Beyond Nuclear's written comments to NRC opposing Holtec takeover of Palisades & Big Rock Point in Michigan
(Beyond Nuclear's written comment #1)
I would like to call your attention to a report written by my co-worker Paul Gunter, Reactor Oversight Project Director at Beyond Nuclear. The report is entitled "Leak First, Fix Later: Uncontrolled and Unmonitored Radioactive Releases from Nuclear Power Plants." The report is posted online here: <http://www.beyondnuclear.org/reports/>. Palisades has had so many tritium leaks, that Palisades got its own chapter! This radioactive contamination of the Palisades site should be completely cleaned up. "Natural attenuation," as the nuclear power industry and NRC euphemistically call it, is not acceptable. For the radioactive contamination to flow into Lake Michigan, or inland aquifers, over time, does not mean it will dilute to "safe" levels or concentrations. In fact, such artificial radioactivity flowing into Lake Michigan means the accumulation of radioactive risks in the Great Lakes. The Great Lakes is not a radioactive industrial sewer or cesspool, for Palisades to discharge or leak its hazardous radioactive pollution into! Once in Lake Michigan, hazardous artificial tritium, and other radioactive contamination, can and will contaminate drinking water supplies, such as for South Haven and other shoreline communities, drawn from Lake Michigan. Artificial radioactivity, far from "diluting" to "safe levels" in Lake Michigan, will also instead bio-accumulate, bio-concentrate, and bio-magnify, up the food chain. Unsuspecting humans are at the top of the food chain, and will be harmed with the most concentrated, hazardous doses thereby. Artificial radioactive contamination from Palisades flowing into inland aquifers over time would also increase the concentration of hazardous substances, such as tritium, in yet another potential drinking water supply. The Palisades Park resort community, immediately adjacent to the Palisades nuclear power plant, draws its potable water supply for drinking, cooking, washing, bathing, etc. from wells that tap area aquifers. Palisades' Nuclear Decommissioning Trust Fund, already woefully inadequate after being looted by Consumers Energy and Entergy in 2007, to the tune of $316 million, from which it has never recovered, should not be allowed any further looting or draining away for non-decommissioning expenses, such as irradiated nuclear fuel management, or site restoration (storm water management, landscaping, etc.). An arbitrary and capricious decision by Holtec International and SNC-Lavalin, to only clean up radioactive contamination down to a depth of 3 feet beneath ground surface level, and that decision's arbitrary and capricious approval by NRC, are outrageous and unacceptable. All radioactive contamination should be cleaned up, no matter how deeply down it extends. To do otherwise is to doom unsuspecting future generations of people, and other living things, to harm from hazardous radioactive contaminants, generated by Palisades, and simply abandoned in place by Holtec, with NRC's blessing. Besides water flow, there is also a lot of wind-driven erosion of sandy soils at Palisades. This means that any contamination abandoned on site, will simply flow into the environment over time, to harm people and other living things, downwind, downstream, up the food chain, and down the generations, over a very long period of time. Tritium, for example, has a 12.3 year half-life. Its hazardous persistence can be calculated as 10 to 20 half-lives, that is, 123 to 246 years. That's why tritium contamination at Palisades, as documented in Paul Gunter's report cited above, must be completely cleaned up, no matter how far down it goes in the soil and groundwater, or even Lake Michigan sediments or substrate, it goes. Otherwise, it can and will continue to do health damage to humans, and other living things, who/which ingest it, either through food or water, inhalation or absorption through skin, for the next 123 to 246 years after it was generated in the first place. Palisades has also generated other radioactive hazards besides tritium. A comprehensive probe must be conducted, to determine if other, even longer-lasting radioactive hazards have in fact contaminated the Palisades site. Cs-137 has a half-life of 30 years, so a hazardous persistence of 300 to 600 years. Sr-90 has a half-life of 28 years, so a hazardous persistence of 280 to 560 years. Pu-239 has a half-life of 24,000 years, so a hazardous persistence of 240,000 to 480,000 years. If such contaminants exist at the Palisades site, they must be identified, and completely cleaned up, in order to protect the Great Lakes ecosystem, and all the people and living beings who reside there, in both current and future generations.
Sincerely,
Kay Drey, Beyond Nuclear Board of Directors President, University City, MO
and Kevin Kamps, Beyond Nuclear Radioactive Waste Specialist, and Don't Waste Michigan Board of Directors Member, representing the Kalamazoo Chapter, Cell: (240) 462-3216, kevin@beyondnuclear.org
Beyond Nuclear
7304 Carroll Avenue, #182
Takoma Park, Maryland 20912
www.beyondnuclear.org
Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic.
admin
(Beyond Nuclear's written comment #2)
Please consider the following attachments as public comment in this proceeding. This includes the Beyond Nuclear letter sent to Michigan Governor Gretchen Whitmer on December 7, 2020, concerning Palisades and Big Rock Point license transfer from Entergy to Holtec. Note that the letter cc'd Michigan Attorney General Dana Nessel, whose office has petitioned to intervene and requested a hearing before the NRC's Atomic Safety and Licensing Board in this transfer proceeding. In addition, a large number of additional State of Michigan agency officials, state legislators, the U.S. congressional delegation, and Indigenous Nations' leaders, were also cc'd on the letter.
Attached to the letter were these three documents:
Nuclear Plant Decommissioning, A New Crisis and New Opportunity for States;
Decommissioning Trust Funds, What States Can Do to Stop Waste, Fraud, and Abuse, and Protect their Citizens;
Background Supplement to Comments by Hudson River Sloop Clearwater on Indian Point License Transfer Application from Entergy to Holtec.
The package conveys our many concerns about the proposed license transfer from Entergy to Holtec at Palisades and Big Rock Point. The concerns raised in the Indian Point backgrounder can also serve as a cautionary tale re: the very same companies, only proposing license transfer at other nuclear power plant sites in Michigan, rather than at Indian Point in New York. For these reasons, the attached files are entirely relevant to this proceeding, and should be treated as such by NRC. Thank you for your consideration.
Sincerely,
Kay Drey, Beyond Nuclear Board of Directors President, University City, MO
and Kevin Kamps, Beyond Nuclear Radioactive Waste Specialist, and Don't Waste Michigan Board of Directors Member, representing the Kalamazoo Chapter, Cell: (240) 462-3216, kevin@beyondnuclear.org
Beyond Nuclear
7304 Carroll Avenue, #182
Takoma Park, Maryland 20912
www.beyondnuclear.org
Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic.
admin
(Beyond Nuclear comment #3)
Attached is a 23-page listing of Kalamazoo Gazette newspaper headlines having to do with Consumers Power Company, the then owner of Palisades and Big Rock Point nuclear power plants, with dates ranging from January 2, 1972 to May 8, 1991.
Eight separate attachments, each covering 2-3 pages of the 23-page document, were required, because of the large size (50+ Megabytes) of the entire 23-page document, given your regulations.gov size limit per attachment.
The index was provided to me by Kay Cumbow, a long-time Palisades and Big Rock Point citizen watchdog in Michigan, affiliated with multiple grassroots organizations over several decades. Many of the articles have to do with Palisades, and some have to do with Big Rock Point. I request that you search through them for articles having to do with radioactive releases at either Palisades or Big Rock Point. That would provide further evidence re: where radioactive contamination at these nuclear power plant sites is, that still needs to be cleaned up, in order to protect the Great Lakes, and all people and other living things that call them home.
Please note that Big Rock Point operated beginning in 1962, so those years of operations also need to be accounted for. There may be other newspapers of record, besides the Kalamazoo Gazette, such as the Traverse City Record Eagle, and others even closer, as in Petoskey, where records of radioactive contamination incidents at Big Rock Point are recorded.
In addition, Big Rock Point kept operating after 1991, till August 1997, when it entered its decommissioning phase.
Palisades, of course, also continued operating after May 1991 -- right up to the present actually. So additional Kalamazoo Gazette (which later changed its affiliation and name to MLive) article archives should be searched. One way to do this would be at the following online database, provided by the Kalamazoo Public Library (KPL):
Search terms such as or could yield results. The local reference room at the KPL may also prove very valuable, such as its microfiche and microfilm collections.
The point is, the U.S. Nuclear Regulatory Commission is mandated to protect public health, safety, security, and the environment. The NRC should be very concerned with the radioactive contamination at both the Palisades and Big Rock Point nuclear power plant sites, where it is located, and making sure it is completely cleaned up, no matter how deep down beneath the current ground surface level it goes, and even if it extends beyond Palisades and Big Rock Point's property lines, such as into Lake Michigan itself. Any source of information that could provide insights or shed light on those vital questions and pursuits must be carefully examined, including local newspaper coverage of the infamous Operating Experience (OE) at both atomic reactors.
NRC's own dockets on both reactors should be exhaustively searched. In the past several weeks alone, a thousand or more documents -- most more than 25-years old -- have appeared in the Palisades docket at NRC ADAMS. These documents, too, should be carefully scrutinized by NRC staff. And whichever company that owns Palisades and Big Rock Point, going forward, and whichever companies that do the decommissioning (facility dismantlement and radiological cleanup) work at Palisades, should be required, by NRC, to completely clean up any and all radioactive contamination at the site.
Even the Big Rock Point site should be carefully re-examined for lingering radioactive contamination. We fear significant, hazardous radioactive contamination remains at the Big Rock Point site, even today. Please see the 11/30/2006 report entitled "Say Yes to Michigan, Say No to the 'Plutonium State Park': Background on Big Rock Point Nuclear Power Plant." It documents over 3 million curies of radioactivity released into the environment by Big Rock Point, by its own admission, as long documented in documents in NRC's possession. These massive releases did not disappear into nothingness. Some of them could still contaminate the Big Rock Point site. Some of them may have migrated off-site, but are still nearby. The site and its environs should be carefully examined for lingering radioactive contamination. This includes the Big Rock Point subsurface, below the arbitrarily and capriciously shallow cut off point that NRC allowed then owner Consumers Energy, and its decommissioning contractor British Nuclear Fuels, Ltd., to call it a day at. As documented in the report, Big Rock Point had significant spills, leaks, and operational radioactivity releases, that were never adequately cleaned up, far from it, even though decommissioning was declared finished in 2006, and NRC even has gone so far as to release the site for unrestricted use.
In short, these sites are like crime scenes. Forensic investigation is called for. Lingering contamination must be completely removed.
Sincerely,
Kevin Kamps
Beyond Nuclear & Don't Waste Michigan
admin
(Beyond Nuclear comment #4)
Thanks to Kay Cumbow, longtime grassroots Palisades watchdog in Michigan, for alerting me to this information below.
It is from the 1980s. 3 overflows in 8 years from the cooling towers at Palisades, and according to Consumers Power, the radioactive contamination came from the South Radwaste Building, after the overflows mixed with heavy rains and flooded the South Radwaste Building. 3 overflows in an 8 year period before the problem was fixed. They state that the radioactivity came from the Radwaste Building, but are not certain, since other leaks are/were allowed, as well. Also they just list the "principle" radioactive contaminants, which leaves questions about the other unnamed radioactive contaminants. Just a 6-inch cover of soil on top to protect against wind erosion at the onsite South Radwaste Area. See maps on pages 9 & 10. How have heavy rains/flooding impacted Palisades over the years and decades, especially radioactively contaminated areas such as those documented below.
All such radioactive contamination on site, at both Palisades and Big Rock Point, must be cleaned up, no matter how deeply below ground it has migrated, nor how broadly -- including off the Palisades and Big Rock Point property lines, including into Lake Michigan itself, and its sediments.
Sincerely,
Kevin Kamps, Radioactive Waste Specialist, Beyond Nuclear & Don't Waste Michigan
REQUEST UNDER 10 CFR 20.302 TO RETAIN CONTAMINATED SOIL ONSITE AT PALISADES PLANT (TAC NO. 67408) References: (1) CPCo's letter, T. C. Bordine to NRC
https://www.nrc.gov/docs/ML0608/ML060870601.pdf
Snip: "By letters dated November 12, 1987 and January 29, 1988 (Reference 1) the Consumers Power Company submitted a request pursuant to 10 CFR 20.3024a) for the disposal of contaminated soil onsite at Palisades Nuclear Plant."
The 6,000 cubic feet of onsite contaminated soil contain a total radionuclide inventory of 5.1 mCi, based on radioactive material that was deposited in the soil due to the flooding of the South Radwaste Building. The contaminated area is located inside the security fence, and is on company's controlled land. This area (South Radwaste Area) is fenced in within the plant's south security fence.
Snip: "The area known as the South Radwaste Area has been contaminated by several cooling tower overflows (three times in an eight-year period) and redistributed by heavy rain showers. The flooding was due to instrument failures that caused the cooling tower bypass valve to open during normal operation. This valve is now electrically isolated during cooling tower operation.
The licensee conducted a soil survey because the South Radwaste Building was in the main path of water overflows from the cooling tower. In the survey, the licensee found that radioactive material was deposited in the soil because of the flooding (associated with these cooling tower overflows) of contaminated areas inside the South Radwaste Building. Although the majority of the radioactive material has been packaged as radwaste and will be subsequently shipped offsite (16 boxes each having a volume of 98 cubic feet) containing 85% of the estimated activity), a large volume of low level contaminated soil is contained in the fenced area described as South Radwaste Area (Area B). The South Radwaste Area is located directly south of the plant's south security fence (see Figures 1 and 2). - - 2 - The specific area contaminated is noted as Area B on the survey grid map. The total activity of this area (5.1 mCi) is based on 6,000 cubic feet of soil contaminated with the spoils from the South Radwaste Building. Table I lists the principal nuclides identified in the contaminated soil. The activity in this table is based on measurements in 1987, and in a recent submittal (Reference 5) the activity concentrations in the contaminated area are now showing a 10 percent drop in activity. The radionuclide half-lives, which are dominated by 30-year Cs-137, meet the staff's 10 CFR 20.302 guidelines (6) which apply to radionuclides with half-lives less than 35 years. The contaminated soil has a six-inch layer of clean topping material (gravel) to prevent migration of the radioactive material via wind erosion. The approval to retain the soil in place will be documented in the licensee's FSAR and ODCM. Table 1 Average Nuclide Concentration (pCi/g) Total Activity (mCi) Co-60 0.05 0.079 Cs-137 30 5.0 Total 5.079 RAD)IOLOGICAL IMPACTS The licensee has evaluated the following potential exposure pathways to members of the general public from the radionuclides in the contaminated soil: (1) external exposure caused by direct radiation from radionuclides in the soil; and (2) internal exposure from inhalation of resuspended radionuclides. The staff has reviewed the licensee's calculational methods and assumptions and finds that they are consistent with NRC Regulatory Guide 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I,' Revision 1, October 1977; the staff finds the assessment methodology acceptable.
admin
(Beyond Nuclear written comment #5)
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(Beyond Nuclear written comment #6)
Please address the concerns raised by this coalition of environmental groups in Michigan on Nov. 30, 2006, re: lingering radioactive contamination at the Big Rock Point nuclear power plant site, even after Consumers Energy and British Nuclear Fuels, Ltd. declared decommissioning completed, and NRC approved releasing the site for unrestricted use.
admin
(Beyond Nuclear's written comment #7)
Please address the risks of barging high-level radioactive waste (irradiated nuclear fuel and GTCC LLRW) on the surface waters of Lake Michigan, from Palisades to Port of Muskegon, as US DOE proposed in the context of the Yucca Mountain, NV dumpsite proposal (see attached), and as Holtec has proposed in its PSDAR. Also, what plans exist for barging Big Rock Point's irradiated nuclear fuel and GTCC LLRW on the surface waters of Lake Michigan, as documented by Pacific Northwest National Labs, under contract to DOE? All such schemes, proposals, and documentation must be readily accessible to the concerned public. Why was it not included already in the relevant license transfer application documents?
Similarly, address any and all plans by Holtec to barge radioactive steam generators, from Palisades, on the waters of the Great Lakes, as through the Chicago waterways to the Mississippi. What are the risks?