Beyond Nuclear media statement, re: MPSC public comment mtgs. about Entergy Palisades's closure
News from Beyond Nuclear
For Immediate Release, May 8, 2017
Contact: Kevin Kamps, Beyond Nuclear & Don’t Waste Michigan (Kalamazoo chapter), (240) 462-3216, kevin@beyondnuclear.org
Media Statement by Kevin Kamps, Beyond Nuclear/Don’t Waste Michigan, re: Michigan Public Service Commission public comment meetings about Entergy Palisades atomic reactor’s closure
[The entirety of this media statement was also read into the official record as a public comment]
Lawrence, MI—“In spring 2006, Palisades’ previous owner, Consumers Energy, urged the Michigan Public Service Commission (MPSC) to approve its sale of the atomic reactor to Louisiana-based Entergy Nuclear. Consumers listed several ‘significant future capital expenditures [that were] required,’ including: ‘Reactor vessel head replacement; Steam generator replacement; Reactor vessel embrittlement concerns.’
Consumers executives explained to concerned local residents and environmental group representatives that Entergy Nuclear, a company with a large atomic fleet, experienced nuclear workforce, and economy of scale, could afford to make the repairs that Consumers could not. MPSC, as well as the Nuclear Regulatory Commission (NRC), swallowed the bait and switch, hook, line and sinker.
Entergy had no intention of undertaking these major, expensive safety repairs. Each abandoned fix represents a distinct pathway to reactor core meltdown, and potential catastrophic release of hazardous radioactivity into the Great Lakes environment.
The lid (reactor vessel head) replacement is now ten years overdue, even though the 2002 cautionary tale of the Hole-in-the-Head fiasco at Davis-Besse, on Ohio’s Great Lakes shore, was the nearest-miss to a reactor disaster in the U.S. since the Three Mile Island Unit 2 meltdown of 1979.
The steam generators have badly needed replacement, despite previous replacements in 1991, after only 20 years of operations at Palisades – a uniquely bad performance in the U.S. nuclear power industry. Despite degraded steam generator related permanent shutdowns at San Onofre Units 2 and 3 in California, due to major associated safety risks, Entergy has refused to perform the vitally needed job, 11 years after Consumers told MPSC it was needed.
Most infamously, Palisades has the worst neutron radiation-embrittled reactor pressure vessel (RPV) in the U.S. The 46-year old RPV is very vulnerable to pressurized thermal shock (PTS), meaning it could simply fracture through-wall. There would then be no contingency to cool the core, and a meltdown would follow. If the containment then failed, like happened at three Fukushima Daiichi reactors, then large-scale radioactive liquid discharges would flow into groundwater and Lake Michigan, and radioactive gas clouds, and particulate fallout, would contaminate Van Buren, Allegan, Kalamazoo and other counties downwind, depending on which way the wind was blowing.
A coalition of dozens of Michigan environmental groups has warned about the RPV embrittlement risks not for years, but for decades. The concern served as the primary contention against the 2011 to 2031 license extension at Palisades; opponents also raised legal objections to regulatory rollbacks in 2014 to 2015. However, despite decades of documented danger, NRC ultimately rejected all challenges, enabling the dangerously embrittled Palisades reactor to continue operating.
In addition to all the serious safety risks listed above, as documented by Union of Concerned Scientists and others, Palisades also has had a uniquely bad plague of control rod drive mechanism (CRDM) seal failures, and even through-wall leaks of highly radioactive, primary coolant water. This epidemic of CRDM failures has continued from 1972, right up to the present.
Scandalously, the NRC has allowed all these high-risk problems to persist, for years and decades, despite the agency’s mandate to protect public health, safety, and the environment. In the case of RPV embrittlement, NRC simply weakened its safety regulations, in order to enable Palisades to keep operating for years and decades to come, despite the risks. Associated Press investigative reporter Jeff Donn cited PTS regulatory rollback as a top example of NRC collusion with industry, in a June 2011 four-part series.
The Japanese Parliament concluded, a year after the still ongoing Fukushima Daiichi nuclear catastrophe began, that the root cause was collusion between the regulatory agency, nuclear industry, and government officials. NRC, Entergy Palisades, and U.S. Representative Fred Upton (Republican-St. Joe, MI, and U.S. House Energy and Commerce Committee chairman for many years, until just recently, with direct oversight on nuclear power safety matters) have exhibited just such potentially catastrophic collusion right here in southwest Michigan, to all of our peril.
But the Michigan Public Service Commission has colluded with Consumers Energy and Entergy too, to keep the dangerously age-degraded Palisades atomic reactor operating.
MPSC not only allowed the sale from Consumers to Entergy to proceed, but also sweetened the deal, by approving a scandalous raid on the Palisades decommissioning (facility dismantlement and radioactive contamination cleanup) fund, to the tune of $316 million. A third went to Consumers, a third went to Entergy, and a third went back to ratepayers. But it has severely depleted the fund, likely irreparably.
In a 2005 document, Consumers reported that it would cost $868 million (expressed in year 2003 U.S. dollars) to decommission Palisades, although it was not clear if this referred to decommissioning costs after 40 years of operations (by 2011), or 60 years of operations (by 2031). In a 2006 report, Consumers declared that $597 million (expressed as 2006 dollars) had accumulated in the decommissioning fund. Given this admitted shortfall in the decommissioning fund of at least $271 million, it is shocking that the MPSC approved an additional $316 million raid, worsening the shortfall that much more.
The only recourse now is either to accept a woefully inadequate cleanup, leaving significant, hazardous radioactive contamination behind in the soil, groundwater, Lake Michigan sediments, and food chain, or else gouge ratepayers yet again, to make up for the many hundreds of millions, or even billions of dollars of shortfall. After all, the 67 Megawatt-electric (MW-e) Big Rock Point reactor, Palisades’ sister nuclear plant in Charlevoix, Michigan, cost $366 million to decommission. So how can the 800 MW-e Palisades reactor be decommissioned for a mere $426 million (the figure reported by Entergy as the accumulated total in the decommissioning fund, by the end of February 2017)?
Remarkably, despite MPSC’s scandalous approval in 2007, of the highest Power Purchase Agreement (PPA) that Nuclear Information and Resource Service (NIRS) executive director Tim Judson had ever seen, Entergy Palisades has still managed to lose money, to not keep its head above water. NIRS’s Judson is a noted watch-dog on nuclear power economics, as well as outspoken opponent of old atomic reactor bailouts at ratepayer expense.
Thus, MPSC has given new meaning to ‘public service’ – serving the public up for dinner, to Consumers and Entergy Nuclear. To begin to correct such disservice to the public, MPSC should terminate the exorbitant Palisades PPA.
The gouging of ratepayers, and the high-risk to residents downwind and downstream, must end. Palisades must be closed, as announced, by October 2018 at the latest, 11 years later than it was supposed to in the first place (Palisades’ initial 40-year operational license extended from 1967 to 2007). Palisades must be shutdown, before it melts down.
A just transition for the workforce and local host communities is a top priority, as is safety, security, environmental and health protection, during post-shutdown decommissioning. So too is the management of the irradiated nuclear fuel (high-level radioactive waste) stored on-site, which is why we have long called for Hardened On-Site Storage (HOSS), as close as possible to the point of generation, as safely as possible.
Regarding replacing Palisades’ electrical output, the carbon-free, nuclear-free approach is the way to go. Energy efficiency is the lowest hanging fruit. Renewable power, such as wind power and solar power, is the way of the future, if we are to have a future. Efficiency and renewables are safe, secure, clean, and affordable, as opposed to dirty, dangerous, and expensive fossil fuels and nuclear power.”
--30—
Kevin Kamps serves as Radioactive Waste Watchdog at Beyond Nuclear. 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. Kamps also serves as a board of directors member for Don’t Waste Michigan, representing the Kalamazoo chapter, and as an advisory board member for Citizens for Alternatives to Chemical Contamination.
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Media coverage:
http://wwmt.com/news/local/west-michigan-weighs-in-on-plan-to-close-palisades
http://www.mlive.com/news/kalamazoo/index.ssf/2017/05/palisades_nuclear_plant_closur_1.html
http://www.bradenton.com/news/business/article149472579.html
http://wmuk.org/post/wsw-long-checklist-palisades-closes
http://wincountry.com/news/articles/2017/may/09/public-service-commission-hearings-on-palisades/
http://www.mlive.com/news/kalamazoo/index.ssf/2017/05/palisades_nuclear_plant_closur_1.html
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Summary of Public Comment Meetings:
Voices calling for Palisades's closure dominated the MPSC public comment meetings. Entergy announced in early December 2016 that it would permanently shut down Palisades by October 2018.
Those calling for Palisades's closure included: Mark Muhich from Sierra Club Michigan Chapter Nuclear-Free Committee; David Schonberger from Alliance to Halt Fermi 3, a Michigan Environmental Council member organization; Kraig Schultz, Maynard Kaufman, and Bette Pierman, from Michigan Safe Energy Future-Shoreline Chapter; Iris Potter from Michigan Safe Energy Future-Kalamazoo Chapter; and Jan Boudart from Nuclear Energy Information Service in Chicago.
Concerned local residents also spoke out forcefully for Palisades's closure, including Barbara Pellegrini from Hagar Township, and Jodi Flynn and Ann Scott from Palisades Park (the community of cottages immediately adjacent to the atomic reactor).
There were also many members of the media in attendance, including those listed above, as well as A.C. Aldag from the Bangor Apple Press.
The MPSC will hold administrative law hearings in Lansing, in June. A final decision by the MPSC, regarding whether or not the Power Purchase Agreement between Entergy Nuclear and Consumers Energy, will be allowed to be terminated five years early, will be made by August.
The MPSC is also accepting written comments, of unlimited number and length. The MPSC encouraged those wishing to submit public comments to do so by the time of the administrative law hearings in June, if possible, although comments will continue to be accepted until the end of the proceeding.
As communicated by the MPSC itself:
To submit written comments,
you may send them to:
mpscedockets@michigan.gov
or by mail to:
7109 W Saginaw, Lansing, MI 48917
In the subject line, please include:
"Case Number U-18250 comments"
Please feel free to use any, or all, of the Beyond Nuclear media statement above, or the additional Beyond Nuclear comments below, to write you own for submission to MPSC.
admin
Beyond Nuclear's additional public comments*:
(1.) In a document from more than a decade ago, Palisades's previous owner, Consumers Energy, reported that it would cost $868 million to decommission Palisades (as expressed in Year 2003 dollar figures; a question is, did Consumers Energy's cost estimate for decommissioning account for 40 years of operations (1971 to 2011), or 60 years of operations (1971 to 2031, as rubber-stamped by the Nuclear Regulatory Commission in early 2007?)).
Adjusting for inflation, this cost to decommission would be $1.15 billion (as expressed in Year 2017 dollar figures.)
But in February, 2017, Entergy Nuclear admitted that there is only $426 million in Palisades's decommissioning fund.
This means that currently, there is a $724 million shortfall in decommissioning funding!
Consumers Energy (1971 to 2007) and Entergy Nuclear (2007 to present) have made the radioactive mess at Palisades, and they should be required to pay for cleaning it up!
(2.) But how can Palisades's decommissioning "only" cost $1.15 billion (as expressed in Year 2017 dollar figures)?
Palisades's sister atomic reactor, Big Rock Point in Charlevoix, was an "early atomic joint" (as Victor McManemy's song put it), and a tiny one -- "only" 67 Megawatts-electric (MWe). And Big Rock Point "only" operated 35 years (from 1962 to 1997). In 2006, Consumers Energy reported that Big Rock Point had cost $366 million to decommission (the decommissioning took from 1997 to 2006). Adjusted for inflation to Year 2016 dollar figures, Big Rock Point's decommissioning cost $447 million.
But Palisades is 800 MWe, nearly a dozen times larger in size than Big Rock Point. And Palisades has already operated for 46 years (1971 to 2017), and plans to operate another 1.5 years. Palisades's 47.5 years of operations is significantly longer than Big Rock Point's 35 years of operations.
Multiplying $447 million by 12 (how much bigger Palisades is than Big Rock Point) means a ballpark figure for Palisades's decommissioning should be more like $5.36 billion (with a B!). It stands to reason that Palisades should cost more to decommission than Big Rock Point, as well, because it will have operated for 12.5 years longer, thus allowing for more radioactive contamination of the surrounding environment, as well as the plant's infrastructure.
A complicating factor is that Big Rock Point was also a very messy "atomic joint," essentially an experimental reactor that had large-scale radioactivity releases, as due to broken experimental fuel rods (including mixed oxide plutonium, MOX) in the operating core, as well as due to leaks and spills. This is documented in a 2006 NIRS report.
(Additional concerns about the inadequate cleanup of radioactive contamination at Big Rock Point can be found here, including press statements by NIRS, Don't Waste Michigan, Coalition for a Nuclear-Free Great Lakes, and a large coalition of Michigan groups -- many of which happen to be actively engaged in Palisades issues, more than a decade later!)
However, Palisades also has a notorious record of leaks and spills, meaning significant radioactive contamination of the soil and groundwater, as well as Lake Michigan sediments -- not to mention the nuclear power plant's own physical infrastructure.
Another factor that would boost Palisades's decommissioning price tag significantly, would be a requirement for a comprehensive cleanup of radioactive contamination. Incredibly, the U.S. Nuclear Regulatory Commission's regulations for decommissioning only require cleanup down to a depth of several inches, or a few feet at most, regardless of how deep the contamination goes.
Palisades's tritium and other radioactive releases into soil and groundwater (see the Palisades chapter in this Beyond Nuclear report) could easily extend down tens of feet in the soil and groundwater (and even Lake Michigan sediments), if not more. (At the Connecticut Yankee atomic reactor, for example, contamination extended down hundreds of feet, according to Deb Katz, executive director of Citzens Awareness Network.) Making the contamination risks at Palisades all the worse, the 200 cottages immediately next door, at the more than century-old Palisades Park resort community, still draw drinking water from wells; if the contaminated groundwater under Palisades interacts with the well water at Palisades Park, residents could drink (or bathe, wash with, cook with, etc.) concentrated doses of radioactive contamination. This is beyond hypothetical. Tritium leaks and concentrated contamination in groundwater impacted the community at Godley Park, IL, neighboring Exelon Nuclear's Braidwood atomic reactors (see relevant chapter in Beyond Nuclear report).
(3.) Jessica Azulay of AGREE (Alliance for a Green Economy) and Tim Judson of NIRS (Nuclear Information and Resource Service) co-authored a white paper regarding the permanent shutdown of Entergy's FitzPatrick atomic reactor on the Lake Ontario shore in upstate New York. See "REPLACING FITZPATRICK: How the Closure of a Nuclear Reactor can Reduce Greenhouse Gasses and Radioactive Waste, while Creating Jobs and Supporting the Local Community."
Dave Kraft of NEIS (Nuclear Energy Info. Service of Chicago) authored position papers on permanent shutdowns at Illinois atomic reactors, drawing lessons from the shutdown of Zion Units 1 and 2 on the Lake Michigan shore, 30 miles north of Chicago. See, for example, "The Need to Formally Establish a Planned Economic Mitigation Fund for Reactor Communities in Illinois," and "WATCHDOGS: Zion's nuclear fallout; still reeling from '98 closing," Chicago Sun-Times, Jan. 7, 2017.
Their white papers emphasized the vital importance of prioritizing a "just transition" not only for the closing atomic reactors' workforce, but also for the host communities, such as in terms of tax revenues. These are important principles to apply at the Palisades atomic reactor on the Lake Michigan shore.
(4.) Regarding Palisades's on-site irradiated nuclear fuel, Hardened On-Site Storage (HOSS), as close as possible to point of generation as possible, as safely as possible, is the wisest course of action in the interim, although it is certainly not a permanent solution. Michigan organizations -- including Citizens for Alternatives to Chemical Contamination, Citizens Resistance at Fermi Two, Coalition for a Nuclear-Free Great Lakes, Don't Waste Michigan, IHM Sisters Justice, Peace, and Sustainability Office, International Science Oversight Board-Organic Consumers Association, Izaak Walton League-Dwight Lydell Chapter, Lone Tree Council, Kalamazoo Non-violent Opponents of War, Michigan Environmental Council (itself a coalition of more than 70 groups), Swords Into Plowshares Peace Center & Gallery, Voices for Earth Justice -- have joined with hundreds of others across the country, representing all 50 states, to endorse HOSS.
HOSS, as close, as safely as possible, to point of generation, is a much preferable alternative to rushing headlong into barge shipments of high-level radioactive waste on Lake Michigan. The U.S. Department of Energy (DOE) proposed such barge shipments, from Palisades to the Port of Muskegon (as well as from Wisconsin's three Lake Michigan shoreline reactors, into the Port of Milwaukee), as part of its scheme to dump irradiated nuclear fuel at Yucca Mountain, Nevada. A single sinking, from the 453 proposed barge shipments on Lake Michigan, could spell radioactive catastrophe for the headwaters of the drinking water supply for 40 million people downstream in the U.S., Canada, and Native American First Nations -- the Great Lakes.
Centralized interim storage facility schemes -- as targeted at Waste Control Specialists, LLC in Andrews, Texas, and the Eddy-Lea [Counties] Energy Alliance in southeastern New Mexico -- could also launch such barge shipments on Lake Michigan (Palisades and the Wisconsin reactors lack direct rail access; to ship the 100+ ton transport containers, either barges -- or else heavy-haul trucks -- would be needed to transfer the containers from Palisades, to the nearest railhead, for train shipment out West.)
Yucca Mountain, Nevada, and the de facto parking lot dumps targeted at sites just 35 miles apart, across the Texas-New Mexico border, also fail basic tests of acceptability. They violate environmental justice principles (Yucca Mountain is Western Shoshone Indian land, as recognized by the "peace and friendship" Treaty of Ruby Valley, signed by the U.S. government in 1863; the Texas-New Mexico border "nuclear sacrifice zone" is home to a large percentage of Latin American/Hispanic residents). In addition to these lands being home to people of color communities, there are also significant percentages of residents of low income in these places. Lastly, these sites are already heavily polluted (Yucca Mountain is near the Nevada Test Site, scene of many hundreds of above- and below-ground nuclear weapons test blasts since 1951; the Texas-New Mexico borderlands have extensive fossil fuel extraction, as well as nuclear ("low-level" radioactive waste dumping, and uranium enrichment) industries. Further targeting them for these radioactive waste dumps is a text book case of environmental injustice, or radioactive racism.
Neither Yucca Mountain, nor the de facto permanent parking lot dumps, have obtained consent from the targeted communities, violating the Final Report (Jan. 2012) top recommendation of the Blue Ribbon Commission on America's Nuclear Future.
Besides all that, they are scientifically unsuitable, risking failure and catastrophic releases of hazardous radioactivity into the environment.
For all these reasons, and many more, HOSS, as close, as safely as possible, is the preferred interim alternative.
(5.) Entergy is taking steps in Vermont to sell its permanently closed Vermont Yankee atomic reactor site to a company, NorthStar, that is but a startup in the nuclear decommissioning field. NorthStar is comprised of a consortium of several other companies, including Waste Control Specialists, LLC (see above), and Transnuclear (Areva of France). Prior to WCS and Areva's involvement, NorthStar partners' experience in nuclear decommissioning included only a single small-scale research reactor, not full-size commercial atomic reactors like Vermont Yankee, or now Palisades.
At an Entergy open house held at its Emergency Operations Center in Benton Harbor, MI on March 29, 2017, a Palisades employee confirmed openly that NorthStar would very likely take over the Palisades site after the reactor's October 2018 permanent closure. However, during the formal presentations and question and answer period of the open house, higher level Entergy Palisades spokesmen denied a decision has been made to sell the Palisades site to NorthStar. But given Entergy's association with NorthStar at Vermont Yankee, chances are good that this is in fact the plan, whether Entergy Palisades will currently admit it or not.
Some problems with NorthStar's plans include the fact that its major partners are either bankrupt, or on the verge of it.
Areva of France has been in financial free fall for several years. The only reason that it didn't cease to exist long ago, is that it is majority French government owned, meaning it has the full faith and credit of the French treasury backing it up (meaning French taxpayers are being gouged!). Areva also has some serious skeletons in its closet. For example, Areva had a plague of externally contaminated high-level radioactive waste shipments in France. This came to light only because it was revealed by investigative journalists and environmental watch-dogs, not through admissions by Areva or French government regulators. Shipments were contaminated on their exterior surface, giving off radioactivity dose rates on average 500 times "permissible" (not to be confused with "safe") doses; one shipment was emitting dose rates 3,300 times "permissible"! Although workers were at most risk, given how closely they have to interact with the shipping container, innocent public bystanders were also put at increased risk.
WCS, NorthStar's other major nuclear industry partner, is itself facing grave financial challenges. In fact, this has led WCS to request of the U.S. Nuclear Regulatory Commission (NRC), that its application to construct and operate a centralized interim storage facility (see above) for commercial irradiated nuclear fuel, be suspended. WCS is hoping that its competitor in the "low-level" radioactive waste dumping business, EnergySolutions of Utah, will simply take it over, to save it from financial failure. However, the U.S. Justice Department filed an anti-trust lawsuit against the merger in 2016; legal hearings were just held in Delaware, where WCS is incorporated, concerning the monopolization risks.
How much sense does it make to entrust Palisades's radioactive contamination cleanup, and high-level radioactive waste management, to a consortium, NorthStar, whose constituent companies -- WCS, Areva -- have so many skeletons in their closet, and are on the brink of financial failure?! It's a recipe for disaster, especially considering Palisades's woefully underfund decommissioning coffers! NorthStar would undoubtedly cut corners on safety, security, health and environmental protection, in order to just break even, let alone make a profit.
*Please note that Beyond Nuclear's Kevin Kamps attempted to deliver these additional comments, above, orally at the evening session of the MPSC public comment meeting in Lawrence, MI on May 8, 2017.
However, because Kamps had submitted ten minutes worth of oral public comments during the prior session, he was not allowed to do so.
This despite the fact that these additional comments were not a repeat of the earlier comments.
Most absurdly, because MPSC made an ad hoc decision, that those who spoke in the previous session, could not speak in the later session. They stood by this on-the-spot, arbitrary and capricious policy, even though only a few new people making oral submissions came to the later session.
The MPSC policy resulted in well over half of the second session being wasted in repeated breaks, as no new persons wishing to make public comment stepped forward.
Kamps was not the only advocate for Palisades's closure who wished to speak again in the second session, after having spoken in the previous session.
What made this MPSC on-the-fly policy all the more frustrating, and wasteful, was that the agency had brought at least ten staffpersons, including the three commissioners and an administrative law judge, as well as a court stenographer, from Lansing to Lawrence. Why so much time, as well as ratepayer and/or taxpayer money, would be wasted on a policy of not receiving public comment from persons wishing to make it, went unexplained.
Making the policy even more inexplicable is comparing it to the MPSC policy on written submissions, which is for unlimited numbers of written submissions, of unlimited length. This is an appropriate and appreciated policy regarding written submissions, but it makes the MPSC's strict limits on orally submitted comments all the more inexplicable.
Well, let's take them up on that offer, in terms of both quantity and quality, and generate as many written comments as possible, that are as comprehensive as possible, calling strongly for Palisades's closure, by October 2018 at the very latest! Shutdown before meltdown!
