NRC-FirstEnergy meeting on 12/17/15 re: concerns with Davis-Besse's emergency diesel generators

On Mon., Dec. 14th, NRC staff publicly announced that a meeting originally scheduled for Tuesday morning, Dec. 15th, has been rescheduled for Thursday morning, Dec. 17th, beginning at 10:30am Eastern. The meeting will take place by teleconference, re: a License Amendment Request (LAR) by FirstEnergy, to revise  required safety standards regarding Emergency Diesel Generators (EDGs) at Davis-Besse.

Here are the toll-free call-in numbers:

Phone: 888-950-6757

Passcode: 12158

Concerned local residents, environmental group representatives, and news media reporters are encouraged to call-in. 

The postponement of the meeting was announced just a few hours after the filing of an official allegation concerning Davis-Besse's EDGs by David Lochbaum, director of the Nuclear Safety Program at Union of Concerned Scientists. 

Lochbaum has documented that concerns with the EDGs at Davis-Besse date back not months, but years -- to 2012. (See "Additional Relevant Documents" linked at the bottom of this web post.)

The application was submitted 4/1/15 and is available under ADAMS Accession No. ML15091A143. (Beyond Nuclear received this doc as a PDF from Blake Purnell, and posted it at the Beyond Nuclear website at the following link: http://static1.1.sqspcdn.com/static/f/356082/26729948/1449862061550/4+1+15+ML15091A143+-+Davis-Besse+-+License+Amendment+Request+to+Revise+Emergenc....pdf?token=IBYEWgfqTzERpW5%2BZirIXFajX2U%3D )

By letter dated Sept. 21, 2015 (ML15222A179), the NRC requested additional information to complete its review of the License Amendment Request (LAR). FENOC response, dated 10/14/15, is immediately below.

A supplement to the application was submitted on 10/14/15 and is available under ADAMS Accession No. ML15287A251. (It is viewable online at the NRC's website, posted here: http://pbadupws.nrc.gov/docs/ML1528/ML15287A251.pdf )]

On Dec. 7, 2015, NRC's Mr. Purnell emailed more detailed "Questions for Meeting" to Beyond Nuclear's Kevin Kamps. (Please note, as mentioned above, the meeting will now take place on Thursday, December 17th at 10:30am Eastern.)

However, Lochbaum's allegation email cited above documents that concerns regarding Davis-Besse's EDGs date back not to April 2015, but rather to 2012. (See "Additional Relevant Documents," listed at the bottom of this web post.)

Shockingly, and frighteningly, it appears that 45 years after NRC's predecessor agency, the U.S. Atomic Energy Commission (AEC) established basic EDG safety standards, and nearly 40 years after Davis-Besse began operating, they still don't have assurance that the EDGs will work correctly, or at all, if called upon!

Here is NRC's basic agenda for the meeting, including NRC points of contact:

[Title: Meeting with FirstEnergy Nuclear Operating Company

Date(s) and Time(s): December 17, 2015, 10:30 AM to 11:00 AM

Location: Teleconference

Category: This is a Category 1 meeting. The public is invited to observe this meeting and will have one or more opportunities to communicate with the NRC after the business portion of the meeting but before the meeting is adjourned.

Purpose: Discuss April 1, 2015, license amendment request to revise emergency diesel generator minimum voltage and frequency surveillance requirements at Davis-Besse Nuclear Power Station.

Contact: Blake Purnell, 301-415-1380

Blake.Purnell@nrc.gov

[Blake Purnell, Project Manager, Plant Licensing Branch III-2 and Planning and Analysis Branch, Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission]

and

Jennifer Hauser, 301-415-1687

Jennifer.Hauser@nrc.gov ]

ADDITIONAL BACKGROUND INFORMATION ON SAFETY SIGNIFICANCE OF EDGs

As so tragically shown at Fukushima Daiichi, the emergency diesel generators (EDGs) are the last line of defense against reactor core meltdown and catastrophic radioactivity release.

In June 1998, after a tornado scored a direct hit at Davis-Besse, passing between the Shield Building and cooling tower, destroying the electric grid (and thus the primary source of electricity to run safety and cooling systems), the emergency diesels nearly failed. The second and last EDG broke down a number of times over the course of the ensuing day after the tornado struck. The headline in the Kalamazoo Gazette, a day or two after the smoke cleared, was "Nuclear Disaster Averted" at Davis-Besse. "Narrowly" went without saying.

Dave Lochbaum at UCS said at the time that but for the extraordinary efforts by Davis-Besse personnel, such as to revive the repeatedly failing second and last EDG, that nuclear disaster may not have been narrowly averted.

As Fukushima has shown, hot reactor cores have to be cooled for days after the nuclear reaction is stopped, or else they'll still melt down due to the decay heat. Dr. Gordon Edwards of Canadian Coalition for Nuclear Responsibility recently made this point at the Port Huron, MI day-long event opposing the Canadian Great Lakes shore nuke waste dump on Nov. 9th. He pointed out that the radioactive decay, alone, still generates around 10% of the thermal heat of an operating reactor core, more than enough to melt down the core without active cooling. That's how very radioactive (as well as thermally hot) irradiated nuclear fuel is. It's why, nearly five years after the meltdowns at Fukushima, Tokyo Electric still pumps hundreds of tons of cooling water per day into the ruined reactors (even though they don't know exactly WHERE the melted cores are located!), to prevent another overheating, re-meltdown, and renewed "China syndrome." It's also why irradiated nuclear fuel must be cooled for at least five years in high-level radioactive waste storage pools, before transfer to air-cooled dry cask storage (it's too thermally hot, not to mention too radioactive, before that, for storage in dry casks).

By the skin of its teeth, Davis-Besse avoided a core meltdown in June 1998. My understanding is the second and last EDG gave up the ghost for good, shortly after the grid was restored, to provide electricity to the safety and cooling systems. I assume that while Davis-Besse workers were performing repeated "CPR" on the second, and last, EDG, other FirstEnergy work crews were racing to restore the grid in time.

It's incredible that our society is willing to play such high-stakes games of "radioactive Russian roulette," when electricity could be provided safely with renewables and efficiency (not to mention securely, cleanly, affordably, reliably, etc.). In fact, Dr. Al Compaan, emeritus professor of physics at UT, served as our environmental coalition's expert witness in our intervention against the 20-year license extension at Davis-Besse, testifying that solar photovoltaics (PV) alone, or wind power alone, could readily replace Davis-Besse's 908 Megawatts-electric. (Of course, solar PV and wind power in combination could all the more readily replace Davis-Besse!) The NRC Atomic Safety and Licensing Board Panel was interested to hear more, and granted us a hearing on the technical merits of our renewable alternatives to 20 more years of Davis-Besse's risks. But FirstEnergy appealed that ruling. The NRC Commissioners sided with FirstEnergy, and overruled the licensing board. Thus, our hearing denied.

Just below is pasted in the section, re: the June 1998 tornado strike "near miss," from Beyond Nuclear's 2010 backgrounder on Davis-Besse's many close calls with catastrophe [the full backgrounder is posted online at: http://static1.1.sqspcdn.com/static/f/356082/9994732/1293650246863/Davis+Besse+20+More+Years+of+Radioactive+Russian+Roulette+Nov+2010+corrected+Dec+28+2010.pdf?token=ttX228310Ed3CI9ZXWzCw%2FYRzFk%3D]

Direct hit by tornado, June 24, 1998

An F2 tornado, with wind speeds of 113 to 157 miles per hour, scored a direct hit on Davis-Besse, with the funnel cloud passing between the cooling tower and the containment building. The control room operators, running the reactor at 99% power, had little to no advance warning of the twister, until alerted by the guard shack, which had spotted it approaching the plant. Although the reactor was then immediately scrammed, a large amount of radioactive decay heat in the core would need to be actively cooled for many hours, even days. As a safety precaution, operators immediately attempted to initiate the plant’s two emergency diesel generators (EDGs). However, the first EDG initially failed to start, and was forced more than once over the course of the next day to be declared inoperable due to overheating of the room housing it. In addition, the second EDG was later declared inoperable “due to an apparent problem with the governor control.” This “uncertainty of the operability of the EDGs” was a very serious concern, as the tornado had caused extensive damage to Davis-Besse’s electrical switchyard, as well as to the region’s electrical transmission lines, leading to a complete loss of offsite power that lasted for nearly 27 hours. Thus, the EDGs were needed to cool the thermally hot core, as well as to cool the irradiated nuclear fuel storage pool, for over a day. Complete failure of both the offsite power supply, as well as the EDGs, could lead to core damage and even a meltdown in a short period of time, as well as boil off of the radioactive waste storage pool’s cooling water supply [after many days], which could cause spontaneous combustion of the irradiated nuclear fuel within [a short period of time after irradiated nuclear fuel rods were exposed to air]. Such a reactor meltdown and/or pool fire could result in catastrophic radioactivity releases.24 In addition to the dicey electricity supply to run vital safety and cooling systems, Davis-Besse’s emergency alert system and communications were largely destroyed or inoperable. For example, most of the emergency sirens across Ottawa County no longer worked after the electrical distribution system was so severely damaged. Ironically, when needed most, the emergency sirens did not work. Thus, the public would have been “in the dark” had there been radiological releases, and Davis-Besse could not even communicate with the State of Ohio or neighboring counties to coordinate emergency response.25

Footnote 24: See, for example, Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants (NRC, NUREG-1738, 2001), as well as the 1982 NRC/Sandia National Lab report, “Calculation of Reactor Accident Consequences” (CRAC-2).

Footnote 25: See: NRC news releases, both dated June 25, 1998, “NRC TEAM DISPATCHED TO DAVIS-BESSE NUCLEAR PLANT,” (http://permanent.access.gpo.gov/lps11598/www.nrc.gov/reading-rm/doc-collections/news/1998/98-40iii.html), and “NRC INSPECTION TEAM MONITORING DAVIS-BESSE PLANT  RESPONSE TO TORNADO DAMAGE AND LOSS OF OFFSITE POWER,” (http://permanent.access.gpo.gov/lps11598/www.nrc.gov/reading-rm/doc-collections/news/1998/98-40aiii.html); see also LICENSEE EVENT REPORT (LER) 1998-006-00, “Tornado Damage to Switchyard Causing Loss of Offsite Power,” EVENT DATE 6/24/98, REPORT DATE 08/21/1998.

Additional Relevant Documents

1.) License amendment request dated May 23, 2012, seeking to increase the EDG minimum voltage from 4,031 volts to 4,070 volts. This license amendment request is posted online in ADAMS under ML12144A383.

2.) NRC email dated June 21, 2012, to FENOC, indicating that the LAR could not be accepted for review until some additional information was provided. That email is in ADAMS under ML14324A823.

3.) A FENOC letter dated July 16, 2012, to NRC, withdrawing the LAR. This letter is in ADAMS under ML12199A056. The letter indicated FENOC did not want to provide the additional information requested by NRC.

4.) July 30, 2012 letter from NRC to FENOC, acknowledging that the LAR had been withdrawn. This letter is in ADAMS at ML12200A387.

In an April 10, 2015 NRC "Component Design Bases Inspection Report" at Davis-Besse, NRC listed a "finding" re: "Vulnerability of Emergency Diesel Generator Crosstie to a Non-Essential Bus" (Page 10 to 12, or 13 to 15 on PDF counter)