ML14122A029
| ML14122A029 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/21/2014 |
| From: | Kamps K Beyond Nuclear |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 79FR13079 00021, NRC-2010-0298 | |
| Download: ML14122A029 (15) | |
Text
Page I of 1= // As of: April 24, 2014 Received:
April 21, 2014 Status: Pending_Post Tracking No. ljy-8bo3-71d2 Comments Due: April 21, 2014 Submission Type: Web Docket: NRC-2010-0298 Receipt and Availability of Application for License Renewal Comment On: NRC-2010-0298-0033 License Renewal Application for Davis-Besse Nuclear Power Station, Unit 1; Draft Supplemental Generic Environmental Impact Statement Document:
NRC-2010-0298-DRAFT-0044 Comment on FR Doc # 2014-05021 Submitter Information Name: Kevin Kamps T] .7 Address: Cl)Beyond Nuclear 71]6930 Carroll Avenue, Suite 400 .../ :w.: Takoma Park, 20912 ---Email: kevin@beyondnuclear.org 5 General Comment See attached file(s)Attachments 4 21 14 DEIS comment vis a vis 5th Cracking Contention Supplement dated 8 16 12 SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add= ,~ittps://www.fdms gov/fdms-web-agency/compoinentlcontentstreamer?objectld=0916cO64816c0359&for...
04/24/2014 Comments re: Davis-Besse 20 year license extension vis a vis our environmental coalition's 5 th Cracking Contention Supplement dated 8 16 12[posted online at: www.beyondnuclear.org/storage/FOIA Appendix B contention supplement 8 16 2012.pdfl Document B/i [undated; Davis-Besse Nuclear Power Plant, Unit Licensing Basis Seismic Ground Motion Concern. (3 pages)], pages 7-10/101 in the supplement:
The ACRS and NRC Staff expressed concerns about D-B's seismic qualifications.
Where ACRS called for a factor of 0.20g ground acceleration as a conservative Safe Shutdown Earthquake, a mere 0.15g acceleration factor was called for in D-B's Updated Safety Analysis Report (USAR).Given the Aug./Sept.
2013 revelations of worsening cracking, and the Feb. 2014 revelations of SB wall gaps and rebar damage from hydro-demolition activities to open the access opening, our concluding paragraph re: Document B/I is more relevant than ever: "NRC FOIA Response Number I 's inclusion of Document B/I shows that 36 years [now 38] after ACRS and NRC Staff first expressed seismic risk concerns at Davis-Besse, these concerns still haunt the facility -now, frighteningly, in the context of a severely cracked shield building." Of course, the 2011 Fukushima nuclear catastrophe should compel FENOC, NRC and ACRS to take seismic risks at D-B all the more seriously.
Document B/2 [10/14/11; Email from P. Hernandez, NRR to J. Zimmerman, NRR RE: 2011-10-13, POP -Davis-Besse Containment Shield Building.
(1 page)], p.10/101: Despite NRC's early hopes and optimistic assumptions that the SB cracking would prove to be a "non-issue," it actually rendered the Outer Face Rebar Mat structurally dysfunctional.
Combined with 2013's worsening cracking and 2014's wall gap and rebar damage, this is now all the more significant.
Document B/4 [10/18/1I; Email from S. CuardadoDeJesus (sic), NRR to R. Auluck, NRR et al. on Davis-Besse Shield Building Issue Summary. (2 pages)], p. 11-12/101:
Based on Bechtel and Sargent and Lundy's "expert opinion the indications found in the concrete were a product of the hydro-blasting operations and not a pre-existing condition...The NRC inspectors concur with the actions taken to date by the licensee and continue to evaluate the licensee's preliminary conclusions that the indications are related 1 to the hydro-demolition and do not appear to be preexisting flaws in the concrete shield building." Although FENOC et al. backed away from this root cause theory, once cracking was discovered across the SB, far from the hydro-blasted access opening, Intervenors nonetheless asserted that hydro-demolition can inflict damage to the SB. In fact, FENOC et al. concurred that it was the first, most likely explanation for the cracking.
Therefore it must be possible that hydro-demolition can, in fact, damage the SB.Intervenors' warning, that the second access opening in three years (2011 and 2014)made necessary by D-B's unexpected early failure of the replacement reactor lid after just 7 years of service life, proved prescient, given not only the 2011-2014 SB wall gap, but also the rebar damage inflicted by hydro-blasting open the access opening.for the steam generator replacements: "This added breach by hydro-blasting in 2014 risks inflicting yet more damage on the shield building.
This is an aging-related safety issue that could very well increase the safety and environmental risks of the proposed license extension operations from 2017 to 2037." Intervenors again assert that early failure resulting from a botched steam generator replacement project (challenged by Intervenors in a separate ASLB proceeding), or yet another early failure of a replacement lid, could well necessitate yet another access opening the SB before 2037, risking yet more hydro-blasting damage.Document B/9 [11/04/11, Email from P. Hernandez, NRR to E. Sanchez Santiago, RIII on Questions about Davis Besse Shield Building Report from DORL. (2 pages)], p. 12-14/101:
NRC Staffer Hernandez wrote "1 think the greater concern is will the SB 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 11/I condition?" He wrote this about the sub-surface laminar cracking at the SB Outer Face. rebar mat. The worsening of the cracking would not be revealed until Aug./Sept.
2013, and the added risks of SB wall gaps and rebar damage would not be revealed until Feb. 2014. These recent revelations only make his question, "will the SB stay standing," all the more relevant now.Till now, the SB Inner Face rebar mat has not been checked for cracking impacting its structural integrity, even though Intervenors have documented that the Inner Face was open to exposure to the elements (including moisture saturation and penetration, as well as freezing conditions, just as was the exterior of the SB from the early 1970s till August 2012) for several long years, before the SB dome was added, and before the Initial 2 Construction Opening was closed. This vulnerability of SB Inner Face rebar and concrete to degradation was especially true at the very top of the SB wall before the dome's installation, as previous Intervenor cracking contention/supplement filings' have noted, based on NRC questioning and FENOC/PII responses.
Document B/10 [11/07/11; Davis Besse Shield Building Issue NRC Technical Reviewer Focus Questions.
(1 page)], p. 14-15/10 1: Re: NRC's question and Intervenors' response ("Is extent of condition adequately understood, given limited data points?" echoes Intervenors' questions along t he same lines), we still feel the same way. The sites on the SB where cores bores are required should be increased significantly, as should the frequency of such testing.Re: [Does the licensee's analysis provide reasonable assurance that the shield building will perform its design function?
Why or why not?a. If yes, does the shield building remain in conformance with all licensing and design basis requirements including required Codes and required safety margins?.Note that if the shield building is functional but nonconforming, then the licensee would be able to restart the plant, but would be expected to have a plan in place to restore conformance (additional analysis, repairs, or license amendment) at the next reasonable opportunity. (emphasis added)], I'm not at all clear where this stands. Did FENOC provide that "restoration of licensing and design basis" by Dec. 1, 2012, as they were committed to do at the Oak Harbor High School show down in August 2012?Re: NRC's question [3. Has the licensee provided reasonable assurance that the shield building will remain capable of performing its design function in the near and distant future (i.e. the condition will not worsen)? Why or why not? If not, are we comfortable until the next refuel outage (May 2012) and why, and what additional actions from the licensee, if any, do we think are necessary going forward? (emphasis added)], what's remarkable is that these questions have not been answered in the past two years, and are as relevant now as they were in 2012, if not more so.Document B/13 [11/09/11; Email from P. Hernandez, NRR to R. Auluck, NRR et a].Re: Davis Besse Shield Building teleconference.
(1 page)], Document B/15 [11/11/1l; Email from J. Zimmerman, NRR to M. Evans, NRR re: DB shield building.
(1 page)], and Document B/16 [11/12/11; Discussion points relayed to the licensee after our internal technical discussion (I page)], p. 15-19/101:
The tail-wagging-the-dog, where NRC aided and abetted FENOC's rush to restart the reactor despite unanswered questions and unanalyzed risks re: SB cracking, may also very well account for the SB wall gap discovered in Feb. 2014. It appears likely that, as the repair on the access opening was rushed, the gap resulted from carelessness in the 3 rush job. Intervenors' protested this rush job in their original cracking contention filed on Jan. 10, 2012, as well.At page 18/101, we documented the NRC "Concern that sampling did not eliminate I.F.[Inner Face] cracking at top of SB (different undefined failure mechanism Then [sic]in the shoulder).
Thus, core bore, chemical analysis, etc. testing, and on a frequent basis, of the Inner Face rebar and concrete should be part and parcel of the AMP going forward.Also, the current re-do of the root cause report further bolsters challenges Intervenors' have been raising for over two years, but have yet to receive any relief for from NRC or ASLB, such as in the form of a hearing on the merits of our cracking contention and its supplements.
Also, on p. 18/101, we documented NRC's concern that the extensive cracking 20 feet down from the top of the SB in an area of dense rebar "Challenges Prof. Darwin [a FENOC expert witness] concern that rebar splices be outside cracked region," and "Any splice in cracked regions require further evaluation
-Prof. Darwin.. .Design calc -fully effective rebar, unverified assumption (ACI 349.3R not applicable to laminar cracking)".
lemphasis added]The damage to the rebar at the edges of the access opening in Feb. 2014 due to hydro-demolition raises the specter that Professor Darwin's caveats are being violated.
The damaged rebar also raises questions about mistakes made during the access opening repair work in late 2011. Recurring mistakes (SB wall gaps, rebar damage) during SB access opening repairs (2002, 2011) raise the specter that such mistakes will again be made in 2014, which will decrease radiological containment safety margins during the 2017-2037 license extension.
Document B/18 [11/15/11; Email from P. Hernandez, NRR to J. Zimmerman, NRR on Draft email. (I page)], p.19/101: "This document states "The licensee requested a delay of the public meeting to give them more time to finish the splice evaluation.
The NRC accepted so that we would have time to review the documents before the meeting," (emphasis added). Again, as at p. 18/101, FENOC's struggle to account for structural integrity and design function of rebar splice areas is still a concern now, given indications of worsening cracking in Aug./Sept.
2013, as well as rebar damage from hydro-demolition revealed in Feb. 2014.Document B/19 [11/15/11; Email from P. Hernandez, NRR to M. Evans, NRR et al. RE: Updated Davis-Besse Containment Shield Building POP. (I page)], p.20/101: The safety significance of rebar splice regions in the context of cracking, ,s shown in preceding entries, is further reflected by NRC and FENOC's efforts to hastily postpone a public meeting "so that the licensee has more time to finish their calculations of the rebar splices and so that [NRC] can review them beforehand.
It was at the licensee's request that it was changed." FENOC's struggle to account for structural integrity and design function of rebar splice areas is still a concern now, given indications of worsening 4 cracking in Aug./Sept.
2013, as well as rebar damage from hydro-demolition revealed in Feb. 2014.Document B/22 [11/17/i1; Email from P. Hernandez, NRR to E. Sanchez Santiago, RIII on Davis Besse Operability question. (I page)] and Document B/24 [11/17/11; Email from P. Hernandez, NRR to M. Evans, NRR et al., on Davis Besse Operability question.(2 pages)], p.24/101: Given that FENOC is currently re-doing its RCR, yet again, and the fact that restoration of licensing and design bases at D-B are still dubious, Intervenors made this prescient observation nearly two years ago: "...NRC's Hernandez said, "The basis for continued operation should be frequently and regularly reviewed until corrective actions are successfully completed." Of course, few if any corrective actions were "successfully completed" between this November 17, 2011 email, and Davis-Besse's restart. But the corrective action schedule leading up to, and during, the proposed 2017-2037 license extension period also leaves a lot to be desired. FENOC's Aging Management Plan for shield building cracking includes only infrequent and irregular reviews of the basis for continued operation.
In fact, apart from than applying weather sealant 40 years late, there are no corrective actions planned by FENOC. Impulse Response monitoring tests and bore hole sampling are very few and far between under the proposed FENOC AMP." Intervenors' concerns have yet to be rectified, despite FENOC's admission to worsening cracking (Aug./Sept.
2013), as well as SB wall gaps and rebar damage (Feb. 2014).Document B/23 [11/17/11; Davis-Besse Containment System Primary Steel Containment and Shield Building. (I page)], p.27-28/101:
We asserted: "This document also claims "The shield building was designed to withstand forces generated by design bases seismic events," but this assertion is challenged, if not outright undermined, by Document B/1 's revelations.
Intervenors cite NRC's admission, "The existing as-found condition of cracking in the concrete of the shield building has raised questions on the ability of the structure to maintain its ability to perform its design functions under conditions that would introduce active forces (such as a seismic event or potentially rapid changes in the environmental conditiohis)," as supportive of its call for a hearing on the merits of these issues." Abdul Sheikh warned in Document B/26 (see below) that "I am concerned that the concrete will fail in this region due to bending in this region even under small loads." (emphasis added). That added "small load" could be a seismic one, especially in an era of artificial earthquakes spawned by natural gas fracking, an activity that takes 5 place in the region surrounding Davis-Besse.
After Fukushima, such risks are inexcusable.
Document B/25 [11/21/ Il (date barely visible on actual document, due to it being printed on top of NRC's letterhead);
Davis-Besse Nuclear Power Station Containment Shield Building Issue. (8 pages)], p.28-39/101:
p.3 2/1 0 1" ... [T]he shield building cracking is also SAMA-related, for FENOC's Severe Accident Mitigation Alternatives analyses undoubtedly assumed an intact and functional shield building, not the severely cracked one of doubtful functionality that exists in reality. In fact, NRC concludes page 2 by acknowledging this: The existing as-found condition of cracking in the concrete of the shield building has raised questions on the ability of the structure to maintain its ability to perform its design functions under conditions that would introduce active forces in the structure (such as a seismic event or potentially rapid changes in environmental conditions).
... Dr. Darwin is quoted: "Thus, if the splices in the circumferential steel are located outside of the crack region, I agree with and support the conclusion..." But NRC itself (as in Document B/1 6, above) confirmed rebar splices are located inside the crack region: cracking at the "Top of shield building -360' around 20' down from the top...Challenges Prof. Darwin concern that rebar splices be outside cracked region." p.33/101...Dr. Darwin is also quoted: "they [the lap splices in the laminar crack region] are currently carrying the normal environmental loading (such as seasonal thermal gradient)and have since the structure was constructed." In other words, since the building is still standing, it must be strong enough to handle relatively normal circumstances.
But given the severe cracking, can the shield building withstand added stresses, such as due to natural disasters (earthquakes, tornadoes, tornado missiles, etc.) or a reactor accident?...In Paragraph 2 on page 5, FENOC responds to NRC questioning:
Lap splices entirely within the crack zone are conservatively assumed to give way and fail to transfer load. In a large concrete structure the reinforcement steel and concrete act in a memibrane fashion.If a local lap splice is ineffective the load will transfer to the adjacent load carrying members. Local structural failures would only exist if a large number of lap splices were to line up in the same crack area. The horizontal reinforcement bars in the shield building were well staggered to preclude this very issue.p.34/101 This is an entirely qualitative argument -and a very optimistic one at that-- not backed up by empirical data. Intervenors seek a more rigorous, conservative analysis, such as might occur via a hearing on the merits.6 Page 5, paragraph 3 carries forth in the same qualitative manner. No empirical data is provided to ensure that cracks will not line up in a catastrophic way. Although FENOC and its experts assure us that the risk is low, no probability figure is actually given for the risk of a shield building failure with potentially catastrophic consequences.
Page 5, paragraph 4 of FENOC's response states: Since the reinforcement steel development specified staggered bar splices and the reinforcement steel is lightly loaded, Dr. Darwin suggested that the develdpment could be evaluated on a percentage basis. That is, if the loading in the section is one third of the allowable, then at least one third of the section must contain solid (uncracked) regions to fully utilize the reinforcement steel.To Intervenors, such an overly simplistic analysis, based on unsupported assumptions, is a very risky basis for reasonable assurance of shield building function for the next quarter century (2012 to 2037)." Also on p.34/101"FENOC goes on to state in the fifth paragraph on page 5, "Conservative assumptions have been made to limit the extremely difficult data collection efforts." Intervenors are concerned that, due to the expense and time required to undertake such "extremely difficult data collection efforts," FENOC's assumptions are not conservative, and its data collection efforts (IR testing, core bore sampling) are too few and far between, both spatially across the shield building structure, but also temporally (testing is much too infrequent under FENOC's AMP) over months, years, and even decades." Given the added risks of worsening cracking, SB wall gaps, and rebar damage, Intervenors re-assert no effort should be spared under the SB cracking AMP. Neither difficulty nor expense of testing methods or frequency is an excuse.On p.35/101"It is curious that the NRC did not require investigation of less-accessible areas, as well as whole sections of the shield building that FENOC simply assumes are not cracked, given the safety and environmental risks." If a simple, basic acoustic test had been done on the access opening repair of 2011, it would have instantly revealed the gap.On p.36/101"On page 6 at "4)", even though NRC requests that FENOC "Confirm that both vertical and horizontal rebar if located in a crack region are not considered in the strength 7 evaluation," FENOC nonetheless responds by assuming that half of the outside hoop reinforcement is effective, even though it has not investigated to make sure that cracking in those areas has not rendered outside hoop reinforcement completely ineffective." Given the worsening cracking revealed in Aug./Sept.
2013, as well as the SB wall gap and rebar damage revealed in Feb. 2014, NRC must require FENOC be more conservative in its assumptions about rebar structural integrity.
These assumptions must be tested to confirm their accuracy.p.36/101"In the second paragraph under "4)", FENOC explicitly states that the only places on the shield building where zero credit is taken for vertical reinforcement credit is at the flute shoulders and main steam penetrations.
But this does not account for the cracked upper 20 feet of the shield building and the large uninvestigated portions of the remainder of it.Under the circumstances, FENOC should be made to empirically verify that the portions of the shield building being counted on to maintain safety margins are, in reality, still solid." The 20 11-2014 damaged rebar at the SB access opening repair location shows that FENOC's simple assumptions of rebar structural integrity across vast stretches of the SB are inaccurate and undermine "adequate protection" of public health, safety, and the environment.
p.36-37/1 01"FENOC's statement, "Note that the vertical and hoop reinforcement is actually present and sufficiently bonded and will provide the necessary serviceability requirements such as crack control as it has under normal operating conditions since the structure was built," appears to assume, inappropriately, that the cracks will not grow worse over time. That question and concern, and the risks it raises, are at the very heart of Intervenors' contention, as supplemented.
Not only does the "It-Must-Still-Be-Functional-Because-It-Hasn't-Failed-Yet" approach fail to account for worsening cracking over time from 2012 to 2037, but it also fails to address the impact of added stresses on the severely cracked shield building, such as natural disasters, reactor accident conditions, daily/seasonal/annual thermal cycles, and freeze/thaw cycles. These are aging-related concerns and disputes with the application." The cracking was shown to be growing worse with age, in Aug./Sept.
2013. Simply assuming rebar, as well as concrete, functionality, with AMP monitoring and testing, is indefensible.
p.37/101[On page 7, under "5)", NRC requests that FENOC "Ensure that the required rebar bond strength will carry the entire design load (18.5 ksi) plus adjacent load from adjacent rebar 8 in cracked area. FENOC responds that 12.4 ksi loads due to normal circumstances have been supported since the shield building was constructed, so the shield building is proven capable of withstanding at least that much stress. But: ...The Table also shows that a maximum stress of 21.7 ksi is expected in this reinforcement under combined dead, seismic and thermal load and 13.7 ksi for dead, wind and normal thermal load. Since we assume that outside reinforcement is to be treated ineffective in carrying any additional stress beyond 12.4 ksi, under accident thermal loads that may cause stresses in excess of what the rebar can carry (assumed to be 12.4 ksi), the reinforcement is assumed to detach itself from the outer section of the shell. Because there is no restraint provided by the reinforcement, the accident thermal gradient will tend to self relieve, albeit trying to cause an increase in the crack width until the section finds a new balance. (emphasis added)Such an admission, that additional stress could "increase
... the crack widthl," is an admission of age-related degradation potential.
It is also evidence that a strong enough stress could even "fail" the shield building, at least to the extent that the rebar will detach from the outer section of the concrete shell. The risk of such a failure would grow more likely, even under small additional stresses, if cracking worsens over time, such as during the license extension.]
The worsening cracking revealed in Aug./Sept.
2013 shows that additional stresses, other than time, may not even be required to further damage the SB. Certainly, 6dditional stresses would simply hasten the damage.Document B/26 [I 1/22/11; Email from A. Sheikh, NRR to E. Sanchez Santiago, Rill on Questions for the Conference Call. (I page)], p.39-42/101:
Given the significance of rebar lap splice located in cracking zones, as affirmed by none other than FENOC's expert witness, Dr. Darwin, himself, the following statements by NRC Staffer Abdul Sheikh are very significant:
p.40/101"At "3.", Sheikh seems to identify problems with FENOC's work regarding the "lap splice issue." This is most significant, for FENOC's own expert, Dr. Darwin, emphasized the importance of lap splice regions, pointing out that his endorsement of FENOC's hypotheses only holds so long as the cracking does not exist in lap splice regions. At "4.", Sheikh identifies a related disconnect, stating: "If this is the assumption, stress used for lap splice calculation should account for 100% increase in the stress." p.41/101 At "5.", Sheikh wrote: "The licensee justification for ignoring the dead (DL) and normal (To) in calculation of rebars splice does not appear to be justified.
The stresses due to dead load and thermal loads will be locked in the rebars and cannot 9 be ignored." Given that Sheikh had already warned of his concern that even "small loads" could cause concrete failure "due to bending," and Dr. Darwin's warning on the significance of lap splice regions, Intervenors are most concerned about FENOC unjustifiably ignoring any stresses on the shield building in its analyses and calculations.
Similar concerns are elaborated in Sheikh's point "6.": "The licensee considers the allowable stress in the rebar to be 60 ksi and ignores a phi factor (0.9) in his evaluation for lap splice. In addition, the licensee has not accounted for any additional uncertainty due the field conditions." Per Sheikh's concerns, it is imperative that there be a full account of all such phi factors and uncertainties due to the field conditions." Given worsening cracking, SB wall gaps, and rebar damage, this rebar lap splice/cracking risk deserves focused attention in a hearing.Documents B/27 [11/23/11; Email from A. Howe, NRR to S. West, Rill et al. on Where do we stand on Davis Besse? (1 page)] and B/28 [11/23/Il; Email from A. Howe, NRR to M. Evans, NRR et al., on Call with Steve West on Davis Besse. (1 page)], p.42-44/101: This document clearly lays out NRC's rush, under pressure from FENOC, to approve reactor restart, despite deepening complexities and unanswered questions about the safety-significant SB cracking.
NRC Staffers worked over time, including on weekends, evenings, and even over holidays, to provide FENOC the green light it was pressuring for. This rush now appears to have included a poor job repairing the SB access opening of late 2011, introducing a SB wall gap, as well as damaging rebar. This was followed by over two years (Dec. 2011 to Feb. 2014) of full power operations with a severely compromised SB.Document B/30 [11/27/I ; Email from J. Zimmerman, NRR to M. Evans, NRR Re: Dav is-Besse Draft CAL. (2 pages)], p.46-47/101
- Further documents NRC's rush -over a holiday weekend -- to approve D-B reactor restart, despite unfinished safety-significant calculations, etc.Document B/31 [11/28/1I; Email from B. Lehman, NRR to S. CuadradoDeJesus, NRR RE: Shield building discussion with Melanie next week. (I page)], p.47/101: NRC OGC attorney Brian Harris's assertive insistence to attend NRR Staff meetings re: the cracking in D-B's SB shows the license extension significance and relevance of the issue -he is the lead NRC attorney opposing our intervention.
10 Document B/32 [12/01/1 1; Email from R. Haskell, NRR on New OpE Forium Possting (sic): Davis Besse -Cracks Discovered in Shield Building During Reactor Vessel Head Replacement. (I page)], p.48-49/101
- p.48/1 0 1"No explanation is given by this NRC FOIA response as to how the deepening complexity of questions and concerns about Davis-Besse's shield building cracking could be resolved so quickly, in mere days or even hours, allowing NRC to confi-dently assure safety and authorize restart so quickly. As shown by NRC's allowing FENOC until February 28, 2012 to submit its root cause report, only to allow it to amend the root cause report in mid-May because the original was so badly flawed and incomplete, it is now retrospectively clear that NRC's questions and concerns were not resolved by the time the CAL was issued on December 2, 2011. Not just FENOC's, but even NRC's behavior, harkens back to the 2002 Hole-in-the-Head Fiasco, about which the NRC Office of Inspector General concluded that not only FENOC, but also NRC itself, was guilty of prioritizing FENOC profits over public safety (NRC OIG, "Event Inquiry Regarding NRC's Regulation of Davis-Besse p.49/101 Regarding Damage to the Reactor Vessel Head," OIG-02-03S, 12/30/2002, http://www~nrc.gov/readiing-rm/doc-collections/insp-gen/2003/02-03s.pdf).
Intervenors fear this NRC attitude of "reactor operations approval at any cbst," so clearly exemplified by the rushed December 2, 2011 CAL authorizing rushed restart, will affirm the supposed legitimacy of the politicized decision-making culture during the proposed 2017-2037 period, as well. That decision-making culture will be fleshing out the Davis-Besse AMP for cracking.
A hearing is warranted to assure that politicization of aging management is as unlikely as possible." The NRC has now saw fit to require of FENOC yet another revision to the root cause report, due to the worsening cracking discovered in Aug./Sept.
2013. NRC has given FENOC till mid-2014 to complete it.Document B/34 [12/01/11; Email D. Morey, NRR to S. CuadradoDeJesus, NRR Re: Davis-Besse Shield Building. (I page)], p.50/101, and Document B/35 [12/02/Il; Email from D. Morey, NRR to B. Lehman, NRR et al RE: Davis-Besse Shield Building. (I page)], p.51/101: Further documentation of NRC's mad dash to approve rushed restart of D-B despite the SB cracking, despite a lack of even basic information about the cracking, and despite significant incomplete analyses and unanswered questions, perhaps in an effort to approve the restart before FENOC, tail wagging the dog fashion, simply did it anyway.11 Such a rush job, it now appears, included a hasty repair of the access opening, which left a large gap in the wall, as well as damaged rebar.Document B/36 [12/02/11; Email from B. Lehman, NRR to S. Sakai, NRR et al. FW: Davis Besse POP. (2 pages)], p.52/101: Any remaining questions within NRC's ranks were silenced by the decision to issue the CAL, slamming the door shut. NRC's internal contradictions are on full display, when you compare this email of finality, to ones sent just hours earlier, laying out significant areas of questioning, concern, and uncertainty not yet resolved.Document B/40 [12/06/11; Email from B. Lehman, NRR to S. CuadradoDeJesus, NRR on Shield Building RAI. (1 page)]: p.60/101 : "...So many different forms of cracking, in widely different areas of the shield p.61/101: building, likely involve multiple root causes, which FENOC has not identified nor accounted for. Nor has NRC required FENOC to do so. Intervenors fear that such unaccounted-for root causes, as well as incomplete accounting of the extent of the cracking and safety/environmental risk significance, and consequently inadequate corrective actions, will lead to worsening of known cracks, not to mention initiation and worsening of unknown cracks. This, of course, would increase the risks." The worsening cracking admitted to in Aug./Sept.
2013, as well as FENOC's need to re-do its RCR yet again by mid-2014, seem to confirm Intervenors' August 2012 warnings and concerns as accurate and well founded.Document B/41 [12/06/11; Presentation Slides on Dav is-Besse Shield Building Crack. (6 pages)]: p.62/101..."Intervenors are concerned that FENOC's response, based on Dr. Darwin's advice, is inadequate
-that merely broad strokes of understanding are good enough, that not "every square inch" of the building need be checked. Intervenors assert that neglecting to perform confirmatory tests on vast areas of the shield building could miss large areas of severe cracking, which have rendered the shield building unfit for safety or 12 environmental duty, and will cause this to only worsen over time, due to age-related degradation worsening both known, and currently unknown, cracking." Compare this to the access opening repair put in place in late 2011. A signrificant gap in the SB wall, combined with damaged rebar, made this area of the containment prone to failure, if it had been tested by additional stresses.
Luckily, it was not. Are there other areas of gaps or damaged rebar across the SB wall of which FENOC, and NRC, are currently unaware? Why is testing to confirm structural integrity across the SB not being required?p.62/ 101: "...NRC also states that the "Licensee's Position" is that "Primary concern is ability of outside rebar to perform its intended function.
Observations of construc-tion opening and testing indicate concrete is firmly attached to rebar mat". But this flies in the face of the admission, by both NRC and FENOC, that the outer rebar layer is dysfunctional." (emphasis added)Ironically, it was FENOC's -and NRC's -lack of observation that led to the SB wall gap and rebar damage, revealed in Feb. 2014. That lack of observation allowed for more than two years of full power operations (Dec. 2011 to Feb. 2014), with a severely compromised SB.Re: p.63/101["...NRC mentions the need for FENOC to "Determine root cause and develop a long-term monitoring program (due 2/28/12)".
FENOC failed on both scores. Although FENOC did submit a root cause report by 2/28/12, NRC identified so many p.64/101 holes in it that FENOC was forced to submit a revised root cause analysis report in mid-May. David Lochbaum, Director of the Nuclear Safety Project at the Union of Concerned Scientists, pointed out to NRC Region 3 Administratrator, Chuck Casto, in late May that this was a prima facie violation of IOCFR50.9 requirements that FENOC submit complete and accurate information by the February 28, 2012 deadline.
But NRC has done nothing to enforce this regulation, nor hold FENOC accountable for its violation.
In addition, FENOC did not publish its "long-term monitoring program" (its AMP) till April 4, 2012 -- over a month late. Even then, FENOC's AMP was woefully inadequate, and remains so to this day."]That was nothing. Now, in the aftermath of the Aug./Sept.
2013 worsening cracking, FENOC is again re-doing its RCR. The latest version is not due till mid-2014-well over two years later than the original deadline for the RCR.13 Re: p.64/101["...NRC also mentions requiring FENOC to "Select multiple un-cracked areas to investigate to verify the cracking is not spreading (due 90 days)". But the only un-cracked areas to be examined are located right next to already known cracks. A shield building-wide look is not being required, so severe cracking in large areas of the shield building could be occurring, that FENOC has simply assumed is not there."]This is all the more ironic in light of the fact that a single, basic acoustic test would have revealed the SB wall gap of 201 1-2014. Simply assuming structural integrity is not adequate to protect public health, safety, and the environment.
Document B/44 [12/13/l1; Email from M. Galloway, NRR to A. Sheikh, NRR et al., RE: Davis-Besse Shield Building. (I page)], p.66/1 01: NRC Staffer Abdul Sheikh admits "Davis Bessee [sic] shield building has'not been designed for containment accident pressure and temperature." If the Davis-Besse concrete, steel reinforced shield building was not even designed for the levels of pressure and temperature that would result from a steel containment accidental breach, then it stands to reason that a severely cracked shield building would be even more vulnerable to catastrophic failure than an un-cracked shield building.
In fact, Abdul Sheikh himself, in Document B/26, stated "I am concerned that the concrete will fail in this region due to bending in this region even under small loads." As Sheikh indicates above, a breach of the steel containment vessel at Davis-Besse would subject the severely cracked shield building not to "small loads," but to accident pressures and temperatures that it was never designed to withstand, even when brand new and un-cracked!14