The U.S. Nuclear Regulatory Commission's (NRC) Advisory Committee on Reactor Safeguards (ACRS) will discuss FirstEnergy Nuclear Operating Company's (FENOC) application for a 20-year license extension (2017-2037) at its problem-plagued Davis-Besse atomic reactor on the Lake Erie shore in Oak Harbor, OH. However, while the ACRS discussion with FENOC and NRC staff officials is to address the entire license extension application, and NRC staff's Safety Evaluation Report (SER), a major focus will be the severe and worsening cracking of Davis-Besse's concrete containment Shield Building.
On Wed., Nov. 4, from 1 to 4pm Eastern, and continuing from 4 to 6pm Eastern, the NRC ACRS will discuss Davis-Besse's license extension application, despite its Shield Building's severe, and worsening, cracking. The call-in number is 1-866-822-3032; Passcode 8272423.
As shown on the NRC ACRS agenda for the meeting, Agenda Items 3.1 and 3.2, from 1-4pm Eastern, Wed., Nov. 4th, will be on the Davis-Besse license extension application. And during the latter part of the 4-6pm Eastern time block on Wed., Nov. 4th (Agenda Item 4.2), Davis-Besse's license extension will again be discussed. The severe, and worsening, cracking of the concrete containment Shield Building is a major stumbling block, and will be a major focus of the discussion.
Then on Thurs., Nov. 5th, during the 3-6pm Eastern time block, Agenda Item 8.2 will again be about Davis-Besse.
(The Fri., Nov. 6th session from 1-6pm Eastern could also involve a continuation of the Davis-Besse discussion, as could the 8:30am to Noon Eastern time block on Sat., Nov. 7th. Presumably, during all open-to-the-public sessions, the telephone bridge line should be functional.)
One or more public comment opportunities should be provided throughout the agenda at various times. Concerned citizens, as well as media reporters, are encouraged to listen-in, and to take advantage of the public comment opportunities, to let the ACRS know what you are thinking or to ask questions.
As you can see at this NRC posting, this ACRS multi-day meeting re: Davis-Besse is one of the very last check boxes, before NRC rubber-stamps the 20-year license extension, despite the Shield Building cracking. (Of course, environmental intervenors will continue to oppose the license extension at every turn -- including their Nuclear Waste Confidence court appeal, now before the second highest court in the land, the U.S. Court of Appeals for the District of Columbia Circuit.)
BACKGROUND
As official intervenors with legal standing before NRC's Atomic Safety and Licensing Board (ASLB), Beyond Nuclear and environmental coalition allies have raised official contentions in opposition to the license extension, regarding the containment cracking, beginning in January 2012, and continuing till now. These numerous major legal filings have fallen on deaf ears at ASLB.
However, after having denied our documented allegations along the very same lines, for four years, FirstEnergy made startling admissions on September 23, 2015 at an ACRS subcommittee meeting. Beyond Nuclear issued a press release the very next day about these significant revelations of the serious risks FENOC has now acknowledged regarding the worsening containment cracking.
For example, FirstEnergy admitted that collapse of large chunks of concrete from the Shield Building's exterior surface is a risk to safety-related systems, structures, and components below.
At Page 247, lines 21 to 23, the transcript from the 9/23/15 NRC Advisory Committee on Reactor Safeguards subcommittee meeting records the following passage:
(Mr. Byrd for FirstEnergy):
“…the answer is, yes, it could impact components that are safety related.”
Mr. Byrd of FirstEnergy's tesimony continues on Page 247, line 25, to Page 248, line 11:
"We have, first of all, the auxiliary building, which you can see clearly on this picture is safety related. And so having concrete falling on top of the auxiliary building is definitely impacting a safety related structure. We also, on that area to the left-hand side, we have our [borated] water storage tank, which is safety related. And obviously if we had large sections of concrete falling off the building, that would also effect the [borated] water storage tanks. We recognize that potential right in the beginning when we identified this condition.”
It must be pointed out that, if FirstEnergy "recognize[d] that potential right in the beginning when we identified this condition,” that is in October 2011, when the cracking was first revealed, they did not share or communicate that recognition with the pubilc, the media, or its own shareholders. In fact, FirstEnergy did quite the opposite, as by countering and denying, at every turn, such warnings made by environmental intervenors in the license extension proceeding, from January 2012 till this year.
Another highlight of the NRC ACRS subcommittee meeting on 9/23/15, was ACRS subcommittee members' repeated questioning of FirstEnergy as to why Impulse Response (IR) testing was not a part of its Aging Management Plan for the Shield Building cracking -- why it was not a requirement, instead of merely an option, as FirstEnergy kept insisting. This ACRS criticism echoed one made by Beyond Nuclear et al. for the past four years as well, that FirstEnergy has significant blind spots, when it comes to even knowing how bad the cracking is.
And given FirstEnergy's false assurance -- that its monitoring alone will prevent the worsening (a half-inch, or more, every time it freezes) cracking from coming to the point where actual chunks of concrete spall off the exterior, and crash down -- such blind spots are a serious problem.
Of course, there is also the potential risk of an earthquake -- another point that came up more than once during the ACRS subcommittee meeting on 9/23/15. Seismic risk seems to be the one they are most concerned about.
This also fits a pattern environmental intervenors have tried to call attention to since January 2012. During their multi-year intervention and numerous major legal filings, the environmental coalition repeatedly quoted two NRC safety engineers' late 2011 warnings, shortly after the cracking came to light, obtained in June 2012 via a hard won response by NRC to a coalition Freedom of Information Act (FOIA) request:
An NRC safety engineer inspects the cracking of the Davis-Besse Shield Building wall, shortly after it was first revealed on Oct. 10, 2011."I think the greater concern is will the SB [Shield Building] stay standing, and not whether or not the decorative concrete will fall off. Because the licensee has not performed core bores to see if there is cracking in the credited concrete, do they have a basis to say that the structural concrete will maintain a Seismic II/I condition?" ---Pete Hernandez, NRC, 11/4/11 (see FOIA document B/9, Page 1, bottom paragraph);
"I am concerned that the concrete will fail in this region due to bending in this region even under small loads." ---Abdul Sheikh, NRC, 11/22/11 (see FOIA document B/26, point #2, last sentence).
Although FirstEnergy has done a relatively small number of core bores since, given the size of the Shield Building, the testing has been woefully inadequate, as intervenors have warned countless times in the ASLB license extension proceeding. Impulse Response (IR) testing could well show where more core bores are needed, but FirstEnergy refuses to do such comprehensive IR testing, and NRC staff refuses to require it, despite the ACRS subcommittee members' strong questioning on 9/23/15 as to why not.
In fact, the first FOIA document released to the environmental coalition (undated NRC document B/1) showed that the ACRS had seismic concerns at Davis-Besse even "prior to operation" (that is, before April 22, 1977).
The arrow marks the location of sub-surface laminar cracking at the outer rebar mat (layer), located three inches beneath the exterior face concrete of the Shield Building. Still image from NRC Office of Public Affairs video.That early concern, and NRC staff safety engineers Hernandez and Sheikh's 2011 warnings, were vindicated by FirstEnergy's admissions, and ACRS's documented concern, on 9/23/15. Such concerns are all the more serious now, that the Shield Building is known to be severely cracked, and worsening with every freeze-thaw cycle.
An earthquake -- or another tornado strike, like the one that happened in June 1998 (see Page 3 of this 2010 Beyond Nuclear backgrounder on the many near-misses at Davis-Besse over the decades) -- could be that additional "small load" that causes the Shield Building to fail and collapse, impacting safety significant systems, structures, and components below. Beyond Nuclear et al. have been making these arguments for four years, but they have been attacked by FirstEnergy and NRC staff, and have been ignored by the Atomic Safety and Licensing Board. As revealed on 9/23/15, it seems that FirstEnergy and ACRS are admitting these are -- and have been all along -- valid concerns.
For more information, see the 8/8/2012 Beyond Nuclear backgrounder "What Humpty Dumpty Doesn't Want You to Know: Davis-Besse's Cracked Containment Snow Job." (see photo, above left).