BEYOND NUCLEAR PUBLICATIONS

Search
JOIN OUR NETWORK

     

     

DonateNow

Relicensing

The U.S. nuclear reactor fleet is aging but owners are applying to the Nuclear Regulatory Commission for license extensions to operate reactors an additional 20 years beyond their licensed lifetimes. Beyond Nuclear is challenging and opposing relicensing efforts.

.................................................................................................................................................................................................................

Thursday
Nov132014

Coalition presses case against reactors on Great Lakes

Lake Erie's shores are dotted with numerous large-scale atomic reactors and coal burners. These thermal-electric power plants dump 2/3rds of the heat they generate as waste into the environment, contributing to recent toxic algae blooms visible in this satellite photo.An environmental coalition, including Beyond Nuclear, is working at fever pitch against degraded old, and proposed new, reactors on the Great Lakes shoreline in southeast Michigan and northwest Ohio.

Davis-Besse, OH

At U.S. Nuclear Regulatory Commission (NRC) headquarters in Rockville, Maryland, the groups Beyond Nuclear, Citizens Environment Alliance of Southwestern Ontario (CEA), Don't Waste Michigan, and the Green Party of Ohio pressed their case against a 20-year license extension at FirstEnergy Nuclear Operating Company's problem-plagued Davis-Besse atomic reactor east of Toledo. An oral argument pre-hearing was ordered to take place on Nov. 12th by the NRC Atomic Safety and Licensing Board Panel (ASLBP) overseeing the License Renewal Application (LRA) proceeding. The coalition first intervented against the license extension nearly four years ago.

Attorney Terry Lodge, Beyond Nuclear's Kevin Kamps, and Don't Waste MI's Michael Keegan represented the coalition before NRC ASLBP. The coalition was joined by expert witness Arnie Gundersen, Chief Engineer of Fairewinds Associates, Inc. The focus of the day-long hearing was the severe, and worsening, cracking of Davis-Besse's concrete containment Shield Building. The dangerously deteriorating Shield Building is the last line of defense against a catastrophic release of hazardous radioactivity, as from a reactor core meltdown and Inner Steel Containment Vessel failure due to a reactor disaster, earthquake, tornado missile, etc. The coalition has filed numerous contentions about the cracking since it was first revealed on October 10, 2011.

The coalition issued a press advisory about the Nov. 12th oral hearing. The Toledo Blade has reported on this story.

Fermi 2, MI

Beyond Nuclear, CEA, and Don't Waste MI, again represented by Toledo-attorney Terry Lodge, will appear at oral argument pre-hearings before an NRC ASLB on November 20th in Monroe, Michigan. The coalition is opposing the 20-year license extension proposed at Detroit Edison's Fermi 2 atomic reactor in nearby Frenchtown Township, on the Lake Erie shore. Fermi 2 is the single biggest G.E. Mark I Boiling Water Reactor in the world -- the same design as melted down and exploded, times three, at Fukushima Daiichi, Japan.

Beyond Nuclear's Reactor Oversight Director, Paul Gunter, will argue a contention calling for radiological filters on hardened vents, an obviously needed safety upgrade actively ignored by a majority of the NRC Commissioners, despite the lessons that should have been learned from the Fukushima nuclear catastrophe. Beyond Nuclear's Freeze Our Fukushimas campaign calls for the shutdown of all U.S. Mark I and II reactors. (See Beyond Nuclear's Freeze Our Fukushimas pamphlet.)

Beyond Nuclear's Radioactive Waste Watchdog, Kevin Kamps, will argue a contention regarding serious safety risks associated with the Fermi nuclear power plant's off-site transmission line corridor, as well as radioactive waste contentions.

Another group, Citizens Resistance at Fermi Two (CRAFT), has launched another 15 contentions against the license extension.

Fermi 3, MI

The coalition comprised of Beyond Nuclear, Citizens for Alternatives to Chemical Contamination (CACC), CEA, Don't Waste MI, and the Sierra Club Michigan Chapter -- again represented by attorney Terry Lodge -- continues to press its case against the proposed new Fermi 3 reactor, to be built on the very site that the Fermi 1 "We Almost Lost Detroit"  reactor partially melted down on October 5, 1966.

The coalition intervened against Fermi 3 on March 9, 2009, and has since filed dozens of contentions against the proposal.

Its transmission line corridor NEPA (National Environmental Policy Act) contention is still before the NRC Commissioners, thanks to a sua sponte motion by the NRC ASLBP itself. On behalf of the coalition, Lodge just filed a motion with the NRC Commissioners, supporting the ASLBP's request to the Commissioners for permission to carry out its own independent review of what appears to be NRC staff violations of NEPA, for not including the required "hard look" at the environmental impacts of Fermi 3's transmission line corridor in the FEIS (Final Environmental Impact Statement).

In addition, the coalition has appealed the ASLBP's rejection of its quality assurance (QA) contention to the full NRC Commission. Arnie Gundersen of Fairewinds serves as the coalition's Fermi 3 QA expert witness. The NRC Commissioners will likely rule on the QA and transmission corridor contentions in the near future.

Friday
Nov072014

Environmental coalition cites lack of Nuclear Waste Confidence, calls for suspension of reactor licensing proceedings

An environmental coalition embroiled in numerous old, degraded reactor license extension -- as well as proposed new reactor construction and operation license -- proceedings has filed its "CONSOLIDATED REPLY TO ANSWERS TO PETITIONS TO SUSPEND FINAL REACTOR LICENSING DECISIONS, MOTIONS TO ADMIT A NEW CONTENTION, AND MOTIONS TO REOPEN THE RECORD" before the U.S. Nuclear Regulatory Commission (NRC).

The filing is a response to "Answers" filed a week ago by NRC staff and the nuclear utilities, as well as to an amicus curiae filing made by the Nuclear Energy Institute, the industry's lobbying arm in Washington, D.C. The environmental coalition's "Consolidated Reply" was prepared by Diane Curran of the Washington, D.C. law firm Harmon, Curran, Spielberg + Eisenberg, LLP, as well as Mindy Goldstein, Director of the Turner Environmental Law Clinic at Emory University School of Law in Atlanta.

Terry Lodge, a Toledo-based attorney who represents Beyond Nuclear and other environmental groups in their interventions against the Davis-Besse, OH and Fermi 2, MI license extensions, and the Fermi 3, MI Construction and Operating Licence Application (COLA), filed the "Consolidated Reply" in these proceedings.

Thursday
Oct302014

Beyond Nuclear warns NRC against weakening RPV embrittlement/PTS safety regulations at Palisades

Entergy's problem-plagued Palisades atomic reactor, and the Great Lake and region of southwest Michigan it puts at dire, and increasing, risk.

Nuclear watchdog groups have long been concerned about Pressurized Thermal Shock (PTS) risks due to the worst embrittled reactor pressure vessel (RPV) in the U.S., at Palisades, located on the Lake Michigan shoreline.

A sudden decrease in temperature, given the intense pressure (around 2,000 pounds -- or a ton -- per square inch) on the neutron radiation-embrittled metal of the RPV, could fracture it like a hot glass under cold water. A Loss of Coolant Accident (LOCA) would follow, risking containment failure and catastrophic release of hazardous radioactivity downwind, downstream, up the food chain, and down the generations.

The longer Palisades operates, the worse its risk of a breakdown phase accident, as due to PTS. (See Union of Concerned Scientists' "Bath Tub Curve" -- due to the curve's shape -- of break-in and breakdown phase risks, including nuclear power "data points," such as Three Mile Island Unit 2, Chernobyl, Davis-Besse's hole-in-the-head fiasco, and Indian Point's steam generator tube rupture.)

March 28, 1982: "The Risk of a Meltdown," March 28, 1982 New York Times op-ed by NRC reactor safety engineer Demetrios Basdekas.* 

June, 1987: Residual Life Assessment of Major Light Water Reactor Components--Overview, Volume 1, NUREG/CR 4731, EGG-2469, Volume 1, June 1987, Editors V.N. Shah and P.E. MacDonald (see Server, Odette, Ritchie re: Reference temperature for nil ductility transition increasing from 40 degrees F to 280 to 290 degrees F or higher in extreme cases, due to RPV embrittlement with age).

July 8, 1993: "Pressurized Thermal Shock Potential at Palisades: History of Embrittlement of Reactor Pressure Vessels in Pressurized Water Reactors," prepared by Michael J. Keegan (rekeyed August 3, 2005).*

February 21, 2000: Consumers Energy letter to the NRC, "Palisades Reactor Vessel Neutron Fluence Reevaluation" (ADAMS Accession No. ML003686516).

October 26, 2004 (Date Submitted; Revised December 14, 2004): Generalization of Plant-Specific Pressurized Thermal Shock (PTS) Risk Results to Additional Plants, Table 1. Plants with highest RTNDT, U.S. NRC.*

March 22, 2005: Palisades Nuclear Plant, Application for Renewed Operating License, (ADAMS Accession No. ML050940429).

2005-2007: NRC rubberstamped Palisades' 20 year license extension in 2007, despite two years of widespread, determined grassroots resistance by a coalition of environmental groups and concerned local residents. Palisades' embrittled RPV, vulnerable to PTS, was a major concern raised during the intervention against the license extension.

August 8, 2005: REQUEST FOR HEARING AND PETITION TO INTERVENE, submitted to the U.S. NRC ASLB, by attorney Terry Lodge, on behalf of Don't Waste Michigan and NIRS, in opposition to Palisades' 20-year license extension (the first contention, on page 4, regards The license renewal application is untimely and incomplete for failure to address the continuing crisis of embrittlement).

September 16, 2005: PETITIONERS’ COMBINED REPLY TO NRC STAFF AND NUCLEAR MANAGEMENT COMPANY ANSWERS, submitted to the U.S. NRC ASLB, by attorney Terry Lodge, on behalf of Don't Waste Michigan and NIRS, in opposition to Palisades' 20-year license extension (pages 2 to 23 are regarding Contention 1, The license renewal application is untimely and incomplete for failure to address the continuing crisis of embrittlement).

March 17, 2006: PETITIONERS’ NOTICE OF APPEAL FROM ASLB DENIAL OF HEARING, AND SUPPORTING BRIEF, submitted to the U.S. NRC ASLB, by attorney Terry Lodge, on behalf of Don't Waste Michigan and NIRS, in opposition to Palisades' 20-year license extension (Appeal of dismissal of Contention No. 1, The license renewal application is untimely and incomplete for failure to address the continuing crisis of embrittlement, pages 3 to 9).

March 20, 2006: Environmental coalition letters, to U.S. Senators Carl Levin (D-MI) and Debbie Stabenow (D-MI), requesting they initiate a Government Accountability Office (GAO) investigation into embrittlement risks at Palisades in particular, but also into NRC weakening of PTS safety standards nationwide.

Spring 2006: Consumers Energy power point presentation to the Michigan Public Service Commission, highlighting "Reactor vessel embrittlement concerns" at Palisades.

May 18, 2006: "Halting 20 Extended Years of Risky Reactor Operations and Radioactive Waste Generation and Storage on Lake Michigan at Palisades Nuclear Power Plant: Comments on NUREG-1437, Supplement 27 to the Generic Environmental Impact Statement for License Renewal of the Palisades Nuclear Power Plant," submitted by an environmental coalition to NRC (see section XI., Plant Aging Increases Accident Risk, pages 26-27). See List of organizations opposing 20-year license extension at Palisades nuclear power plant.

December 20, 2010: Entergy Nuclear Operations, Inc. letter, "Updated Palisades Reactor Vessel Pressurized Thermal Shock Evaluation" (ADAMS Accession No. ML110060692). Before this point, the Palisades RPV was calculated to surpass the PTS screening criterion limit by 2014. After this reevaluation, the Palisades RPV was deemed good to go, vis a vis PTS, till April 2017.

July 26, 2011: The U.S. Nuclear Regulatory Commission (NRC) held a meeting with the nuclear power industry regarding "technical discussions related to the evaluation of irradiation effects on RPV [Reactor Pressure Vessel] ferritic materials for operating plants, with particular focus on 10 CFR [Title 10, Code of Federal Regulations, Part] 50.61a and the NRC’s Embrittlement Database."

December 7, 2011: NRC letter, "Updated Reactor Pressure Vessel Pressurized Thermal Shock Evaluation for Palisades Nuclear Plant (TAC No. ME5263)," ADAMS Accession No. ML112870050.

March 9, 2012: Letter regarding PTS risks at Palisades, sent to U.S. Senators Carl Levin and Debbie Stabenow (Democrats from Michigan), signed by numerous Don't Waste MI chapters across the state, as well as their attorney, Terry Lodge of Toledo, OH.

May 25, 2012: 25 concerned local residents and environmental group representatives met with NRC Chairman Greg Jaczko in South Haven, MI, near Palisades; RPV embrittlement and PTS risk was a top issue discussed.

May-June, 2012: Nuke Info Tokyo (the newsletter of Citizens' Nuclear Information Center), No. 148, May/June 2012, including the Part I of the article "Aging Nuclear Power Plants focusing in particular on irradiation embrittlement of pressure vessels," by Hiromitsu Ino (pages 10 to 12, and continued in newsletter No. 149, below; the article in No. 148 also includes Figure: Genkai-1 Monitoring Test Sample Data and JEAC and 4201-2004 Prediction Curve).

July-August, 2012: Nuke Info Tokyo, the newsletter of Citizens' Nuclear Information Center, No. 149, July/August 2012, including Part II of the article "Aging Nuclear Power Plants focusing in particular on irradiation embrittlement of pressure vessels," by Hiromitsu Ino (continued from the article in newsletter No. 148, above; pages 10 to 14, and concluded on page 5). Additional Tables and Figures were included in Hiromitsu Ino's articles.

March 9, 2013: Kevin Kamps of Beyond Nuclear's questions to NRC re: the agency Webinar on RPV embrittlement/PTS risks at Palisades.

March 25, 2013: Around two dozen concerned local residents and environmental group representatives met with NRC Commissioner William Magwood IV in South Haven, MI, near Palisades; RPV embrittlement and PTS risk was a top subject discussed. Letters containing questions and concerns from meeting attendees to Commissioner Magwood, and his responses, are posted under NRC ADAMS Accession No. ML13142A424.

April 2, 2013: Plot, used as part of the end-of-cycle public meeting held on April 2, 2013 (see ADAMS ML13093A19), showing the variation of the embrittlement reference temperature (RT-PTS) with years of radiation exposure.

May 28, 2013: "Response to Concerns Raised in Letter Sent to the NRC by Ms. Alice Hirt," by NRC Commissioner William Magwood IV, to Alice Hirt, including: "Concerns regarding the embrittlement of the Palisades' reactor vessel and the extension of their operating license"; "Concerns with the predictability of assessing this irradiation embrittlement"; and a plot charting Embrittlement RT-PTS in degrees Fahrenheit versus Dates (Years of Reactor Operation).

December 18, 2013: Entergy Nuclear sent its "UPDATED REACTOR VESSEL FLUENCE EVALUATION SUPPORTING A REVISED PRESSURIZED THERMAL SHOCK SCREENING CRITERIA LIMIT (TAC NO. MF2326)" to NRC, asserting its Palisades atomic reactor in Covert, Michigan on the Lake Michigan shoreline (see photo, left) is safe to operate till August 2017, despite having the worst embrittled RPV in the U.S.

June 5, 2014: Meeting in Benton Harbor, MI, between more than a dozen concerned local residents and environmental group representatives, with Chairman Macfarlane; Palisades RPV embrittlement and PTS risk was a top subject discussed. See Barbara Pellegrini's letter to NRC Chairman Allison Macfarlane.

July 29, 2014: Entergy Nuclear sent the U.S. Nuclear Regulatory Commission (NRC) a document entitled "License Amendment Request to Implement 10 CFR 50.61 a, 'Alternate Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events'" regarding its problem-plagued, age-degraded Palisades RPV. This license amendment would effectively enable Palisades to continue operating past August 2017, despite its violation of NRC embrittlement safety standards.

August 29, 2014: In an email dated August 29, 2014, NRC confirmed that its "Acceptance Review" had determined that Entergy's application was sufficient for NRC to continue with a more in-depth technical review of the matter.

October 30, 2014: Beyond Nuclear submitted comments by NRC's arbitrarily short October 30th deadline regarding yet another request by Palisades for a weakening of RPV embrittlement/PTS safety regulations, in the form of a change of methodology to assess the problem. Such pencil whipping has occurred many times over the decades at Palisades, in order to enable ongoing operations, despite the RPV's seriously degraded condition.

October 30, 2014: Michael Keegan of Don't Waste Michigan in Monroe, MI also submitted comments on behalf of the statewide nuclear power watchdog coalition, by NRC's October 30th deadline.

*This document was submitted to NRC as supporting documentation for official public comments by Beyond Nuclear on October 30, 2014. See immediately above.

Monday
Oct272014

Beyond Nuclear to challenge Davis-Besse containment cracking at NRC HQ on Nov. 12th

Severe sub-surface laminar cracks in the Shield Building concrete adjacent to rebar (left) grow a half-inch every time it freezes at Davis-Besse. Core bore monitoring tests (right) are too few and far between, and too infrequent.

Please listen-in by phone, to show your support, as Beyond Nuclear and environmental allies challenge the problem-plagued Davis-Besse atomic reactor's proposed 20-year license extension. The focus of the Wednesday, November 12th hearing, beginning at 9 AM Eastern sharp, will be worsening cracking of the concrete containment. Your presence on the phone line will let the U.S. Nuclear Regulatory Commission (NRC), its Atomic Safety and Licensing Board Panel (ASLBP), and FirstEnergy Nuclear Operating Company know they are being watched. It will also let Beyond Nuclear and its allies know they have your support.

According to the NRC ASLB point of contact, law clerk Sachin Desa:

"...The dial-in number for calling in to the Davis-Besse November 12th Oral Argument (listen-only) is 888-790-4078.  When prompted, please enter the passcode 2475418.  

If others are interested in listening in on the call, please have them reach out to me so we can keep an accurate count.

The argument will start at 9:00 AM Eastern Time.  Please try to be on the line at least five minutes early so as to allow time to work through any technical issues that may arise.  Let me know if there are any further questions.

Sachin Desai, Law Clerk

Atomic Safety and Licensing Board Panel
U.S. Nuclear Regulatory Commission

Sachin.Desai@nrc.gov | 301-415-6523"

Background:

The U.S. Nuclear Regulatory Commission (NRC) Atomic Safety and Licensing Board Panel (ASLBP) overseeing FirstEnergy Nuclear Operating Company's (FENOC) application proceeding for a 20-year license extension at its problem-plagued Davis-Besse atomic reactor in Oak Harbor, OH on the Lake Erie shore has announced oral argument pre-hearings will be held at NRC HQ in Rockville, Maryland on Wed., Nov. 12th, beginning at 9am Eastern sharp. The hearing will focus on the environmental coalition's latest concrete containment cracking contention, motivated by recent revelations of "ice-wedging crack propagation," despite earlier assurances by FENOC -- backed by NRC staff -- that the already severe cracking could not possibly get worse.

As ordered by the ASLBP, "a listen-only line will be available for members of the public that wish to listen to the proceedings by telephone. Interested members of the public should contact Sachin Desai [at 301-415-6532 or Sachin.Desai@nrc.gov] no later than Monday, November 10, 2014 to receive the listen-only telephone conference number and passcode...Those participating by telephone should be on the line at least five minutes early so as to allow time to work through any technical issues that may arise."

Please see Sachin Desai's detailed call-in instructions, posted above in bold.

Supporters of this environmental intervention are encouraged to phone and listen-in, to show NRC, the ASLBP, and FENOC that people care, and to show support for the intervening groups and their representatives.

If you happen to be in Washington, D.C. at the time (such as for Michael Mariotte of NIRS's Lifetime Achievement Award event on Nov. 10th, and/or the Sierra Club Nuclear-Free Campaign gathering beginning on Nov. 14th), you can also attend this ASLBP proceeding in person:

"The oral argument will be held at the NRC [Headquarters] on November 12, 2014, in the Advisory Committee on Reactor Safeguards Meeting Room 2 (Room #2B1), which is on the second floor of Two White Flint North, 11545 Rockville Pike, Rockville, Maryland 20852...All persons participating in person should arrive at the NRC at least fifteen minutes early so as to allow sufficient time to pass through security screening."

NRC HQ is located immediately across the street from the White Flint Metro Station on the Red Line.

30-minutes ahead of time would be safer, actually, given NRC's strict security and escorting protocols. Be sure to bring a valid photo ID.

The environmental coalition intervening against Davis-Besse's 2017-2037 license extension includes Beyond Nuclear, Citizens Environment Alliance of Southwestern Ontario, Don't Waste Michigan, and the Green Party of Ohio. The coalition is represented by Terry Lodge, an attorney based in Toledo. The coalition launched its intervention nearly four years ago, on December 27, 2010. The coalition has raised numerous concrete containment cracking contentions since the severe -- and now admittedly worsening -- problem was first revealed in late 2011.

Thursday
Oct162014

Environmental coalition filings on Davis-Besse Shield Building cracking issue

The environmental coalition challenging FirstEnergy Nuclear Operating Company's (FENOC) proposed 20-year license extension at the problem-plagued Davis-Besse atomic reactor, near Toledo on the Lake Erie shore, has been challenging Shield Building cracking since January 10, 2012. Below are the coalition's filings thus far, in chronological order, as well as associated coalition press release, FirstEnergy Nuclear Operating Company (FENOC) filings, U.S. Nuclear Regulatory Commission (NRC) staff filings, NRC Atomic Safety and Licensing Board Panel's (ASLBP) orders, etc.:

2011

June 15, 2011: ASLBP's Initial Scheduling Order (“ISO”).

October 10, 2011: "Laminar crack discovered in the shield building access opening during 17M (documented under CR 2011-03346)" (as put by Performance Improvement International in its 9/11/13 Full Apparent Cause Evaluation on ice-wedging crack propagation, not released by FENOC until ten months later, on 7/8/14. See PII FACE, p.26 of 98 on PDF counter. 17M refers to the 17th mid-cycle outage.)

October 31, 2011: Letter from R. Seeholzer, FirstEnergy, to the Investment Community (provided as Attachment 1 to FENOC’s Original Contention 5 Answer).

December 2, 2011: NRC Confirmatory Action Letter (CAL), permitting FENOC to rush the restart of the Davis-Besse reactor, despite the recently discovered cracking of unknown origin, extent, and safety significance (NRC ADAMS ML# ML11336A355).

2012

January 5, 2012: FENOC Presentation Slides, NRC Public Meeting (provided as Attachment 2 to FENOC’s Original Contention 5 Answer).

January 10, 2012Environmental Intervenors' original cracking contention. (Motion for Admission of Contention No. 5 on Shield Building Cracking, 61 pages.)

January 31, 2012: NRC Integrated Inspection Report. 93 pages.

February 6, 2012: FENOC's Answer Opposing Intervenors' Motion for Admission of Contention No. 5 on Shield Building Cracking. 137 pages.

February 13, 2012: Intervenors' Combined Reply in Support of Motion for Admission of Contention No. 5. 110 pages. (Associated February 14, 2012 coalition press release)

February 27, 2012: Filing (Intervenors' first Motion to Amend 'Motion for Admission of Contention No. 5') based on U.S. Rep. Kucinich's (D-OH) revelation that the shield building's outer rebar layer was no longer structurally functional, due to the cracking. First contention supplement/amendment. (Associated coalition media release.)

February 27, 2012: Letter from B. Allen, Vice President-Nuclear, FENOC, to C. Pederson, Acting Administrator, NRC, Submittal of Shield Building Root Cause Evaluation (submitted as an enclosure to Letter from T. Matthews, FENOC Counsel, to Board, Notification of Filing Related to Proposed Shield Building Cracking
Contention (Feb. 29, 2012).

April 5, 2012: Letter from D. Imlay, FENOC, to NRC, Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application (TAC No. ME4640) and License Renewal Application Amendment No. 25, Attachment L-12-028 (provided as an enclosure to the Board Notification for April 2012 RAI Response); Letter from T. Matthews, FENOC Counsel, to the Board, Notification of Filing Related to Proposed Shield Building Cracking Contention

May 7, 2012: Davis-Besse Nuclear Power Station Reactor Vessel Head Replacement and Shield Building Cracking Inspection Report 05000346/2012007 (DRS) (provided as an enclosure to Letter from B. Harris, Staff Counsel, to Board (May 10, 2012)).

May 17, 2012: Revised Root Cause Evaluation (dated May 8, but not submitted till May 17, as an enclosure to Letter from T. Matthews, FENOC Counsel, to Board, Notification of Filing Related to Proposed Shield Building Cracking Contention), 131 pages. (In its September 11, 2013 Full Apparent Cause Evaluation (see below) -- not released by FENOC until July 8, 2014 -- PII refers to this document as RCA-1, Performance Improvement International Laminar Cracking Root Cause (Davis-Besse Condition Report 2011-03346)).

May 24, 2012: FENOC Davis-Besse nuclear power station, Unit 1, Submittal of Contractor Root Cause Assessment Report, Revised Root Cause Assessment Report, or RRCAR, from B.S. Allen, FirstEnergy Nuclear Operating Company, to Cynthia D. Pedersen, NRC, NRC/RGN-III/ORA, L-12-196, NRC ADAMS Accession No. ML12138A037, 257 pages. (Per immediately above, in its September 11, 2013 Full Apparent Cause Evaluation (see below) -- not released by FENOC until July 8, 2014 -- PII refers to this document as RCA-1, Performance Improvement International Laminar Cracking Root Cause (Davis-Besse Condition Report 2011-03346)).

June 4, 2012: Filing, (Intervenors' second Motion to Amend and Supplement Proposed Contention No. 5 (Shield Building Cracking)) in response to FENOC's woefully inadequate Aging Management Plan (AMP) for the shield building's cracks. Second contention supplement/amendment.

June 21, 2012: NRC Inspection to Evaluate the Root Cause Evaluation and Corrective Actions for Cracking in the Reinforced Concrete Shield Building of the Containment System 05000346/2012009(DRS). See page 3 of Attachment 2 (Page 35 of 46 on PDF counter) for a photo showing how severe the subsurface laminar cracking discovered on Oct. 10, 2011 actually was.

June 29, 2012: FENOC’s Answer Opposing Intervenors’ Motion to Amend and Supplement Proposed Contention No. 5 (Shield Building Cracking).

July 16, 2012: Filing (Intervenors' Third Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking)), in response to FENOC's revised root cause analysis report, which revealed that shield building cracking was first observed not in October 2011, but rather August 1976. Third contention supplement/amendment.

July 23, 2012: Filing (Intervenors' Fourth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking)), based on revelations in FENOC contractor Performance Improvement International's revised root cause assessment report, which revealed 27 areas of skeptical NRC questioning about FENOC's "Blizzard of 1978" theory of shield building cracking (the environmental Intervenors also posted documents supportive of this fourth contention supplement/amendment). NRC ADAMS Accession No. ML12205A507, 56 pages.

August 16, 2012: Contention supplement (Intervenors' Fifth Motion to Amend and/or Supplement Proposed Contention No. 5 (Shield Building Cracking)), on the severe shield building cracking, which cites U.S. Nuclear Regulatory Commission (NRC) documents revealed through a Freedom of Information Act (FOIA) request submitted by Beyond Nuclear. The coalition issued a media release about this contention supplementation.

August 2012: Beyond Nuclear prepared a report, entitled "What Humpty Dumpty Doesn't Want You to Know: Davis-Besse's Cracked Containment Snow Job," which summarized the coalition's work in 2012 on Davis-Besse's dangerously degraded condition, focused on the Shield Building cracking.
August 22, 2012: Licensing Board Notice (Advising Parties of Amendments to 10 C.F.R. Part 2; unpublished).
2012: ASLBP Order to hold oral argument pre-hearings in Toledo on Monday, November 5 and Tuesday, November 6 [Election Day].
November 5 and 6 [Election Day], 2012: Oral argument pre-hearings in Toledo before ASLBP (transcripts).
November 20, 2012: Letter from T. Matthews, FENOC Counsel, to the Board, Notification of Filing Related to Shield Building Laminar Cracking: Letter from D. Imlay, FENOC, to NRC, Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application (TAC No. ME4640) and License Renewal Application Amendment No. 36, Attachment L-12-418 (provided as an enclosure to the Board Notification for November 2012 RAI Response).

2013

The environmental coalition (Beyond Nuclear, Citizens Environment Alliance of Southwestern Ontario, Don't Waste Michigan, and Sierra Club Ohio Chapter) intervention against Davis-Besse's steam generator replacement project included concerns about damage to the Shield Building. Arnie Gundersen, Chief Engineer of Fairewinds Associates, Inc., served as the coalition's expert witness. (Multiple filings) 

See also:

September 3, 2013: NRC Safety Evaluation Report [SER] Related to the License Renewal of Davis-Besse Nuclear Power Station, available at ADAMS Accession No. ML13248A267. 895 pages. See particularly Section 3.0.3.3.9. NRC states in its April 15, 2014 RAI (see below): "Following review of the Shield Building Monitoring Program, responses to several rounds of follow-up Requests for Additional Information (RAIs), and an updated Shield Building Monitoring Program, the NRC staff found the Updated Shield Building Monitoring Program to be acceptable, as documented in Section 3.0.3.3.9. [of this SER]."

September 11, 2013: RCA-2, Performance Improvement International Laminar Crack Propagation Root Cause (Davis-Besse Condition Report 2013-14097). See Enclosure 2, beginning at page 17 of 98, of FENOC's July 8, 2014 (see below) letter to the ASLBP. Note that FENOC withheld this PII report for 10 months, despite its significance.

September 20, 2013: Preliminary Notification -- [NRC] Region III, Preliminary Notification of Event or Unusual Occurrence, PNO-III-13-007, Davis-Besse Shield Building Laminar Cracks, NRC ADAMS ML# ML13263A410, 2 pages.

November 1, 2013: Davis-Besse Nuclear Power Station NRC Integrated Inspection Report 05000346/20130004, available at ADAMS Accession No. ML13308A283. (Excerpts from the November 2013 NRC Inspection Report were provided as Attachment 2 to FENOC’s Answer to Contention 6.)

2014 
April 22, 2014 (Earth Day, 3 years to the day before Davis-Besse's original 40-year license expires): The coalition issued a press release.

ASLB filing:

MOTION FOR ADMISSION OF CONTENTION NO. 6 ON SHIELD BUILDING CONCRETE VOID, CRACKING AND BROKEN REBAR PROBLEMS

Exhibits: #1, NRC Preliminary Notice of Event or Occurrence (Feb. 19, 2014); #2, Toledo Blade article, “Davis-Besse Had Air Gap in Shield Building,” (Feb. 15, 2014); #3, Declaration of Victoria Clemons (April 14, 2014); #4, Minutes of Internal Meeting of Davis-Besse Oversight Panel (Oct. 18, 2001); #5, Minutes of Internal Meeting of Davis-Besse Oversight Panel (Oct. 29, 2002); #6, NRC Preliminary Notice of Event or Occurrence (Sept. 20, 2013); #7, NRC Request for Additional Information (April 15, 2014); #8, Expert Witness Report of Arnold Gundersen, 50-246-LA (2013).

DEIS comments:

1. Amory Lovins' "Nuclear power’s competitive landscape and climate opportunity cost," March 28, 2014 (TMI+35), Dartmouth College, NH

Amory Lovins on uncompetitiveness of old atomic reactors. At page 5 Lovin’s writes: "Reactors are promoted as costly to build but cheap to run. Yet as Daniel Allegretti ably described, many existing, long-paid-for U.S. reactors are now starting to be shut down because just their operating cost can no longer compete with wholesale power prices, typically depressed by gas-fired plants or windpower."

2. PJM Interconnect: 30% grid integration of renewables not a problem.

In fact, it was well known to PJM (Pennsylvania/Jersey/Maryland) Interconnect, covering 13 states and this nation's largest single electric grid, as published in this 2010 2010 ISO/RTO Metrics Report, posted at the website of the U.S. Federal Energy Regulatory Commission, that wind power and solar PV are available in abundance and that there is no disruption or destabilizing of "baseload grid" associated with their integration. Replacement power was available in 2010, and is available now, and certainly in 2017.

On Dec. 27, 2010, the environmental coalition -- with University of Toledo professor emeritus Al Compaan as its expert witness -- contended that wind and solar PV, combined with compressed air energy storage, could easily replace Davis-Besse's 908 megawatts of electricity during the 2017-2037 period. In 2011, the ASLB agreed to hear the contention. But on March 27, 2012, the five-member NRC Commission, responding to an appeal by FENOC, unanimously overruled the ASLB, rejecting the renewables-as-alternative-to-license-extension hearing. Interveners reassert their contention and call for the NRC Commissioners' order to be reversed, because they are simply wrong. The coalition reserves the right to appeal the rejection of its renewables contention to federal court, once the ASLB proceeding has concluded.

3. Beyond Nuclear's Radioactive Waste Watchdog, Kevin Kamps, also submitted five comments to NRC: #1, Jan. 10, 2012 SB cracking contention's relevance to DEIS; #2, four 2012 cracking contention supplements' (Feb. 27; June 4; July 16; July 23) relevance to DEIS; #3, fifth cracking contention supplement's (Aug. 16, 2012) relevance to DEIS; #4, Dec., 2010 backgrounder, "Davis-Besse Atomic Reactor: 20 MORE Years of Radioactive Russian Roulette on the Great Lakes Shore?!"; #5, Aug. 2012 SB summary report, "What Humpty Dumpty Doesn't Want You to Know: Davis-Besse's Cracked Concrete Containment Snow Job". 

4. Joe DeMare's comments. Joe is a local resident near Davis-Besse. He is also an official intervener, as part of the environmental coalition, against the license extension. Joe is affiliated with the Ohio Green Party.

May 16, 2014: FENOC’s Answer Opposing Intervenors’ Motion for Admission of Contention No. 6.

May 16, 2014: NRC Staff’s Answer to Motion for Admission of Contention No. 6 on Shield Building Concrete Void, Cracking and Broken Rebar Problems.

May 23, 2014: Intervenors’ Reply in Support of Motion for Admission of Contention No. 6 on Shield Building Concrete Void, Cracking and Broken Rebar Problems.

July 3, 2014: FENOC filing "L-14-224," including: cover letter; Attachment L-14-224, "Reply to Requests for Additional Information for the Review of [LRA] Section B.2.42"; and Enclosure, Amendment No. 51 to the D-B LRA. NRC ADAMS ML# ML14184B184, 14 pages.

July 8, 2014: FENOC filing, "Notification of Documents Related to Davis-Besse Shield Building," including: Enclosure 1 (identical to July 3, 2014 post immediately above); and Enclosure 2, "Full Apparent Cause Evaluation, Shield Building Laminar Crack Propagation." NRC ADAMS Accession No. ML14189A452, 98 pages.

July 25, 2014: ASLB Memorandum and Order (Denying Intervenors' Motion for Admission of Contention No. 6 on Shield Building Concrete Void, Cracking and Broken Rebar Problems). 19 pages.

September 29, 2014: Letter from E. Sayoc, NRC, to R. Lieb, FENOC, Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station License Renewal Application (TAC No. ME4640), available at ADAMS Accession No. ML14258A285 (requesting supplemental information regarding 2013 Shield Building operating experience).
NRC's posted schedule for Davis-Besse's License Renewal Application (LRA) proceeding shows that there are few hurdles left before NRC rubberstamps the 20-year extension. Davis-Besse's current, initial 40-year operating license expires on April 22 (Earth Day), 2017. The environmental Intervenors' filed a request for hearings and petitioned to intervene against the license extension by NRC's original deadline of December 27, 2010.
October 27, 2014: ASLBP NOTICE AND ORDER (Scheduling Oral Argument) [for November 12, 2014, as well as specifying subject areas of enquiry parties should be ready to discuss]