Documentation re: Entergy Palisades' request to NRC for permission to do a "Band-Aid" repair on a reactor vessel head penetration
On Monday, September 14th 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.
admin
NRC meeting announcement, dated Sept. 15th:
Meeting Location Teleconference
Contact Booma Venkataraman
301-415-2934
Scott Wall
301-415-2855
Participation Level Category 1 NRC Participants
Jay Collins , Office of Nuclear Reactor Regulation
External Participants
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).
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".
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 23rd and requests approval by Thursday, October 1st. 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 31st 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 2nd with the head set back on the flange a couple days…” (before???)… “that.”
Jay Collins: 35:50 “Understood, October 2nd was when you would start demobilization.”
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
admin
4 Palisades Weld Repair Documents, Docketed at 1 pm, Monday, September 29, 2020:
| 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 |
| Document Title: | Attachment 2 - Framatome, Inc. Affidavit Supporting Withholding of Proprietary Information. |
| Document Type: | Legal-Affidavit |
| Document Date: | 09/27/2020 |
| 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
|
admin
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