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

Submitted via email to the listed recipients:

Mssrs. Wall, Collins and Giessner:

Kindly review and respond to the attached letter from Beyond Nuclear, Don't Waste Michigan, Citizens Action Coalition, Michigan Safe Energy Future, Nuclear Energy Information Service, and Nuclear Information and Resource Service, opposing an emergency action request by IMPC, owner of D.C. Cook Nuclear Power Plant.

I have pasted the letter below and attached it as a .pdf. [linked here]

Thank you.

Terry J. Lodge, Esq.

(419) 205-7084

--------------------------------------------------------------------------------------------------------------

                            October 9, 2020

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

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

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

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

Dear Mssrs. Wall, Collins and Giessner:

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

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

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

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

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

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

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

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

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

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

Sincerely,

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

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

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

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

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

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

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

Attachment: Lochbaum Summary [linked here]

Cc:

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

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

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

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

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

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

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

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

From: David Lochbaum <davelochbaum@gmail.com>

Date: 10/07/2020 12:55 PM

Subject: Cook and leakage

Hello Michael:

Attached [linked here] is a short report I prepared on the Cook Unit 1 relief request.

 

I had a few hours this morning to followup on yesterday's response.

It seems clear that I&M's negligence at best or incompetence at worst created the situation that it now finds itself requesting NRC relief from. NRC should not condone or reward negligence and/or incompetence, particularly with public safety in the imbalance.

So, except for being unlawful and potentially unsafe, there's little wrong with I&M's request.

Feel free to distribute as you wish.

Thanks,

Dave Lochbaum

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

NEWS FROM BEYOND NUCLEAR For immediate release, Wednesday, September 30, 2020 Contact:  Kevin Kamps, Beyond Nuclear, kevin@beyondnuclear.org, (240) 462-3216; Michael J. Keegan, Don't Waste Michigan, mkeeganj@comcast.net, (734) 770-1441; Terry J. Lodge, Legal Counsel for Beyond Nuclear and Don't Waste Michigan, tjlodge50@yahoo.com, (419) 205-7084

"Band-Aid" Reactor Vessel Head Repair Proposed at Palisades Nuclear Plant

NRC Asked to Approve Risky “Loophole” in ASME Code

COVERT TOWNSHIP, MI -- Today Beyond Nuclear and Don’t Waste Michigan filed a Freedom of Information Act (FOIA) Request with the U.S. Nuclear Regulatory Commission (NRC), seeking documentation on the severely degraded reactor pressure vessel head at the half-century old Palisades nuclear power plant, located on the eastern shore of Lake Michigan, a few miles south of South Haven.    On Monday, September 14, the NRC disclosed to the public this latest “Degraded Condition” at Palisades, in Event Report number 54897. This degradation is associated with a principal safety barrier, the reactor pressure vessel head.  One day later, on Sept. 15, NRC hastily and quietly announced a poorly noticed "Public Meeting," scheduled for Monday, September 21, to review this “Degraded Condition” with representatives from Palisades's owner, Entergy Nuclear.  At this September 21 meeting, Entergy Nuclear representatives presented NRC staff, from both the agency's national headquarters in Rockville, Maryland, as well as its Midwest/Region III headquarters in Lisle, Illinois, with an "emergent alternative request" to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, related to the repair of cracked Palisades reactor pressure vessel head penetrations.  Entergy is requesting a repair that will last only 1.82 years, instead of the industry-accepted standard repair that would last 27 years.   Entergy Nuclear has announced permanent closure of the Palisades atomic reactor in 1.7 years from now, by May 31, 2022. However, Entergy had previously announced, in December 2016, an October 2018 date certain closure for Palisades, only to later renege. NRC has rubber-stamped a 60-year operations license at Palisades, which does not expire until 2031.   "Entergy is looking for the NRC to approve a 'loophole' in the ASME code," stated Arnold Gundersen, nuclear engineer with Fairewinds Energy Education. Gundersen has previously served as Beyond Nuclear and Don't Waste Michigan's expert witness, regarding Palisades's reactor pressure vessel neutron radiation embrittlement pressurized thermal shock risks.   The ASME code is the national boiler and pressure vessel code. Any industrial application holding pressure must meet the ASME code. The ASME code is well thought out, and worked out, by experts, and dates back to the era of steam engines, but also applies to nuclear power plants.   In spite of the poorly noticed “Public Meeting,” several members of the public did attend the September 21 teleconference. The public watch-dogs and concerned citizens included: Kraig Schultz of Michigan Safe Energy Future (MSEF) in Grand Haven, MI: Michael Keegan of Don't Waste Michigan in Monroe, MI; Jan Boudart of Nuclear Energy Information Service (NEIS) in Chicago, IL; and Kevin Kamps of Beyond Nuclear in Takoma Park, Maryland.   MSEF's Kraig Schultz spoke out in opposition during the meeting, sharing his concern about undue, excessive risk being incurred by the public.  In a letter to NRC, dated Monday, Sept. 28, Mr. Schultz wrote: "On Monday, September 21, 2020, Palisades Nuclear Power plant operators announced that they are planning to skip important steps in repairing the cracks that have developed since 2018.  Palisades operators are asking the NRC to give it permission to skip these steps. …The NRC should not allow Palisades operators to bully it or force the approval of lower quality repair procedures.  Catastrophic failure events often do not happen in isolation.  They can result from cascading failures of seemingly tiny things that snowball into major events...”.   NEIS board member Jan Boudart expressed frustration with the NRC creating silos, and in doing so refusing to answer her questions, and avoiding meaningful dialogue on the extreme neutron radiation embrittlement of the Palisades reactor pressure vessel.  Her comments can be heard at the following link to an audio recording of the September 21 NRC-Entergy Palisades public meeting (the recording takes less than a minute to download and open): https://drive.google.com/file/d/17w2c2Elzi4t3Fnjqvx4Zf2wLIiqPI5Ki/view     The comments by the four members of the public begin with Kraig Schultz at the 39 minute and 25 second mark on the audio recording. In addition to Schultz and Boudart, public comments also came from Kevin Kamps of Beyond Nuclear, and Michael Keegan of Don't Waste Michigan.     "As we've documented for decades, Palisades has one of the worst neutron-embrittled reactor pressure vessels in the country, and in the world," said Kevin Kamps of Beyond Nuclear, based in Takoma Park, Maryland. "Activation of the emergency core cooling system, as due to failure of this 'Band-Aid' repair job proposed for the vessel head, could cause a pressurized thermal shock of the reactor pressure vessel, resulting in a through-wall fracture, and inevitable reactor core meltdown," Kamps added.   "Band-Aid" is not hyperbole, but an actual quote. It is the phrase that some workers at Entergy Nuclear Palisades are using, to refer to the proposed repair. The quote was overheard by an anonymous source in a position to know, and communicated to Kevin Kamps.   A 1982 report, commissioned by NRC, and carried out by Sandia National Laboratory in Albuquerque, New Mexico, estimated shocking casualty figures, and property damage, downwind and downstream of Palisades, in the event of a reactor core meltdown. The report is most commonly referred to as CRAC-II (CRAC is short for Calculation of Reactor Accident Consequences), but is also known as the Sandia Siting Study, or NUREG/CR-2239 (NUREG refers to Nuclear Regulation; CR is short for Contractor Report).The CRAC-II report estimated 1,000 "peak early fatalities" (acute radiation poisoning deaths), 7,000 "peak early [radiation] injuries," and 10,000 "peak cancer deaths" (latent cancer fatalities), to be expected downwind and downstream of a reactor core meltdown at Palisades, and consequent large-scale release of hazardous ionizing radioactivity into the environment. The CRAC-II study also estimated $52.6 billion in property damage downwind and downstream of a Palisades meltdown.   However, as reported by Associated Press investigative reporter Jeff Donn after the Fukushima nuclear catastrophe in Japan, in 2011, in a four-part series entitled "Aging Nukes," populations have soared around atomic reactors like Palisades since 1982, so casualty figures would be significantly worse in 2020. And when adjusted for inflation alone, the property damage figures, expressed in Year 2019 dollar figures, would surmount $141 billion. Donn also cited reactor pressure vessel neutron embrittlement safety standard rollbacks as a top example of NRC regulatory retreat, and capture of the so-called regulator by the industry.   Michael J. Keegan with Don’t Waste Michigan stated “This alternative repair amounts to an experiment that the NRC should not condone.  Entergy is a Limited Liability Company (LLC), and with tens of thousands of lives, all of Lake Michigan, and hundreds of billions of dollars in property damage on the line, the NRC must not approve this make-shift 'Band-Aid' repair.  This experiment must not be approved.”   For comprehensive documentation, please visit the Beyond Nuclear webpage at this link, http://www.beyondnuclear.org/safety/2020/9/26/documentation-re-entergy-palisades-request-to-nrc-for-permis.html, or reach out to the contacts listed above. -30-

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

Update on October 1, 2020 by admin

A DISASTER WAITING TO HAPPEN

Palisades atomic reactor, MI

Entergy Nuclear has requested the Nuclear Regulatory Commission allow it to do a "Band-Aid" repair on a cracked reactor pressure vessel (RPV) head penetration, a principal safety barrier. "Band-Aid" is not hyperbole, but reportedly the term some plant workers use to refer to the risky loophole in American Society of Mechanical Engineering safety standards. Beyond Nuclear and Don't Waste Michigan issued a press release, and their legal counsel, Terry Lodge, filed a Freedom of Information Act Request. Palisades has the worst neutron-embrittled U.S. RPV, risking pressurized thermal shock fracture, and meltdown, on Lake Michigan's shore. An NRC-commissioned study estimated more than 11,000 people could die, and 7,000 be injured, with $141 billion in property damage, if Palisades melts down.

READ MORE.

 

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

[Submitted via <foia@nrc.gov>; see FOIA request, in PDF format, as submitted on Beyond Nuclear letterhead, linked here.]

Dear NRC FOIA Officer:

   Please respond to the below FOIA request, which is also attached to this email.  Thank you.

Terry J. Lodge, Esq.

Counsel for Beyond Nuclear and Don't Waste Michigan

FROM: Beyond Nuclear     

7304 Carroll Avenue, #182
Takoma Park. MD 20912
Tel: 301.270.2209
Email: info@beyondnuclear.org
www.beyondnuclear.org

                        September 29, 2020

TO: Chief Division of Freedom of Information and Publication Services
Office of Administration U.S. Nuclear Regulatory Commission
Washington, DC 20555
Via email only to foia@nrc.gov

    Subject:  Beyond Nuclear / Don't Waste Michigan FOIA Request Pertaining to Palisades Nuclear Power Plant

Dear FOIA Officer:

    Pursuant to the Freedom of Information Act (FOIA); 5 U.S.C. 552(b), et seq., Beyond Nuclear and Don't Waste Michigan hereby request information for the subject matter described as follows. This request covers, but is not limited to, all draft and final reports, correspondence, memoranda, notes, records of telephone contacts, electronic communications including fax transmissions and email, or other written records, whether in paper or digital format, preserved via the use of any medium (e.g., paper documents, final notes, or word processors or computer discs, diskettes, hard drives, or network systems.) In addition, this request includes studies, analyses, work papers, internal or external communications of any sort, testimony, press releases, reports, diagrams and drawings, memoranda of the like and photographs in print or digital format concerning, recording or in any way related to the following:

    1) All records dated on and after September 8, 2020 [related to the discovery of
degradation of a principal safety barrier at Penetration 34 and Penetration 17 first publicly articulated on September 11, 2020 [at Event Number: 54897] of analyses, assessments, discussions, and/or evaluation of the risk implications of operation of Palisades reactor pressure vessel head with alternative 21.8-month repair Penetration weld 34 and Penetration weld 17 versus standard established weld 27-year repair for Penetration welds.
    Included within the scope of this request are records dated on and after September 8, 2020, commenting on and/or discussing risk analyses, assessments, discussions and/or evaluations of the risk implications of catastrophic failure of Penetration welds leading to loss of coolant accident (LOCA) cascading into Pressurized Thermal Shock (PTS) of the dangerously neutron-embrittled reactor pressure vessel, after activation of the Emergency Core Cooling System, risking through-wall fracture, and inevitable core meltdown.

    2) All records regarding the NRC’s assessment of the significance of findings and observations from February 1, 2018 forward pertaining to Penetration welds repairs performed in the Spring of 2018, including Penetration Quality Assurance provided by Framatome, Entergy  and the NRC; Documents from 2018 Penetration examinations; Documentation indicating QA review by the NRC.  

    3) All documentation demonstrating previous approval of 21.8 months Penetration weld repair at any U.S. reactor elsewhere that have had exact weld repair proposed with 21.8 months.  Request for methodology utilized including metallurgical failure analysis justifying lesser repairs without Stress Relief and Pressure Testing as proposed at Palisades. Also, all documentation referencing 27 year weld repair vs. 21.8 month weld repair.  All documentation showing the Inspection Records of remaining / balance of Penetration welds at Palisades.  Please include documentation that these Penetration weld Inspections have been reviewed and approved by the NRC.

    4) Request “Palisades CEDM Nozzle IDTB Repair- Life Assessment Summary,” Document Number 51-5047343-009, referred to herein as “Document.”  The Non-Proprietary document has been identified as: PNP 2020-031 Framatome Document No. 51-9292503-002, Palisades CEDM Nozzle IDTB Repair- Life Assessment Summary. We request provision of the Proprietary edition.  Citations 2 through 9 have been redacted, please provide these documents. This document has been identified by Framatome to be reviewable on a need-to-know basis.  FOIA Petitioners have a need to know, and we stand amenable to nondisclosure if it is provided to an independent expert of our choosing.  There is absolutely no intent to use this information to commercial advantage or disclosure.  If there are additional legal requests or hurdles to be able to obtain this document, please advise.  

    5)  Please provide all documents and communications prepared or utilized by, in the possession of, or routed through the NRC related to items 1, 2, 3 and 4 above.

    For any portion of the request that you deny, Beyond Nuclear and Don't Waste Michigan request that you describe the information that is denied, identify the exception to the FOIA on which you rely, and explain how that exception applies to the withheld information.

    Pursuant to federal regulations at 10 CFR § 9.41, Beyond Nuclear and Don't Waste Michigan request that any search and copy fees incurred as a result of this search be waived, and provide the following information in response to the eight criteria listed in § 9.41(b):

    1) Purpose of request: The purpose of the request is to gather information on NRC oversight and enforcement of regulation regarding the operation of nuclear power generating stations and public safety. The requested information is currently not publicly available through the agency’s public document room. The public interest is served by the release of requested documents.

    2) Extent to which Beyond Nuclear and Don't Waste Michigan will extract and analyze the substantive content of the records: Beyond Nuclear and Don't Waste Michigan are qualified to make use of the requested information. Beyond Nuclear and Don't Waste Michigan with expert consultation and legal counsel have in the past demonstrated the ability to interpret information and communicate that information in a form comprehensible to the general public.
Beyond Nuclear and Don't Waste Michigan have demonstrated competent participation in NRC 2.206 Petitions, Interventions before the Atomic Safety Licensing Board.  Additionally, they have evinced public interest and advocated for environmental protection and nuclear safety at the Palisades NPP, as well as many other reactors, for decades.  Beyond Nuclear and Don't Waste Michigan staff and researchers have thirty plus years of working relationship with physicists, structural and nuclear engineers, federal policy analysts and other respected professionals who contribute to the full understanding of NRC oversight and enforcement of regulation regarding the operation of nuclear power generating stations and public safety.

    3) Nature of the specific activity or research in which the records will be used: Beyond Nuclear and Don't Waste Michigan have qualifications to utilize the information to contribute to public understanding of NRC oversight and enforcement of regulation regarding the operation of nuclear power generating stations and public safety, particularly the Palisades NPP in Michigan.

    4) Likely impact on the public understanding of the subject as compared to the level of understanding of the subject prior to disclosure: Public understanding of the issues regarding NRC oversight and enforcement of requirements for the protection of public safety will be increased by the disclosure of this information particularly because it involves an urgent repair with almost no public notification in advance.

    5) Size and nature of the public to whose understanding a contribution will be made:
Don't Waste Michigan regularly provides resource material to electronic and print media outlets with very broad outreach to its constituency and the interested public, particularly in Michigan, where the Palisades NPP is located. Don't Waste Michigan regularly provides documents and information to email network listservs with upwards of two thousand registrants. Beyond Nuclear performs similar public communications services, including to its own twelve thousand plus members and supporters nation-wide, but also via dozens of nation-wide listservs, as well as by maintaining an educational website.

    6) Means of distribution of the requested information: Beyond Nuclear and Don't Waste Michigan will utilize regional and national media contacts in both electronic and print media outlets to provide very broad outreach to the public and interested stakeholders on this issue. Beyond Nuclear and Don't Waste Michigan will also share information with interested parties concerned about NRC oversight and enforcement of public safety requirements. Additionally, Beyond Nuclear and Don't Waste Michigan will post information on regional and state Environmental Networks and Newsletters.  Beyond Nuclear will post FOIA-released documents at its website.  

    7) Whether free access to information will be provided: Yes. Beyond Nuclear and Don't Waste Michigan have always and will continue to provide the information obtained through FOIA without charge to the general public. Information from the FOIA requested will be prepared to be electronically posted material on Environmental web sites, including Beyond Nuclear’s own for downloading free of charge. Beyond Nuclear and Don't Waste Michigan will provide electronic copy of information to all interested members of the public without charge.

    8) No commercial interest by Beyond Nuclear and Don't Waste Michigan or any other party: Beyond Nuclear and Don't Waste Michigan have no commercial interest in obtaining the requested information. This information is provided to all public requests without charge. The interest of Beyond Nuclear and Don't Waste Michigan is to promote an open policy debate on the NRC oversight and enforcement of requirements for the protection of public health and safety. The interest of Beyond Nuclear and Don't Waste Michigan is to participate in all avenues afforded by the NRC and to utilize FOIA responses to do so.

    Please send responses to all three email addresses listed below. Thank you.

                        Sincerely,
                        
                        /s/ Kevin Kamps           
                        Kevin Kamps
                        kevin@beyondnuclear.org
                        Beyond Nuclear
                        7304 Carroll Avenue, #182, Takoma Park, MD 20912
                        Tel: 301.270.2209 Email: info@beyondnuclear.org
                        www.beyondnuclear.org
                        
                        /s/ Michael J. Keegan   
                        Michael J. Keegan
                        mkeeganj@comcast.net
                        Don't Waste Michigan
                        
                        /s/ Terry J. Lodge         
                        Terry J. Lodge, Esq.
                        316 N. Michigan St., Suite 520
                        Toledo, OH 43604-5627
                        (419) 205-7084
                        Tjlodge50@yahoo.com
                        Counsel for Beyond Nuclear and Don’t Waste Michigan

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

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

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

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

DEGRADED CONDITION

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

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

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

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

"The licensee notified the NRC Senior Resident Inspector."

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

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

Update on September 15, 2020 by admin

NRC meeting announcement, dated Sept. 15th:

Meeting Dates and Times

09/21/20  11:00AM - 12:00PM

Meeting Announcement

Meeting info

Purpose The purpose of this teleconference is for the Nuclear Regulatory Commission (NRC) staff to discuss with Entergy its emergent alternative request to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, related to the repair of the Palisades reactor pressure vessel head penetrations.  Meeting Feedback

Meeting Location Teleconference
Contact Booma Venkataraman
301-415-2934

Scott Wall
301-415-2855

Participation Level Category 1 NRC Participants

Booma Venkataraman, Office of Nuclear Reactor Regulation
Jay Collins , Office of Nuclear Reactor Regulation
External Participants

Jim Miksa, Entergy
Docket Numbers - Facility Names 05000255 - Palisades

Related Documents

ML20260H350 - 09/21/2020 Pre-Submittal Teleconference with Entergy Nuclear Operations, Inc. (Entergy) Regarding a Proposed Alternative to ASME Code Requirements for Repair of Reactor Pressure Vessel Head Penetrations at Palisades Nuclear Plant (Palisades).

Update on September 21, 2020 by admin

Documents related to the meeting:

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML20267A386

There are links provided there to four separate documents:

1.) Palisades Nuclear Plant, Relief Request, Number RR 5-8, Proposed Alternative to ASME [American Society of Mechanical Engineers] Section XI Code Requirements for Repair of Reactor Pressure Vessel Head Penetrations;

2.) Attachment 1 - Relief Request Number RR 5-8, Proposed Alternative to ASME Section XI Code Requirements for Repair of Reactor Pressure Vessel Head Penetrations;

3.) Attachment 3 - Framatome Inc. Affidavit Supporting Withholding of Prorietary Information;

4.) Framatome Document No. 51-9292503-002, "Palisades CEDM Nozzle IDTB Repair - Life Assessment Summary".

Update on September 21, 2020 by admin

Link to audio recording of the 11am Eastern, Monday, September 21st NRC-Entergy Palisades meeting (a Category 1 public teleconference), recorded by Kraig Schultz of Grand Haven, MI, a member of Michigan Safe Energy Future (MSEF), who resides 50 miles from Palisades:

https://drive.google.com/file/d/17w2c2Elzi4t3Fnjqvx4Zf2wLIiqPI5Ki/view

As documented on the audio recording, attendees at this meeting included: NRC staff from both HQ in Rockville, MD as well as the Region III office in Lisle, IL; Entergy Nuclear Palisades representatives; and public watch-dogs and concerned citizens, including Kraig Schultz of MSEF in Grand Haven MI, Michael Keegan of Don't Waste Michigan in Monroe MI, Jan Boudart of Nuclear Energy Information Service in Lisle, IL, and Kevin Kamps of Beyond Nuclear in Takoma Park MD (a board member of Don't Waste MI, representing the Kalamazoo chapter).

Kraig Schultz of Michigan Safe Energy Future has provided the following transcriptions of especially significant portions of the meeting (with the time stamp from the recording indicated):

10:40-11:41  Entergy Employee (Jim Mitka?):  
“The purpose of this call is to discuss Entergy’s plan to submit a plan to submit a relief request for an alternative to the ASTM … code requirements for the repair of Palisades reactor vessel head penetrations.  The relief request scope is for the repair of two penetrations at nozzle location 17 and 34.

Entergy plans to submit the relief request on Wednesday, September 23^rd and requests approval by Thursday, October 1^st.  The request date is based on the current reactor vessel head penetration repair schedule.

The proposed duration of the relief request is 20 months based on Entergy’s notification of cessation of permanent power operations at Palisades no later than May 31^st of 2022. “
-------------

17:58-20:17   Framatone Employee: 
“The weld repairs performed previously at Palisades have a life expectancy of 27 effective full power years.  The life expectancy of the weld repairs being performed this outage have been conservatively estimated at 21.8 effective full power months.  The reason for the difference is due to not performing surface stress improvement of the repairs.  Surface stress improvement process results in compressive stresses being induced on the surface of the new weld and the adjacent base materials.  And without performing surface stress remediation the surface of the weld and the adjacent base materials will remain in tension.  The life of the weld repair without stress improvement has been evaluated using primary water stress corrosion cracking crack growth model revision 1 of MRP 420.  The predicted primary water stress corrosion cracking surface life of the repair is in excess of the 20 effective full power month length of the remaining cycle at Palisades.

If the updated MRP 55 equation had been used instead, the repair life would have been slightly longer.

The life expectancy calculated for the current repairs is considered conservative since it is assumed that there are small axial flaws in the Alloy 600 nozzle that were barely not detected by the surface examination.  And, it is also assumed that the flaws start to grow immediately upon plant start up.  In other words there is no incubation period. 

Palisades is currently scheduled to operate for only one more fuel cycle, which is less than 20 months.  The plant will permanently cease operations on May 31, 2022 as previously mentioned.  Therefore, the repairs performed during this outage will remain in place for the one remaining fuel cycle in the operating life of the plant.

As part of the planned alternative, the following documentation will be included, a proprietary version of the life assessment summary, along with an affidavit for withholding the proprietary information, and a non proprietary version of the same life assessment summary.”


22:00  Jay Collins at NRC Asked
”The 21.8 effective full power months, is a figure which you’ve provided here, is that just an attempt to be greater than the 20 months identified by need for this relief request, or is there potentially additional margin within the assessment?”

Person named ??????, Fractional Mechanics Lead from ???
“The answer, Jay Collins, to that question; this is based on explicit calculations that Framatone has performed that yielded the 21.8 effective full power months.”

Greg Hubbers Palisades Engineering: 26:16
“The timeline for the last relief request was from our repair in 2004 out until the end of life of Palisades in 2031 which was 27 full effective power years.”

Jay Collins:  34:37  “Can we get a plant status, as far as where you guys are with these repairs; have you started these repairs at risk at this point?  Are you at liberty to have those discussions at this point?”

Jim Mitka:  34:58  “We have not commenced repairs as of today.  We are in the process of mobilizing and prepping to start repairs in the near future.”

Jay Collins: 35:14  “And when is the anticipated head lift back to put it back on the vessel?  Or, is that non-appropriate to ask?”

Jim Mitka:  35:28 “Per our current repair plan, the demobilization of equipment for the repair is on October 2^nd with the head set back on the flange a couple days…” (before???)… “that.”

Jay Collins:  35:50 “Understood, October 2^nd was when you would start demobilization.”   

Update on September 28, 2020 by admin

---------- Forwarded message ---------
From: Kraig D Schultz <kraig@schultzengineering.us>
Date: Mon, Sep 28, 2020 at 8:07 AM
Subject: Palisades Request for Relief RR 5-8
To: <Booma.Venkataraman@nrc.gov>, <Scott.Wall@nrc.gov>

To the NRC,

The Palisades nuclear power plant is about to enter its 50th year of operation.  This milestone is amazing given its reputation for having one of the most embrittled reactor pressure vessels in the world.  That two new cracks have developed in the lid of the vessel since 2018 should give us yet another warning that we are in a dangerous phase of operation for this plant, the age degraded phase.   Given the brittleness of the vessel, we are potentially just one rapid emergency shutdown from it bursting and resulting in a Fukushima-like event in Michigan.

On Monday, September 21, 2020, Palisades Nuclear Power plant operators announced that they are planning to skip important steps in repairing the cracks that have developed since 2018.  Palisades operators are asking the NRC to give it permission to skip these steps.  Furthermore, the Palisade operators gave the NRC a short deadline to approve the lower quality repairs with the attitude that the NRC is expected to approve this behavior.

This is NOT the role we expect the NRC to play.  The NRC’s job is to regulate the nuclear industry and ensure that a culture of safety is maintained.  The NRC should not allow Palisades operators to bully it or force the approval of lower quality repair procedures.  The NRC has the authority, the resources and the responsibility to send strong messages to the nuclear industry that now is NOT the time to relax regulations, now is the time to be EXTRA vigilant.  With an average age of about 38 years old, the U.S. commercial nuclear fleet is in the phase of its lifecycle where we must be taking extra diligence to combat age related degradation. 

Catastrophic failure events often do not happen in isolation.  They can result from cascading failures of seemingly tiny things that snowball into major events.  We have enough problems going on in 2020 to worry about.  Having our nuclear plant operators deciding to do non-regulation repairs when they see fit for the sake of financial profit is unacceptable.

We rely on the NRC to safeguard our community by enforcing NRC regulations.  We support strong action by the NRC to enforce regulations that ensure our nuclear fleet operates safely until each plant reaches the end of its service.

Specifically, pertaining to ML20267A386

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML20267A386 

Document Title:

Palisades Nuclear Plant, Relief Request Number RR 5-8, Proposed Alternative to ASME Section XI Code Requirements for Repair of Reactor Pressure Vessel Head Penetrations.

On September 21, 2020, two methods were discussed for repairing the current cracks in the Palisades Reactor Pressure Vessel Head.  One is calculated to last 1.8 years (21.8 Months) and the other to last for 27 years.  Palisades is requesting to use the 1.8 year repair because they claim they will cease operations 1.7 years from now (on or before May 31, 2022).

The NRC has licensed Palisades to operate until 2031 (11 more years).  A 1.8 year repair does not take the plant to the end of its license period and therefore should be rejected.

Entergy Corporation, the owners of Palisades Power plant, have a long history of trading risk to the community for corporate profit.  The entire reactor lid was supposed to be replaced as part of the purchase from Consumers Energy in 2007.  Prior to 2018, the Entergy corporation fooled our community and the NRC by stating it was going to shut down in October 2018.  They later changed the shut down date to 2022.  With this tactic, they traded public safety for corporate profit when proposing relief requests to the NRC based on shifting shut down dates.

If the operators of Palisades cannot afford to repair the cracks in the lid of the reactor vessel per regulations, then perhaps the NRC should revoke its license to operate immediately?

Therefore, we stand in support of NRC actions to reject the Palisades relief request RR 5-8 and require that Palisades operators do repairs per regulations until the end of its license.

Alternatively, if the NRC should decide to allow a lower quality repair, it should amend Palisades license to expire on the proposed May 31, 2022 date.

Finally, let’s proceed to the final shutdown with an attitude of humility and cautious respect for the most powerful force in the universe, the force that binds our atoms together.  Instead of doing just barely enough to make it to shutdown, let’s ratchet up our focus and excellence so that we complete our operations safely and without incident. 

Sincerely,

On Behalf of Michigan Safe Energy Future

Kraig D. Schultz   

Update on September 29, 2020 by admin

4 Palisades Weld Repair Documents, Docketed at 1 pm, Monday, September 29, 2020:

ML20272A166

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML20272A166 

Document Title:	Attachment 3 - Framatome Document No. ANP-3876, Revision 1Q1NP, "Response to NRC Request for Additional Information of Palisades Relief Request Number RR 5-8, Repair of Reactor Pressure Vessel Head Penetration, Inservice Inspection Program, .....
Document Type:	Code Relief or Alternative Report, Technical Response to Request for Additional Information (RAI)
Document Date:	09/30/2020

ML20272A165

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML20272A165 

Document Title:	Attachment 2 - Framatome, Inc. Affidavit Supporting Withholding of Proprietary Information.
Document Type:	Legal-Affidavit
Document Date:	09/27/2020

ML20272A163

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML20272A163 

Document Title:	Palisades Nuclear Plant, Response to Request for Additional Information Regarding Relief Request Number RR 5-8, Proposed Alternative to ASME Section XI Code Requirements for Repair of Reactor Pressure Vessel Head Penetrations.
Document Type:	Letter
Document Date:	09/28/2020 ML20226A272 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML20226A272  Document Title: Arkansas Nuclear One, Units 1 and 2, Grand Gulf, Indian Point, Unit 3, Palisades, River Bend and Waterford 3 - Request to Use a Provision of a Later Edition of the ASME BPV Code, Section XI (EPID L-2020-LLR-0108) Document Type: Letter Safety Evaluation Document Date: 08/18/2020

Update on September 29, 2020 by admin

[Submitted via <foia@nrc.gov>; see FOIA request, in PDF format, as submitted on Beyond Nuclear letterhead, linked here.]

Dear NRC FOIA Officer:

   Please respond to the below FOIA request, which is also attached to this email.  Thank you.

Terry J. Lodge, Esq.

Counsel for Beyond Nuclear and Don't Waste Michigan

FROM: Beyond Nuclear     

7304 Carroll Avenue, #182
Takoma Park. MD 20912
Tel: 301.270.2209
Email: info@beyondnuclear.org
www.beyondnuclear.org

                        September 29, 2020

TO: Chief Division of Freedom of Information and Publication Services
Office of Administration U.S. Nuclear Regulatory Commission
Washington, DC 20555
Via email only to foia@nrc.gov

    Subject:  Beyond Nuclear / Don't Waste Michigan FOIA Request Pertaining to Palisades Nuclear Power Plant

Dear FOIA Officer:

    Pursuant to the Freedom of Information Act (FOIA); 5 U.S.C. 552(b), et seq., Beyond Nuclear and Don't Waste Michigan hereby request information for the subject matter described as follows. This request covers, but is not limited to, all draft and final reports, correspondence, memoranda, notes, records of telephone contacts, electronic communications including fax transmissions and email, or other written records, whether in paper or digital format, preserved via the use of any medium (e.g., paper documents, final notes, or word processors or computer discs, diskettes, hard drives, or network systems.) In addition, this request includes studies, analyses, work papers, internal or external communications of any sort, testimony, press releases, reports, diagrams and drawings, memoranda of the like and photographs in print or digital format concerning, recording or in any way related to the following:

    1) All records dated on and after September 8, 2020 [related to the discovery of
degradation of a principal safety barrier at Penetration 34 and Penetration 17 first publicly articulated on September 11, 2020 [at Event Number: 54897] of analyses, assessments, discussions, and/or evaluation of the risk implications of operation of Palisades reactor pressure vessel head with alternative 21.8-month repair Penetration weld 34 and Penetration weld 17 versus standard established weld 27-year repair for Penetration welds.
    Included within the scope of this request are records dated on and after September 8, 2020, commenting on and/or discussing risk analyses, assessments, discussions and/or evaluations of the risk implications of catastrophic failure of Penetration welds leading to loss of coolant accident (LOCA) cascading into Pressurized Thermal Shock (PTS) of the dangerously neutron-embrittled reactor pressure vessel, after activation of the Emergency Core Cooling System, risking through-wall fracture, and inevitable core meltdown.

    2) All records regarding the NRC’s assessment of the significance of findings and observations from February 1, 2018 forward pertaining to Penetration welds repairs performed in the Spring of 2018, including Penetration Quality Assurance provided by Framatome, Entergy  and the NRC; Documents from 2018 Penetration examinations; Documentation indicating QA review by the NRC.  

    3) All documentation demonstrating previous approval of 21.8 months Penetration weld repair at any U.S. reactor elsewhere that have had exact weld repair proposed with 21.8 months.  Request for methodology utilized including metallurgical failure analysis justifying lesser repairs without Stress Relief and Pressure Testing as proposed at Palisades. Also, all documentation referencing 27 year weld repair vs. 21.8 month weld repair.  All documentation showing the Inspection Records of remaining / balance of Penetration welds at Palisades.  Please include documentation that these Penetration weld Inspections have been reviewed and approved by the NRC.

    4) Request “Palisades CEDM Nozzle IDTB Repair- Life Assessment Summary,” Document Number 51-5047343-009, referred to herein as “Document.”  The Non-Proprietary document has been identified as: PNP 2020-031 Framatome Document No. 51-9292503-002, Palisades CEDM Nozzle IDTB Repair- Life Assessment Summary. We request provision of the Proprietary edition.  Citations 2 through 9 have been redacted, please provide these documents. This document has been identified by Framatome to be reviewable on a need-to-know basis.  FOIA Petitioners have a need to know, and we stand amenable to nondisclosure if it is provided to an independent expert of our choosing.  There is absolutely no intent to use this information to commercial advantage or disclosure.  If there are additional legal requests or hurdles to be able to obtain this document, please advise.  

    5)  Please provide all documents and communications prepared or utilized by, in the possession of, or routed through the NRC related to items 1, 2, 3 and 4 above.

    For any portion of the request that you deny, Beyond Nuclear and Don't Waste Michigan request that you describe the information that is denied, identify the exception to the FOIA on which you rely, and explain how that exception applies to the withheld information.

    Pursuant to federal regulations at 10 CFR § 9.41, Beyond Nuclear and Don't Waste Michigan request that any search and copy fees incurred as a result of this search be waived, and provide the following information in response to the eight criteria listed in § 9.41(b):

    1) Purpose of request: The purpose of the request is to gather information on NRC oversight and enforcement of regulation regarding the operation of nuclear power generating stations and public safety. The requested information is currently not publicly available through the agency’s public document room. The public interest is served by the release of requested documents.

    2) Extent to which Beyond Nuclear and Don't Waste Michigan will extract and analyze the substantive content of the records: Beyond Nuclear and Don't Waste Michigan are qualified to make use of the requested information. Beyond Nuclear and Don't Waste Michigan with expert consultation and legal counsel have in the past demonstrated the ability to interpret information and communicate that information in a form comprehensible to the general public.
Beyond Nuclear and Don't Waste Michigan have demonstrated competent participation in NRC 2.206 Petitions, Interventions before the Atomic Safety Licensing Board.  Additionally, they have evinced public interest and advocated for environmental protection and nuclear safety at the Palisades NPP, as well as many other reactors, for decades.  Beyond Nuclear and Don't Waste Michigan staff and researchers have thirty plus years of working relationship with physicists, structural and nuclear engineers, federal policy analysts and other respected professionals who contribute to the full understanding of NRC oversight and enforcement of regulation regarding the operation of nuclear power generating stations and public safety.

    3) Nature of the specific activity or research in which the records will be used: Beyond Nuclear and Don't Waste Michigan have qualifications to utilize the information to contribute to public understanding of NRC oversight and enforcement of regulation regarding the operation of nuclear power generating stations and public safety, particularly the Palisades NPP in Michigan.

    4) Likely impact on the public understanding of the subject as compared to the level of understanding of the subject prior to disclosure: Public understanding of the issues regarding NRC oversight and enforcement of requirements for the protection of public safety will be increased by the disclosure of this information particularly because it involves an urgent repair with almost no public notification in advance.

    5) Size and nature of the public to whose understanding a contribution will be made:
Don't Waste Michigan regularly provides resource material to electronic and print media outlets with very broad outreach to its constituency and the interested public, particularly in Michigan, where the Palisades NPP is located. Don't Waste Michigan regularly provides documents and information to email network listservs with upwards of two thousand registrants. Beyond Nuclear performs similar public communications services, including to its own twelve thousand plus members and supporters nation-wide, but also via dozens of nation-wide listservs, as well as by maintaining an educational website.

    6) Means of distribution of the requested information: Beyond Nuclear and Don't Waste Michigan will utilize regional and national media contacts in both electronic and print media outlets to provide very broad outreach to the public and interested stakeholders on this issue. Beyond Nuclear and Don't Waste Michigan will also share information with interested parties concerned about NRC oversight and enforcement of public safety requirements. Additionally, Beyond Nuclear and Don't Waste Michigan will post information on regional and state Environmental Networks and Newsletters.  Beyond Nuclear will post FOIA-released documents at its website.  

    7) Whether free access to information will be provided: Yes. Beyond Nuclear and Don't Waste Michigan have always and will continue to provide the information obtained through FOIA without charge to the general public. Information from the FOIA requested will be prepared to be electronically posted material on Environmental web sites, including Beyond Nuclear’s own for downloading free of charge. Beyond Nuclear and Don't Waste Michigan will provide electronic copy of information to all interested members of the public without charge.

    8) No commercial interest by Beyond Nuclear and Don't Waste Michigan or any other party: Beyond Nuclear and Don't Waste Michigan have no commercial interest in obtaining the requested information. This information is provided to all public requests without charge. The interest of Beyond Nuclear and Don't Waste Michigan is to promote an open policy debate on the NRC oversight and enforcement of requirements for the protection of public health and safety. The interest of Beyond Nuclear and Don't Waste Michigan is to participate in all avenues afforded by the NRC and to utilize FOIA responses to do so.

    Please send responses to all three email addresses listed below. Thank you.

                        Sincerely,
                        
                        /s/ Kevin Kamps           
                        Kevin Kamps
                        kevin@beyondnuclear.org
                        Beyond Nuclear
                        7304 Carroll Avenue, #182, Takoma Park, MD 20912
                        Tel: 301.270.2209 Email: info@beyondnuclear.org
                        www.beyondnuclear.org
                        
                        /s/ Michael J. Keegan   
                        Michael J. Keegan
                        mkeeganj@comcast.net
                        Don't Waste Michigan
                        
                        /s/ Terry J. Lodge         
                        Terry J. Lodge, Esq.
                        316 N. Michigan St., Suite 520
                        Toledo, OH 43604-5627
                        (419) 205-7084
                        Tjlodge50@yahoo.com
                        Counsel for Beyond Nuclear and Don’t Waste Michigan