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Five years ago, Southern Nuclear Operating Company identified a key atomic reactor safety risk: the potential for hydrogen generated from an atomic reactor meltdown to seriously damage the containment of the AP1000 atomic reactor at Vogtle Units 3 and 4. In a letter to the NRC, the Company states: “Design reviews in 2011 identified a credible scenario in which the applicable plant damage state meets the core damage frequency cutoff to be considered as part of the severe accident analysis”The AP1000 containment is already within 1 pound per square inch of its design limit without considering the additional pressure that would be created by either a detonation or deflagration shock wave if one of the proposed igniters causes backflow into a sub-compartment“. (BREDL Request for Hearing, May 2016)
Fukushima Daiichi Nuclear Power Station,  Reactors 1 to 4 from right to left.16 March 2011, 09:35 AM (local time)  CC BY-SA 3.0  by Digital Globe
Fukushima Daiichi Nuclear Power Station, Reactors 1 to 4 from right to left.16 March 2011, 09:35 AM (local time) CC BY-SA 3.0 by Digital GlobeHydrogen-air explosions occurred in Unit 1, 3 and 4, causing structural damage. A vent in Unit 2’s wall, with water vapor/”steam” clearly visible, prevented a similar large explosion.https://en.wikipedia.org/wiki/Fukushima_Daiichi_nuclear_disaster

A Nuclear Regulatory Commission Atomic Safety and Licensing Board will hold a teleconference Wed., Aug. 3, to hear oral arguments on a hearing request regarding a license amendment request for two new reactors at the Vogtle site in Georgia… The contentions challenge Southern Nuclear’s request to amend details of the Vogtle new reactor licenses regarding safety features called hydrogen igniters.” http://www.nrc.gov/docs/ML1601/ML16011A522.pdf

ND-15-0280 Enclosure 1 Request for License Amendment: Containment Hydrogen Igniter Changes (LAR-15-003) http://www.nrc.gov/docs/ML1503/ML15037A715.pdf http://www.nrc.gov/docs/ML1503/ML15037A715.pdf

From BREDL’s petition to intervene regarding hydrogen igniters for Toshiba (Westinghouse) AP 1000, proposed for Vogtle Nuclear Power Station:
First, the LAR assumes concentration of hydrogen is uniform throughout the AP1000 containment, including in sub-compartments. From a chemical standpoint, hydrogen has been known to stratify, meaning that it forms in strata or layers. These layers then can explode when too much hydrogen has formed in one area near an igniter.

Such stratification would cause the very explosion the Westinghouse & Southern Company proposed igniters are being supplied to prevent.

Second, the Company hypothesizes that the only source of hydrogen is emitted from the reaction between zirconium and water. This reaction only produces hydrogen, which is not combustible unless it is diluted by oxygen.

Third, other sources of hydrogen production are ignored, which can produce hydrogen and oxygen in a stoichiometric ratio, causing an explosion simply from being in proximity to the proposed hydrogen igniters.

Fourth, radiolytic decomposition of water has been ignored as a source of both hydrogen and oxygen, and concrete degradation from contact with corium creates both hydrogen and oxygen, called the Molten Core Concrete Interaction (MCCI)

Finally, SNOC’s analysis ignores the possibility that the igniter can create a flame that blows back through the In-containment Refueling Water Storage Tank (IRWST) roof vents along the steam generator dog house wall into the sub-compartment causing a serious detonation. According to the World Association of Nuclear Operators (WANO), backflow did occur at Fukushima” (Louis A. Zeller, Executive Director Blue Ridge Environmental Defense League, pp. 11-12, Emphasis our own; excerpts in context below; original here: http://www.nrc.gov/docs/ML1612/ML16124B062.pdf)

The text is excerpted from:
In the Matter of: SOUTHERN NUCLEAR OPERATING CO. License Amendment Application for Combined Licenses NPF-91 and NPF-92 Vogtle Electric Generating Plant Units 3 and 4 Docket Nos. 052-00025 and 052-00026; NRC-2008-0252-0057, May 2, 2016,PETITION FOR LEAVE TO INTERVENE AND REQUEST FOR HEARING BY THE BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE AND ITS CHAPTER CONCERNED CITIZENS OF SHELL BLUFF REGARDING SOUTHERN NUCLEAR OPERATING COMPANY’S REQUEST FOR A LICENSE AMENDMENT AND EXEMPTION FOR CONTAINMENT HYDROGEN IGNITER CHANGES, LAR-15-003“:

p. 2: “Description of the Proceeding

On February 9, 2012, the Nuclear Regulatory Commission approved Southern Nuclear Operating Company’s application for a license to construct and operate two additional Westinghouse AP1000 reactor units at Plant Vogtle, located on the banks of the Savannah River in Shell Bluff, Georgia. Vogtle Electric Generating Plant Units 3 and 4 are now under construction (“Vogtle Units 3 and 4”). On February 6, 2015, the Company summited a request seeking a license amendment and exemption related to the installation of hydrogen igniters within the reactor containment structure at Vogtle Units 3 and 4. (1) The Company’s license amendment request proposes to modify the design of the hydrogen ignition system by adding two igniters to be positioned at the roof vents of the In-Containment Refueling Storage Tank. Other changes requested would change the design of the hydrogen igniters and alter their control systems.
[…]
p. 6: “Background

Under Title 10 CFR Part 52, all nuclear power plant construction must be in accord with the plant’s design and current licensing basis (CLB) as well as the applicable statutes and regulations. The process for modifying the CLB is set forth in 10 CFR 52.98(f).3 A licensee that requests an amendment or exemption must perform 1) an applicability determination evaluation, 2) a safety-security interface evaluation, 3) a construction impacts evaluation and 4) a 10 CFR 50.59-like screening evaluation. See COL-ISG-025. If upon completion of its review the NRC finds that there would be unacceptable incompatibilities, it may condition its approval of the LAR upon the licensee making adjustments to the existing design and licensing basis. See Entergy Nuclear Vermont Yankee, L.L.C. and Entergy Nuclear Operations, Inc. (Vermont Yankee Nuclear Power Station), LBP-04-28, 60 NRC 548, 565 (2004).

Overview of the Contentions to be Raised in this Petition

Five years ago, Southern Nuclear Operating Company identified a key atomic reactor safety risk: the potential for hydrogen generated from an atomic reactor meltdown to seriously damage the containment of the AP1000 atomic reactor at Vogtle Units 3 and 4. In a letter to the NRC, the Company states:

Design reviews in 2011 identified a credible scenario in which the applicable plant damage state meets the core damage frequency cutoff to be considered as part of the severe accident analysis. (4)

3 §52.98(f): Any modification to, addition to, or deletion from the terms and conditions of a combined license, including any modification to, addition to, or deletion from the inspections, tests, analyses, or related acceptance criteria contained in the license is a proposed amendment to the license. There must be an opportunity for a hearing on the amendment.
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[Footnote] 4 Southern Company Letter, February 6, 2015, Request for a License Amendment and Exemption: Containment Hydrogen Igniter Changes (LAR-15-003), page 4 of 19″

p. 7:
This plant damage risk was identified by the Company well before the Vogtle COL license was issued in 2012. Unaccountably, four more years elapsed before the company informed NRC of this risk to the Unit 3 and 4 reactors; presently, this selfsame risk is the subject of License Amendment Request LAR-15-003.

On February 9, 2012, the day the license for Vogtle Units 3 and 4 were approved, the chairman of the NRC stated, “[U]ltimately, my responsibility is to make what I believe is the best decision for nuclear safety. I simply cannot authorize issuance of these licenses without any binding obligation that these plants will have implemented the lessons learned from the Fukushima accident before they operate.” See CLI-12-02, Chairman Gregory B. Jaczko, Dissenting at 1. (emphasis added)

The Petitioners hereby seek to raise two contentions centered on the hydrogen ignition problem raised by SNOC: 1) the danger presented by the poorly conceived modifications posed by the LAR, and 2) the failure of the NRC to properly incorporate the experience gained from previous hydrogen explosions in its license for Vogtle.

Petitioner’s requests for leave to intervene and a hearing are supported by an affidavit submitted on behalf of the Petitioner by Arnold Gundersen (“Gundersen Declaration”) (Attachment A).

Based on our review, the license amendment request has not been fully evaluated by the NRC and is not justified by the information presented by the Company.

CONTENTION ONE: The proposed modification by The Southern Company creates an extremely dangerous situation rather than mitigating it.
(i) Specific issue of law or fact to be raised

p. 8:
New nuclear power plant construction must be conducted in accordance with the combined license (COL) current licensing basis (CLB) (5), the Atomic Energy Act, and the applicable regulations. The change process for the COL is set forth in 10 CFR 52.98.

(ii) Brief explanation of contention

Relying on its engineering judgement instead of rigorous testing and analysis would result in an unanalyzed condition that significantly compromises plant safety.

Instead of protecting against the threat of a hydrogen buildup and subsequent explosion, the proposed solution introduces a new threat to the already vulnerable AP1000 containment by placing Vogtle Units 3 and 4 hydrogen igniters possibly near the location of excess concentrations of hydrogen. Good engineering practice includes the axioms “extrapolate existing data into unknown regions with extreme caution” and “when possible, always test in the real world.” (6)

(iii) Contention is within the scope of the proceeding

Pursuant to 10 CFR 52.98, the NRC is responsible for approval of any modification, addition or deletion from the license (CLB). The LAR involves a change to the COL, Appendix C, and departures from plant-specific Tier 1 information, tests, analyses and acceptance criteria (ITAAC).
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[Footnote]
5 As defined in 10 CFR 54.3 – CLB is the set of NRC requirements applicable to a specific plant and a licensee’s written commitments for ensuring compliance with and operation within applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and in effect. The CLB includes the NRC regulations contained in 10 CFR Parts 2, 19, 20, 21, 26, 30, 40, 50, 51, 52, 54, 55, 70, 72, 73, 100 and appendices thereto; orders; license conditions; exemptions; and technical specifications. It also includes the plant-specific design-basis information defined in 10 CFR 50.2 as documented in the most recent final safety analysis report as required by 10 CFR 50.71 and the licensee’s commitments remaining in effect that were docketed licensing correspondence such as licensee responses to NRC bulletins, generic letters, and enforcement actions, as well as licensee commitments documented in NRC safety evaluations or licensee event reports.
6 Seven Axioms of Good Engineering: Development of A Case Study-Based Course for NASA, Roger C. Forsgren NASA Academy of Program/Project & Engineering Leadership (APPEL) http://appel.nasa.gov/wp-content/uploads/sites/2/2014/06/SAGE-Paper.pdf

p. 9:
(iv) Issues raised are material to the findings NRC must make

One necessary component of NRC review of a license amendment application is review of the proposed amendment’s compatibility with the licensee’s existing design and licensing basis. If the NRC finds that there would be unacceptable incompatibilities, it may condition its approval of the amendment upon the licensee making necessary adjustments to the existing design and licensing basis to resolve these incompatibilities. Entergy Nuclear Vermont Yankee, L.L.C. and Entergy Nuclear Operations, Inc. (Vermont Yankee Nuclear Power Station), LBP-04-28, 60 NRC 548, 565 (2004).

(v) Expert opinion supporting Petitioner’s contention

Experience in Japan is illustrative of the unanticipated problems that have been created by the LAR placing hydrogen igniters near a source of hydrogen based simply on “engineering judgment” and not a root cause analysis determination. On September 17, 2013, the Japan Nuclear Energy Safety Organization (JNES) made a presentation to the International Atomic Energy Agency (IAEA) (7) to inform it that at Fukushima Daiichi Unit 1, the deflagration shockwave that occurred was created by a hydrogen explosion due to a spark on the refueling level (top floor) of Unit 1. 400 kilograms of hydrogen leaked from the containment, not just at the top but from the sides and bottom as well and migrated upward. The deflagration shock wave developed horizontally. However, at Fukushima Daiichi Unit 3, an entirely different explosion progression occurred. Even though hydrogen is lighter than air and Unit 3 had similar leakage paths to those at Unit 1, the detonation shockwave that occurred was due to 1000 kilograms of hydrogen that remained in the basement for unknown reasons and did not flow upward to the refueling
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[Footnote] 7 Severe Accident Analyses of Fukushima-Daiich Units 1 to 3, Harutaka Hoshi and Masashi Hirano, Japan Nuclear Energy Safety Organization (JNES), September 17, 2012, http://www.aec.go.jp/jicst/NC/sitemap/pdf/P-4.pdf
(p.9)

p. 10:
floor. The detonation shock wave developed vertically, and was much more forceful than the deflagration shockwave on the top floor. Gundersen Declaration, Section 16.

The AP1000 containment is already within 1 pound per square inch of its design limit without considering the additional pressure that would be created by either a detonation or deflagration shock wave if one of the proposed igniters causes backflow into a sub-compartment. Gundersen Declaration, Section 22. Gundersen concludes: “If the NRC allows the proposed poorly designed hydrogen igniter modification to be implemented at Vogtle Units 3 and 4, a gross containment failure from a detonation shock wave in a sub-compartment is likely to occur.” Gundersen Declaration, Section 26.

(vi) Information showing a genuine dispute with licensee

The Company has not done the prudent and required evaluations: 1) an applicability determination evaluation, 2) a safety-security interface evaluation, 3) a construction impacts evaluation and 4) a 10 CFR 50.59-like screening evaluation. Rather, it has relied on its engineering judgement.

CONTENTION TWO: The engineering and support of the proposed modification fails to evaluate historical precedents of hydrogen explosions as a significant contributor to atomic reactor risk.

(i) Specific issue of law or fact to be raised

New nuclear power plant construction must be conducted in accordance with the combined license (COL) current licensing basis (CLB), the Atomic Energy Act, and the applicable regulations. The change process for the COL is set forth in 10 CFR 52.98.

p. 11:
(ii) Brief explanation of the contention

Rather than performing a rigorous gaseous diffusion and flame propagation analysis, the Company chose to place two hydrogen igniters in a “likely area” by relying upon the personal “engineering judgment” of its engineers. A much more rigorous analysis is warranted.

(iii) Contention is within the scope of the proceeding

Pursuant to 10 CFR 52.98, the NRC is responsible for approval of any modification, addition or deletion from the license (CLB). The LAR involves a change to the COL, Appendix C, and departures from plant-specific Tier 1 information, tests, analyses and acceptance criteria (ITAAC).

(iv) Issue is material to the findings NRC must make

One necessary component of NRC review of a license amendment application is review of the proposed amendment’s compatibility with the licensee’s existing design and licensing basis. If the NRC finds that there would be unacceptable incompatibilities, it may condition its approval of the amendment upon the licensee making necessary adjustments to the existing design and licensing basis to resolve these incompatibilities. Entergy Nuclear Vermont Yankee, L.L.C. and Entergy Nuclear Operations, Inc. (Vermont Yankee Nuclear Power Station), LBP-04-28, 60 NRC 548, 565 (2004).

(v) Expert opinion supporting Petitioner’s contention

First, the LAR assumes concentration of hydrogen is uniform throughout the AP1000 containment, including in sub-compartments. From a chemical standpoint, hydrogen has been known to stratify, meaning that it forms in strata or layers. These layers then can explode when too much hydrogen has formed in one area near an igniter.

p. 12:
Such stratification would cause the very explosion the Westinghouse & Southern Company proposed igniters are being supplied to prevent.

Second, the Company hypothesizes that the only source of hydrogen is emitted from the reaction between zirconium and water. This reaction only produces hydrogen, which is not combustible unless it is diluted by oxygen. (8)

Third, other sources of hydrogen production are ignored, which can produce hydrogen and oxygen in a stoichiometric ratio, causing an explosion simply from being in proximity to the proposed hydrogen igniters.

Fourth, radiolytic decomposition of water has been ignored as a source of both hydrogen and oxygen, (9) and concrete degradation from contact with corium creates both hydrogen and oxygen, called the Molten Core Concrete Interaction (MCCI). Gundersen Declaration, Section 14.

Finally, SNOC’s analysis ignores the possibility that the igniter can create a flame that blows back through the In-containment Refueling Water Storage Tank (IRWST) roof vents along the steam generator dog house wall into the sub-compartment causing a serious detonation. According to the World Association of Nuclear Operators (WANO), backflow did occur at Fukushima Daiichi.10 Gundersen Declaration, Section 15.
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[Footnote]
8 For a demonstration of a hydrogen explosion as pure hydrogen is diluted with oxygen, see “Hydrogen buildup at Fukushima? What does it mean & why does it happen?” Fairewinds Energy Education, November 16, 2011, at http://www.fairewinds.org/nuclear-energy-education/hydrogen-buildup-at-fukushima-what-does-it-mean-why-does-it-happen?rq=hydrogen 9 Radiolytic Decomposition of Coolant Water in Cirus Reactor, D.G.Vartak, L.H.Prabhu, G.C.Shah, C.J.Jose, & M.N.Raval, Reactor Operations Division, BARC http://www.iaea.org/inis/collection/NCLCollectionStore/_Public/05/103/5103331.pdf 10 “Fukushima Accident,” WANO, updated April 2016, http://www.world-nuclear.org/information-library/safety-and-security/safety-of-plants/fukushima-accident.aspx

p. 13
(vi) Information showing a genuine dispute with licensee

Petitioners hereby seek to ensure that the requested license amendment is not issued by the U.S. Nuclear Regulatory Commission. SNOC has not demonstrated full compliance with the Atomic Energy Act and implementing regulations. A licensee generally bears the ultimate burden of proof. Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit 1), ALAB-697, 16 NRC 1265, 1271 (1982), citing 10 C.F.R.
§ 2.325 (formerly § 2.732).

Conclusion

The granting of the Company’s License Amendment Request does not comply with the current licensing basis, the applicable statutes and regulations, or the process for modifying the current licensing basis as set forth in 10 CFR 52.98(f) Vogtle Units 3 and 4. The Nuclear Regulatory Commission cannot approve this license amendment request.

Our principal interests are the health and safety of our members living near the plant and the general public. For the foregoing reasons, the contentions are admissible and should be admitted for a hearing.

Respectfully submitted

Louis A. Zeller, Executive Director Blue Ridge Environmental Defense League” (Emphasis added; See original in its entirety here: http://www.nrc.gov/docs/ML1612/ML16124B062.pdf
(A lot of it has to do with the topic of “standing”. Since officially the US government says that within a 50 mile radius water and agricultural land may be impacted by fallout from a nuclear disaster, that their standing was being questioned is bizarre. The whole concept of “standing” is bizarre because nuclear disasters can have serious impacts more than 1000 miles away. And, what if you have an organic farm 51 miles from the reactor? Or even 60 miles?)

From the US NRC:
No: 16-044 July 27, 2016 Contact: Scott Burnell, 301-415-8200

Atomic Safety and Licensing Board to Hold Oral Argument Aug. 3 on Hearing Request for Vogtle New Reactor Amendment

A Nuclear Regulatory Commission Atomic Safety and Licensing Board will hold a teleconference Wed., Aug. 3, to hear oral arguments on a hearing request regarding a license amendment request for two new reactors at the Vogtle site in Georgia. The board is the independent body within the NRC that conducts adjudicatory hearings and renders decisions on legal challenges to licensing actions.

The Board will hear arguments on contentions filed by the Blue Ridge Environmental Defense League and its chapter, Concerned Citizens of Shell Bluff. The contentions challenge Southern Nuclear’s request to amend details of the Vogtle new reactor licenses regarding safety features called hydrogen igniters.

The teleconference will begin at 9:30 a.m. on Aug. 3, with the Board participating from the ALSB Hearing Room at 11555 Rockville Pike, Rockville, Md. Members of the public and media are welcome to observe the teleconference in person or listen via telephone, but participation will be limited to the parties, lawyers and witnesses. Those interested in attending or listening should contact Cooper Strickland at 301-415-5880 or Cooper.Strickland@nrc.gov by July 29. Those planning to attend should arrive at least 15 minutes early to allow time for security screening. No signs or any type of demonstration will be permitted in the hearing room.

Documents related to the hearing request are available on the NRC’s Electronic Hearing Docket by clicking on the folder entitled “Vogtle 52-025 and 52-026-LA-2” on the left side of the page. More information about the role of the ASLB in the licensing process is available on the NRC website.
http://www.nrc.gov/docs/ML1601/ML16011A522.pdf

Arnie Gunderson declaration: http://www.nrc.gov/docs/ML1612/ML16124B064.pdf

fairewinds Arnie hydrogen expt. 2011 flame
Arnie’s excellent demonstration of the problem: http://www.fairewinds.org/nuclear-energy-education/hydrogen-buildup-at-fukushima-what-does-it-mean-why-does-it-happen?rq=hydrogen (Image from video)

Hydrogen possesses the NFPA 704’s highest rating of 4 on the flammability scale because its elemental form of H2 hydrogen gas risks autoignition when mixed even in small amounts with ordinary air; hydrogen gas and normal air can ignite at as low as 4% air due to the oxygen in the air and the simplicity and chemical properties of the reaction. However, hydrogen has no rating for innate hazard for reactivity or toxicity. The storage and use of hydrogen poses unique challenges due to its ease of leaking as a gaseous fuel, low-energy ignition, wide range of combustible fuel-air mixtures, buoyancy, and its ability to embrittle metalsthat must be accounted for to ensure safe operation. Liquid hydrogen poses additional challenges due to its increased densityand the extremely low temperatures needed to keep it in liquid form.https://en.wikipedia.org/wiki/Hydrogen_safety

Sparks fly as a hydrogen burn-off igniter test is conducted May 5 at the Redstone Test Center on Redstone Arsenal in Huntsville. The igniters will be used for NASA’s Space Launch System to burn off any free hydrogen that can potentially collect at the aft of the rocket about 10 seconds before liftoff.
Image credit: RTC
http://www.nasa.gov/exploration/systems/sls/multimedia/engineers-test-hydrogen-burn-off-igniters-for-space-launch-system.html
Sparks fly as a hydrogen burn-off igniter test NASA