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 (ASLB) orders, etc.:
January 10, 2012: Original cracking contention.
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 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.)
June 4, 2012: Filing, in response to FENOC's woefully inadequate Aging Management Plan (AMP) for the shield building's cracks. Second contention supplement/amendment.
July 16, 2012: Filing, 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, 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).
August 16, 2012: Contention supplement, 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.
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)
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).
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."
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.
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.
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." 98 pages.