captured regulator, corrosion, embrittlement, hydrogen attack, lying with statistics, methodological assumptions, NRC, nrc embrittlement, nuclear dangers, nuclear reactor, nuclear reactor pressure vessel, nuclear reactors, nuclear safety, NUREG, Pressurized Thermal Shock, PTS, PWR, reactor pressure vessel, statistics, US NRC
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In the April 18, 2013 US NRC “Summary of the March 19, 2013 Public Meeting Webinar Regarding Palisades Nuclear Plant” one finds brazen legalese statements by the US NRC in order to defend one of Entergy’s aging reactors, Palisades (Note that the NRC also had lawyer(s) working on the corporate side pushing the judge to ignore current concerns at Davis Besse Nuclear Power Station too. Davis Besse and Palisades endanger the largest surface fresh water system on earth.) The NRC inadvertently points out that, most likely, no US nuclear reactor has the more resistant materials required for safety starting in 1977.
Someone asked the NRC:
“Which are the other most embrittled plants in the U.S.? How many PWRs will reach their screening criteria in the next 10 years?”
The NRC responded:
“The NRC currently estimates that the following plants will exceed the PTS screening criteria of 10 CFR 50.61 during their 20-year period of operation beyond their original 40 year licenses. Updated fluence calculations, capacity factors changes, power uprate, new surveillance data, and improved material property information (i.e., the use of direct rather than correlative measurements of the vessel material’s resistance to fracture) can change these estimates…
1. Point Beach 2 (2017)
2. Palisades (2017)
3. Diablo Canyon 1 (2033)
4. Indian Point 3 (2025)
5. Beaver Valley 1 (2033)”
(It’s not clear if these years are the license expiration dates, or when they are estimated as in most danger of reactor pressure vessel fractures, minus uprates etc, which increase stress and put them at risk more quickly. PTS is Pressurized Thermal Shock. Point Beach is also on the Great Lakes (Lake Michigan, as is Palisades)
According to the NRC, Entergy-Palisades didn’t violate standards because there weren’t any! “Palisades did not violate the NRC’s PTS safety standards in 1981 since the NRC did not have any regulations pertaining to PTS until June 26, 1984.”
The NRC inadvertently explains that US Reactors are not up to even 1977 standards:
“For new plants, the reactor vessel beltline materials should have the content of residual elements such as copper, phosphorus, sulfur, and vanadium controlled to low levels. The levels should be such that the predicted adjusted reference temperature at the ¼ T position in the vessel wall at end of life is less than 200 °F. [These] recommendations … will be issued in evaluating construction permits docketed on or after June 1, 1977.” http://pbadupws.nrc.gov/docs/ML1310/ML13108A336.pdf
“There has been no ground-breaking on new nuclear plants in the United States since 1974. Up until 2013, there had also been no ground-breaking on new nuclear reactors at existing power plants since 1977.” http://en.wikipedia.org/wiki/Nuclear_power_in_the_United_States
Since permitting would normally come before ground-breaking this appears to mean that no nuclear reactors currently in operation are up to the 1977 standards for prevention of embrittlement. 1977 was 37-38 years ago. Jimmy Carter was President and the Cold War was far from over. Apple home computers weighed 11.5 pounds excluding the screen, which probably weighed almost as much. Apple Ipad air weighs less than one pound.
The NRC further states:
“In conclusion, there was no violation of NRC requirements concerning PTS at Palisades. Had Palisades ever violated PTS requirements the NRC would have shut down the plant.
Regulatory Guides do not contain requirements, only recommendations.” http://pbadupws.nrc.gov/docs/ML1310/ML13108A336.pdf
So, since the “Regulatory Guides only contain recommendations”, anything goes? What’s the NRC for then? Making the US tax-payer pay for lawyers and staff to protect the interests of the nuclear power industry? Safety doesn’t matter? Regulations are supposed to be laws. Aren’t they?
Where did concern about the US budget go anyway? A good place to start cuts is the US NRC, which has long been called an instance of regulatory capture. They don’t look captured to us, but rather leading the charge! Contrary to the opinion of certain French journalists who were recently enraged because the US wants France to pay them for future help in French invasions of Africa, the US taxpayer isn’t supposed to be a money tree for industry and the world. The French journalist said that the cost was a drop in the bucket of the US Defense budget, pointing to how spoiled and ungrateful France has been since World War II.
“My question is, didn’t Palisades first violate NRC’s PTS safety standards 10 short years into its operation, by 1981? This was documented in the following document: July 8, 1983: “Pressurized Thermal Shock Potential at Palisades: History of Embrittlement of Reactor Pressure Vessels in Pressurized Water Reactors,” prepared by Michael J. Keegan, Coalition for a Nuclear Free Great Lakes, Monroe, Michigan (re-published August 3, 2005).
In the referenced 1983 document by M. Keegan (Coalition for a Nuclear Free Great Lakes) it is stated that:
“Embrittlement at Palisades in 1981 was reported to occur at temperatures of between 190 and 220 degrees F. As noted earlier the NRC had originally set reference temperature for nil ductility transition (RTNDT) at 200 degrees F. As early as 1981 Palisades had exceeded these original RTNDT limits.”
Note: The RTNDT term refers to a metric that the NRC uses to quantitatively assess brittleness and can roughly be described as the temperature below which the material transitions from ductile to brittle behavior.
These statements are not accurate in several respects. First and foremost, Palisades did not violate the NRC’s PTS safety standards in 1981 since the NRC did not have any regulations pertaining to PTS until June 26, 1984, when 10 CFR 50.61 was first promulgated. The RTNDT limit of 200 °F incorrectly attributed to PTS in the article appeared in Regulatory Guide 1.99 “Radiation Embrittlement of Reactor Vessel Materials”, Revision 1, which was adopted in 1977. This document states:
“For new plants, the reactor vessel beltline materials should have the content of residual elements such as copper, phosphorus, sulfur, and vanadium controlled to low levels. The levels should be such that the predicted adjusted reference temperature at the ¼ T position in the vessel wall at end of life is less than 200 °F. [These] recommendations … will be issued in evaluating construction permits docketed on or after June 1, 1977.”
Regulatory Guides do not contain requirements, only recommendations. This recommendation amounted to good practice guidance that new plants should limit copper content in their reactor vessels which, by 1977, was known to promote embrittlement. In any event, this recommendation did not apply to the Palisades plant which received its construction permit on March 14, 1967.
In conclusion, there was no violation of NRC requirements concerning PTS at Palisades. Had Palisades ever violated PTS requirements the NRC would have shut down the plant. The plant is operating safely in compliance with 10 CFR 50.61.” http://pbadupws.nrc.gov/docs/ML1310/ML13108A336.pdf
NOT ONLY DO NEUTRONS CAUSE EMBRITTLEMENT, WHICH CAN LEAD TO REACTOR PRESSURE VESSEL FAILURE, HYDROGEN ATTACK CAN ALSO LEAD TO REACTOR PRESSURE VESSEL FAILURE, AS CAN CORROSION. THEY ALL WORK TOGETHER TO WEAKEN THE NUCLEAR REACTOR PRESSURE VESSEL. THEY MUST BE EVALUATED TOGETHER. EFFECTS WOULD BE SYNERGISTIC. THESE FAILURES CAN OCCUR AT ANY TIME IN BWR OR PWR THEY ARE JUST MORE LIKELY TO OCCUR IN PRESSURIZED REACTORS (PWR). THEY ARE ALSO MORE LIKELY TO OCCUR DUE TO THERMAL SHOCK BUT COULD FAIL WITHOUT IT.
Palisades is on Lake Michigan. About the Great Lakes here:
“The Great Lakes are the largest surface freshwater system on the Earth. Only the polar ice caps contain more fresh water.” They contain “84% of North America’s surface fresh water about 21% of the world’s supply of surface fresh water…. The Great Lakes Basin encompasses large parts of two nations, the United States and Canada. Nearly 25% of Canadian agricultural production and 7% of American farm production. Population is more than 30 million people – roughly 10% of the U.S. population and more than 30% of the Canadian population” Read more: http://www.epa.gov/greatlakes/basicinfo.html
Those with good memories may recall that we posted this a little over one month ago. We reposted it to help with comments.