(final version)
March 25, 2014
Mr. Mark A. Satorius
Executive Director for Operations
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001
Dear Mr. Satorius:
SUBJECT: 10 CFR 2.206 Petition requesting emergency ultrasonic inspection
test or best available flaw detection technology for USA reactor plants similar
to the thousands of cracks discovered in Belgium nuclear power plants.
“The discovery of the cracks in the reactors “could be a
problem for the entire global nuclear industry,” says Jan Bens, general director
of the Belgian Federal Agency for Nuclear Control (FANC), speaking on.”
This is a 2.206 on all US nuclear
plants. Please place on all plant dockets especially Vermont Yankee and Kewaunee
Power Station.
I don’t even
think a LOCA in a vessel is even a consideration in plant licensing and this
could be our Fukushima style accident in the USA.
Cracks discovered in the walls of Belgian nuclear reactors are
causing unease among experts. The reason: a previously unknown phenomenon –
material fatigue. There are fears that many more reactors could be affected.
Several thousand
cracks have been discovered by corrosion experts in the pressure vessels of two
reactors at the Belgian nuclear power stations Doel 3 and Tihange 2. Caused by
a previously unknown phenomenon, material fatigue, it is feared the finding
could have implications outside of Belgium.
The discovery of
the cracks in the reactors “could be a problem for the entire global nuclear
industry,” says Jan Bens, general director of the Belgian Federal Agency for
Nuclear Control (FANC), speaking on.
Examination of
nuclear reactors demanded
Of most concern
are the cracks that have been found in the walls of pressure vessels, the part
of reactors where the highly radioactive chain reaction takes place. During
such a process, the vessel is under extreme stress and instability caused by
the cracks could cause a potentially catastrophic release of radioactive
contamination.
It is already known that pressure vessels can
become fatigued as a result of stress caused by pressure, temperature and
radioactive materials. But the Belgian Nuclear Research Center in Mol has only
just found out “that the material is mechanically weakened through radiation
much more than previously thought,” says Heinz Smital, nuclear physicist and
expert at Greenpeace.
Nuclear material corrosion expert Walter
Bogaerts, of Belgium’s University of Leuven says that corrosion factors have
until now been “underestimated”, globally. He adds: “I would be really
surprised if it had not also occurred elsewhere.”
Reactors could be shut down
Digby MacDonald, an expert in corrosion at
the University of California, Berkley, analyzed the cracks together with
Bogaerts and has advised nuclear reactor operators and government regulators
that they should use ultrasound equipment to carefully examine reactors for
cracks. “All reactor operators should be require under the leadership of
regulatory authorities,” says MacDonald. He adds that the results of such
detailed investigations “could be insignificant, or so strong that all the
reactors must be shut down.”
According to
nuclear experts, hydrogen from the reactor can penetrate the reactor wall and
there in the steel increase the interior pressure causing small bubble and
cracks from just a few millimeters in size “up to seven centimeters”, says
Smital.
Using special
ultrasound equipment, experts discovered 13,047 cracks in total in the Belgian
reactor Doel 3 and 3,149 in Tihange 2. The reactors have been shut down, as a
result. Whether they will once again be connected to the network is, as of yet,
unclear.
Danger for the
nuclear industry
The appearance of
the cracks as a result of material fatigue has caused a tide of reaction.
Safety checks are being demanded all over world and “could lead to a wave of
reactor closures”, says Smital.
Greenpeace
successfully sued the Belgian nuclear authority FANC in January following the
publication of the detailed investigative documents. “It's a very delicate
matter and could indeed have a huge impact on the whole nuclear industry,” says
Smital. Greenpeace is demanding that all reactors worldwide are closely
examined.
The German
Environment Ministry has also reacted and is seeking to have immediate contact
with the Belgian authorities to see whether the findings could be applicable to
German reactors.
But according to Greenpeace, the Belgian
findings confirm the growing threat posed by old nuclear power plants. The
world’s reactors now have an average age of 29 years. “That is no longer state-of-the-art, which can be dangerous, even
when you upgrade,” says Smital. “What are now needed are scenarios for a shut
down of plants. Every country needs a get-out plan.””
BWR:
Vermont Yankee (June 1974)
PWR:
Kewaunee Power Station (Nov 1972) (preferred to be first)
Both these
plants are permanently shut down so it won’t disrupt plant operations. An
emergency ultrasonic inspection could occur very quickly based on the plants
permanently shut down status and the Kewaunee plant is similar to the Belgium
PWRs and its age. The nuclear fuel is out of the core and the surroundings
would have lower doses. You could quickly strip off the vessel insulation and
you wouldn't need to replace it for lower doses. You wouldn’t have to
replace the core interior components either?
2) I request
large bore holes samples be cut out of both vessel at the worst place similar
to the “Davis Besse hole in the reactor head” event. Then transport the vessel
specimens to a respected metallurgic laboratory for comprehensive off site
testing.
3) Request
an immediate NRC report and public meeting on the vulnerabilities with US
reactor cracking and these mysterious weakened vessels.
4) If
distressing and unsafe results are discovered at Vermont Yankee or Kewaunee, I
request that within six months all USA plants be ultrasonically tested or
better technology.
5) How has the average concentration of hydrogen in the coolant changed over the recent decades? Would an increasing concentration of hydrogen in the coolant lead to more hydrogen ions getting injected into the vessel iron?
6) Does noble chemistry increase or decrease this kind of corrosion?
7) Are there other chemicals added to the coolant that could make this kind corrosion worst?
8) What are they talking about here:
"However, as Belgian continues to debate the fate of the
reactors, prolonged studies on the steel used in the construction of the
reactors revealed unprecedented embrittlement – unusual swelling – that
can compromise the integrity of the plant and possibly cause ruptures, spewing dangerous radioactive
material equivalent to an
atomic bomb."
9) I understand all US nuclear plants have
coupons and I consider them irrelevant to this problem.
10) Request the NRC coordinate with the Belgian Federal Agency for Nuclear Control (FANC).
11)
Request detailed inspection on the condition of the reactor cladding and a
explanation of any defects.
Sincerely,
Mike Mulligan
Hinsdale NH
1-603-336-8320
steamshovel2002@yahoo.com
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