Written by Glenn Carroll, Coordinator of Nuclear Watch South………..
Nuclear Watch South has docketed a Petition for Public Hearing with the U.S. Nuclear Regulatory Commission (NRC) in opposition to Southern Nuclear/Georgia Power’s request for license to load nuclear fuel into Vogtle 3 reactor in November 2020.
In the petition, which is supported by a civil engineer who worked on the team at Vogtle responsible for ITAAC (inspections, tests, analysis and acceptance criteria), the group contends that the information submitted by Southern Nuclear/Georgia Power is grossly incomplete and insufficient to qualify for review by the NRC.
At issue is the NRC’s novel ITAAC review process which must establish that a new reactor conforms to its design prior to operation. The process provides for public hearing under the Atomic Energy Act and 10 CFR 52.99.
Nuclear Watch South focused on the nuclear island and the shield building in its filing. ITAAC #760 and #761, respectively, are extremely large with many elements. They are critical paths to construction completion and the nuclear island walls and shield building provide the primary barrier to radiological releases from the risky reactors. They also contain massive amounts of concrete which requires civil engineer oversight and for which Nuclear Watch South’s expert witness had responsibility during his Vogtle tenure.
Upon investigation it became startling clear that Southern Nuclear/Georgia Power had not provided any substantive information on these vital ITAAC. Close examination showed that of 399 ITAAC filed by Southern Nuclear/Georgia Power, a total of 277, 70% of the total ITAAC, were submitted as Incomplete (UINs). The process allows the filing of UINs but in lieu of finished tests, it is incumbent on the would-be licensee to show how it will obtain data and verify conformance of as-built to design. Nuclear Watch South found that many of the ITAAC UINs indeed satisfied NRC requirements, however, the biggest ones, #760 for the nuclear island, and #761 for the shield building were disturbingly blank.
Background information in the filing details large failures early in the Vogtle construction process which were caught by the NRC and prompted redesign and do-overs. In 2012, construction was halted due to improperly installed rebar. In 2013, the first concrete pour at Vogtle led to a stop work order and an NRC finding of “significant breakdown in the Quality Assurance of [then contractor] CB&I.” These significant delays at the beginning of Vogtle 3 & 4 construction contributed to the now five-year delay in the project.
More germaine to the ITAAC hearing, however, the filing chronicles a steady reduction in the ITAAC review team following the Westinghouse bankruptcy in 2017. Georgia Power took over as project manager of Vogtle 3 & 4 when Westinghouse exited the nuclear business and, against industry standards, radically reduced the number of ITAAC personnel even as it was ramping up the craft work force to the current 9,000 workers.
When the only remaining civil engineer on the ITAAC team was laid off in 2018, it was unclear how Southern Nuclear/Georgia Power would complete the concrete-related ITAAC. Now Nuclear Watch South has established that they have failed to supply the necessary detailed documentation, indeed ANY documentation, on the nuclear island and the shield building and yet had the audacity to apply for nuclear fuel load with a virtually blank application form.
“Southern Nuclear and Georgia Power appear to have been banking on a Free Pass at the NRC,” says Glenn Carroll, Nuclear Watch South coordinator. “The bar for the ITAAC hearing process is set so high, and the materials are so arcane and voluminous, it appeared impossible to second-guess what they were doing, even though it was ridiculous on its face that Vogtle Unit 3 would be ready for fuel load in November of this year.
“Fortunately,” she continues, “a concerned former insider stepped up to sort through the details and point out that the most important details are simply not there. We believe that by intervening in the NRC ITAAC process we can hold Georgia Power to the regulatory standard to help ensure that Vogtle 3 will be safe if indeed it is ever finished.”
The ITAAC review process is an unprecedented new process created by the NRC in 1989, called “one-step licensing,” and designed to bolster the moribund nuclear industry by “streamlining the license process” and “removing uncertainty.” One-step licensing, called Combined Operating License (COL), replaced the licensing process under which the nation’s 114 old nuclear reactors were licensed. The original fleet of reactors were built under a regimen which required a construction license followed by a lengthy review of the completed reactor to establish conformity and safety in order to receive the operating license. For the COL, “Step Two” of the old licensing process has been replaced by the ITAAC process in which every detail of nuclear reactor construction is required to be documented and verified within a numbered record of tests, photos, measurements, etc. and signed off on by engineers then thoroughly reviewed by NRC staff.
Southern Nuclear/Georgia Power is the first utility to undergo the new ITAAC process required to obtain the operating license and permission to load nuclear fuel. Before its demise following Westinghouse bankruptcy, Summer in South Carolina was on track to be the first to experience the new ITAAC process. Nuclear Watch South is the only petitioner to challenge Southern Nuclear/Georgia Power’s NRC license to load fuel.
The petition was filed in response to a Notice in the Federal Register published February 12, 2020, setting forth the rules of engagement and an April 13, 2020, deadline to petition for a hearing and opportunity to intervene as a party of record.
On April 3, 2020, Nuclear Watch South requested a deadline extension in light of the extreme disruption of the novel coronavirus and pointing to Southern Company’s April 1, 2020, annual 8K filing with the SEC which warned of likely delays to Vogtle construction from COVID-19. In the request, Nuclear Watch South argued that the safety review to establish whether Vogtle as-built conforms with the Westinghouse AP1000 design is not urgent as the Vogtle 3 reactor is still far from complete, and requested the deadline be extended to 60 days beyond the official lift of COVID-19 quarantine.
Nuclear Watch South’s request was vigorously opposed by both Southern Nuclear/Georgia Power and the staff of the NRC, although the NRC suggested a one-week extension. The NRC subsequently issued an Order extending the deadline by one week to April 20, 2020.
In the days leading up to Nuclear Watch South’s filing, COVID-19 erupted on the Vogtle site with the number of cases mounting from one case on April 6, 2020, to 89 positive cases on April 20, 2020. In addition to several workers having to be quarantined (mandated for the rest of the State of Georgia) with every new positive case, Southern Nuclear/Georgia Power currently intends to lay off 2,000 workers in reaction to the disease outbreak on the Vogtle construction.
For further information and links to Nuclear Watch South’s Petition to Public Hearing and other related documents visit http://www.nonukesyall.org