ML21116A577
| ML21116A577 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 04/26/2021 |
| From: | Alan Anderson Physicians for Social Responsibility, Wisconsin |
| To: | NRC/OCM |
| SECY RAS | |
| References | |
| 50-266-SLR, 50-301-SLR, RAS 56073, Subsequent License Renewal | |
| Download: ML21116A577 (20) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of ) Docket Nos. 50-266 & 50-301-SLR NextEra Energy Point Beach, LLC )
April 26, 2021 (Point Beach Nuclear Plant, Units 1 and 2, )
Subsequent License Renewal Application)
)
PHYSICIANS FOR SOCIAL RESPONSIBILITY WISCONSINS MOTION TO AMEND CONTENTION 2 (INADEQUATELY TESTED REACTOR COOLANT PRESSURE BOUNDARY)
Now comes the Petitioner, Physicians for Social Responsibility Wisconsin (PSR WI),
on its behalf and also on behalf of its members, by and through counsel, and pursuant to 10 C.F.R. § 2.309(c)(1), moves to amend Contention 2 in the particulars set forth below.
INTRODUCTION On March 23, 2021, PSR WI filed a Petition to Intervene in this proceeding in which it propounded Contention 2, which states:
Point Beachs continued operation violates 10 CFR Part 50, Appendix A, Criterion 14 because the reactor coolant pressure boundary has not been tested so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture, and the aging management plan does not provide the requisite reasonable assurance.
PSR WI now seeks to amend Contention 2 to incorporate newly-discovered information, to-wit, a letter dated March 22, 2021 from the Electric Power Research Institute to the Document Control Desk of the U. S. Nuclear Regulatory Commission, the subject of which is Potential Non-Conservatism in EPRI Report, BWRVIP-100, Rev. 1-A, 3002008388 and Impacted BWRVIP Reports. The letter was docketed in ADAMS as ML21084A164 on April 2, 2021 and presented new information that was not available prior to April 2, 2021. A complete copy of the letter is annexed hereto and incorporated herein by reference. The new information in the EPRI letter provides a new and additional basis for Contention 2.
BACKGROUND Petitioner PSR WIs expert witness for Contention 2 is Arnold Gundersen, who has more than 50 years of experience in Nuclear Engineering.1 Contention 2 addresses the phenomenon of neutron embrittlement, whereby neutron radiation from inside a nuclear power plants core gradually weakens the the structural integrity of the metallurgy, making it so brittle that it is catastrophically vulnerable to Pressurized Thermal Shock (PTS). Neutron embrittlement can be problematic because if embrittlement becomes extensive, the dense metallic nuclear reactor can shatter like glass and cause a Class 9 radiological accident, the worst nuclear catastrophe category.2 Mr. Gundersen stated in his original, March 23, 2021, Declaration, and PSR WI correspondingly has pleaded in its Petition, that in recent years, the NRC has systematically removed conservative calculational aspects of the embrittlement process to allow continued operation by not removing coupons/capsules from reactor pressure vessels in order to metallurgically analyze and develop actual data on the true state of embrittlement. One of the most-embrittled reactor vessels in the country is Point Beach Unit 2. Analysis of capsules/
coupons from that reactor, as well as other embrittled reactors should be conducted in order to 1
Mr. Gundersens curriculum vitae is attached to the Declaration of Arnold Gundersen (Gundersen Declaration) previously filed in this proceeding.
2 Declaration of Arnold Gundersen, Nuclear Engineer (Gundersen Declaration) at ¶¶ 7.4.1, 7.4.4.
assess whether to allow the Point Beach reactors to continue operations. For decades, the NRC has not required Point Beach and its cohorts to examine available coupons/capsules, which has deprived the NRC and the public of significant scientific data on which to justify continued reactor operations - or their termination.
Mr. Gundersens opinion expressed in March was as follows:
As the US nuclear fleet ages, the NRC has systematically removed conservative calculational aspects of the embrittlement process to allow continued operation. The NRC has not incorporated the actual data from coupons in the remaining five worst atomic power reactors in the U.S. to be used for the embrittlement analysis applied to NextEras Point Beach reactors to allow their continued operation. Instead of evaluating Point Beachs specific metallurgy, the NRC has allowed Point Beach and its cohorts to use analytical techniques that ignore the data from sample coupons it could readily test.
Additionally, there is no scientific basis by which the Point Beach reactors should continue operating unless there is a complete physical analysis of the coupons from its reactors and the five other reactors that are its embrittled cohorts.3 Therefore, I conclude that Point Beachs continued operation violates 10 CFR Part 50 Appendix A, Criterion 14.4 Criterion 14 requires that [t]he reactor coolant pressure boundary shall be designed, fabricated, erected, and tested so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture.
The EPRI letter has prompted Mr. Gundersen to provide a Supplemental Declaration (attached). In it, he states:
At some point during 2020, the Electric Power Research Institute (EPRI) became aware of errors in the computer codes its members use to predict the neutron embrittlement of components inside US nuclear reactors. EPRI determined that these embrittlement codes are not accurate and are under-predicting the extent of embrittlement damage to reactor components within the atomic reactor cores.
Underpredicting the damage from neutron embrittlement is definitely non-3 Id. at ¶ 7.8.2.
4 Id. at ¶ 7.8.3.
conservative and may create serious safety flaws if left unchecked.
EPRI and the NRC met in private for a confidential meeting held on February 17, 2021. At that meeting, EPRI informed the NRC of its concerns about the newfound embrittlement errors in the EPRI computer code.
EPRI mailed a formal letter to the NRC on March 22, 2021, informing the NRC that it had found severe errors in one or more of its computer codes used to calculate neutron embrittlement to core internal structures.5 The EPRI letter was filed in the NRC Public Document Room (PDR) on April 2, 2021. I became aware of EPRIs letter several days later.
The EPRI letter is terse at only two pages plus five pages of attachments.
Moreover, EPRIs brevity hides most of the problems it discovered under the secrecy cloak of proprietary material. Even with its secrecy cloak, the letter clarifies that numerous embrittlement documents are hidden from public scrutiny. While hiding most of the embrittlement problems as proprietary, the EPRI letter also hints at significant flaws identified in analytical computer codes in use since 2016.
According to the EPRI letter:
BWRVIP-100, Rev. 1-A, published in 2016, was developed to support the evaluation of in-service flaws in BWR core shrouds. It provides fracture toughness relationships as a function of neutron fluence for BWR core shrouds. Research was carried out from 2016 to 2020 to obtain additional fracture toughness data on irradiated stainless steels with an emphasis on weld metal. A preliminary evaluation of results from this testing program, as well as the results of other applicable testing programs, indicates that the relationships published in BWRVIP-100, Rev. 1-A are non-conservative in the fluence range from 5E20 n/cm2to 3E21 n/cm2 when considering the newly acquired weld metal data As a consequence of this Transfer of Information, the BWRVIP-235 software should not be used going forward to evaluate flaws in the weld region of reactor internals where the accumulated fluence is greater than 5E20 n/cm2(E>1MeV).
Recipients should evaluate their use of these EPRI products to determine if any flaw evaluations could be impacted, possibly resulting in either a reduction in structural margins or changes in inspection frequencies (Emphasis Added).
According to EPRIs letter, this particular revision of the flawed EPRI 5
https://www.nrc.gov/docs/ML2108/ML21084A164.pdf embrittlement code has been applied since 2016. However, analyses on real-world irradiated samples in 2020 proved that the analytical code was faulty and underestimated embrittlement damage at reactors for at least five years.
The EPRI letter confirms several key concerns I identified previously in my first declaration concerning the embrittlement obstacle at Point Beach:
! Mathematical modeling of neutron embrittlement is prone to errors and is frequently incorrect, creating unsafe conditions.
! There is no substitute for using frequent real-world material samples to determine the actual degraded condition of a reactors internals subject to high neutron fluence levels.
! Point Beach does not have an adequate number of physical samples for NextEra to periodically sample to determine if its core internal structures will remain safe in the extended license period of 60 to 80 years.
These particular real-world embrittled samples EPRI used to assess its code came from Boiling Water Reactors. Yet, the letters dire warning highlights my expert concern submitted in my first declaration. With my professional experience in nuclear reactor non-destructive inspection testing, I opine that the physical specimens and coupons at Point Beach may indeed identify that embrittlement calculations made at Point Beach are not conservative. Moreover, without testing the physical specimens and coupons at Point Beach, NextEra is severely risking public safety.
High neutron fluence levels similar to those identified by EPRI in the BWRs it examined are already present in the internal core structures at Point Beach. After operating for only 20 years, Point Beach realized this neutron fluence damage to internal core structures when it replaced almost 200 baffle-former bolts during the 1990s.
That replacement of almost 200 baffle-former bolts occurred more than 20 years ago, yet I cannot find any record that the baffle-former plates themselves have been tested and were replaced if warranted. Testing the baffle-former plates, which are known to have undergone high neutron fluence, should have been undertaken by NextEra at Point Beach.
Therefore, the warning in EPRIs letter is directly applicable to the existing and projected conditions of the internal core structures at Point Beach.
Finally, EPRIs letter supports and amplifies my concerns previously submitted in my first declaration and reinforces my conclusion that the Point Beach vessel and internals sampling program is inadequate.
It is imperative and prudent for public safety with such an old and degraded reactor that NextEra determines through the physical sampling and testing of coupons if Point Beach may operate safely for the proposed extension.
Point Beach was originally designed to operate for 40 years. Its original metallurgical sampling program was established to monitor embrittlement by neutron fluence during its 40 year design life.
REQUEST FOR LEAVE TO AMEND CONTENTION A. Applicable Standards NRC regulation 10 C.F.R. § 2.309( c) allows a petitioner to amend its contentions if the presiding officer finds that the petitioner has demonstrated good cause by satisfying the following factors: (i) the information on which the filing is based was not previously available; (ii) the information upon which the filing is based is materially different from information previously available; and (iii) the filing has been submitted in a timely fashion based on the availability of the subsequent information. An amended contention generally is considered timely if it is filed within 30 days of the date upon which the new information became available. Shaw AREVA MOX Services (Mixed Oxide Fuel Fabrication Facility), 67 NRC 460, 493 (2008)
(Many times, boards have selected 30 days as [the] specific presumptive time period for timeliness of contentions filed after the initial deadline (collecting cases6)). There is as yet no initial scheduling order in this proceeding; Petitioner PSR WI is proceeding cautiously and staying within the customary 30-day minimum window for amendment, so this request is timely.
6 See, e.g., Entergy Nuclear Vermont Yankee LLC (Vermont Yankee Nuclear Power Station),
Docket No. 50-271-LR (ASLBP No. 06-849-03-LR), Licensing Board Order (Initial Scheduling Order)
(Nov. 17, 2006) at 7 (unpublished); Entergy Nuclear Generation Co. (Pilgrim Nuclear Power Station),
Docket No. 50-293-LR (ASLBP No. 06-848-02-LR), Licensing Board Order (Establishing Schedule for Proceeding and Addressing Related Matters) (Dec. 20, 2006) at 7 (unpublished); Southern Nuclear Operating Co. (Early Site Permit for Vogtle ESP Site), Docket No. 52-011-ESP (ASLBP No.
07-850-01-ESP-BD01), Licensing Board Order (Prehearing Conference and Initial Scheduling Order)
(May 7, 2007) at 3 (unpublished).
B. Amended and Substituted Contention PSR WIs proposed Amended and Substituted Contention 2 follows:
Point Beachs continued operation violates 10 CFR Part 50, Appendix A, Criterion 14 because the reactor coolant pressure boundary has not been tested so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture, and the aging management plan does not provide the requisite reasonable assurance. The Electric Power Research Institute has recently admitted that its computer software for predicting embrittlement in boiling water reactors is nonconservative.
Physical specimens and coupons at Point Beach may indeed prove that embrittlement calculations made at Point Beach are not conservative. Without testing the physical specimens and coupons at Point Beach, NextEra is severely risking public safety.
DEMONSTRATION OF GOOD CAUSE FOR LATE FILING PSR WI satisfies the three-prong test for good cause to file this amended contention based on new information as follows:
A. The information upon which the filing is based was not previously available.
The EPRI letter was not publicly available in ADAMS until April 2, 2021. PSR WI could not have known about this significant admission by EPRIs that its vaunted software was nonconservative in predicting embrittlement in BWRs. This revelation significantly adds to and confirms Mr. Gundersens expert conclusions in support of Contention 2.
B. The information upon which the filing is based is materially different from information previously available.
The unexpected EPRI admissions undermine the confidence that in recent years has elevated computerized forecasts and models as a means of projecting embrittlement above actual scientific metallurgical testing.
This new information strengthens and supplements the material issue of potential nonconservatism in computer modeling that may be undermining the aging management of the PBNP reactor vessels and internals. PBNP is storing two capsules in the spent fuel storage pool at the reactor site, one from each unit7 that were removed from the reactors in 1994 and 1997, respectively, and they have not been tested. Testing now, 25 years after removal, will provide no useful data. In addition, each reactor still contains a Capsule N inside the two reactor units, noted as being held on standby.8 These N capsules should be analyzed to provide actual physical data to test NextEras optimistic hypotheses.
C. The amended contention has been submitted in a timely fashion based on the availability of the subsequent information.
The amended contention is being filed within 30 days of PSR WI having learned of the EPRI letter that forms the basis of the amended contention, and therefore, the amended contention is timely. Shaw AREVA MOX Services, supra, 67 NRC at 493.
CONCLUSION For all of the reasons stated above, this Motion should be granted and supplementation and amendment of PSR WIs Contention 2 should be allowed.
April 26, 2021 /s/ Terry J. Lodge Terry J. Lodge, Esq.
316 N. Michigan St., Suite 520 Toledo, OH 43604-5627 (419) 205-7084 Fax (419) 932-6625 tjlodge50@yahoo.com lodgelaw@yahoo.com Counsel for Physicians for Social Responsibility Wisconsin, Petitioner CERTIFICATE OF SERVICE I hereby certify that on April 26, 2021, I deposited the foregoing PHYSICIANS FOR 7
Point Beach Nuclear Plant Units 1 and 2 Subsequent License Renewal Application (Public Version), November 2020 (ML20329A247), p. 1208/1528 of .pdf.
8 Id.
SOCIAL RESPONSIBILITY WISCONSINS MOTION TO AMEND CONTENTION 2 (INADEQUATELY TESTED REACTOR COOLANT PRESSURE BOUNDARY) in the NRCs electronic docket of this proceeding and that according to the protocols of that system, it was to be automatically transmitted to all parties of record registered to receive electronic service.
/s/ Terry J. Lodge Terry J. Lodge, Esq.
Counsel for Petitioner PSR WI UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of ) Docket Nos. 50-266 and 50-301 NRC20210021 NextEra Energy Point Beach, LLC )
April 26, 2021 (Point Beach Nuclear Plant, Units 1 and 2) )
)
SUPPLEMENTAL DECLARATION OF ARNOLD GUNDERSEN, NUCLEAR ENGINEER Under penalty of perjury, I, Arnold Gundersen, declare as follows:
1.! My name is Arnold Gundersen. I am sui juris. I am over the age of 18 years old.
2.! Physicians for Social Responsibility Wisconsin (PSR-WI) has retained Fairewinds Associates, Inc., of which I am an officer and employee, to review a license application to the nuclear regulatory commission to extend the licensed life of NextEras Point Beach nuclear reactors until they have operated for 80-years, along with the related Environmental Report for NextEra Energy Point Beach, LLCs Point Beach Nuclear Plant, Units 1 and 2. My observations and conclusions are offered to a reasonable degree of scientific certainty based on my experience and relevant information sources.
3.! This declaration supplements an earlier declaration I provided in this case on March 23, 2021.
4.! My professional qualifications are identified in my CV that was provided to the parties in my original declaration. It is important to note that previously I served as a member of the Radiation Safety Committee and the Senior Vice President of an ASME Section XI nuclear reactor non-destructive inspection division of an NRC (Nuclear Regulatory Commission) licensed corporation (Nuclear Energy Services / NES division of PCC Penn Central Corporation). The division I headed provided construction and outage-related inspection activities on nuclear reactor vessels and piping and reactor internal structures throughout the United States.
5.! At some point during 2020, the Electric Power Research Institute (EPRI) became aware of errors in the computer codes its members use to predict the neutron embrittlement of components inside US nuclear reactors. EPRI determined that these embrittlement codes are not accurate and are under-predicting the extent of embrittlement damage to reactor components within the atomic reactor cores.
6.! Underpredicting the damage from neutron embrittlement is definitely non-conservative and may create serious safety flaws if left unchecked.
7.! EPRI and the NRC met in private for a confidential meeting held on February 17, 2021. At that meeting, EPRI informed the NRC of its concerns about the newfound embrittlement errors in the EPRI computer code.
8.! EPRI mailed a formal letter to the NRC on March 22, 2021, informing the NRC that it had found severe errors in one or more of its computer codes used to calculate neutron embrittlement to core internal structures.1 9.! The EPRI letter was filed in the NRC Public Document Room (PDR) on April 2. I became aware of EPRIs letter several days later.
10.!The EPRI letter is terse at only two pages plus five pages of attachments. Moreover, EPRIs brevity hides most of the problems it discovered under the secrecy cloak of proprietary material. Even with its secrecy cloak, the letter clarifies that numerous embrittlement documents are hidden from public scrutiny. While hiding most of the embrittlement problems as proprietary, the EPRI letter also hints at significant flaws identified in analytical computer codes in use since 2016.
According to the EPRI letter):
BWRVIP-100, Rev. 1-A, published in 2016, was developed to support the evaluation of in-service flaws in BWR core shrouds. It provides fracture toughness relationships as a function of neutron fluence for BWR core shrouds. Research was carried out from 2016 to 2020 to obtain additional fracture toughness data on irradiated stainless steels with an emphasis on weld metal. A preliminary evaluation of results from this testing program, as well as the results of other applicable testing programs, indicates that the relationships published in BWRVIP-100, Rev. 1-A are non- conservative in the fluence range from 5E20 2 2 n/cm to 3E21 n/cm when considering the newly acquired weld metal dataÉ 1.! As a consequence of this Transfer of Information, the BWRVIP-235 software should not be used going forward to evaluate flaws in the
"#$$%&'(()))*+,-*./0(1/-&(234!56(234!5678!97*%1:"
weld region of reactor internals where the accumulated fluence is greater than 5E20 n/cm2 (E>1MeV).
2.! Recipients should evaluate their use of these EPRI products to determine if any flaw evaluations could be impacted, possibly resulting in either a reduction in structural margins or changes in inspection frequencies
[Emphasis Added].
11.!According to EPRIs letter, this particular revision of the flawed EPRI embrittlement code has been applied since 2016. However, analyses on real-world irradiated samples in 2020 proved that the analytical code was faulty and underestimated embrittlement damage at reactors for at least five years.
12.!The EPRI letter confirms several key concerns I identified previously in my first declaration concerning the embrittlement obstacle at Point Beach:
12.1.! Mathematical modeling of neutron embrittlement is prone to errors and is frequently incorrect, creating unsafe conditions.
12.2. There is no substitute for using frequent real-world material samples to determine the actual degraded condition of a reactors internals subject to high neutron fluence levels.
12.3.Point Beach does not have an adequate number of physical samples for NextEra to periodically sample to determine if its core internal structures will remain safe in the extended license period of 60 to 80 years.
13.!These particular real-world embrittled samples EPRI used to assess its code came from Boiling Water Reactors. Yet, the letters dire warning highlights my expert concern submitted in my first declaration. With my professional experience in nuclear reactor non-destructive inspection testing, I opine that the physical specimens and coupons at Point Beach may indeed identify that embrittlement calculations made at Point Beach are not conservative.
Moreover, without testing the physical specimens and coupons at Point Beach, NextEra is severely risking public safety.
14.!High neutron fluence levels similar to those identified by EPRI in the BWRs it examined are already present in the internal core structures at Point Beach. After operating for only 20 years, Point Beach realized this neutron fluence damage to internal core structures when it replaced almost 200 baffle-former bolts during the 1990s.
15.!That replacement of almost 200 baffle-former bolts occurred more than 20 years ago, yet I cannot find any record that the baffle-former plates themselves have been tested and were
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