ML14122A027

Comment (19) of Kevin Kamps on Behalf of Beyond Nuclear, Opposing License Renewal Application for Davis-Besse Nuclear Power Station, Unit 1; Draft Supplemental Generic Environmental Impact Statement

ML14122A027
Person / Time
Site:	Davis Besse
Issue date:	04/21/2014
From:	Kamps K Beyond Nuclear
To:	Rules, Announcements, and Directives Branch
References
79FR13079 00019, NRC-2010-0298
Download: ML14122A027 (7)

Text

I~/z ~9/~/Page 1 of IPUBLIC SUBMISSION As of: April 24, 2014Received:

April 21, 2014Status: Pending-Post Tracking No. ljy-8bo3-4xzj Comments Due: April 21, 2014Submission Type: WebDocket: NRC-2010-0298 Receipt and Availability of Application for License RenewalComment On: NRC-2010-0298-0033 License Renewal Application for Davis-Besse Nuclear Power Station, Unit 1; Draft Supplemental GenericEnvironmental Impact Statement Document:

NRC-2010-0298-DRAFT-0042 Comment on FR Doc # 2014-05021 Submitter Information Name: Kevin KampsAddress:Beyond Nuclear6930 Carroll Avenue, Suite 400Takoma Park, MD, 20912Email: kevin@beyondnuclear.org

JDm/General CommentSee attached file(s)Attachments 4 21 14 draft EIS comment vis a vis 1 10 12 cracking contention SUNSI Review CompleteTemplate

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04/24/2014 The following is provided as public comment on the NRC draft EIS re: Ddivis-Besse's proposed 20 year license extension Link to original Jan. 10, 2012 cracking contention filed with the NRC ASLB:http://www.beyondnuclear.org/storage/FINAL%20Contention%205%20Cracking%20Jan uary%20 I0%20201I2.pdf It is noteworthy to point out that, after an initial period of support for our contention, NRC Staff opposed it after the publication of FENOC's Aging Management Plan in earlyApril, 2012At point #20, on p.21-22, we stated:"Those patches are, of course, weak spots themselves, both the welded area on the innersteel containment, a mere 1.5 inches thick, as well as the "patched" area on the concreteshield building/secondary reactor containment structure, a mere 2.5 feet th-ick. Asexplained below, on January 4, 2012, David Lochbaum of UCS questioned whether themultiple holes cut in containment, and thus the multiple "patches" applied afterwards, overlapped, and how so. The "welds" on the inner steel container, and "repours" ofconcrete on the outer shield/secondary containment

building, are themselves weak spots -perhaps repeatedly so in spots that have been involved in more than one cut-through andrepair. This is a safety-significant issue that will grow all the more so with age-related degradation, and the prospect for yet one more cut-through and "repair" (patch) for the2014 steam generator replacement project.

In fact, FENOC has answered Lochbaum's question about the overlap of the breaches.

In its January 5, 2012 Camp Perry powerpoint presentation cited previously, on Slide #18 (page 9 of the hardcopy handout),

FENOC documents that indeed all of the first three breaches

-1970, 2002, and 2011 -have already overlapped, specifically in the top left-hand quadrant."

As revealed via our FOIA request (dated Jan. 26, 2012), by documents NRC provided usin summer 2012, contractors Bechtel and Sargent and Lundy themselves at first suspected that the hydro-demolition process itself, used to breach the Shield Building, wasresponsible for the cracking.

Although the cracking proved to be far more widespread than the access opening area impacted by the hydro-demolition

activity, Bechtel andSargent and Lundy's concern is a strong indication that hydro-demolition can in fact be aconcern in terms of damage.In fact, in Feb. 2014, it was revealed that the hydro-demolition just carried out as part ofthe steam generator transplant operation had damaged the rebar in the Shield Buildingaccess opening area. On April 15, 2014, NRC Staff included this concern about rebardamage issue in Requests for Additional Information (RAls) regarding the 2017-2037 Aging Management Plan (AMP).Davis-Besse has breached its Shield Building four times: the Initial Construction Opening in the 1970s; the 2002 reactor lid replacement access opening; the 2011 reactor1 lid replacement access opening; and the 2014 steam generator replacement accessopening.

This is more than any other nuclear power plant. Each breach of the ShieldBuilding risks more damage to the structure.

Davis-Besse cannot guarantee not needingto breach the Shield Building yet again before 2037.At point #22, on p.23-24, we stated:"This approach appears more attuned to an arbitrary outage schedule, with a speedyreturn to economically-profitable "production" rather than taking a conservative, analytical approach to determination of root causes, extent, and safety-significance ofcracking in the shield building.

Such an approach imperils Intervenors, the people theyrepresent, and countless residents downwind and downstream of the aged and agingDavis-Besse atomic reactor in the Great Lakes Basin."NRC's OIG reported at the end of 2002, after the Hole in the Head fiasco revealed earlierthat year, that NRC -in addition to FENOC -had prioritized the company's bottom lineabove public safety. NRC has repeated that behavior since 2011 -allowing the companyto rush reactor restart in Dec. 2011, before knowing the root cause, extent of condition, and corrective actions needed, regarding Shield Building cracking.

In fact, givenrevelations of the worsening of previously known cracking, and the initiation ofpreviously unknown cracking, in August/September 2013. NRC has postponed FENOC'sdue date for a "revised revised" root cause report and corrective action (agingmanagement) plan until mid-2014

-more than two years after the original Feb. 28, 2012deadline.

As David Lochbaum of UCS indicated in May of 2012, FENOC's failure toprovide complete, accurate information by Feb. 28.2012 constituted a IOCFR50.9 violation, but NRC has never taken enforcement action.At point #23, on p.24, we stated:"Of additional concern is that the pour of new concrete to re-seal the shield buildingforeclosed significant investigatory options for examination and further analysis of thecause, extent, and significance of the cracks, such as direct visual examination, directmeasurement, direct sampling, etc. In effect, evidence of the cracking has been buriedunder inches or feet of concrete, due to FENOC's rush to re-start, and NRC's letting themget away with it."In fact, in Feb. 2014 we learned that, by leaving in place metal forms in late 2011,FENOC had concealed a 25 foot long, 6 to 12 inch wide, air space or gap of yet to berevealed depth through the 30 inch thick Shield Building wall. The metal forms prevented visual examination of the gap. Thus, not only did the rushed resealing of the accessopening involve an incomplete concrete pour -it also prevented visual examination anddiscovery of the very gap resulting from the rush-job conducted during the rush to restartthe reactor in Dec. 2011. Thus, Davis-Besse operated at full power for over two years -2 from early December 2011 to Feb. 1,2014 -with a significant void space in its ShieldBuilding wall, of yet-to-adequately-be-determined impact on containment safety margins.Such risky behavior by FENOC and NRC, working in collusion and complicity, cannotbe endured for an additional 20 years.At point #25, on p.26, we stated:"If the shield building loses its ability to perform its safety- and security-related functions, Davis-Besse should be immediately shut down, of course. But this very risk,the potential loss of shield building safety and security function over time, is exactlythe kind of analysis that should be included in FENOC SAMA analyses regarding theDavis-Besse license extension.

Such analyses have not been done. Similarly, the potential for Davis-Besse's cracked shield building to cause its early retirement, before its currentlicense expiration in 2017, or before its extended 2037 license expiration proposed byFENOC, should be addressed by FENOC's reliability

analyses, and its energyalternatives analyses.

For, if Davis-Besse's days are numbered, due to its cracked shieldbuilding, then Intervenors' wind, solar, and compressed air energy storage contentions increase in merit. FENOC, and the Region of Interest as a whole, should be preparing now to replace Davis-Besse and the NRC should reflect such a reality through its ownindependent analysis in the Draft Environmental Impact Statement on the licenseextension proposal."

FENOC's SAMA analyses assume a safe, sound Shield Building capable of performing its designed containment function.

However, the severe cracking known since October2011, combined with wall gaps in resealed access openings in 2002 and 2011, seriously undermine any such optimistic assumptions.

As Intervenors' SAMA contentions havechallenged since the beginning of this license extension application proceeding, FENOC's SAMA analyses need fundamental re-evaluation.

NRC's draft EIS does not adequately address these needed SAMA re-evaluations, if itaddresses them at all.Mark Cooper, an energy economist at Vermont Law School, warned on April 10, 2014that nuclear utilities must plan for replacement power -as from efficiency upgrades anddevelopment of renewable sources of electricity

-in advance of the inevitability thatatomic reactors will one day close, lest our electric grids lurch from crisis to crisis. Infact, in July 2013, Cooper identified Davis-Besse as one of a dozen reactors most at riskof near-term shut down, due to a variety of factors, including economic factors (cost, oldage, stand alone status, and only a 25-year future even if it gets an extension),

operational factors (lack of reliability, long-term outages),

as well as multiple safety factors.

(seeExhibit ES-1: Retirement Risk Factors of the Nuclear Fleet, page iv, posted online athttp://216.30.191

.148/071713%20VLS%20Cooper%20at%20risk%20reactor%20report%

20FINAL1

.pdf).3 At point #40, on p. 38-39, we stated:"A problem with this examination protocol is that this visual inspection program islimited to external surfaces.

The present cracking controversy involves internal

cracking, not visible to the naked eye on the surface.

That is another reason that Interveners areconcerned that the early December pouring of the concrete to patch the shield buildinghole may have covered up evidence of cracking that could only be obtained throughdirect visual inspection, but is now under inches or feet of concrete."

The rushed access opening reseal, in the lead up to the rushed reactor restart, in late 2011,not only concealed primary evidence of severe Shield Building wall cracking, it alsointroduced a substantial gap in the resealed access opening, concealed from visualexamination by metal plates that had been left in place. FENOC's ability to detect seriousproblems with the Shield Building without direct visual examination seems quite limited.The substantial Shield Building wall gap introduced in 2011, for example, remainedundiscovered until Feb. 2014, when visual examination revealed it during the steamgenerator replacement cut of yet another access opening through the Shield Building.

During the Dec. 2011 to Feb. 2014 time frame, not a single acoustic test that could haverevealed the wall gap was performed.

Along the same lines, the white wash applied to the exterior of the Shield Building inAugust 2012 has concealed visual evidence of surface cracking ever since. Intervenors called for comprehensive root cause, extent of condition, and corrective actionexamination, documentation, and analyses throughout late 2011 and all of 2012 (in fact,still call for it) -for all forms of cracking and other Shield Building

problems, not justsub-surface laminar cracking.

FENOC's and NRC's priority on production (companyprofit),

rather than public safety, has glossed over serious Shield Building

problems, ofdeep safety and environmental concern on the brink of approval of a 20-year licenseextension.

In fact, we addressed this concern at the very end of point #45, on p.46-47,stating:"Intervenors question with alarm the safety significance of the potential for worsening concrete shield building cracking over the next five years of licensed operations.

Contemplating such worsening cracking for the next quarter century, considering the 20year license extension

proposed, raises the level of alarm considerably.

Interveners contend that Davis-Besse should be shut down on Earth Day (April 22), 2017 -its lastlicensed date for operations under the original 40 year license -at the very latest.In fact, by Sept. 2013, FENOC admitted worsening of previously identified

cracking, aswell as initiation of newly discovered cracking

-that is, age-related cracking.

This isclear evidence that Intervenors' cracking should have been admitted for ASLB hearing inthe first place -it still should be.At point #48, on p.50, we stated:4 "In request for additional information (RAI) B.1 4-1, issued on May 19, 2011, the staffasked the applicant to describe the programmatic activities that will be used tocontinually identify aging issues, evaluate them, and as necessary, enhance the agingmanagement programs (AMPs) or develop new AMPs for license renewal.

In its responsedated June 24.2011 , the applicant stated that it currently has a procedurally controlled operating experience review process, as required by NUREG-0737, "Clarification ofTMI Action Plan Requirements,"

Item I.C.5, "Procedures for Feedback ofOperating Experience to Plant Staff." The applicant stated that this procesý provides forthe systematic identification and transfer of lessons learned from site and industryexperience into fleet and station processes to prevent events and enhance the safety andreliability of its operations."

The irony of this, of course, is that the Three Mile Island precursor incident at Davis-Besse, 18 months before the TMI meltdown, could have prevented the TMI meltdown, had that OE [Operating Experience]

been shared with TMI by Davis-Besse, or evenNRC. But that did not happen, and the rest is history.

This TMI precursor incident wasdescribed, in summary, in a backgrounder about Davis-Besse's numerous close calls withdisaster, previously put on the record in this proceeding, posted online athttp://wwvw.beyondnuclear.org/storage/Davis%2OBesse%2020%`20More%/20Years%20of

%20Rad ioactive%20Russian%20Roulette%2ONov%202010%20corrected%2ODec%202 8%202010.pdf (see pages 1-2).Given NRC Staff s April 15, 2014 RAIs, it is clear that NRC Staff is still not clear thatFENOC has aging-related cracking of the Shield Building, and associated "adequate protection" concerns associated with Shield Building safety-related design functionality, comprehensively

covered, under its 2017-2037 AMP.At point #51, on p.55, we stated:"NRC's DB RAI 3.1.2.2.16-3, on page 6, also directly touches upon Intervenors' presentcontention.

This is due to the fact that degradation of the steam generators.will requiretheir premature replacement, requiring yet another breach of the Davis-Besse concreteshield building.

FENOC already plans such an organ transplant in 2014. But if FENOCscrews up this aging management program badly enough, it could very well have toreplace steam generators yet again in the future, during the license extension, even afterthe 2014 steam generator replacement.

Given the fact that Davis-Besse currently has itsthird lid, with no guarantees that a fourth lid will not be needed, necessitating yet anotherconcrete shield building breach, it is not far fetched to raise the concern about yet moresteam generator replacements post-2014.

Each breach of the concrete shield buildingrisks introducing more weakness into the structure, and undermining its vital safetyfunction.

The late Jan., 2012 San Onofre (CA) steam generator tube rupture occurred a few weeksafter this Jan. 10, 2012 contention was filed. The defective San Onofre replacement steamgenerators led to the permanent shutdown of San Onofre Units 2 and 3 in June 2013.5 Although we also filed a steam generator replacement contention at Davis-Besse in May,2013, which included concerns about Shield Building

breaches, that contention wassummarily dismissed by the ASLB. Thus, the steam generator replacement "experiment" at Davis-Besse is now well underway, and only time will tell how long they will last, andhow soon the Shield Building must again be breached, if FENOC chooses.to replacelarge nuclear components located within the Shield Building.

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