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