NRC to Hold Virtual Meeting to Discuss 2019 Performance of Palisades Nuclear Power Plant [5:30-7pm Eastern, Thurs., Aug. 13 -- advance registration required]

As stated by NRC: The session will run from 5:30-7 p.m., Eastern Time [Thurs., Aug. 13th]. Online registration is required to participate. Following registration, a confirmation email will be sent with details on how to join the meeting. To hear the presentation, those interested must register to obtain the phone call-in number.

NRC has also stated: Interested members of the public must register at the website address [see lik above] to see the visual portion of the presentation. In addition, interested members of the public must call in via telephone at 800-369-3153 and enter passcode 8409690 in order to listen to the presentation because the video application will have no sound. After registering, a confirmation email will be sent with details for joining the webinar, and the telephone number and passcode for the audio portion. This is a virtual public meeting where participants will be able to see the presentation on a computer screen and listen to the presenters through their phone. There is also the option to join via phone only by calling in to the number provided in the registration confirmation.

And as stated in an action alert by Beyond Nuclear sent out to Palisades watch-dogs, and concerned residents, in the area:

Please see the NRC press release below. Then below that is the previous email, cut and pasted in, re: this meeting, that I sent out in response to NRC's first announcement of the August 13th meeting. It gives ideas for subject matter that you could bring up during the Q&A/public comment time after the NRC dog and pony show concludes. For example, the 2019 performance of Palisades (the only thing NRC is going to consider "in scope" for the meeting, in the agency's Byzantine arbitrariness and capriciousness, designed to block public knowledge and discussion), in its relation to major ongoing, and worsening with time, safety risks, dating back in some cases not years but decades, could be a way to thread NRC's arbitrary and capricious needle.

As but one example, Palisades has long had the worst neutron embrittled reactor pressure vessel of any U.S. pressurized water reactor (PWR) -- and perhaps any PWR in the world -- at risk of through-wall breach due to pressurized thermal shock (PTS). If this were to occur, a reactor core meltdown would ensue. Despite this, NRC has taken recent steps to further weaken embrittlement safety standards, to not require actual physical data collection and analysis to examine PTS risks, etc., all in order to accommodate ongoing operations at severely age-degraded reactors like Palisades.

Note that you have to pre-register with NRC in advance, in order to take part in the meeting.

Please help watch-dog this meeting if you can. Please spread the word. Thanks.

---Kevin Kamps, Beyond Nuclear & Don't Waste Michigan

---------- Forwarded message ---------
From: opa administrators <opa@nrc.gov>
Date: Thu, Aug 6, 2020 at 10:44 AM
Subject: NRC to Hold Virtual Meeting to Discuss 2019 Performance of Palisades Nuclear Power Plant
To: Kevin Kamps <kevin@beyondnuclear.org>

Nuclear Regulatory Commission - News Release

No: III-20-012 August 6, 2020

Contact: Viktoria Mitlyng, 630-829-9662 Prema Chandrathil, 630-829-9663

NRC to Hold Virtual Meeting to Discuss 2019 Performance of Palisades Nuclear Power Plant

Nuclear Regulatory Commission staff will discuss the 2019 safety performance of the Palisades nuclear power plant in Michigan during a virtual meeting scheduled for Aug. 13.

The Palisades plant is in Covert, Mich., operated by Entergy Nuclear Operations Inc.

The session will run from 5:30-7 p.m., Eastern Time. Online registration is required to participate. Following registration, a confirmation email will be sent with details on how to join the meeting. To hear the presentation, those interested must register to obtain the phone call-in number.

NRC staff responsible for plant inspection and oversight will participate, including the resident inspectors based full-time at the site.

Palisades operated safely during 2019. At the conclusion of the year, all inspection findings and performance indicators were green, or of very low safety significance. As a result, the plant in 2020 will receive the normal level of oversight, which entails thousands of hours of inspection each year.

The NRC Reactor Oversight Process uses color-coded inspection findings and indicators to measure plant performance. The colors start at green and increase to white, yellow or red, commensurate with the safety significance of the issues involved. Inspection findings or performance indicators with more than very low safety significance trigger increased NRC oversight.

Inspections are performed by two NRC resident inspectors assigned to the plant and specialist inspectors from the Region III Office in Lisle, Ill.

The annual assessment letter for Palisades, as well as the meeting notice, are available on the NRC website. Current performance information is available and updated on a quarterly basis.

[Link to press release attachment on NRC email, as this list does not support attachments: <http://static1.1.sqspcdn.com/static/f/356082/28334903/1597163194367/8+6+20+NRC+press+release+20-012.iii.pdf?token=gRBLWMcHC0e3M%2BJ2qkSd8W0HLcc%3D>]

PREVIOUS EMAIL I SENT AROUND AUGUST 3RD, WITH IDEAS FOR SUBJECT MATTER YOU COULD BRING UP DURING THE Q&A/PUBLIC COMMENT TIME AFTER THE NRC DOG AND PONY SHOW CONCLUDES:

Dear Friends and Colleagues,

Here is a link to the NRC letter posted online:
http://static1.1.sqspcdn.com/static/f/356082/28332220/1596514192077/8+13+20+2019+Palisades+EOC+Licensee+Letter.pdf?token=rxCk0qPrVYWiZ3LsG5h78db%2FlrY%3D

The end of year review webinar will be on Thursday, August 13, 2020, from 5:30 p.m. to 7:00 p.m. EDT.

Here is an NRC staff point of contact: April Nguyen, Acting Chief, Branch 2, Division of Reactor Projects, E-mail: April.Nguyen@nrc.gov, Phone: (630) 829-9587

Here is the link to the Meeting Info.:

https://adamswebsearch2.nrc.gov/webSearch2/view?AccessionNumber=ML20212L557

Here is the Public Participation section of the NRC's Meeting Info.:

[Public Participation: This is a Category 3 Meeting. The webinar will begin with a presentation by NRC staff on the NRC’s assessment of performance for the site during 2019. Following the presentation, members of the public will have the opportunity to ask questions specific to the safety performance and the NRC’s role in ensuring safe plant operations. The NRC staff will provide guidance during the webinar on the methods available to ask a question. Alternatively, questions may be submitted in advance to April.Nguyen@nrc.gov.

Interested members of the public must register at the website address below to see the visual portion of the presentation. In addition, interested members of the public must call in via telephone at 800-369-3153 and enter passcode 8409690 in order to listen to the presentation because the video application will have no sound. After registering, a confirmation email will be sent with details for joining the webinar, and the telephone number and passcode for the audio portion. This is a virtual public meeting where participants will be able to see the presentation on a computer screen and listen to the presenters through their phone. There is also the option to join via phone only by calling in to the number provided in the registration confirmation. In order to participate, please register for the webinar no later than one business day prior to the August 13, 2020, meeting at: https://usnrc.webex.com/usnrc/onstage/g.php?MTID=e5fc172c3c9fe44dda34b17004da678aa System Requirements for Attendees for the webinar: https://help.webex.com/en-us/1vek5r/Webex-Meetings-SystemRequirements-and-Cross-Platform-Information#Webex-Meetings-SuiteSystem-RequirementsIf you have any questions or should need assistance concerning registration for the meeting, please call or email the meeting contact.]

Here is another Meeting Details posting by NRC:

https://www.nrc.gov/pmns/mtg?do=details&Code=20200913

Please take part if you can, to watch-dog Palisades and NRC. Please spread the word.

Thanks.

---Kevin Kamps, Beyond Nuclear & Don't Waste Michigan

P.S. Palisades is scheduled for a refueling outage beginning late August. NRC will consider this out of scope, as the meeting is supposedly a review of Palisades' 2019 performance (eight months after 2019 ended!). But at the Cook end of year review, I pushed the envelope on refueling outages and Covid-19 risks, and they did entertain the question to some extent, although their answer left a lot to be desired.

The refueling outage will bring 1,000+ refueling outage workers, of unknown Covid-19 infection status, into Van Buren County in late August, representing a serious risk of Covid-19 not only at the Palisades nuclear power plant itself, but also in the host counties where the workers will be staying for a month or longer.

See the press release about our coalition's June 19th letter to Gov. Whitmer, warning not only about the risk of Covid-19 spread, but also about the safety shortcuts and regulatory retreat taking place under the cover of Covid-19:

http://www.beyondnuclear.org/nuclear-power/2020/6/22/nuclear-power-safety-concerns-in-michigan-amidst-the-covid-1.html

See the letter to Gov. Whitmer, here:

http://www.beyondnuclear.org/nuclear-reactors-whatsnew/2020/6/20/nuclear-power-safety-concerns-in-michigan-amidst-the-covid-1.html

See the associated briefing paper, here:

http://www.beyondnuclear.org/safety/2020/6/22/briefing-paper-nuclear-power-safety-concerns-in-michigan-ami.html

Here is a cut and paste of the Palisades section from the briefing paper:

Concerns re: Palisades Atomic Reactor in Covert Township, Van Buren County, on the Lake Michigan Shore

As revealed in a Nuclear Energy Institute document (see page 5 of 5 on PDF counter), Palisades is scheduled for a refueling outage set to begin in late August, 2020. The large, out-of-county and even out-of-state, itinerant workforce, that would come in to perform refueling outage tasks would run the risk of spreading coronavirus in Van Buren County, and beyond in southwest Michigan, at around the same time that a second major wave is feared to potentially commence state-wide, and nationally.

Palisades is already infamous for its long list of safety and security problems. One example is its badly embrittled reactor pressure vessel, the worst at any reactor in the U.S. and perhaps in the entire world, at risk of a pressurized thermal shock through-wall breach, which would cause a reactor core meltdown. Another example is its degraded steam generators, which were supposed to have been replaced many long years ago, but never were. Yet another example is its deteriorated reactor lid, also overdue for replacement by not years, but more than a decade. A steam generator tube cascading failure, or a lid breach, are also pathways to reactor core meltdown. Palisades is set to shut down for good in October 2022. In fact, Entergy had previously announced permanent shutdown by October 2018, but reneged.

Thus, this refueling outage would very likely, and thankfully, be Palisades' last. So why not power down the reactor to cold shutdown, and wait to see how Michigan is faring with the pandemic? As stated above, with reduced demand, and Michigan's glut of electricity supply, Palisades' generation likely will not even be needed any time soon, if ever. Why not avoid the pandemic risks of a refueling outage, and the radiological risks of long ignored and neglected major safety repairs and replacements, by simply shutting down Palisades for good, rather than refueling one last time? The wisdom of this precaution is enhanced by the worsening, historic Lake Michigan high water levels, which threaten the Palisades atomic reactor facilities proper, including the highly controversial, long troubled, shoreline irradiated nuclear fuel dry cask storage for highly radioactive wastes. The recent Midland flooding serves as a cautionary tale that the risks of flooding at Palisades cannot be ignored.

As with the Fermi 2 CRAC-II figures cited above, Palisades's CRAC-II figures are also sobering. Estimated casualties from a reactor meltdown at Palisades include: 1,000 peak early fatalities (acute radiation poisoning deaths), 7,000 peak early radiation injuries, and 10,000 peak cancer deaths (latent cancer fatalities). Of course, these casualty estimates are low, considering that the population around Palisades has soared since 1982. And property damages reported as $52.6 billion in Year 1982 dollar figures would now surmount $141 billion in Year 2019 dollar figures.

Security concerns associated with worker fatigue

Another concern at Palisades that deserves emphasis is the risk that owner/operator Entergy could yet seek fatigue rule exemptions regarding security guards. As mentioned above, DTE has sought, and gotten NRC approval for, lifting fatigue rules for security guards at its Fermi 2 reactor, which is already bad enough. But Entergy, including at Palisades, has long had security guard fatigue and other problems, going back not years, but decades. The Project on Government Oversight (POGO) published a report on the first anniversary of the 9/11 terrorist attacks entitled "Nuclear Power Plant Security: Voices from Inside the Fences." It focused on Entergy's overwork of security guards at its Indian Point nuclear power plant near New York City (Unit 2 thankfully shut down for good on April 30, 2020).

But Palisades (owned by Consumers Energy till 2007, and by Entergy since then) was also infamous for its security guard force fatigue at the time, after a security guard suffered a nervous breakdown on the job while heavily armed. Fortunately, no one was physically harmed, including the security guard.

POGO identified NRC's permissive authorization to nuclear utilities like Entergy, to work security guards 72 hours per week, week after week, to their breaking point, as a major contributing factor to the problems.

Also on the first anniversary of the 9/11 attacks, Palisades was the subject of an exposé in the New York Times, regarding a significant security breach. In 2007, after Entergy took ownership, yet another major security breach at Palisades was revealed in a cover article in Esquire Magazine. And just several years ago, Palisades security guards were implicated in a document falsification scandal, regarding visual fire watch inspections, as reported by News Channel TV-3 in Kalamazoo. The common thread to all these security failures and violations has been security guard force fatigue and overwork. But now, instead of 72-hour work weeks, NRC is allowing 86-hour work weeks for security guards and other safety-significant workers.

This includes control room operators. As revealed in a March 11, 2013 article in the Japan Times, about a nuclear power plant in Illinois ("Toxic management erodes safety at 'world's safest' nuclear plant: Echoes of Fukushima at Exelon's flagship Byron Station in Illinois," by Dreux Richard), excessive fatigue and other stresses on control room operators can lead to stress-related ailments, that can prove fatal; in addition, two control room operators there even committed suicide (a tragedy that has similarly since been seen with an overwhelmed American emergency room physician in the context of COVID-19). Both on the security and safety fronts, as well as regarding environmental protection, such nuclear worker fatigue-induced mistakes and violations raise the specter of radiological harm to communities downwind and downstream from Michigan's operating atomic reactors.

And as our coalition warned NRC Chairwoman Allison Macfarlane, in a face-to-face meeting in June 2014 in Benton Harbor, Palisades' location, immediately adjacent to Van Buren State Park (and along a state-designated kayak and canoe water trail, and a location already very popular with sail and power boaters), as well as Cook's location very near Warren Dunes State Park, introduces the added risk of fatigued security guards interacting with beachgoers, swimmers, and boaters. These Michiganders and out-of-state visitors are often not warned, as by adequate or any signage or other notice, about the Michigan state law, enacted several years ago, giving nuclear power plant security guards indemnity for wounding or even killing innocent, unwitting "trespassers," mistaken as dangerous terrorists. (In fact, the Republican Michigan State legislator who introduced the bill admitted, as reported by Lindsey Smith on Michigan Radio, that the legislation was meant to deter non-violent anti-nuclear and environmental protests at Michigan's atomic reactors; troublingly, they should think twice before holding such protests, he was quoted as warning in the interview.)

Palisades' sister atomic reactor, Big Rock Point in Charlevoix County, Michigan, on the Lake Michigan shoreline, is also of concern during this time of coronavirus global pandemic. The eight dry casks containing highly radioactive waste (seven casks holding irradiated nuclear fuel, one holding so-called Greater Than Class C "low" level radioactive waste) must be monitored and maintained at all times, to prevent incidents or accidents, such as overheating, leaks, etc. Security is an ongoing concern as well, which is why Big Rock Point's dry casks should be hardened.

---------- Forwarded message ---------
From: nrc_mail_r3 resource <nrc_mail_r3.resource@nrc.gov>
Date: Mon, Aug 3, 2020 at 10:02 PM
Subject: PUBLIC WEBINAR TO DISCUSS NRC 2019 END-OF-CYCLE PLANT PERFORMANCE ASSESSMENT OF THE PALISADES NUCLEAR PLANT
To: Kevin Kamps <kevin@beyondnuclear.org>

SUBJECT:  PUBLIC WEBINAR TO DISCUSS NRC 2019 END-OF-CYCLE PLANT PERFORMANCE ASSESSMENT OF the Palisades nuclear plant

ADAMS Accession Number ML20212L546

Beyond Nuclear Press Statement Re: FBI raids and arrests on Ohio House Speaker Householder, et al., related to Ohio's billion dollar bailout of two dangerously age-degraded nuclear power plants

NEWS FROM BEYOND NUCLEAR For immediate release, July 21, 2020 Contact: Kevin Kamps, Beyond Nuclear radioactive waste specialist, (240) 462-3216, kevin@beyondnuclear.org

Beyond Nuclear Press Statement

Re: FBI raids and arrests on Ohio House Speaker Householder, et al., related to Ohio's billion dollar bailout of two dangerously age-degraded nuclear power plants

TAKOMA PARK, MD  --   Press statement from Kevin Kamps, radioactive waste specialist at Beyond Nuclear:   "What's really scary is that the corruption is not just monetary, or legislative. Davis-Besse's containment structure is corrupted, in the sense that the Shield Building is severely cracked, even to the point of potential collapse. The reactor pressure vessel is corrupted, in the sense of neutron embrittlement risking pressurized thermal shock through-wall fracture, as well as boric acid corrosion. The high-level radioactive waste storage pool is corrupted, in the sense that it is leaking. The replacement steam generators are corrupted, in the sense that they are experimental, maximizing profits at the expense of safety. The physical corruption of the Davis-Besse nuclear power plant is what really worries me, regarding the health, safety, and environment for countless Ohioans -- and Great Lakes residents beyond -- downwind, downstream, up the food chain, and down the generations, in terms of the worsening risks of a catastrophic release of long-lasting hazardous radioactivity. Davis-Besse should have been retired a long time ago, for the sake of safety alone. And yet the reactor sails ever deeper into the uncharted waters of reactor meltdown risk, while churning out ever more high-level radioactive waste, for which we have no good solution.   Perry, for its part, is infamous for worker over exposures to hazardous radioactivity. It was also the first U.S. atomic reactor to suffer damage from earthquake activity, a risk that only worsens with Perry's age-related degradation.   Both atomic reactors should be shut down ASAP. Just consider the Nuclear Regulatory Commission CRAC-II study, short for Calculation of Reactor Accident Consequences, also known as the 1982 Sandia Siting Study, or as NUREG/CR-2239. For Davis-Besse, the report predicted 1,400 peak early fatalities, 73,000 peak early injuries, 10,000 peak cancer deaths, and $84 billion in property damage, in the event of a reactor core meltdown and catastrophic radiation release onto the winds and waves. Perry's CRAC-II figures are 5,500 acute radiation deaths, 180,000 radiation injuries, 14,000 latent cancer fatalities, and $102 billion in property damage. But as AP investigative reporter Jeff Donn reported in June 2011, in his series 'Aging Nukes,' populations have soared around atomic reactors like Davis-Besse and Perry since 1982, so casualties would now be significantly higher. And when adjusted for inflation alone, Davis-Besse and Perry's property damage figures would be $225 billion, and $273 billion, respectively. Given such risks, and now given the apparent corruption associated with their ongoing operations, both reactors should be shut down as soon as possible."   From 2010 to 2016, Beyond Nuclear helped lead a coalition of environmental groups, including Don't Waste Michigan, the Ohio Green Party, and Citizen Environmental Alliance of Southwestern Ontario, that unsuccessfully challenged Davis-Besse's 20-year license extension. From 2013 to 2014, Beyond Nuclear joined with that same coalition, as well as the Sierra Club Ohio Chapter, to challenge Davis-Besse's experimental steam generator replacements; Fairewinds Energy Education chief engineer, Arnie Gundersen, served as expert witness for the coalition. In both proceedings, Toledo, Ohio attorney Terry Lodge served as the coalition's legal counsel. -30-

Beyond Nuclear is a 501(c)(3) nonprofit membership organization. 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. The Beyond Nuclear team works with diverse partners and allies to provide the public, government officials, and the media with the critical information necessary to move humanity toward a world beyond nuclear. Beyond Nuclear: 7304 Carroll Avenue, #182, Takoma Park, MD 20912. Info@beyondnuclear.org. www.beyondnuclear.org.

Briefing Paper: Nuclear Power Safety Concerns in Michigan amidst the COVID-19 Pandemic

Attachment -- Briefing Paper:

Nuclear Power Safety Concerns in Michigan amidst the COVID-19 Pandemic

June 10, 2020

Introduction

On the 50th anniversary of Earth Day, April 22, 2020, four Michigan-based safe energy groups, along with national organizations with large Michigan memberships, wrote to Vice President Mike Pence as President Trump's COVID-19 Task Force director. The federal Centers for Disease Control and Prevention, Federal Emergency Management Agency, Federal Energy Regulatory Commission, Nuclear Regulatory Commission, and Occupational Safety and Health Administration were copied on the letter. The letter regarded "Urgent Actions Required to Mitigate COVID-19 Impacts in [the] Nuclear Energy Industry," and "Demand[s] for Immediate Corrective Action to Address Urgent COVID-19 Pandemic Risk."  Please see the letter, linked here, signed by 86 organizations.  We have not received acknowledgement of receipt of the letter, nor a direct response.

But NRC's Chairwoman, Kristine Svinicki, did write Vice President Pence on May 18th, enclosing our April 22nd letter. She thus indirectly, but most unsatisfactorily, responded to our concerns, by claiming the agency is on top of nuclear safety in light of the COVID-19 pandemic. We strongly disagree. She wrote the vice president:

The steps taken by the NRC staff include the identification of regulatory requirements that could pose challenges during the declared public health emergency, and the areas where the staff believed that temporary flexibilities, such as approved exemptions, would not compromise the ability of licensees to maintain the safe and secure operation of NRC-licensed facilities.

We are very concerned with NRC's false confidence, that widespread, sudden rollbacks of hard-won and long-established safety and security regulations "would not compromise" safety and security, as well as environmental and health protection, for workers and the public.

When NRC Chairman Svinicki wrote "The NRC staff communicated the processes available to licensees for requesting these flexibilities in a transparent way through public teleconferences," she neglected to mention that every single one of such teleconferences included strong opposition to such regulatory rollbacks, expressed by a large number of safe energy and public interest organization representatives, as well as concerned citizens living in the shadow of nuclear power plants, including Michiganders. The concerns fell on deaf ears.

We found Chairwoman Svinicki's letter to Vice President Pence woefully inadequate. Contrary to her false assurances, the NRC Office of Nuclear Reactor Regulation listing of "COVID-19 Regulatory Activities for Nuclear Reactors" is very revealing. A large number of "COVID-19 Power Reactor Approved Licensing Actions" are listed, including dozens of Exemption Requests. One example is Fermi's Part 26 Exemption - Work Hours. DTE requested the exemption on May 11, and by May 14 already had NRC's approval. How NRC could comprehensively analyze the impacts of significantly weakening hard-won, long-established worker fatigue protections, on worker health and nuclear safety, in just three days, astounds us. NRC did not even list the regulatory rollback regarding safety-significant torus inspection and repair at Fermi 2, also discussed in the briefing paper, even though it is currently happening, amidst the coronavirus global pandemic. In addition, the utter silence and non-response from the White House COVID-19 Task Force deepens our alarm.

We are concerned that this is but the tip of the iceberg of expedited regulatory rollbacks to come, amidst this global pandemic. Listed at a website section with the Orwellian title "Focusing on Safety While Providing Temporary Flexibility," NRC has laid the groundwork for countless additional regulatory exemptions in the following areas, should nuclear utilities but request them: 10 CFR Part 20 Respiratory Radiological Protection Requirements; 10 CFR Part 26 Work Hour Requirements; 10 CFR 50.55a Owner's Activity Reports; 10 CFR Part 55 Operators' Licenses; 10 CFR Part 73 Physical Protection; and 10 CFR Part 50.48 Fire Brigade Requirements. We fear the operating Michigan atomic reactors could seek such safety-significant exemptions in the near future, increasing risks to workers and the public.

NRC even appears to be prepared to weaken emergency preparedness and response requirements.

On June 8, 2020, Beyond Nuclear, Nuclear Information and Resource Service, and other organizations again wrote to Vice President Pence. The letter served as an update on the COVID-19 situation at nuclear power plants, including in Michigan. It also responded to various points in NRC Chairwoman Svinicki's May 18, 2020 letter to Vice President Pence.

COVID-19 and Radiological Safety Concerns re: the Fermi Unit 2 Atomic Reactor in Frenchtown Township, Monroe County, on the Lake Erie Shore

Beginning in early May, a series of articles revealed the large-scale spread of COVID-19 infections among the Fermi 2 workforce, both permanent employees who live locally, as well as a very large temporary workforce, many of whom have come in from other Michigan counties or states, to perform various tasks during the refueling outage that began on March 21, 2020. These articles include:  "Virus puts Fermi 2 refueling outage on hold," by Tom Henry, Toledo Blade, May 4, 2020; "DTE temporarily suspends Fermi refueling work," by Blake Bacho, Monroe Evening News, May 6, 2020;  "Fermi 2 struggles with large COVID-19 outbreak among workers," by Dave Battagello, Windsor Star, May 13, 2020;  "Fermi-2 reactor in Michigan sees over 200 workers test positive for novel coronavirus during outage," by Michael McAuliffe and Keiron Greenhalgh, S&P Global Platts, May 13, 2020; and  "Refueling Outage at Fermi 2 complicated, delayed due to coronavirus cases among workers," by Tom Henry, Toledo Blade, May 16, 2020.

The May 16th Toledo Blade article reported on a company memo obtained by The Blade, which stated there were at least 147 positive cases as of May 4. But that number has risen steadily since widespread Fermi 2 workforce testing began, as reported by the Windsor Star and S&P Global Platts on May 13th.

However, it is unclear whether the 237 coronavirus positive test cases at Fermi 2, as confirmed by Ron Maracle, vice president of Local 687 of the Michigan Regional Council of Carpenters and Millwrights (as quoted in the May 13th S&P Global Platts article cited above), includes any or all of the Monroe-based Laborers local union Fermi 2 workforce, which reportedly also suffers a large number of positive cases. In fact, yet to be confirmed social media posts, such as at the Monroe Evening News Facebook page as early as May 15th, allegedly posted by Fermi workers, claim the total number of coronavirus positives at the nuclear power plant then numbered over 300 individuals, with hundreds more self-isolating. How much more has coronavirus spread among the Fermi 2 workforce in the past several weeks? There has even been one COVID-19 death alleged at Fermi 2, but with no official acknowledgement.

It is worth noting that a yet to be confirmed social media post by a Fermi worker alleged that the first coronavirus positive test case result was known at Fermi 2 as early as March 3rd. That would have been a full week before the first officially reported coronavirus positive in the State of Michigan. Of course, regardless of the permanent home address, even if in another state, of that alleged coronavirus positive individual working at Fermi 2, it would have marked the beginning of a high risk for spread of coronavirus, not only within the Fermi nuclear power plant workforce, but beyond, into the wider Monroe County community.

The disconcerting lack of transparency originates not only from Fermi 2's owner/operator, DTE Energy, but also from relevant federal agencies, and even from the county and state health departments, as reported on May 16th by the Toledo Blade, regarding the coronavirus infection outbreak at Fermi 2:

Kim Comerzan, the Monroe County Health Department’s officer/director, declined to provide a specific number of positive test cases. Messages left for two spokesmen at the Michigan Department of Health and Human Services were not returned.

“I can only say that reports of positive cases are reported to the state of permanent residence,” Ms. Comerzan said. “We are in communication with Fermi regularly and working with them to manage the situation.”

While officially reporting positive cases to the worker's state of permanent residence is necessary, it is not sufficient. Of course the Monroe County Health Department, as well as the Michigan Department of Health and Human Services, should also keep careful records of each individual coronavirus positive test case result, and conduct prompt, comprehensive follow-on contact tracing, in order to protect the Michigan host community's health and safety, as well as to prevent further coronavirus spread in the Great Lakes State. Have some of these Fermi workers from other counties or states, testing positive for coronavirus infection, resided in Monroe County for the entire refueling outage, from March 21st till now? Have itinerant workers from elsewhere returned to Fermi 2, without self-isolating for two weeks, and without being tested before returning to the nuclear power plant worksite? What about the spread of coronavirus at Fermi 2 by asymptomatic workers who have not undergone testing?

Underscoring such concerns, national media reports have indicated that coronavirus positive cases, and presumably also COVID-19-related deaths, in the State of Florida, could well be significantly under-reported, due to the DeSantis administration's decision to not include data for those whose permanent residence is officially listed in other states. (Of course, a very large number of Michigander "Snowbirds" spend the winter months in Florida, before returning to Michigan to spend the warmer months at their home state residence.) Full transparency is essential to stopping the spread of coronavirus. But we have not seen full transparency at Fermi 2. Very far from it.

DTE's "extended safety stand down," first reported by the Toledo Blade on May 4th, was a clear indication of the very serious spread of coronavirus among the Fermi 2 workforce. A major concern is that this will lead to further spread into the greater Monroe County host community, due in part to the presence of a large number of itinerant refueling outage workers, including those from other states or Michigan counties. The Fermi 2 refueling outage began on March 21st. Refueling outages typically last for around a month. But DTE announced in mid-May the refueling outage will last nearly three months (83 days), until mid-June. This means that at least a certain number of itinerant refueling outage workers could have remained in Monroe County throughout this three-month period, and/or that other out-of-state or out-of-county, itinerant refueling outage workers, could have gone away and then come back, to continue their work at Fermi 2 for the next weeks, despite their unknown coronavirus infection status.

Radiological Safety Concerns at Fermi 2

On April 16, 2020 attorney Terry Lodge of Toledo, Ohio, on behalf of Don't Waste Michigan and Beyond Nuclear, filed a request for expedited relief with the U.S. Nuclear Regulatory Commission (NRC), regarding a Title 10 Code of Federal Regulations Part 2.206 emergency enforcement petition at Fermi 2. David Lochbaum, a retired nuclear engineer who served for several decades at the Union of Concerned Scientists, the U.S. Nuclear Regulatory Commission, and in the nuclear power industry, is serving as technical advisor to intervenors Don't Waste Michigan and Beyond Nuclear on the 2.206 petition. The petition focuses on the risks associated with DTE not conducting a comprehensive inspection, and repair, regarding the degraded torus at Fermi 2. The torus is a giant doughnut-shaped cylindrical ring structure at the base of the reactor, which plays a vital part in the plant's pressure-suppression radiological containment system design, associated with containment from the environment of catastrophic amounts of hazardous radioactivity, in the event of a reactor core meltdown. Problems with inner liner degradation risking debris blockage of torus water flow have persisted, not for years, but for decades. We are most concerned that the national pandemic emergency not be exploited to serve as an excuse to forgo comprehensive inspections and needed repairs on the torus, as well as other safety-significant systems, structures, and components at Fermi 2. (See the Don't Waste Michigan and Beyond Nuclear press release about the petition filing here, as well as additional documentation about Fermi 2 torus risks over the past years and decades.)

Fermi 2 is Not Currently Needed for Electricity Reliability

Along these lines, among the urgent requests for immediate needed actions in order to protect the health and safety of nuclear industry workers and the general public, the 86-group, April 22nd letter to Vice President Pence listed the following:

"For any operations-related decisions prioritizing resumed or continued operation because of reliability considerations, ensure that any potential safety impacts are fully mitigated. In many regions of the country, grid operators enjoy installed capacity margins well in excess of what is required to ensure reliability of the electricity system, especially during the low load spring months, making the temporary postponement of refueling outages irrelevant to grid reliability. In addition, the pandemic has resulted in significant reductions in electricity consumption throughout the U.S. Local grid reliability needs must be objectively evaluated, in order to properly balance the public health risks of refueling and restarting reactors during the pandemic. NRC must not permit licensees to operate reactors with increased nuclear safety risks, under any circumstances."

In fact, Fermi 2 has been idled since March 21st, with no impact on local, regional, or state-wide electricity service reliability. During this time period, one of the reactors at D.C. Cook also went offline, for 10 days, due to an unplanned shutdown resulting from a reactor coolant leak, from the pressure boundary, above technical specification limits. Thus, two of Michigan's largest atomic reactors were not generating electricity at the same time, for 10 days, and yet no negative impact on electrical reliability on the state-wide grid took place. Thus, given the excess electricity supply in Michigan, vital and comprehensive safety inspections and repairs, as with the dangerously degraded torus at Fermi 2, should be required to be completed before  the reactor's restart. (The specific situation at Cook is discussed in more detail below, towards the end of this briefing paper.)

Radioactive Risks at Fermi 2

The risks downwind, downstream, up the food chain, and down the generations, are just too dire to do otherwise. Fermi 2 is a General Electric Mark I Boiling Water Reactor, an identical twin design to the Fukushima Daiichi reactors in Japan, which suffered multiple explosions, a triple-meltdown, and a catastrophically large-scale release of hazardous radioactivity, beginning in mid-March 2011. Only, Fermi 2 is super-sized, nearly as large as Fukushima Daiichi Units 1 and 2 put together.

An NRC-commissioned report, CRAC-II (short for Calculation of Reactor Accident Consequences, also known as the 1982 Sandia Siting Study, or NUREG/CR-2239), yielded such startling figures about the potential consequences of U.S. atomic reactor meltdowns, that the agency tried to suppress the results. But thanks to U.S. Representative (now U.S. Senator) Ed Markey's efforts, the report was ultimately made public. Here are the shocking casualty and property damage figures from CRAC-II regarding Fermi 2: 8,000 peak early fatalities (acute radiation poisoning deaths); 340,000 peak early (radiation) injuries; 13,000 peak cancer deaths (latent cancer fatalities); and $136 billion in property damages (in 1982 dollar figures).

But as Associated Press (AP) investigative reporter Jeff Donn revealed in his four-part series "Aging Nukes" beginning in June 2011, populations have soared around atomic reactors like Fermi 2. Thus, casualties would be even larger now. And when adjusted for inflation, property damages could exceed $364 billion in Year 2019 dollar figures.

Counterintuitively, safety risks actually increase during refueling outages at General Electric Boiling Water Reactors (BWRs) like Fermi 2. As explained by Don't Waste Michigan and Beyond Nuclear's technical advisor David Lochbaum, the reason is because certain safeguards are relaxed or eliminated during a refueling outage, that are required during reactor operations. It is important to remember that even during a refueling outage, around two-thirds of the still-usable nuclear fuel remains in the reactor core, even before another one-third of fresh fuel is loaded prior to reactor restart.

In addition, the indoor wet storage pool for irradiated nuclear fuel at Fermi 2 remains very densely packed to the gills, containing several times more highly radioactive nuclear fuel than the original design allowed for. This includes the one-third of a core of intensely thermally hot irradiated nuclear fuel just removed from the reactor. As Princeton researchers F. von Hippel and M. Schoeppner revealed in 2016, as reported by Science Magazine, a "spent fuel fire on U.S. soil could dwarf impact of Fukushima." The case study, the Peach Bottom Unit 2 and 3 atomic reactors in Pennsylvania, are identical in design to Fermi 2, General Electric Mark I Boiling Water Reactors. The study shows that trillions of dollars (with a T) in property damages are possible downwind of Peach Bottom, in the event of an irradiated nuclear fuel storage pool fire. Potentially, the need to evacuate many millions of Americans could occur. In fact, Japanese Prime Minister Naoto Kan revealed in February 2012 that he had ordered the secret contingency planning to prepare to evacuate 35 to 50 million people from northeastern Japan and metro Tokyo, in the event the Fukushima Daiichi Unit 4 storage pool had caught fire. The only reason it did not, as reported by the U.S. National Academy of Science (on which Princeton researcher F. von Hippel also served), was sheer luck. Thus, there can be no further reduction in safety margins at Fermi 2, even during the refueling outage shutdown; the COVID-19 emergency is no excuse to increase radiological risks.

Regulatory Rollbacks at Fermi 2 Amidst the Pandemic Emergency

Despite this, DTE applied to NRC on May 11th for exemption from worker fatigue rules. NRC approved the request three short days later. Our concerns about the risks of worker fatigue led to another urgent demand for action in our April 22nd letter to Vice President Pence, et al.:

"Provide for immediate re-evaluation by the Task Force of NRC exemptions to lift work-hour limits for reactor power operations from 72 to 86 hours per week during the pandemic, due to the increased levels of fatigue on (a) workers' vulnerability to COVID-19 and (b) radiological health and safety."

In addition to grueling 86-hour work weeks, we remain concerned that workers can now be forced to work up to 16-hours per day (excluding shift turnover time!), and 12-hour shifts for 14 consecutive days. The dangers include the stress and fatigue levels weakening workers' immune systems, and general health, to the point where they are even more vulnerable to contracting COVID-19, or other ailments; and the increased risk of such stressed and fatigued workers making safety-critical mistakes on the job, that leads to incidents or even accidents, with radiological safety implications not only for the Fermi 2 workforce, but also for the general public downwind and downstream. NRC treats each of its mounting waivers, exemptions, and deferrals in isolation. But our April 22nd letter to Vice President Pence called for:

"Subject[ing] all current reviews of licensee petitions for postponements and exemptions of scheduled maintenance and inspections of reactor systems, structures, and components (including those seeking expedited review during refueling outages) to (a) a cumulative risk analysis and (b) an integrated review by the COVID-19 Task Force."

Increasing worker fatigue must now be added to the list for a cumulative, integrated safety review, and risk analysis, at Fermi 2.

Emergency preparedness and response concerns

Another call in our April 22nd letter to Vice President Pence et al. stated:

"Provide for immediate preparation of required Disaster Initiated Reviews (DIR) of the impact of the pandemic on emergency response plans at all reactor sites and fuel cycle facilities. Inexplicably, NRC has not yet done this, despite the express requirements of NRC Manual Chapter 1601, paragraph 03.02, and the FEMA Standard Operating Guide. Review of DIRs by the Task Force should be a high priority." (internal citations omitted)

DIRs published by FEMA on May 19th, for nuclear power plants in other states besides Michigan, were woefully inadequate. They appeared to be little more than short form letters, simply altering the names of the reactors and the FEMA region numbers. The DIRs we have been able to obtain thus far indicate the scope of the FEMA assessment was to merely examine the local off-site response organizations, which is necessary, but far from sufficient. A comprehensive examination of emergency response plans is what is needed. Hopefully the emergency response organizations in Michigan are intact, but the real question is, are the emergency response plans themselves workable in the pandemic? Social distancing and Personal Protective Equipment for congregate evacuation shelters, distribution of potassium iodide (KI) to protect residents' thyroids downwind and downstream of a reactor meltdown, availability of medical personnel, radiological decontamination equipment, etc., are the real questions that should be addressed by FEMA DIRs, but this seems to not be happening.

These concerns apply as much at the Palisades and Cook atomic reactors (addressed further, below) as they do at Fermi 2. Neither NRC nor FEMA have yet to explain how a mass evacuation in the event of a catastrophic radioactivity release during a disaster at an atomic reactor in Michigan, and mass sheltering at pre-established emergency evacuation centers, would comport with current stay-home, stay-safe and social distancing orders.

In fact, Don't Waste Michigan and Beyond Nuclear's technical advisor, David Lochbaum, has addressed this exact failure of the federal agencies. See his May 1st "A Tornado in the Midst of a Pandemic," featured in the publication Nuclear Intelligence Weekly.

And of course, the May 19th dam failures and resulting floods near Midland, resulting in the mass evacuation of 11,000 people, showed clearly the complexity of emergency response, and especially mass evacuation and sheltering, during this COVID-19 pandemic. Fortunately, the research reactor at Dow Chemical dodged the bullet during the floods. And also fortunately, two proposed, large-scale commercial atomic reactors in Midland were cancelled in the 1980s, so no radioactive risks were present at that particular site during last month's flooding. But the pandemic, now further complicated by a fast-breaking, volatile national crisis in the aftermath of the George Floyd murder by police, demonstrates the danger that Michigan's already stretched emergency response capabilities could be overwhelmed by a radiological emergency at this time, such as one unfolding at any of Michigan's four operable commercial reactors.

The latest re: Coronavirus at Fermi 2

Because of the lack of transparency by officials re: the worsening coronavirus infection rates at Fermi 2, watch-dogs have had to puzzle together developments through back channels. On June 1st, Michael Keegan of Don't Waste Michigan and Coalition for a Nuclear-Free Great Lakes, posted the following updates to the Facebook page of the Monroe Evening News:

[H]ere is quick count report:

Toledo Blade reports May 17th that DTE acknowledged 147 persons positive with COVID  existed at Fermi on May 4th;  DTE would not provide updates.

 

Platts/McGraw-Hill reports Carpenters Local went on record with 237 Fermi workers on May 13th.

Laborers Local in Monroe reported to have been one of two trades hit hard.  But no numbers given.

Windsor Star reports May 12th that there are Facebook postings of 200 persons positive COVID at Fermi 2.

Monroe News reports May 8th "a large group of" and has not reported out since.

Facebook reports of over 300 and waiting on results of 2,200 on May 15th at Monroe News Facebook page.

Traveling nuclear workers who are COVID positive are not getting reported for Monroe County, even though they have been in Monroe for several months, and continue to be in Monroe, be it now in quarantine or stay at home.

 

Regardless if reported to other counties, these 2,200 workers have been living among the Community of Monroe.

Citizens of Monroe County have the right to know about this "Shadow COVID Cluster." Monroe News reported out May 8th but has not reported out since.  Please see the Monroe News, Windsor Star, McGraw-Hill Platts, and Toledo Blade articles.

Several open Facebook postings at Monroe News beginning 5/15/20 talking about over 300 persons positive with COVID, and these persons are not being included in Monroe County total because they came in from out of town to do the nuclear work. 

Facebook postings of Camper Trailer village of COVID positive workers at Fermi gate.

There are workers being put up at MGM in Detroit, at Quality Inn in Monroe, and Camper Trailers.  There was a 14 day quarantine which was up Monday May 18th.  Work crews back to work on Monday, May 18th.  But some work crews went back on May 4th, shortly after "Stand Down" - All of this posted up at Facebook, mostly Monroe News.  Does the Community of Monroe have the right to know? 

Concerns re: Palisades Atomic Reactor in Covert Township, Van Buren County, on the Lake Michigan Shore

As revealed in a Nuclear Energy Institute document (see page 5 of 5 on PDF counter), Palisades is scheduled for a refueling outage set to begin in late August, 2020. The large, out-of-county and even out-of-state, itinerant workforce, that would come in to perform refueling outage tasks would run the risk of spreading coronavirus in Van Buren County, and beyond in southwest Michigan, at around the same time that a second major wave is feared to potentially commence state-wide, and nationally.

Palisades is already infamous for its long list of safety and security problems. One example is its badly embrittled reactor pressure vessel, the worst at any reactor in the U.S. and perhaps in the entire world, at risk of a pressurized thermal shock through-wall breach, which would cause a reactor core meltdown. Another example is its degraded steam generators, which were supposed to have been replaced many long years ago, but never were. Yet another example is its deteriorated reactor lid, also overdue for replacement by not years, but more than a decade. A steam generator tube cascading failure, or a lid breach, are also pathways to reactor core meltdown. Palisades is set to shut down for good in October 2022. In fact, Entergy had previously announced permanent shutdown by October 2018, but reneged.

Thus, this refueling outage would very likely, and thankfully, be Palisades' last. So why not power down the reactor to cold shutdown, and wait to see how Michigan is faring with the pandemic? As stated above, with reduced demand, and Michigan's glut of electricity supply, Palisades' generation likely will not even be needed any time soon, if ever. Why not avoid the pandemic risks of a refueling outage, and the radiological risks of long ignored and neglected major safety repairs and replacements, by simply shutting down Palisades for good, rather than refueling one last time? The wisdom of this precaution is enhanced by the worsening, historic Lake Michigan high water levels, which threaten the Palisades atomic reactor facilities proper, including the highly controversial, long troubled, shoreline irradiated nuclear fuel dry cask storage for highly radioactive wastes. The recent Midland flooding serves as a cautionary tale that the risks of flooding at Palisades cannot be ignored.

As with the Fermi 2 CRAC-II figures cited above, Palisades's CRAC-II figures are also sobering. Estimated casualties from a reactor meltdown at Palisades include: 1,000 peak early fatalities (acute radiation poisoning deaths), 7,000 peak early radiation injuries, and 10,000 peak cancer deaths (latent cancer fatalities). Of course, these casualty estimates are low, considering that the population around Palisades has soared since 1982. And property damages reported as $52.6 billion in Year 1982 dollar figures would now surmount $141 billion in Year 2019 dollar figures.

Security concerns associated with worker fatigue

Another concern at Palisades that deserves emphasis is the risk that owner/operator Entergy could yet seek fatigue rule exemptions regarding security guards. As mentioned above, DTE has sought, and gotten NRC approval for, lifting fatigue rules for security guards at its Fermi 2 reactor, which is already bad enough. But Entergy, including at Palisades, has long had security guard fatigue and other problems, going back not years, but decades. The Project on Government Oversight (POGO) published a report on the first anniversary of the 9/11 terrorist attacks entitled "Nuclear Power Plant Security: Voices from Inside the Fences." It focused on Entergy's overwork of security guards at its Indian Point nuclear power plant near New York City (Unit 2 thankfully shut down for good on April 30, 2020).

But Palisades (owned by Consumers Energy till 2007, and by Entergy since then) was also infamous for its security guard force fatigue at the time, after a security guard suffered a nervous breakdown on the job while heavily armed. Fortunately, no one was physically harmed, including the security guard.

POGO identified NRC's permissive authorization to nuclear utilities like Entergy, to work security guards 72 hours per week, week after week, to their breaking point, as a major contributing factor to the problems.

Also on the first anniversary of the 9/11 attacks, Palisades was the subject of an exposé in the New York Times, regarding a significant security breach. In 2007, after Entergy took ownership, yet another major security breach at Palisades was revealed in a cover article in Esquire Magazine. And just several years ago, Palisades security guards were implicated in a document falsification scandal, regarding visual fire watch inspections, as reported by News Channel TV-3 in Kalamazoo. The common thread to all these security failures and violations has been security guard force fatigue and overwork. But now, instead of 72-hour work weeks, NRC is allowing 86-hour work weeks for security guards and other safety-significant workers.

This includes control room operators. As revealed in a March 11, 2013 article in the Japan Times, about a nuclear power plant in Illinois ("Toxic management erodes safety at 'world's safest' nuclear plant: Echoes of Fukushima at Exelon's flagship Byron Station in Illinois," by Dreux Richard), excessive fatigue and other stresses on control room operators can lead to stress-related ailments, that can prove fatal; in addition, two control room operators there even committed suicide (a tragedy that has similarly since been seen with an overwhelmed American emergency room physician in the context of COVID-19). Both on the security and safety fronts, as well as regarding environmental protection, such nuclear worker fatigue-induced mistakes and violations raise the specter of radiological harm to communities downwind and downstream from Michigan's operating atomic reactors.

And as our coalition warned NRC Chairwoman Allison Macfarlane, in a face-to-face meeting in June 2014 in Benton Harbor, Palisades' location, immediately adjacent to Van Buren State Park (and along a state-designated kayak and canoe water trail, and a location already very popular with sail and power boaters), as well as Cook's location very near Warren Dunes State Park, introduces the added risk of fatigued security guards interacting with beachgoers, swimmers, and boaters. These Michiganders and out-of-state visitors are often not warned, as by adequate or any signage or other notice, about the Michigan state law, enacted several years ago, giving nuclear power plant security guards indemnity for wounding or even killing innocent, unwitting "trespassers," mistaken as dangerous terrorists. (In fact, the Republican Michigan State legislator who introduced the bill admitted, as reported by Lindsey Smith on Michigan Radio, that the legislation was meant to deter non-violent anti-nuclear and environmental protests at Michigan's atomic reactors; troublingly, they should think twice before holding such protests, he was quoted as warning in the interview.)

Palisades' sister atomic reactor, Big Rock Point in Charlevoix County, Michigan, on the Lake Michigan shoreline, is also of concern during this time of coronavirus global pandemic. The eight dry casks containing highly radioactive waste (seven casks holding irradiated nuclear fuel, one holding so-called Greater Than Class C "low" level radioactive waste) must be monitored and maintained at all times, to prevent incidents or accidents, such as overheating, leaks, etc. Security is an ongoing concern as well, which is why Big Rock Point's dry casks should be hardened.

Concerns re: D.C. Cook Units 1 and 2 Atomic Reactors in the City of Bridgman, Berrien County, on the Lake Michigan Shore

The same NEI document cited above also lists one of the reactor units at Donald C. Cook nuclear power plant as scheduled for a refueling outage in mid-September 2020. Thus, the concerns regarding spread of coronavirus among nuclear workers and the host community, expressed above re: Palisades, will either follow-on immediately, or even overlap, just 30 miles south, in Bridgman, in Berrien County. And as with worker fatigue rule exemptions already approved at Fermi 2, and which we fear may be sought in the weeks or months ahead at Palisades, we are also concerned about such worker fatigue rule exemptions being sought at Cook yet this year. As at Fermi 2 and Palisades, this could lead to increased radiological risks and consequences for worker and public safety and health, environmental protection, and security.

In addition, in early May, a Preliminary Notification of Occurrence was issued by Cook to NRC. Cook Unit 2 experienced an "Unplanned Shutdown Greater Than 72 Hours Due to Reactor Coolant System Leakage Exceeding Technical Specification Limits." Consequently, Cook 2 shut down on May 1st. As documented in NRC's Power Reactor Status Reports for May 2020, Cook Unit 2 only began to power back up on May 12th, reaching 28% power levels that day. By the next day, May 13th, Cook 2 was back at 100% power levels. Thus, from May 1st to 11th, Cook 2 was not generating any electricity at all. It took two more days, till May 13th, for both Cook reactor units to be back at 100% electricity generation levels. And yet, from May 1st to May 11th, despite Cook Unit 2's temporary unplanned shutdown, there were no electricity reliability problems in Michigan. (Around 90% of Cook's electricity is exported to Indiana; only around 10% is consumed by Michiganders.)

It just so happened that Fermi 2 was also simultaneously shut down during those ten days, and still is. Thus, even with two large nuclear reactors in Michigan shut down at the same time, there were no electric reliability issues. What this shows is, these reactors are not needed, as there is an excess of electricity on the grid in Michigan.

NRC's willingness to weaken fire brigade requirements at atomic reactors during this global coronavirus pandemic is also very alarming. Several years ago, a fire in a Cook turbine hall quickly surpassed the on-site fire brigade's ability to bring it under control. Local fire departments from surrounding communities had to be called in to assist. The resulting damage kept one of Cook's units shut for more than a year, until repairs and replacements of damaged or destroyed turbine hall structures and components could be completed.

Several years ago at Palisades, fatigued and overworked security guards who were tasked with performing manual fire watch inspections, instead falsified paperwork saying they had performed the tasks, when in fact they had not. This was brought to light by whistle-blowers, as reported by WWMT TV-3 in Kalamazoo. As it turned out, other Entergy reactors across the country had the same scandal happening. But nowhere worse than at Palisades.

50% of the risk of an atomic reactor meltdown is related to fire risks. At a time of global pandemic, fire protections at Michigan nuclear power plants should be strengthened, not weakened.

Wisdom of Suspension/Postponement of Michigan Atomic Reactor Refueling Outages

For this reason, the refueling outages at Fermi 2, Palisades, and Cook can be suspended, and/or postponed, without any impact on electric reliability in the Great Lakes State. Given the ongoing challenges of the COVID-19 pandemic emergency in Michigan, the risks of refueling outages at Fermi 2 and Cook can be mitigated with delays; at Palisades, a permanent shutdown, instead of a final refueling outage, should be seriously considered.

Cooling and Containment Concerns at Cook

Of added safety and environmental protection concern at Cook are containment problems that date back decades. Although a pressurized water reactor (PWR) design, Cook employs an ice-condensor, pressure-suppression, radiological containment and reactor core cooling design. That is, the containment is potentially too small, and too weak, to contain a large-scale, catastrophic release of hazardous radioactivity, if one or both reactors melt down at Cook. In fact, although boiling water reactors (BWRs), this is what happened at Fukushima Daiichi, Japan, beginning in mid-March 2011. The pressure-suppression containments there were either damaged or destroyed by the meltdowns and explosions, resulting in catastrophic radioactivity releases to the environment.

Exacerbating these concerns, an NRC whistle-blower, Dr. Ross Landsman, in both an official Differing Professional View and an official Differing Professional Opinion, warned in the late 1990s and early 2000s that an area of degradation in the Cook containment structure made its failure risks all the more likely and dire. A significant amount of concrete and rebar were simply missing from an area of containment, due to age-related deterioration, creating an ominous weak spot. A pressure build up within containment could simply breach the structure at this weak spot, allowing hazardous radioactivity releases into the environment. To the best of our knowledge, this degradation has not been addressed since.

(Landsman's revelations came out around the same time as a whistle-blower at a twin-design nuclear plant in Tennessee, Curtis Overall at Watts Bar, revealed problems there that turned out to be even worse at Cook. Assisted by David Lochbaum, who then served as Union of Concerned Scientists Nuclear Power Safety director, NRC was forced to demand related inspections Cook was hoping to avoid. Once the severity of the problem was thus revealed -- literally tons of debris blocking ice-condensor cooling water flow to the core; and a wall not revealed on blueprints doing the same -- both Cook reactor units were shut down from 1997 to 2000, a very significant emergency safety shutdown of long duration. Even then, the lights stayed on in southwest Michigan. Cook's electricity was not, and still is not, even needed, especially at this time of reduced demand due to the coronavirus pandemic economic downturn.)

As with Fermi 2 and Palisades above, both Cook reactor units' CRAC-II meltdown figures are shocking. Cook Unit 1's casualties include: 1,900 peak early fatalities (acute radiation poisoning deaths); 80,000 peak early radiation injuries; and 13,000 peak cancer deaths (latent cancer fatalities). Cook Unit 2's casualties include: 2,000 peak early fatalities; 88,000 peak early radiation injuries; and 13,000 peak cancer deaths. Of course, populations have soared downwind and downstream since 1982, so the casualty figures are underestimated. Regarding property damages, the figures expressed in 1982 dollar figures ($91.9 billion at Cook Unit 1; $101 billion at Cook Unit 2), when adjusted for inflation to Year 2019 dollar figures, would now top $246 billion, and $270 billion, respectively. If both reactor units were involved in a domino effect meltdown catastrophe (as happened at Fukushima Daiichi, Japan), the respective figures would have to be added together for an even more shocking grand total.

[Briefing Paper Prepared by Kevin Kamps, Beyond Nuclear radioactive waste specialist, Don't Waste Michigan board of directors member (Kalamazoo chapter), and Citizens for Alternatives to Chemical Contamination advisory board member, June 10, 2020]

--

Kevin Kamps
Radioactive Waste Specialist
Beyond Nuclear
7304 Carroll Avenue, #182
Takoma Park, Maryland 20912

Cell: (240) 462-3216

kevin@beyondnuclear.org
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.

NRC Preliminary Notification of Occurrence (PNO) at Cook 2 in MI: Reactor Coolant System (RCS) pressure boundary from a pressurizer spray line

Cook nuclear power plant, Bridgman, MI, on Lake Michigan shore.[Cook Unit 2 in Bridgman, MI, on the Lake Michigan shore, went from 100% power level to 0% power level within just several hours, due to this occurrence/event.]

For Immediate Release - Posted to Public into ADAMS at 10:59 am 5/5/2020

D.C. Cook - Preliminary Notice of Occurrence (PNO) - 

The first issued by NRC Industry-wide for 2020

ML20125A383

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML20125A383 

Document Title:	PNO-III-20-001: Unplanned Shutdown Greater Than 72 Hours Due to Reactor Coolant System Leakage Exceeding Technical Specification Limits
Document Type:	NRC Preliminary Notification of Event/Occurrence
Document Date:	05/04/2020

Michael J. Keegan

Don't Waste Michigan

For Immediate Release Docketed 5/4/2020

U.S. Nuclear Regulatory Commission
Operations Center

Event Reports For
5/1/2020 - 5/4/2020

54687

Power Reactor	Event Number: 54687
Facility: COOK Region: 3     State: MI Unit: [] [2] [] RX Type: [1] W-4-LP,[2] W-4-LP NRC Notified By: RODNEY PICKARD HQ OPS Officer: DONALD NORWOOD	Notification Date: 05/01/2020 Notification Time: 11:53 [ET] Event Date: 05/01/2020 Event Time: 03:54 [EDT] Last Update Date: 05/01/2020
Emergency Class: Non Emergency 10 CFR Section: 50.72(b)(2)(i) - PLANT S/D REQD BY TS 50.72(b)(3)(ii)(A) - DEGRADED CONDITION	Person (Organization): ANN MARIE STONE (R3DO)

Unit

SCRAM Code

RX Crit

Initial PWR

Initial RX Mode

Current PWR

Current RX Mode

2

N

Y

100

Power Operation

0

Hot Standby

Event Text

TECHNICAL SPECIFICATION REQUIRED SHUTDOWN DUE TO REACTOR COOLANT SYSTEM PRESSURE BOUNDARY LEAKAGE "At 1000 EDT on May 1 2020, Operations commenced a shutdown of DC Cook Unit 2 to comply with LCO 3.4.13, Condition B Reactor Coolant System (RCS) pressure boundary leakage. "At 0354 EDT on May 1, 2020, Operations detected an estimated 8 gpm Reactor Coolant System leak. The source of the leak could not be identified and Tech Spec 3.4.13, Condition A was entered for unidentified RCS leakage in excess of the 0.8 gpm limit. "At 0745 EDT on May 1, 2020, Unit 2 entered LCO 3.4.13, Condition B when the 4-hour limit to complete the required actions of Condition A could not be met. "At 0945 EDT on May 1, 2020, Unit 2 entered LCO 3.4.13, Condition B when the 4-hour limit to complete the required actions of Condition A could not be met. "At 0945 EDT on May 1, 2020, inspections inside containment identified the leak as pressure boundary leakage from a pressurizer spray line which also requires entry into LCO 3.4.13, Condition B. "At 1059 EDT on May 1, Unit 2 was tripped from 15 percent power. All systems functioned normally. "This event is reportable under 10 CFR 50.72(b)(2)(i), the initiation of any nuclear plant shutdown required by the plant's Technical Specifications as a 4-hour report and under 10 CFR 50.72 (b)(3)(ii)(A), degraded condition, as an 8-hour report. The NRC Resident Inspector has been notified."

Forwarded by

Michael J. Keegan

Don't Waste Michigan

Letter from 86 Organizations to Vice President Pence: Urgent Actions Required to Mitigate COVID-19 Impacts in Nuclear Energy Industry

As posted on the NIRS website. This letter, sent by Beyond Nuclear and 85 allied groups, was submitted on Earth Day's 50th anniversary, April 22, 2020.