Comments by Beyond Nuclear's Kevin Kamps re: Holtec at Palisades [Decommissioning] Community Advisory Panel

The following comments (designed to meet the PCAP's strict three-minute time limit) were made verbally by Kevin Kamps, radioactive waste specialist at Beyond Nuclear, and board of directors member, Don't Waste Michigan, at the April 13, 2022 Palisades [Decommissioning] Community Advisory Panel, held at Lake Michigan College in South Haven, MI:

Holtec CEO Krishna Singh has floated the trial balloon of building one or more so-called Small Modular Nuclear Reactors at Palisades, according to an article by Ben Weiss dated April 8 in ExchangeMonitor. We had long feared this, since Holtec had already pulled this bait and switch at Oyster Creek, New Jersey.

Here is the relevant passage from the end of the article. And I quote:

Meanwhile, Holtec would also consider similar SMR projects at some of its other decommissioning sites such as the Palisades plant in Michigan, Singh said Tuesday.

However, he said the company would not propose advanced reactors for some decommissioning sites — particularly New York’s Indian Point and Massachusetts’s Pilgrim plant — because of local resistance. “They would burn us in effigy if we even said that, never mind build one,” Singh said.

End quote.

So I suppose if Palisades is fair game, so too then is Big Rock Point, also on the Lake Michigan shore, near Charlevoix in northern Michigan? Holtec has also applied to take it over from Entergy.

My response? Over my dead body.

If Krishna Singh thinks the Lake Michigan shore in West Michigan is easy prey for targeting his SMRs, he has revealed his profound ignorance of the proud and effective history of the anti-nuclear movement in Michigan dating back 65 years, when Leo Goodman of the UAW presciently sued the Atomic Energy Commission to prevent the construction of the now infamous “We Almost Lost Detroit” Fermi 1 reactor.

This history includes: Don’t Waste Michigan’s blocking of an 8-state so-called “low-level” radioactive waste dump targeted at us; stopping the Midland Nuclear Power Plant, and other proposed reactors like Fermi 3, dead in their tracks; a groundswell of resistance, including Eternal General Frank Kelley, against Palisades’ dangerous Lakeside dry cask storage in the first place; the shutdown for good of Big Rock Point, and fending off a state park there, due to the lingering, hazardous radioactive contamination of soil, groundwater, and Lake Michigan sediments.

It may have taken us more than 50 years, but the very high risk Palisades atomic reactor itself is now shutting down for good by May 31st. Some local resisters have fought Palisades from pre-construction right up to the present. This includes friends of mine in Kalamazoo, who gathered petition signatures against Palisades before it was built. This also includes Maynard Kaufman of Bangor, founder of the Michigan Organic Food and Farm Alliance, who passed on last summer. In fact, he and his recently departed wife, Barb Geisler, as members and supporters provided Beyond Nuclear with legal standing in our intervention against Holtec’s takeover of Palisades and Big Rock Point, in Feb. 2021, regarding which, 14 months later, we are still waiting on NRC to give us our day in court.

Krishna Singh suggested a burning in effigy. Actually, our forté has been street theater featuring the tarring and feathering of Springfield Nuclear Power Plant owner Mr. Burns from The Simpson’s, but we can be flexible.

Don’t even think about it, Holtec.

Comments by Kraig Schultz of MSEF at the PCAP

The following comments were delivered by Kraig Schultz of the Michigan Safe Energy Future-Shoreline Chapter at the Palisades [Decommissioning] Community Advisory Panel at Lake Michigan College in South Haven, MI on April 13, 2022:

Hello, my name is Kraig Schultz.  I live 50 miles from Palisades.  I am a member of Michigan Safe Energy Future.    I have four comments and I have questions to go with each comment:

My first comment:

The risk of a Chernobyl-scale nuclear accident at Palisades will continue until several years after the plant stops producing electricity.  NRC report, NUREG-1738, entitled “Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants” identifies there is a risk of having a fire in the spent fuel pool until all the fuel bundles are safely transferred from the Spent Fuel Pool to dry cask storage.  It generally takes several years for spent fuel to cool down in the spent fuel pool before it is safe enough to transfer it to dry casks.

So, there is a risk that this plant could cause a major nuclear accident while Holtec owns it.

My questions are, “How much experience does Holtec have with maintaining spent fuel pools?”    “What assurance do we have that Holtec can or will maintain the staffing that it needs so that it can safely transfer the spent fuel to dry casks?”

My second comment:

On the subject of the fuel pool water and other water that may be contaminated with Radioactive particles.   Since Lake Michigan is the source of drinking water for Millions of people, Radioactive water from the plant should not be disposed into Lake Michigan.  

My question is:  How does Holtec propose to dispose of the water from Palisades during the decommissioning process?

My Third comment is:

The metal in nuclear reactors is weakened over time by neutron irradiation.  The weakened metal of the reactor pressure vessel is a risk factor that could lead to meltdowns.  The test coupons in the Palisades Pressure vessel and the metal of the pressure vessel itself can provide critical data to help improve nuclear safety at other plants around the world   Therefore, these materials must be transferred for analysis during decommissioning.

 My question is:  “When and by what methods will Holtec provide the coupons and sections of the Reactor Pressure vessel and to whom will these materials be given?”

My Fourth comment is:

Given Holtec's short history of decommissioning Nuclear Power Plants, it is important that oversight is present to ensure Holtec is held accountable to complete the work described in the PSDAR safely, successfully and within budget.  

My questions are:  “Who is providing this oversight?”  “Will the public have a way to monitor this oversight?”  “How and on what dates will the public have this opportunity for oversight?”

Comments by Beyond Nuclear's Kevin Kamps re: economic analysis at the Palisades [Decommissioning] Community Advisory Panel

The following comments (designed to meet the PCAP's strict three-minute time limit) were made verbally by Kevin Kamps, radioactive waste specialist at Beyond Nuclear, and board of directors member, Don't Waste Michigan, at the April 13, 2022 Palisades [Decommissioning] Community Advisory Panel, held at Lake Michigan College in South Haven, MI:

I would like to say a word about radioactive stigma effect, which I raised at the last meeting as well. Radioactive stigma effect is the negative impact on real estate property values, and other economic sectors, associated with nuclear risks. This includes local real estate property values, the tourism and recreation industries, agriculture and other sectors of the economy.

Radioactive stigma will result from the significant amounts of lingering hazardous radioactive contamination Holtec intends to leave behind, in soil, groundwater, and Lake Michigan sediments, with a wink and a nod from NRC.

Yet more radioactive stigma will result from Holtec dumping radioactive water from the indoor wet storage pool into Lake Michigan, as well as other radioactive wastewater streams during decommissioning. More stigma will result due to high-risk barge shipments of radioactive waste on Lake Michigan, including intensely contaminated steam generators, as well as hundreds of casks of highly radioactive irradiated nuclear fuel.

Another radioactive stigma has to do with reactor pressure vessels. Holtec is already in possession of the third worst embrittled reactor pressure vessel in the country, the closed Indian Point 3 in NY. If Holtec gets its way, it will also soon be in possession of the single worst embrittled reactor pressure vessel in the country, Palisades. Despite this, Holtec — as well as Entergy, and even NRC — are displaying a curious incuriosity about the actual physical status of these dangerously embrittled reactor pressure vessels, and even of some remaining metallic coupons or capsules which were intended to be tested for embrittlement, and yet never have been, and likely never will be. The plan is simply to bury all of this as waste, in leaking so-called “low-level” nuke dumps, such as Waste Control Specialists in Texas, above the Ogallala Aquifer, surrounded by majority Latin American communities. All the embrittlement data would be wasted, lost, literally covered up.

This would be a mistake. Because after IP3, and the Palisades shut down, the worst embrittled RPV in the US will be Point Beach Unit 2, on Wisconsin’s Lake Michigan shore. Rather than shutting down after 50 years of operations like Palisades and IP3, however, Point Beach 2 plans to operate for another three decades, out to 80 years. This will really test NRC’s and industry’s false confidence about RPV embrittlement risks.

A meltdown at Point Beach would represent a radioactive stigma impact of catastrophic proportions. Imagine the economic impact on all economic sectors in southwest Michigan, to be downwind and downstream of a catastrophic reactor meltdown across the Lake. One that could have been prevented, if only Holtec, Entergy, NRC, and the nuclear industry writ large, had performed basic scientific and engineering due diligence, to test their overly optimistic computer models and hypothesis against the real world physical data, and apply lessons learned at Point Beach.

In Japan, when the worst embrittled reactor, Genkai 1, was actually physically tested post-Fukushima for embrittlement, it was discovered that the computer models were overly optimistic. Embrittlement was much worse than the hypotheses had predicted. The reactor was quickly shut down for good.

Comments made by Michigan Safe Energy Future's Iris Potter at the Palisades [Decommissioning] Community Advisory Panel

Iris Potter of the Michigan Safe Energy Future-Kalamazoo Chapter and Palisades Shutdown Campaign made the following comments at the PCAP at Lake Michigan College in South Haven, MI on April 13, 2022:

Good Eve. PCAP members: 

I’m Iris Potter with Michigan Safe Energy Future-Kalamazoo. I love Lake Michigan with all my heart and its land habitat. But, I am very concerned about Decommissioning with all its moving parts and how it will affect all of it including our health. 

Regarding Holtec’s Safety

Program, there are issues that the Panel and the Public should know. 

-There was a near drop of a fully-loaded Holtec UMAX dry cask due to the bad design of the storage system at the San Onofre plant as well as gouging of the exteriors of the casks containers which will accelerate corrosion and ultimate container failure.

 -Regarding the NJ “Oyster Creek Update”  there was a dousing and dosing of a worker due to Holtec's rush job during irradiated nuclear fuel transfer from indoor wet storage pool to dry cask storage. It is one thing to accelerate a timeline but this is dangerous material. There is also no mention of your contingency plan in the event of a cask problem which was to rush a spare transport cask from the NJ HQ’s to Oyster Creek as an emergency interim place to transfer the irradiated nuclear fuel from the problem cask into it. 

Question: Palisades is pretty far from HQs so what is the contingency plan? 

Question: How long would a transport cask serve as interim emergency storage and there is over heat like in a Holtec cask in TX, for one, where water is put in regularly to keep it cool.  

Holtec casks are thin-walled by design and: 

Vulnerable to short-term cracking 

Cannot be inspected inside or out

Cannot be repaired  

Cannot be monitored or maintained to prevent leaks

Vulnerable to explosions

And they rust. 

Each canister has as much highly radioactive cesium as was released from Cherynobl at the 1986 explosion. 

The new casks are heavier, hold more waste, more heat, more radioactivity with high burn-up fuel and greater potential for catastrophes. 

Also, Holtec plans to move the 13 1800 Ton old casks from above the beach at Palisades where they have been for about 29 years back inland closer to Van Buren State Park boundaries and Palisades Park Community. This is concerning due to the unknown gamma ray and neutron dose emissions from these degraded casks and the newer ones, especially since one old has had weld issues since early on. Both the beach and inland do not meet earthquake safety standards but this has been passed off too. Plus, the beach gets closer all the time with high waters and extreme storms now. 

Question: What kind of testing has been done to learn how much these old casks are degraded? 

We continue to advocate for Hardened Onsite Storage or HOSS but the NRC continues to approve the minimal thin wall casks. We deserve the best at this old plant but it is because of money. So, no accelerated rush job here, please. 

Question: What is the air, land and water protocol for radiation monitoring to be? And, we do encourage independent monitoring. 

Questions:  Due to risk concerns, will PCAP be meeting more than 4 times annually as the Chairman can request so the public can be more fully engaged and informed? If undecided, I request it. 

Also, there is one less Public Comment slot at this 3rd meeting and Question, why is that? I request that a last Public Comment slot be re-instated nearer the end of meetings so the public can ask final questions. 

—————————————

Thank you all, 

Iris Potter,

Michigan Safe Energy Future-Kalamazoo

Environmental Coalition Condemns NRC Approval of Holtec Takeover of Palisades Atomic Reactor:

NEWS FROM BEYOND NUCLEAR

For immediate release

Contact:

Terry Lodge, legal counsel, Toledo, OH, (419) 205-7084, tjlodge50@yahoo.com

Michael Keegan, Co-Chair, Don't Waste Michigan, Monroe, MI, (734) 770-1441, mkeeganj@comcast.net

Kevin Kamps, Radioactive Waste Specialist, Beyond Nuclear, Takoma Park, MD, (240) 462-3216, kevin@beyondnuclear.org

Bette Pierman, President, Michigan Safe Energy Future, Benton Harbor, MI, (269) 369-3993, bette49022@yahoo.com

Gail Snyder, Board President, Nuclear Energy Information Service, Chicago, IL, (630) 363-6417, gail.snyder@comcast.net

Environmental Coalition Condemns NRC Approval of Holtec Takeover of Palisades Atomic Reactor

Beyond Nuclear, Don't Waste Michigan, and Michigan Safe Energy Future Had Petitioned U.S. Nuclear Regulatory Commission, Raising Health, Safety, Environmental, and Financial Concerns

[WASHINGTON, DC and COVERT, MI – December 13, 2021] -- Nearly ten months after having met the agency’s arbitrarily short 20-day legal deadline last February, the U.S. Nuclear Regulatory Commission (NRC) has rejected a petition to intervene and request for hearing to NRC. The petition was submitted on behalf of members of the environmental groups by Toledo, OH attorney Terry Lodge, and backed by expert witness Robert Alvarez, senior scholar at the Institute for Policy Studies in Washington, D.C. Some of the legal standing declarants live less than a mile from the Palisades nuclear power plant on the Lake Michigan shoreline.

NRC announced its “Notification of Significant Licensing Action” on Dec. 6, stating that its approval for Palisades’ license transfer from Entergy to Holtec would occur “on or around December 13.” NRC issued its official approval today. The license transfer would take effect shortly after Entergy’s previously announced permanent closure of the half-century old Palisades atomic reactor, by May 31, 2022.

“Not only did NRC force us to meet an impossibly short deadline last February, but then it made us wait nearly ten months, without a peep, only to deny us any hearing on our very serious environmental, health, safety, and fiscal concerns,” said Michael Keegan of Monroe, MI, Don’t Waste Michigan Co-Chairman. “We have been denied our due process rights by this rogue federal agency, captured by the industry it is supposed to regulate,” Keegan added.

“In response to this shocking ruling by the NRC commissioners and staff, I will confer with my clients, to seriously consider an appeal to federal court,” said Terry Lodge, the environmental coalition’s legal counsel.

Chicago-based Environmental Law and Policy Center, as well as the Office of State of Michigan Attorney General, Dana Nessel, had also petitioned NRC for a hearing, in opposition to the Holtec takeover of Palisades.

The environmental coalition’s legal and technical challenges opposed to current owner Entergy Nuclear's license transfer to Holtec International for decommissioning purposes and high-level radioactive waste management include Holtec's disqualifying bad corporate character, and its unacceptable bids to drain the already woefully inadequate Nuclear Decommissioning Trust Fund (NDTF) for non-decommissioning expenses, such as irradiated nuclear fuel management and site restoration.

In fact, as part and parcel of its rejection of the coalition’s hearing request, and its approval of the license transfer, NRC also rubber-stamped Holtec’s waiver request to spend hundreds of millions of dollars from the Palisades NDTF on non-decommissioning expenses.

“NRC’s blank check for Holtec to misappropriate Palisades Decommissioning Trust Funds is an outrage, looting the pocketbooks of hardworking Michiganders,” said Kevin Kamps of Beyond Nuclear, who also serves as a Don’t Waste Michigan board of directors member, representing his native Kalamazoo chapter. “It will undoubtedly shortchange cleanup of radioactive contamination at Palisades, harming current and future generations’ health, safety, and environment downwind and downstream,” Kamps added.

The now rejected intervention also objected to Holtec's large underestimation of both decommissioning expenses, as well as highly radioactive irradiated nuclear fuel management expenses. For example, the coalition's expert witness, Robert Alvarez, an Institute for Policy Studies senior scholar, and a former senior advisor to the U.S. Energy Secretary, has shown that Holtec has given no consideration to high burnup irradiated nuclear fuel's higher thermal heat load and radioactivity levels, even though it comprises a large percentage of the fuel to be stored on-site, and likely for much longer than Holtec's overly optimistic year 2066 terminus date.

Lastly, the coalition has argued for NRC to undertake a Supplemental Environmental Impact Statement, to address: the site's radioactive contamination of soil and groundwater; various "low" level radioactive waste streams, such as steam generators and highly radioactive Reactor Vessel Internals; the need for repackaging irradiated nuclear fuel from non-transportable and even defective current containers into new replacement containers; and increasing radiologic risks due to the current historic high, and worsening, Lake Michigan water levels.

Holtec's proposed takeover would also include Palisades' sibling, the Lake Michigan shoreline Big Rock Point nuclear power plant site in Charlevoix, Michigan, as part of the license transfer package deal. Although NRC in 2006 approved the supposedly-decommissioned site's release for unrestricted use, watchdogs remain very concerned about significant documented radioactive contamination abandoned there. In addition, eight casks of highly radioactive waste are still stored there, with nowhere else to go.

"With no ability to unload the high-level radioactive waste from an already known defective VSC-24 cask, and potentially additional faulty casks of this and other models in the future, Entergy and Holtec have teed up a cataclysmic disaster on the shore of Lake Michigan. Lake Michigan will eventually eat Palisades, and this unaddressed problem amounts to 'Criminal Negligence,'" stated Michael J. Keegan, Co-Chairman of Don't Waste Michigan in Monroe, MI.  

"We continue to call for a safe and complete decommissioning which requires the removal of all radioactive waste that will likely be stored onsite indefinitely," said Bette Pierman, President of Michigan Safe Energy Future in Benton Harbor, MI. "It must be secured in non-permeable hard casks because of the highly radioactive waste. We strongly question Holtec International's decommissioning proposal with no guarantee of this to safeguard our health and that of our precious Lake Michigan. We also have serious concerns about the current Decommissioning Trust Funds--which were previously raided by Consumers Power and Entergy—to cover the complete costs of cleanup and restoration of the Palisades site. We do not want Holtec to leave Michigan ratepayers with a bill and a radioactive legacy," Pierman added.

"We object to NRC allowing Holtec to drain an initial $166 million, and likely more in the future, from the Palisades Nuclear Decommissioning Trust Fund for unrelated high-level radioactive waste management expenses, because that will severely shortchange the cleanup of documented extensive hazardous radioactive contamination of soil and groundwater," said Kevin Kamps, radioactive waste specialist with Beyond Nuclear, a national watchdog group based in Takoma Park, MD. "Abandoned radioactive contamination will flow downstream over time, into Lake Michigan and inland aquifers, both drinking water supplies. The radioactivity will not dilute, but rather bio-concentrate up the food chain, endangering current and future generations," Kamps added.

“As people who share the same Lake Michigan drinking water supply with 16 million other people, we are deeply concerned with how the Palisades closure and decommissioning is handled,” stated Gail Snyder, Board President of Nuclear Energy Information Service, based in Chicago, IL. “Having witnessed the numerous highly questionable dealings surrounding the decommissioning of the Zion nuclear reactors in Illinois from 2010 to the present, we are highly suspicious of Holtec’s motives and capability to conduct a credible and safe decommissioning, and skeptical that the U.S. Nuclear Regulatory Commission will do more than a check-box oversight of the project. For those reasons constant and direct oversight from state and federal legislators in Michigan is imperative,” Snyder warned.

Beyond Nuclear, Don't Waste Michigan, and Nuclear Energy Information Service have also intervened against Holtec's proposal to target majority minority (Hispanic, Indigenous) New Mexico with the country's high-level radioactive waste dump, a so-called "consolidated interim storage facility" (CISF) for irradiated nuclear fuel that risks becoming de facto permanent surface storage. Terry Lodge serves as legal counsel for Don't Waste Michigan and Nuclear Energy Information Service, and five additional grassroots environmental groups from across the U.S., in that proceeding as well. NRC has rejected all opponents' appeals, and the groups have now appealed the case to the U.S. Court of Appeals for the District of Columbia Circuit, as well as the 10th Circuit in the Southwest.

"At the very top of the list of CISF non-starters is highly radioactive waste barge shipments, from Palisades to the Port of Muskegon, for offload onto a train for export out to the Southwest," said Terry Lodge, the environmental coalition's legal counsel. "Irradiated fuel sunk to the bottom of Lake Michigan could cause ruinous radioactive releases into the drinking water supply for tens of millions of people downstream in seven states, two provinces, and a large number of Indigenous Nations. Radioactive steam generator barge shipments across Lake Michigan, through Chicago's waterways, and down the Mississippi River could likewise lead to drinking water catastrophes," Lodge added.
 

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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

Update on December 14, 2021 by admin

On Dec. 14, the Detroit News reported on this story. The article, by Carol Thompson, is entitled "New Company will take control of nuclear plant along Lake Michigan shore". It quotes Beyond Nuclear's Kevin Kamps:

"...That strategy gives Holtec an incentive to rush the work and do it cheaply, said Kevin Kamps, an anti-nuclear activist with Beyond Nuclear. He said Entergy should be responsible for decommissioning Palisades since it operated the plant and should be liable for the radioactive material on site. 

Kamps said he is disappointed but not surprised that the Nuclear Regulatory Commission approved the license transfer. 

“Obviously we know what the answer is going to be," he said. "They've already given the answer. We're going to have to hunker down, appeal and decide whether we're going to appeal to the federal courts.”

Kamps said he fears the company will abandon Palisades if the cost of decommissioning is considerably higher than what is saved in the trust fund..."