A diagram describing pressurized thermal shock in a nuclear reactor. Credit: Japan Atomic Energy Agency. Japan's worst embrittled RPV, at Genkai 1, has been permanently closed in the aftermath of Fukushima.Beyond Nuclear has submitted a dozen official public comments into the U.S. Nuclear Regulatory Commission's (NRC) proceeding regarding the development of Draft Regulatory Guide 1299 (DG-1299), and its technical background document, NUREG-2163. Both DG-1299 and NUREG-2163 are part of NRC's regulatory rollback, known as 10CFR50.61a, a weakening of (already weakened) safety standards contained in 10CFR50.61 (Title 10, Code of Federal Regulations, Parts 50.61 and 50.61a).
10CFR50.61a, or alternate fracture toughness rules for neutron radiation embrittled reactor pressure vessels (RPVs), would increase the risks of a pressurized thermal shock (PTS) through-wall breach, Loss-of-Coolant-Accident, core meltdown, containment failure, and catastrophic radioactivity release to the environment.
On Dec. 1, 2014, Beyond Nuclear and coalition partners Don't Waste MI, MI Safe Energy Future--Shoreline Chapter, and Nuclear Energy Information Service of Chicago, intervened against Entergy Nuclear's License Amendment Request for 10CFR50.61a regulatory relief at its Palisades atomic reactor in southwest MI. Terry Lodge serves as the coalition's legal counsel.
Following are links to Beyond Nuclear's dozen comments re: DG-1299 and NUREG-2163, as well as links to the documents on which they are based.
Comment 1: regarding NRC's over-reliance on PRA (probabilistic risk assessement), or risk-informed regulation, in 10CFR50.61a, and its related DG-1299 and NUREG-2163.
Comment 2: regarding the coalition's Dec. 1, 2014 intervention petition against 50.61a regulatory relief at Palisades.
Comment 3: DECLARATION OF ARNOLD GUNDERSEN, dated Dec. 1, 2014, part of the intervention petition mentioned immediately above. Gundersen serves as the expert witness for the coalition.
Comment 4: regarding DECLARATION OF PIERMAN, KAMPS AND KEEGAN CONCERNING COUPON AVAILABILITY FOR PTS TESTING, dated December 1, 2014.
Comment 5: regarding "PETITIONERS’ COMBINED REPLY IN SUPPORT OF AMENDED PETITION TO INTERVENE AND FOR A PUBLIC ADJUDICATION HEARING OF ENTERGY LICENSE AMENDMENT REQUEST FOR AUTHORIZATION TO IMPLEMENT 10 CFR§50.61a, ‘ALTERNATE FRACTURE TOUGHNESS REQUIREMENTS FOR PROTECTION AGAINST PRESSURIZED THERMAL SHOCK EVENTS’," dated Jan. 20, 2015.
Comment 6: regarding NUCLEAR REACTOR PRESSURE VESSEL CRISIS: GREENPEACE BRIEFING (dated Feb. 15, 2015; 10 pages), and Greenpeace press release, "Thousands more cracks found in Belgian nuclear reactors, Belgian regulatory head warns of global implications," dateline Brussels, Feb. 17, 2015 (2 pages).
Comment 7: regarding Official Transcript of Proceedings, NUCLEAR REGULATORY COMMISSION, Title: Entergy Nuclear Operations, Inc., Palisades Nuclear Plant, Docket Number: 50-255-LA, ASLBP Number: 15-936-03-LA-BD01, Location: Rockville, Maryland, Date: Wednesday, March 25, 2015 (135 pages).
Comment 8: regarding the June 1983 Popular Science article, "Thermal shock--new nuclear-reactor safety hazard?", by Edward Edelson; the January 27, 1970, Advisory Committee on Reactor Safeguards (ACRS), chaired by Joseph M. Hendrie, "REPORT ON PALISADES PLANT," sent to AEC Chairman Glenn T. Seaborg; and the MEMORANDUM and ORDER (Ruling on Petition to Intervene and Request for a Hearing), NRC Atomic Safety and Licensing Board Panel, In the Matter of: ENTERGY NUCLEAR OPERATIONS, INC. (Palisades Nuclear Plant), LBP-15-17, Docket No. 50-255-LA, ASLBP No. 15-936-03-LA-BD01, May 8, 2015.
Comment 9: regarding the 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 (specifically, the first contention, beginning on page 4, regarding "The license renewal application is untimely and incomplete for failure to address the continuing crisis of embrittlement"); the 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); the Petitioners' Appendix of Evidence (129 pages), which accompanied its September 16, 2005 Reply; and the 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. (See, specifically, the portions pertaining to PTS risks, including pages 34-80 (pages 17-63 of 206 on PDF counter), and following, as articulated by attorney Terry Lodge on behalf of intervening groups NIRS and Don't Waste MI.)
Comment 10: regarding the 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, specifically pages 3 to 9, as well as portions of the conclusion relevant to PTS risks/RPV embrittlement).
Comment 11: regarding Spring 2006: Consumers Energy power point presentation to the Michigan Public Service Commission, highlighting "Reactor vessel embrittlement concerns" at Palisades.
Comment 12: Beyond Nuclear submitted for the record a June 2011 AP article, by investigative reporter Jeff Donn, entitled "US nuke regulators weaken safety rules." It was the first installment in a four-part series entitled "Aging Nukes." Beyond Nuclear pointed out that the weakening of RPV embrittlement/PTS safety standards was cited by Donn as a top national example of NRC's collusion with industry to keep age-degraded reactors operating, despite the risks.