neutron fluence, per July 29, 2014 Entergy document (page 11 of 19 on PDF counter). It provides a general description of the various NRC regulations addressing potential RPV embrittlement, and is available at ADAMS Accession No. ML010890301.
March 16, 2001: NRC SECY-01-0045, a periodic status report updating Secy-00-0140, "Reevaluation of the Pressurized Thermal Shock Rule (10 CFR 50.61) Screening Criterion" (see June 23, 2000, above).
May 2001: Framatome ANP report BAW-2398, "Test Results of Capsule SA-240-1 Consumers Energy Palisades Nuclear Plant."
June 2001: "Consensus solution strategy (computer code specification) available," according to NRC Office of Regulatory Research (RES) staff on Oct. 16, 2014 in their briefing to the ACRS (see p.114 of 168 on PDF counter). This concluded the 3 1/2 years of "Planning & Model Building" begun in Jan. 1998 (see above), the "problem" had been "identified" and the "project started." Thus began RES's transition to the "Computing/Thinking/Defending" phase of 50.61a's development, which took four years, till June 2005 (see below; see also the stepping stones of Dec. 2001, Dec. 2002, and Dec. 2004, below).
September 2001: PWR and BWR Pressure Vessel Fluence Calculation Benchmark Problems and Solutions (NUREG/CR-6115). ("Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence")
October 5, 2001: NRC SECY-01-0185, another periodic status report updating SECY-00-0140, "Reevaluation of the Pressurized Thermal Shock Rule (10 CFR 50.61) Screening Criterion" (see June 23, 2000, above), and SECY-01-0045 (see March 16, 2001, above).
December 2001: "Computer code available": a stepping stone in the four-year-long "Computing/Thinking/Defending" phase of NRC RES's development of 50.61a. (see p.114 of 168 on PDF counter, and June 2001 above)
March 2002: Westinghouse report, WCAP-15805, Revision 0, "Analysis of Capsule X from the Carolina Power & Light Company H.B. Robinson Unit 2 Reactor Vessel Radiation Surveillance Program."
May 30, 2002: NRC SECY-02-0092, Status Report: Risk Metrics and Criteria for Pressurized Thermal Shock. This is "the third report of the [NRC] staff's progress in reevaluating the [50.61] rule's technical basis." (see also, above: June 23, 2000; March 16, 2001; and October 5, 2001.) Tellingly, NRC admits (on page 5 of 7) that an array of PTS RPV failure scenarios "have not yet been studied in detail. Consequently, the margins between TWCF [Through-Wall Cracking Frequency] and PTS-induced CDF [Core Damage Frequency] and PTS-induced LERF [Large Early Release Frequency], remain uncertain." (emphasis added) The NRC staff had scheduled discussion with ACRS on this in July 2002, and anticipated initiating a potential rulemaking via NRR by December 2002.
November 2002: Revision 1 to Reg. Guide 1.174.
On Oct. 16, 2014, NRC RES staff, in a briefing to an ACRS subcommittee, summarized RG 1.174 as: Mean CDF = 10(-4)/ry; Delta-Mean CDF = 10(-5)/ry; Mean LERF = 10(-5); Delta-Mean LERF = 10(-6). [CDF is Core Damage Frequency; LERF is Large Early (Radioactivity) Release Frequency; ry is reactor-year.] See p.160 of 168 on PDF counter. RES staff asserted a "Linkage of PTS Limits on TWCF [Through-Wall Cracking Frequency] to CDF & LERF Policy Decisions."
December 2002: "Initial computational results available": another stepping stone in the four-year-long "Computing/Thinking/Defending" phase of NRC RES's development of 50.61a. (see p.114 of 168 on PDF counter, as well as June and Dec. 2001, above)
January 2003: Westinghouse report, WCAP-15958, Revision 0, "Analysis of Capsule V from Pacific Gas and Electric Company Diablo Canyon Unit 1 Reactor Vessel Radiation Surveillance Program."
March 28, 2003: Surveillance capsule W-100 removed from Palisades, the fourth, and most recent, surveillance capsule pull and test, as of November 2014. (See NRC staff, March 2013, #11, page 9 of 15 on PDF counter).
Also see NRC Commissioner Magwood letter to Kraig Schultz of MSEF on May 28, 2013 (see below), which describes Palisades surveillance capsule pull, irradiated capsule ID# W-100, see "Analysis of Capsule W-100 from the Consumers Power Company Palisades Reactor Vessel Radiation Surveillance Program," ADAMS # for report ML040910069 (see March 25, 2004, below).
See also slide 2 on Mark Kirk of NRC RES's presentation at the April 2, 2013 NRC public meeting in South Haven, MI.
February 2004: "Analysis of Capsule W-100 from the Nuclear Management Company Palisades Reactor Pressure Vessel Material Surveillance Program," Reactor Pressure Vessel Surveillance Capsule W-100 Test Report, BWXT Services, Inc. (See Attachment 1, Pages 6 to 296 of 312 on PDF counter in March 25, 2004 document below.)
February 11, 2004: "Fluence Analysis for Reactor Vessel Surveillance Capsule W100," Reactor Pressure Vessel Surveillance Capsule W-100 Test Report," Westinghouse (See Attachment 2, Pages 297 to 312 of 312 on PDF counter in March 25, 2004 document immediately below.)
March 25, 2004: NMC to NRC, "Reactor Pressure Vessel Surveillance Capsule W-100 Test Report."
July 7, 2004: Palisades, License Amendment Re Measurement Uncertainty Recapture Power Uprate.
July 2004: Westinghouse report, WCAP-16251-NP, Revision 0, "Analysis of Capsule X from Entergy's Indian Point Unit 3 Reactor Vessel Radiation Surveillance Program."
September 2004 [Manuscript Completed]: NRC, NUREG/CR-6858, RELAP5 Thermal Hydraulic Analysis to Support PTS Evaluations for the Oconee-1, Beaver Valley-1, and Palisades Nuclear Power Plants. Despite its 608-page length, "This report is [but] one of a series of 21 reports that provide the technical basis that the staff will consider in a potential revision of 10CFR50.61." (Note that the "Date Published" has been left blank on the title page, page 3 of 608 on PDF counter.)
October 26, 2004 (Date Submitted; Revised December 14, 2004): Generalization of Plant-Specific Pressurized Thermal Shock (PTS) Risk Results to Additional Plants, Table 1. Plants with highest RTNDT, U.S. NRC.*
November 24, 2004: Internal NRC staff email written by Stephanie Coffin to Stephen Hoffman and cc'd to several others, re: a November 22, 2004 phone call with Consumers Power Co./Nuclear Management Co. officials re: Palisades RPV PTS risks. Coffin conveys that if NRC does not publish the new PTS rule "in time for them" -- Palisades "currently exceed[s] the screening criteria in 2014 -- "they will submit the Master Curve exemption in 2007." Instead of doing that now, Palisades will instead "be managing it in accordance with the May 27, 2004 guidance from Reyes to the Commissioners," and "They are following Point Beach and Beaver Valley closely." Coffin advised Palisades on the flux reduction requirements of NRC's current rule, and suggested Palisades review Point Beach's submittal, and NRC's associated SER [Safety Evaluation Report]. (In late 2012, Coffin would write to environmental watchdogs at Palisades that NRC Chairman Macfarlane was too busy to meet with them. This, soon after Macfarlane enthusiastically told the watchdogs that she wanted to meet with them about Palisades, and just to write her office to arrange a mutually agreeable date.)
This document is also posted online as part of the Exhibits collection dated September 16, 2005, filed by environmental intervenors against the Palisades 20-year license extension (see Exhibit 1G).
December 1, 2004: ACRS (Joint Subcommittees: Materials and Metallurgy, Thermal Hydraulic Phenomena, Reliability and PRA), dialogue between ACRS Member, Dr. Wallis, and NRC RES staffperson Mark Erickson-Kirk, reveals that "This flaw distribution is based on rather skimpy evidence...". Yet another supposed basis for confidence in NRC PTS risk safety regulations is found to be seriously wanting.
See this document posted here.
Also see it posted at pages 28 to 30 of 129 on PDF counter, in September 16, 2005 Exhibits (see below).
December 2004: "Pretty good computational results available & documented": another supposed stepping stone in the four-year-long "Computing/Thinking/Defending" phase of NRC RES's development of 50.61a. (see p.114 of 168 on PDF counter; June & Dec. 2001, and Dec. 2002, above)
2005-2007: NRC rubberstamped Palisades' 20 year license extension in 2007 (approving operation from 2011 to 2031), despite two years of widespread, determined grassroots resistance by a coalition of environmental groups and concerned local residents. Palisades' embrittled RPV, vulnerable to PTS, was a major concern raised during the intervention against the license extension. During the course of the intervention proceeding, environmental intervenors were assured by NRC that Palisades would have to have a plan for dealing with RPV embrittlement/PTS risks by 2011, or else the reactor would have to be permanently shutdown by 2014 (see Alice Hirt's letter to NRC Commissioner Magwood, March 25, 2013, below).
March 22, 2005: Palisades Nuclear Plant, Application for Renewed Operating License, (ADAMS Accession No. ML050940429).
As Arnie Gundersen wrote in his December 1, 2014 expert declaration (see below, in the "Palisades Embrittlement End of Life Chronology" in point #44 on page 18 of 23 (or 18 of 40 on PDF counter)), this Palisades license extension application acknowledged a projected EOL [End of Life] date for the Palisades RPV of 2014, a date that clearly came out on the record as a broad environmental coalition intervened against the license extension in a contested NRC ASLB proceeding (2005-2007).
April 5, 2005: Letter Transmitting Palisades Nuclear Plant Application for Renewed Operating License.
June 2005: "ACRS Approval": supposed culmination of the four-year-long "Computing/Thinking/Defending" phase of NRC RES's development of 50.61a. (see p.114 of 168 on PDF counter, and June 2001, Dec. 2001, Dec. 2002, and Dec. 2004, above) Hence, the beginning of RES's four-year, "Deciding & Approving" phase.
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 (the first contention, on page 4, regards The license renewal application is untimely and incomplete for failure to address the continuing crisis of embrittlement).*
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).*
See also Petitioners' Appendix of Evidence (129 pages), which accompanied its September 16, 2005 Reply.
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. The transcript is also posted here as a PDF.
November 30, 2005: NRC Requests for Additional Information Related to License Renewal for the Palisades Nuclear Plant, RAI B2.1.16-2.
January 13, 2006: "NMC Response to NRC Requests for Additional Information Dated November 30, 2005 Related to License Renewal for the Palisades Nuclear Plant," RAI B2.1.16-2.
March 7, 2006: ASLBP, "Memorandum and Order, Ruling on Standing, Contentions, and Other Pending Matters," dismissing environmental coalition intervention against Palisades' 20-year license application. RPV embrittlement/PTS risk contention addressed from Pages 31 to 41 of 90 on PDF counter.
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, pages 3 to 9).*
March 20, 2006: Environmental coalition letters, to U.S. Senators Carl Levin (D-MI) and Debbie Stabenow (D-MI), requesting they initiate a Government Accountability Office (GAO) investigation into embrittlement risks at Palisades in particular, but also into NRC weakening of PTS safety standards nationwide.*
Spring 2006: Consumers Energy power point presentation to the Michigan Public Service Commission, highlighting "Reactor vessel embrittlement concerns" at Palisades.*
May 18, 2006: "Halting 20 Extended Years of Risky Reactor Operations and Radioactive Waste Generation and Storage on Lake Michigan at Palisades Nuclear Power Plant: Comments on NUREG-1437, Supplement 27 to the Generic Environmental Impact Statement for License Renewal of the Palisades Nuclear Power Plant," submitted by an environmental coalition to NRC (see section XI., Plant Aging Increases Accident Risk, pages 26-27). See List of organizations opposing 20-year license extension at Palisades nuclear power plant.*
May 2006: "Commission direction to begin rulemaking (SECY-06-0124)": the first supposed stepping stone during RES's so-called "Deciding & Approving" phase in the development of 50.61a. See page 114 of 168 on PDF counter, as well as June 2005 above.
2006: Nuclear Mgmt. Co. (Palisades Nuclear Plant), CLI-06-17, 63 NRC 727, 730 (2006) (affirming the rejection of an RPV embrittlement contention in the Palisades license renewal proceeding and “agree[ing] with the Board’s assessment that [it] consists of only general allegations and obvious truisms (i.e., that the longer the reactor pressure vessel is in service, the more vulnerable to embrittlement it becomes).”
September 19, 2006: Harden, P., "Revision to Reactor Vessel Surveillance Coupon Removal Schedule," Nuclear Management Company, LLC, to US NRC (ADAMS Accession No. ML062630071).
2007: Palisades' original 40-year operating license expired this year. However, a number of years earlier, Palisades persuaded NRC to grant it a "mini" license extension of four years, extending the license from 2007 to 2011. Palisades and NRC referred to this as "recapturing" the 1967 to 1971 construction period, and adding it onto the end of the 1967 to 2007 original 40-year license. However, on January 17, 2007, NRC approved an additional 20-year license extension (2011 to 2031), despite widespread environmental opposition, and an intervention by a coalition lasting from 2005 to 2007.
2007: A metal surveillance capsule/coupon was scheduled to be pulled and tested at Palisades, but NRC allowed Entergy to forego this sampling, as documented by NRC in the March 19, 2013 Webinar (see page 1 of 15 on PDF counter, below). See also August 14, 2007, below.
January 17, 2007: Ayala, J., U.S. Nuclear Regulatory Commission, letter to Paul Harden, Nuclear Management Company, LLC, "Issuance of Renewed Facility Operating License No. DPR-20 for Palisades Nuclear Plant," dated January 17, 2007 (ADAMS Accession No. ML070100449).
March 1, 2007: Recommended Screening Limits for Pressurized Thermal Shock (PTS), NUREG-1874.
March 2007: Branch Technical Position 5-3, "Fracture Toughness Requirements," Revision 2, contained in Chapter 5 of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LRW Edition." (ADAMS Accession No. ML070850035).
April 3, 2007: Elliot, B., U.S. Nuclear Regulatory Commission, internal communication to Mitchell, M., U.S. Nuclear Regulatory Commission, "Development of Flaw Size Distribution Tables for Draft Proposed Title 10 of the Code of Federal Regulations (10 CFR) 50.61a," dated April 3, 2007 (ADAMS Accession No. ML070950392).
July 11, 2007: SECY-07-0104, Proposed Rulemaking, Alternate Fracture Toughness Requirements for Protection Against Thermal Shock Events (RIN 3150-AI01).
August 14, 2007: Letter from T. Tate, Office of Nuclear Reactor Regulation, NRC, to M. Balduzzi, Entergy Nuclear Operations, Inc., "Palisades Nuclear Plant – Approval of Proposed Reactor Vessel Surveillance Capsule Withdrawal Schedule (TAC No. MD3461)," available at ADAMS Accession No. ML071640310.
August 31, 2007: Technical Basis for Revision of the PTS Screening Limit in the Pressurized Thermal Shock (PTS) Rule (10 CFR 50.61): Summary Report (NUREG-1806, Volumes 1 and 2), Date Published August 2007, Manuscript Completed May 2006.
This NRC document package is posted on the ADAMS system under ML# ML072830074. It is also available at ADAMS Accession No. ML072830076. See also ADAMS Accession No. ML072830081.
September 4, 2007: NRC to ENO, "Palisades Nuclear Plant - Request for Authorization to Extend the Third Inservice Inspection Interval for Reactor Vessel Weld Examination (TAC NO. MD3059)." NRC rubberstamped the ENO request in the end -- see July 21, 2008 below.
October 2007: "Public comment": another supposed stepping stone in RES's so-called four-year "Deciding & Approving" phase of 50.61a development. See p.114 of 168 on PDF counter, as well as June 2005 and May 2006, above.
October 3, 2007: Federal Register Notice, 72 FR 56275, Alternative Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events.
May 8, 2008: Letter from H.K. Nieh (NRC) to G. Bischoff (PWROG), Final Safety Evaluation for Pressurized Water Reactor Owners Group (PWROG) Topical Report (TR) WCAP-16168-NP, Revision 2, "Risk-Informed Extension of the Reactor Vessel In-Service Inspection Interval" (TAC No. MC9768), ADAMS Accession Number ML081060045.
June 2008: WCAP-16168-NP, Revision 2, Risk-Informed Extension of the Reactor Vessel In-Service Inspection Interval.
July 21, 2008: Letter from ENO to NRC, Request for Authorization to Extend the Third 10-Year Inservice Inspection Interval for Reactor Vessel Weld Examination, ADAMS Accession Number ML082040342.
July 21, 2008: Letter from ENO to NRC, License Amendment Request for License Condition to Support Implementation of Extended In-Service Inspection Interval, ADAMS Accession Number ML082030796.
February 11, 2009: NRC letter, "Palisades Plant -- Issuance of Amendment RE: Change to In-Service Inspection Interval (TAC No. MD9266), ADAMS Accession Number ML090220442.
March 13, 2009: Draft Final Rule 10 CFR 50.61a, "Alternate Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events," NRC ACRS.
January 4, 2010: 10 CFR 50.61a published in Federal Register. Code of Federal Regulations, 10 CFR Part 50.61a, "Alternate fracture toughness requirements for protection against pressurized thermal shock events," U.S. Nuclear Regulatory Commission, Washington, D.C., Federal Register, Volume 75, No. 1. (See also No. 22, with corrections to part (g) dated February 3, 2010, March 8, 2010, and November 26, 2010.)
As revealed on January 14, 2014 in an NRC RES staff briefing to an ACRS subcommittee (see page 230 of 292 on PDF counter), "Ongoing revision of current regulations and standards related to RPV integrity" -- specifically regarding 10 CFR 50.61a -- were "completed in 2010." At page 160 of 292 of the same document, NRC RES describes its 2010 activities vis a vis 10 CFR 50.61 (PTS) to "Improve quality & uniformity of submittals by providing Inspection and surveillance guidance." Current Activities by NRC staff listed include "DG-1299 developed, in NRR review." ORNL [Oak Ridge National Lab] is also listed as involved, with the note "All ORNL support is provided by project N6438." (see REAP -- Reactor Embrittlement Archive Project -- under 2012, below).
As RES described it to the ACRS on Oct. 16, 2014 (see p.114 of 168 on PDF counter), "10 CFR 50.61a [was] Published," culminating not only a four-year "Deciding & Approving" phase, but also an overall process that began in Jan. 1998.
February 3, 2010: The effective date for the alternate PTS rule, which was included in the Federal Register in January 2010 (see immediately above). As described by Entergy on July 29, 2014, the alternative PTS rule "provides fracture toughness requirements for protection against PTS events for PWR pressure vessels that are less burdensome than the requirements of the PTS rule." (emphasis added)
As noted in the Jan. 4, 2010 entry above, corrections to part (g) were made on Feb. 3, as well as on March 8 and Nov. 26, 2010.
March 2010: U.S. Nuclear Regulatory Commission, NUREG-1874, "Recommended Screening Limits for Pressurized Thermal Shock (PTS)." Showing analyses from Palisades, Beaver Valley, and Oconee used as inputs into the report, it is available at http://www.nrc.gov/reading-rm/doccollections/
nuregs/staff/sr1874/sr1874.pdf. (ADAMS Accession No. ML 15222A848.)
March 8, 2010: Per Jan. 4 and Feb. 3, 2010 entries above, corrections to part (g) in 10 CFR 50.61a were made in the Federal Register on this date.
April 20, 2010: Structural Integrity Associates, Inc., Report No. 0901132.401, Revision 0, "Evaluation of Surveillance Data for Weld Heat No. W5214 for Application to Palisades PTS Analysis." See also November 12, 2010, below. Together, these two documents served as the technical basis for the PTS safety risk regulatory rollback of PTS screening criteria, from January 2014 to April 2017, in the Palisades RPV, at Limiting Beltline Weld W5214. ("Similar Sister Plant" proxies employed, involving the inappropriate averaging of 11 sample surveillance capsules/coupons from very dissimilar RPVs.)
November 12, 2010: Structural Integrity Associates, Inc., Report No. 1000915.401, Revision 1, "Revised Pressurized Thermal Shock Evaluation for the Palisades Reactor Pressure Vessel." See also April 20, 2010, above. Together, these two documents served as the technical basis for the PTS safety risk regulatory rollback of PTS screening criteria, from January 2014 to April 2017, in the Palisades RPV, at Limiting Beltline Weld W5214. ("Similar Sister Plant" proxies employed, involving the inappropriate averaging of 11 sample surveillance capsules/coupons from very dissimilar RPVs.)
November 26, 2010: Per Jan. 4 and Feb. 3, 2010 entries above, corrections to part (g) in 10 CFR 50.61a were made in the Federal Register on this date.
December 20, 2010: Entergy Nuclear Operations, Inc. letter, "Updated Palisades Reactor Vessel Pressurized Thermal Shock Evaluation" (ADAMS Accession No. ML110060692). Before this point, the Palisades RPV was calculated to surpass the PTS screening criterion limit by 2014. After this reevaluation, the Palisades RPV was deemed good to go, vis a vis PTS, till April 2017, as documented by Arnie Gundersen in his December 1, 2014 expert declaration (see below, in the "Palisades Embrittlement End of Life Chronology" in point #44 on page 18 of 23 (or 18 of 40 on PDF counter).
2011: "3 public meetings in 2011" at which "The NRC solicitied input from interested stakeholders on a 10 CFR 50.61a Reg. Guide." (see p.134/168 on PDF counter; see July 12 and 26, 2011, below) Note that environmental watchdogs were distracted by responding to the 3/11/11 Fukushima Daiichi nuclear catastrophe, and its repercussions for U.S. atomic reactors -- as well as by serious accidents at Palisades itself (as on Sept. 25, 2011, below) -- and so did not even know about NRC's "public" meetings, let alone have the time and resources to take part in them.
January 14, 2011: Updated Palisades Reactor Vessel Pressurized Thermal Shock Evaluation.
February 2011: Westinghouse report, WCAP-17341-NP, Revision 0, "Palisades Nuclear Power Plant Heatup and Cooldown Limit Curves for Normal Operation and Upper-Shelf Energy Evaluation."
March 2011: Palisades' already extended license was to have expired now. Palisades' original 40-year license was from 1967 to 2007. As posted at 2007 above, Palisades persuaded NRC to rubberstamp a "mini" extension, from 2007 to 2011, so Palisades could "recapture" its 1967 to 1971 construction period.
(Note that Fukushima Daiichi Unit 1 in Japan, which melted down and exploded beginning on March 11, 2011, would not even have been operating on the day the 9.0 earthquake and 45 foot tall tsunami struck, if a license extension had not been granted to it, just some months prior. The meltdowns and/or explosions that began at Unit 1 cascaded to include Units 2, 3, and 4 as well over the course of the next few days.)
March 7, 2011: Palisades Nuclear Plant, License Amendment Request for Primary Coolant System Pressure - Temperature Limits.
March 11, 2011: The Fukushima Daiichi nuclear catastrophe began.
March 22, 2011: Palisades Nuclear Plant - License Amendment Request for Primary Coolant System Pressure-Temperature Limits.
June 2011: Jeff Donn of the Associated Press publishes a four-part exposé on nuclear power safety risks, entitled "Aging Nukes." In his first article, "US nuke regulators weaken safety rules," Donn pointed to rollbacks on PTS safety standards as the top example of this.*
July 12, 2011: NRC announces its upcoming July 26, 2011 meeting on 50.61a (see immediately below).
July 26, 2011: The U.S. Nuclear Regulatory Commission (NRC) held a meeting with the nuclear power industry regarding "technical discussions related to the evaluation of irradiation effects on RPV [Reactor Pressure Vessel] ferritic materials for operating plants, with particular focus on 10 CFR [Title 10, Code of Federal Regulations, Part] 50.61a and the NRC’s Embrittlement Database."
July 2011: Westinghouse report, WCAP-15353-Supplement 2-NP, Revision 0, "Palisades Reactor Pressure Vessel Fluence Evaluation." See especially Attachment 4. This WCAP report is filed on the NRC ADAMS systems as ML# ML14316A207, as well as ML13295A450.
September 25, 2011: Yellow Finding Accident that came very close to testing Palisades' RPV embrittlement/PTS risks. The accident resulted in Palisades' safety status being lowered two columns by NRC, to "degraded cornerstone," requiring significantly enhanced oversight. Beyond Nuclear posted this on its website regarding the accident. The Detroit Free Press ran a major front page exposé about the accident. An NRC Special Inspection Team wrote a 101-page inspection report about the accident.*
November 29, 2011: Palisades Nuclear Plant - NRC Special Inspection Team (SIT) Report 05000255/2011014 Preliminary Yellow Finding (see September 25, 2011 accident, above).
December 7, 2011: Chawla, M., U.S. Nuclear Regulatory Commission, letter to Anthony Vitale, Entergy Nuclear Operations, Inc., "Updated Reactor Pressure Vessel Pressurized Thermal Shock Evaluation for Palisades Nuclear Plant (TAC No. ME5263)," (ADAMS Accession No. ML112870050). According to NRC Commissioner Magwood's May 28, 2013 letter (see below), this licensee re-evaluation, reviewed and approved by NRC staff, "showed that the PTS screening criteria will not be exceeded till April 2017." NRC thus approved Entergy's analysis and assertion of December 2010 (see above). Previously, the PTS screening criteria was predicted to have been exceeded by 2014.
December 11, 2011: EPRI Final Report, "Materials...PWR Coordinated RVSP [Reactor Vessel Material Surveillance Program]." See Palisades on Pages 38 to 39 of 94 on PDF counter, including Table 6-40, Palisades Current [Surveillance Capsule] Withdrawal Schedule," giving Capsule ID#, Location, Removed at End of Cycle X (Year), Removal (at Effective Full Power Year), and Fluence (in neutrons per square centimeter).
2012: Reactor Embrittlement Archive Project (REAP), database of RPV embrittlement data, posted online by Oak Ridge -- partially to entirely funded by NRC RES. (See page 161 of 292 on PDF counter in January 14, 2014 NRC RES briefing to ACRS subcommittee.)
January 2012: EPRI's Materials Reliability Program (MRP) recommended several technical approaches for NRC to consider, as documented in Report Number 1024811, "Materials Reliability Program: Proposed Resolutions to the Analytical Challenges of Alternate PTS Rule (10 CFR 50.61a) Implementation (MRP 334)." As described by NRC RES (at p.134/168 on PDF) on 10/16/14, the "[i]ntent was to reduce licensee and NRC burden for implementing 10 CFR 50.61a by providing consistent, acceptable levels of safety for cases where compliance evaluations are required," and included "7 areas, 15 specific recommendations (Table ES-1 of MRP-334)." (emphasis added)
Late February, 2012: Under direct questioning by Beyond Nuclear's Kevin Kamps (who took part in the meeting by phone), NRC Office of Regulatory Research's staffer Jennifer Uhle acknowledged that Palisades has the single worst embrittled RPV in the U.S. This took place at an NRC public meeting held at the Beach Haven Event Center in South Haven, MI.*
March 9, 2012: Letter regarding PTS risks at Palisades, sent to U.S. Senators Carl Levin and Debbie Stabenow (Democrats from Michigan), signed by numerous Don't Waste MI chapters across the state, as well as their attorney, Terry Lodge of Toledo, OH.
May 25, 2012: 25 concerned local residents and environmental group representatives met with NRC Chairman Greg Jaczko in South Haven, MI, near Palisades; RPV embrittlement and PTS risk was a top issue discussed. See Beyond Nuclear's webpost about this meeting.*
May-June, 2012: Nuke Info Tokyo (the newsletter of Citizens' Nuclear Information Center), No. 148, May/June 2012, including the Part I of the article "Aging Nuclear Power Plants focusing in particular on irradiation embrittlement of pressure vessels," by Hiromitsu Ino (pages 10 to 12, and continued in newsletter No. 149, below; the article in No. 148 also includes Figure: Genkai-1 Monitoring Test Sample Data and JEAC and 4201-2004 Prediction Curve).*
July-August, 2012: Nuke Info Tokyo, the newsletter of Citizens' Nuclear Information Center, No. 149, July/August 2012, including Part II of the article "Aging Nuclear Power Plants focusing in particular on irradiation embrittlement of pressure vessels," by Hiromitsu Ino (continued from the article in newsletter No. 148, above; pages 10 to 14, and concluded on page 5). Additional Tables and Figures were included in Hiromitsu Ino's articles.* (A July 2011 article by Ino, also translated by Phillip White, was submitted to NRC in Beyond Nuclear's October 30, 2014 comments.*)
2013-2014: Depicted by a "Golden Star," RES describes "DG-1299 being developed" as the culmination of a 15-year 50.61a development process (see p.114 of 168 on PDF counter).
January 2013: Westinghouse report, WCAP-17403-NP, Revision 1, "Palisades Nuclear Power Plant Extended Beltline Reactor Vessel Integrity Evaluation."
February 2013: Westinghouse, WCAP-17651-NP, "Palisades Nuclear Power Plant Reactor Vessel Equivalent Margins Analysis."
February 2013: As revealed in January 14, 2014 NRC RES staff briefing to ACRS subcommittee, below (see Page 230 of 292 on PDF counter), NRC RES began working on the "emergent need" at Palisades re: RPV embrittlement.
March 19, 2013: Kevin Kamps of Beyond Nuclear's questions to NRC re: the agency Webinar on RPV embrittlement/PTS risks at Palisades.* On April 18, 2013, NRC released a summary of the Palisades embrittlement webinar it had held on March 19th. This document has been referred to as: J. Geissner, Summary of the March 19, 2013, Public Meeting Webinar Regarding Palisades Nuclear Plant. It is available at ADAMS Accession No. ML13108A336. The slides from the NRC Public Webinar, Basis for NRC Requirements on Pressurized Thermal Shock, are available at ADAMS Accession No. ML13077A156.
March 25, 2013: Around two dozen concerned local residents and environmental group representatives met with NRC Commissioner William Magwood IV in South Haven, MI, near Palisades; RPV embrittlement and PTS risk was a top subject discussed. Letters containing questions and concerns from meeting attendees to Commissioner Magwood, and his responses, are posted under NRC ADAMS Accession No. ML13142A424. See Beyond Nuclear's webpost about this meeting.*
April 2, 2013: Plot, used as part of the end-of-cycle public meeting held on April 2, 2013 (see ADAMS ML13093A19), showing the variation of the embrittlement reference temperature (RT-PTS) with years of radiation exposure.
April 18, 2013: Giessner, J., U.S. Nuclear Regulatory Commission, letter to Entergy Nuclear Operations, Inc., "Summary of the March 19, 2013, Public Meeting Webinar Regarding Palisades Nuclear Plant," dated April 18, 2013 (ADAMS Accession No. ML13108A336).
April 24, 2013: Sheron, B., U.S. Nuclear Regulatory Commission, letter to Dr. Barbara J. Pellegrini, dated April 24, 2013 (ADAMS Accession No. ML13105A006 and ML13099A293).
April 25, 2013: Magwood, W., U.S. Nuclear Regulatory Commission, letter to Tim Mitchell, Entergy Nuclear Operations, Inc., dated April 25, 2013 (ADAMS Accession No. ML13149A052).
May 16, 2013: Mitchell, T., Entergy Nuclear Operations, Inc., letter to William Magwood, U.S. Nuclear Regulatory Commission, dated May 16, 2013 (ADAMS Accession No. ML13149A047).
May 28, 2013: "Response to Concerns Raised in Letter Sent to the NRC by Ms. Alice Hirt," by NRC Commissioner William Magwood IV, to Alice Hirt, including: "Concerns regarding the embrittlement of the Palisades' reactor vessel and the extension of their operating license"; "Concerns with the predictability of assessing this irradiation embrittlement"; and a plot charting Embrittlement RT-PTS in degrees Fahrenheit versus Dates (Years of Reactor Operation). In addition to Magwood's correspondence with Alice Hirt, many of the other concerned local residents and environmental group representatives likewise raised RPV embrittlement/PTS risk concerns with Magwood (see associated links to documents on NRC website).
Commissioner Magwood's written follow up to MSEF's Kraig Schultz included (on pages 2-3) a table, Summary of surveillance capsules in the Palisades nuclear power plant.
June 25, 2013: Updated Palisades Nuclear Plant Reactor Vessel Fluence Evaluation, Entergy to NRC. (PNP 2013-046). This document is posted on the NRC ADAMS system under ML# ML13176A412.
As Arnie Gundersen wrote in his December 1, 2014 expert declaration (see below, in the "Palisades Embrittlement End of Life Chronology" in point #44 on page 18 of 23 (or 18 of 40 on PDF counter)), this extended Palisades' RPV's "lease on life" from April of 2017 to August of 2017.
June 25, 2013: Westinghouse, WCAP-15353, Supplement 3 -- NP, Revision 0, "Palisades Reactor Pressure Vessel Neutron Fluence Evaluation," dated June 2013 (ADAMS Accession No. ML13176A412).
July 30, 2013: Beaver Valley Unit 1 became the first plant to request NRC approval to implement the 2010 PTS Rule. (See Official Transcript, Advisory Committee on Reactor Safeguards, Metallurgy & Reactor Fuels Subcommittee Meeting at 11 (Oct. 16, 2014), available at ADAMS Accession No. ML14296A342.) That request is under NRC Staff review.
October 21, 2013: Palisades Nuclear Plant 10 CFR 50 Appendix G Equivalent Margins Analysis.
December 18, 2013: NRC's Letter from M. Chawla, Office of Nuclear Reactor Regulation, to A. Vitale, Entergy Nuclear Operations, Inc., Palisades Nuclear Plant, "UPDATED REACTOR VESSEL FLUENCE EVALUATION SUPPORTING A REVISED PRESSURIZED THERMAL SHOCK SCREENING CRITERIA LIMIT (TAC NO. MF2326)", approving Entergy's June 25, 2013 analysis and assertion (see above) that Palisades is safe to operate till August 2017, despite having the worst embrittled RPV in the U.S. Available at ADAMS Accession
No. ML13346A136.
January 14, 2014: ACRS subcommittee is briefed by NRC RES staff on such issues as RPV embrittlement (see pages 26 to 31, or 34 to 39 of 292 on PDF counter). At page 30 (or 38 on PDF counter), NRC RES compares "operating experience" or "emergent" issue at Palisades with the one at Doel in Europe. (Minutes/transcript published on March 12, 2014.)
January 19 (to March 16), 2014: 23rd refueling and maintenance outage, or Cycle 23, at Palisades.
January 22, 2014: Results of Periodic Review of Regulatory Guide (RG) 1.99.
January 30, 2014: Salas, P., AREVA Inc., letter to U.S. Nuclear Regulatory Commission, "Potential Non-Conservatism in NRC Branch Technical Position 5-3," dated January 30, 2014 (ADAMS Accession No. ML14038A265).
February 2014: WesDyne ISI Report, "Entergy Palisades Unit 1 Nuclear Power Plant 10 Year Reactor Vessel Inserve Inspection."
May 13, 2014: NRC email to Entergy Nuclear Operations, Inc., Request for Additional Information, Palisades Nuclear Plant 10 CFR Appendix G Equivalent Margin Analysis - MF 2962.
June 2014: As described by Entergy on July 29, 2014 (on Page 7 of 19 on PDF counter), "The PNP alternate PTS rule evaluation is documented in the enclosed Westinghouse report WCAP-17628-NP, Revison 1, "Alternate Pressurized Thermal Shock (PTS) Rule Evaluation for Palisades," ML14211A525.
June 2014: U.S. Department of Energy, Pacific Northwest National Laboratory (PNNL), operated by Battelle, PNNL-19666, prepared for the U.S. Nuclear Regulatory Commission under a Related Services Agreement with the U.S. Department of Energy, Contract DE-AC05-76RL01830, Technical Letter Report, Evaluation on the Feasibility of Using Ultrasonic Testing of Reactor Pressure Vessel Welds for Assessing Flaw Density/Distribution per 10 CFR 50.61a, Alternate Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock, EJ Sullivan and MT Anderson, June 2014. Posted online at ML# ML14162A001 in NRC's ADAMS system.
June 5, 2014: Meeting in Benton Harbor, MI, between more than a dozen concerned local residents and environmental group representatives, with Chairman Macfarlane; Palisades RPV embrittlement and PTS risk was a top subject discussed. See Barbara Pellegrini's letter to NRC Chairman Allison Macfarlane. As in late February 2012, NRC's acknowledgement that Palisades has the single worst embrittled RPV in the US also came out in this meeting. It happened under direct questioning by Michael Keegan of Don't Waste MI, and others. NRC resident inspector at Palisades, Alex Garmoe, made the admission. See Beyond Nuclear's webpost about this meeting.*
Also see eyewitness affidavits re: NRC's refusal to require metal samples to be analyzed. At the Macfarlane meeting, NRC senior resident inspector Alex Garmoe responded to a question by Michael Keegan of Don't Waste MI that metal surveillance capsule/coupons could not be pulled and tested, because doing so would leave no more coupon/capsules to sample in the future.
June 12, 2014: Entergy Nuclear Operations, Inc., letter PNP 2014-054, Response to NRC Request for Additional Information, Palisades Nuclear Plant 10 CFR 50 Appendix G Equivalent Margin Analysis - MF2962.
June 26, 2014: Entergy Nuclear Operations, Inc., letter PNP 2014-066, Supplemental Response to NRC Request for Additional Information - Palisades Nuclear Plant 10 CFR 50 Appendix G Equivalent Margin Analysis - MF 2962.
July 24, 2014: Transcript, ACRS meeting at NRC Region III HQ in Lisle, IL (see Palisades PTS section).
July 29, 2014: Entergy Nuclear sent the U.S. Nuclear Regulatory Commission (NRC) a document entitled "License Amendment Request to Implement 10 CFR 50.61 a, 'Alternate Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events'" regarding its problem-plagued, age-degraded Palisades RPV. This document is posted in NRC's ADAMS system under the ML# ML14211A524.
This document is also designated as PNP 2014-049, Letter from A. Vitale to NRC Document Control Desk. And here is another ML#: ADAMS Accession No. ML14211A520.
Entergy and NRC both had previously asserted that the Palisades RPV would violate 10CFR50.61 screening criteria by August 2017. 10CFR50.90 requires that "an application for implementation of 10 CFR 50.61a be submitted...at least three years before the RV [Reactor Vessel] is projected to exceed the PTS screening criteria under 10 CFR 50.61." (see Entergy at bottom of p.2 of 19 on PDF counter) Thus, Entergy met its 50.90 deadline with but a few days to spare.
This license amendment would effectively enable Palisades to continue operating past August 2017, despite its violation of NRC embrittlement safety standards. This document is also labeled PNP 2014-049. Also see June 2014 entry, above, for "The PNP alternate PTS rule evaluation...documented in the enclosed Westinghouse report WCAP-17628-NP, Revison 1, "Alternate Pressurized Thermal Shock (PTS) Rule Evaluation for Palisades," ML14211A525.
As Arnie Gundersen also wrote in his December 1, 2014 expert declaration (see below, in the "Palisades Embrittlement End of Life Chronology" in point #44 on page 18 of 23 (or 18 of 40 on PDF counter)), this Entergy request, if approved by NRC, would change the analytical approach for evaluating the End of Life (EOL) date for Palisades RPV, allowing operations to extend beyond the previously identified August 2017 EOL date.
Entergy Palisades posted this confident statement on its website, downplaying the risks of PTS, vis a vis 2014 so-called "inspections" and "analysis" of its worst embrittled RPV in the US.
Entergy requested NRC approval of this License Amendment Request by July 29, 2015 (see below, and see Entergy on page 3 of 19 on PDF counter).
August 2014: Appendix G briefing by NRC RES staff to ACRS.
August 29, 2014: In an email dated August 29, 2014, NRC confirmed that its "Acceptance Review" had determined that Entergy's application was sufficient for NRC to continue with a more in-depth technical review of the matter.
August 29, 2014: Also on this date, NRC published a copy of Entergy's July 29th application for Palisades, License Amendment Request to Implement 10 CFR 50.61a, "Alternate Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events," ML14211A520.
August 30, 2014: Letter from NRC Chairman Allison Macfarlane to Kevin Kamps of Beyond Nuclear, as follow up to June 5, 2014 meeting in Benton Harbor, MI, including regarding "reactor vessel embrittlement."
Summer 2014: As described on Page 230 of 292 on PDF counter in January 14, 2014 NRC RES staff briefing to ACRS subcommittee (see above), "DG-1299 to be released for public comment Summer 2014." Draft Reg Guide 1299 is alternate fracture toughness requirements for protection against PTS in PWRs.
September 30, 2014: Federal Register Volume 79, Number 189 (Tuesday, September 30, 2014), Notices, Pages 58812-58831, From the Federal Register Online via the Government Printing Office [www.gpo.gov], FR Doc No: 2014-23015, NRC publishes Entergy Palisades' application for 50.61a, setting the following deadline "DATES: Comments must be filed by October 30, 2014. A request for a hearing must be filed by December 1, 2014." Also included: "Biweekly Notice; Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations," pages 58,812, 58,814-15.
October 16, 2014: ACRS subcommittee meeting of Metallurgy and Reactor Fuels. See especially the transcript at page 30 (or 31 of 168 on PDF counter), where the following exchange is documented:
"[ACRS Subcommittee] Member Banerjee: Yes, but I mean what is special about Palisades? That's what I was going to ask.
[NRC Office of Regulatory Research's] Mr. Kirk: Well, there are so many things that are special about Palisades."
This transcript is posted on NRC's ADAMS system under ML# ML14296A342.
This agenda is posted on NRC's ACRS website section.
8 days prior to this meeting, it was noticed in the Federal Register.
On page 157 of 168 on the PDF counter of this transcript/power point presentation, NRC RES stated that the "Program office review complete; comments addressed," and that the remaining schedule for DG-1299's [Draft Regulatory Guide-1299] development is: ACRS review, minimum 2 weeks; OGC [NRC Office of General Counsel] review, minimum 4 weeks; and publication for public comment in about 2 weeks. However, that "[s]chedule depends on comments received."
Re: NUREG-2163, again NRC RES claimed "Program office review complete; comments addressed," and that the remaining schedule for its development is: ACRS review, minimum 2 weeks; OGC review, minimum 4 weeks; "Tech. Pubs review," about 4 weeks; and publication for public comments in about 2 weeks -- again with the caveat "[s]chedule depends on comments received."
RES concludes with its "Best Estimate Publication Schedule": "Public comment (60-day period) -- February 2015" and "Publish Final Documents -- Summer 2015."
October 30, 2014: Beyond Nuclear submitted comments by NRC's arbitrarily short October 30th deadline regarding yet another request by Palisades for a weakening of RPV embrittlement/PTS safety regulations, in the form of a change of methodology to assess the problem. Such pencil whipping has occurred many times over the decades at Palisades, in order to enable ongoing operations, despite the RPV's seriously degraded condition.
See also Kamps, K., Beyond Nuclear, comments to proposed no significant hazards consideration (NRC-2014-0207), dated October 30, 2014 (ADAMS Accession No. ML14309A257).
October 30, 2014: Michael Keegan of Don't Waste Michigan in Monroe, MI also submitted comments on behalf of the statewide nuclear power watchdog coalition, by NRC's October 30th deadline.
November 6, 2014: 619th Meeting, Advisory Committee on Reactor Safeguards. NRC RES staff (Stevens and Kirk) brief ACRS on Draft Regulatory Guide 1299 (DG-1299), Regulatory Guidance on the Draft Pressurized Thermal Shock Rule, as well as NUREG-2163, the technical basis for DG-1299. See transcript, pages 1 to 60 of 268 on PDF counter.
This transcript is posted on NRC's ADAMS system under ML# ML14321A542.
See especially page 20 (or 22 of 268 on PDF counter), where, as Arnie Gundersen wrote in his December 1, 2014 expert declaration, "The NRC would seem to agree that using all possible samples is important to an accurate outcome":
'...the vehicle for doing that is doing a statistical comparison of a particular reactor's plant specific surveillance data with the general trends.' (emphasis added)
November 12, 2014: Entergy Palisades to NRC, License Amendment Request for Approval of Palisades Nuclear Plant 10 CFR 50 Appendix G Equivalent Margins Analysis.
November 20, 2014: License Amendment Request for Approval of Palisades Nuclear Plant 10 CFR 50 Appendix G Equivalent Margins Analysis. This document is posted on the NRC's ADAMS system under ML# ML14316A370.
December 1, 2014: By the NRC's mandated deadline, an environmental coalition intervened against Entergy Nuclear Palisades' License Amendment Request re: RPV embrittlement and PTS risk.
See the coalition's intervention filing here ("Petition to Intervene and for a Public Adjudication Hearing of Entergy License Amendment Request for Authorization to Implement 10 CFR [Part] 50.61a, 'Alternate Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events'"), 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 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.
December 8, 2014: "Amended Petition to Intervene and for a Public Adjudication Hearing of Entergy License Amendment Request for Authorization to Implement 10 CFR [Part] 50.61a, 'Alternate Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events'." (The sole modifications between the originally-filed December 1, 2014 Petition and this version is correction of the initial Federal Register reference as it appeared on page 1 of the December 1 filing to reflect Vol. 79 instead of Vol. 78, and also minor modifications to other portions of the Petition and a revised standing declaration for Bette Pierman.)
December 23, 2014: Our expert witness, Chief Engineer Arnie Gundersen at Fairewinds Energy Education, published a humorous short video about a serious subject -- RPV embrittlement and PTS risk at Palisades. It runs 6.5 minutes long.
January 12, 2015: Entergy Nuclear and NRC staff both responded in opposition to Beyond Nuclear et al.'s intervention of Dec. 1, 2014. Note that the environmental coalition's attorney, Terry Lodge of Toledo, agreed, without hesitation, to a request by Entergy's law firm that its response deadline be postponed from Dec. 26, 2014 -- the middle of the holiday season -- until Jan. 12th. Thus, both Entergy and NRC staff's legal teams not only were able to enjoy their holidays, but also had more than two weeks of additional time with which to prepare their attacks against the Dec. 1st intervention petition. (By contrast, the same nuclear industry law firm -- Morgan Lewis -- rejected Lodge's request in a separate proceeding (at Davis-Besse, Ohio) for a one-day extension at the New Year's holiday!)
January 15, 2015: NRC RAI re: Entergy Palisades' LAR for EMA regulatory relief under 10CFR50 Appendix G (ML15012A305).
January 20, 2015: Lodge, and Vermont-based expert witness Arnie Gundersen (Chief Engineer, Fairewinds Associates, Inc.), filed a Combined Reply to NRC staff's and Entergy's Jan. 12, 2015 attacks.
January 20, 2015: Rankin, J., U.S. Nuclear Regulatory Commission, letter to Anthony Vitale, Entergy Nuclear Operations, Inc., "Palisades Nuclear Plant -- Request for Addtional Information (RAI) Regarding the License Amendment Request to Implement 10 CFR 50.61a (TAC No. MF4528)," dated January 20, 2015 (ADAMS Accession No. ML15016A184).
February 2015 (tentative): NRC to publish 50.61a draft final rule in Federal Register, beginning a 60-day public comment period. After that, NRC will take 60 days to review comments, then circulate Final Rule. This was mentioned in NRC RES's briefing to an ACRS subcommittee on Oct. 16, 2014, at p.157 of 168 on PDF counter.
February 5, 2015: FirstEnergy Nuclear Operating Company, the only other utility to apply for 50.61a regulatory relief besides Entergy at Palisades, wrote NRC to withdraw its License Amendment Request. On Feb. 18, NRC approved the LAR application withdrawal. This left Palisades as the only reactor in the US seeking 50.61a regulatory relief.
February 13, 2015: Entergy response to Jan. 20, 2015 (see above) NRC Request for Addtional Information (RAI) regarding the License Amendment Request to implement 10 CFR 50.61a (TAC No. MF4528). [ADAMS Accession No. ML15050A259]
February 15, 2015: Greenpeace International published a briefing paper entitled "Nuclear Reactor Pressure Vessel Crisis." It focused on the global risk implications of widespread, sub-surface, micro-cracking revealed under Ultrasonic Testing (UT) at the troubled Doel-2 and Tihange-3 atomic reactors in Belgium. Initially, in 2012-2013, the cracking was thought to be related to defective manufacturing processes at Rotterdam Drydock Company. However, materials scientists now hypothesize that hydrogen flake corrosion cracking is involved -- and are concerned this could impact reactor pressure vessels worldwide. They call for precautionary testing of all RPVs globally, a warning currently being rejected by the nuclear power industry and its regulators internationally.
February 19, 2015: Day-long NRC meeting re: RPV integrity and related safety risks, including PTS due to neutron embrittlement. Several anti-nuke watchdogs took part by phone, including Kevin Kamps of Beyond Nuclear, and Michael Keegan of Don't Waste MI. Members of the public spoke at each public comment opportunity, demanding NRC stop weakening PTS safety standards. Numerous documents were published by both NRC and industry for use at this meeting. Links to these documents are listed, immediately below.
Agenda.
Presentations (not necessarily in chronological order to match agenda):
Assessment of BTP 5-3 Protocols (Mark Kirk, NRC) (ADAMS Accession No. ML15061A065). [BTP = Branch Technical Position]
Part II: Assessment of Impact on Plants Using BTP 5-3 to Estimate RT-NDT(u) [Reference Temperature-Nil Ductility Transition (unirradiated)] (Simon Sheng, NRC).
Industry Focus Group, Activities Regarding the BTP 5-3 Issue (Wells, Southern Nuclear; Hardin, Electric Power Research Institute).
MRP/BWRVIP, Evaluation of BTP 5-3 (Hardin, EPRI; Server, ATI Consulting; Gamble, Sartrex).
Materials Orientation Toughness Assessment (MOTA) for the Purpose of Mitigating Branch Technical Position (BTP) 5-3 Uncertainties (Koehler, Xcel; Long and Hall, Westinghouse).
FAVOR Cladding Residual Stress Model (Kusnick, NRC).
2015 Revision of the FAVOR* Probabilistic Fracture Mechanics Computer Program (v.15.1) (Kirk, NRC; Bass, Dickson, Williams, Oak Ridge National Lab) [*FAVOR = Fracture Analysis of Vessels - Oak Ridge].
REAP (Reactor Embrittlement Archive Project) (Kirk, NRC; Williams and Bass, Oak Ridge).
Demonstrate Appendix G Margins for PWR RPV Nozzles, PA-MSC-1091R1, Methodology and Progress (Hall, Westinghouse).
Overview of Plans for Revising Title 10 of the Code of Federal Regulations, Part 50, Appendix H, "Reactor Vessel Material Surveillance Program Requirements" (Hardies, NRC).
Pressure Tests of Reactor Coolant System - With the Core Critical (Holmberg, NRC).
February 28, 2015: NUREG-2163, Technical Basis for Regulatory Guidance on the Alternate Pressurized Thermal Shock Rule, Draft Report for Comment, published by NRC. Although dated Feb. 28, the document was not made publicly accessible (docketed) until March 2nd. Also released by NRC in early March, 2015 was Draft Regulatory Guide DG-1299 (Proposed New Regulatory Guide), Draft Guidance on the Pressurized Thermal Shock Rule. Here is the Regulatory Analysis re: DG-1299. Public comments are due May 12th.
March 9, 2015: A second overlapping and parallel intervention was filed by the environmental coalition today. Earlier, 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 50 foot-pounds screening criteria for metal degradation, as early as 2016. Hence, 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, coalition attorney Terry 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.
Beyond Nuclear posted a March 10 web entry about the March 9 filing. Although it repeats a lot of the same info. as immediately above, it does provide some additional background/context.
March 19, 2015: Rankin, J., U.S. Nuclear Regulatory Commission, letter to Anthony Vitale, Entergy Nuclear Operations, Inc., "Palisades Nuclear Plant -- Request for Additional Information Regarding the License Amendment Request to Implement 10 CFR 50.61a (TAC No. MF4528),"dated March 19, 2015 (ADAMS Accession No. ML15072A254).
This is NRC's supplemental RAI re: Entergy's Feb. 13, 2015 response (above). The need for NRC to issue a supplemental RAI stemmed from Entergy's confusing use of two different azimuthal (horizontal orientation) designation systems for RPV locations, without specifying which system was being referred to in its LAR documents. See Entergy's April 1, 2015 response to this supplemental NRC RAI, below.
March 25, 2015: Our environmental coalition defended our intervention (filed on Dec. 1, 2014), against attacks by NRC staff and Entergy, at an NRC Atomic Safety and Licensing Board Panel oral argument pre-hearing at NRC HQ in Rockville, MD. See the transcript of the hearing.
Also see our March 26, 2015 press release about the ASLB oral argument pre-hearing.
(Note the related April 6, 2015 entry below.)
April 3, 2015: NRC staff and Entergy oppositional responses to our March 9 filing (see above).
April 6, 2015: As per above under the March 25, 2015 entry, both Entergy and NRC staff objected to parts of the environmental coalition attorney, Terry Lodge's, testimony at the March 25th oral argument. They accused him of introducing new info., that should not have been allowed in any longer. Lodge will rebut that attack with an official sur-rebuttal, in the near future. It will be posted here and elsewhere on the Beyond Nuclear website ASAP thereafter.
April 10, 2015: The environmental coalition filed its Reply in support of its March 9 intervention petition, rebuttng NRC staff and Entergy attacks filed on April 3 (see above).
Summer 2015 (tentative): Publication of Final 50.61a Rule. This was mentioned in NRC RES's briefing to an ACRS subcommittee on Oct. 16, 2014, at p.157 of 168 on PDF counter.
July 29, 2015: Per Entergy's July 29, 2014 letter (see Page 3 of 19 on PDF counter), it has requested that "To allow for normal NRC processing, ENO requests approval of the proposed license amendment by July 29, 2015. Also, an implementation period of 120 days following the effective date of the amendment is requested." (see November 29, 2015 entry immediately below).
August 14, 2015: Vitale, A., Entergy Nuclear Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Supplemental Information for the Response to the First Request for Additional Information Regarding the Licensee Amendment Request to Implement 10 CFR 50.61a (TAC No. MF4528), dated August 14, 2015 (ADAMS Accession No. ML15230A219).
September 1, 2015: Louden, P., U.S. Nuclear Regulatory Commission, letter to Anthony Vitale, Entergy Nuclear Operations, Inc., "Mid-Cycle Assessment Letter for Palisades Nuclear Plant (Report 05000255/2015005), dated September 1, 2015 (ADAMS Accession No. ML15239B408).
November 29, 2015: Per the entry immediately above, Entergy requested "an implementation period of 120 days following the effective date of the amendment," which would fall on this date.
2017: "...Palisades crosses its 50.61 limit of 270F in 2017. So the reason they have come to us is for regulatory reasons. They don't have legal authority to operate after that without doing something else." ---Mark Kirk, NRC RES, briefing ACRS subcommittee on Oct. 16, 2014 (see p.13/168 on PDF counter of transcript).
At one point, that 2017 cut off date was given as April. It was later relaxed/postponed to August.
2019 (Planned): NRC Commissioner Magwood's letter to Kraig Schultz of MSEF on May 28, 2013 (see above), listed a planned Palisades surveillance capsule pull: installed, irradiated capsule ID# W-80. No title(s) for NRC documentation, nor ADAMS # for report(s), was provided by Commissioner Magwood.
Per Table 6-40 on Page 6-39 of EPRI's December 11, 2011 report above, Capsule W-80 is located at 80 degrees, will be removed at End of Cycle 27 in 2019, and will have a Fluence of 3.06 X 10(19) neutrons per square centimeter.
*This document was submitted to NRC as supporting documentation for official public comments by Beyond Nuclear on October 30, 2014. See above.
NRC file photo of Palisades, on the Lake Michigan shore in Covert, MIAs reported by both the St. Joe-Benton Harbor Herald-Palladium and the Kalamazoo Gazette, the U.S. Nuclear Regulatory Commission (NRC) has cited Entergy Nuclear's Palisades atomic reactor (photo, left) for violations of its own workers' radiological safety protections. The violations took place in February and March 2014, during the replacement of the safety-critical Control Rod Drive Mechanisms (CRDMs), which have been plagued with problems since 1972. NRC has preliminarily designated this violation as a White Finding, "of low to moderate safety significance," which could well lead to NRC lowering Palisades' performance designation as "degraded" (NRC's findings increase in severity from Green, to White, Yellow, and Red).
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