COVERT TOWNSHIP, MI -- Today Beyond Nuclear and Don’t Waste Michigan filed a Freedom of Information Act (FOIA) Request with the U.S. Nuclear Regulatory Commission (NRC), seeking documentation on the severely degraded reactor pressure vessel head at the half-century old Palisades nuclear power plant, located on the eastern shore of Lake Michigan, a few miles south of South Haven. 

 

On Monday, September 14, the NRC disclosed to the public this latest “Degraded Condition” at Palisades, in Event Report number 54897. This degradation is associated with a principal safety barrier, the reactor pressure vessel head.  One day later, on Sept. 15, NRC hastily and quietly announced a poorly noticed "Public Meeting," scheduled for Monday, September 21, to review this “Degraded Condition” with representatives from Palisades's owner, Entergy Nuclear.  At this September 21 meeting, Entergy Nuclear representatives presented NRC staff, from both the agency's national headquarters in Rockville, Maryland, as well as its Midwest/Region III headquarters in Lisle, Illinois, with an "emergent alternative request" to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, related to the repair of cracked Palisades reactor pressure vessel head penetrations.  Entergy is requesting a repair that will last only 1.82 years, instead of the industry-accepted standard repair that would last 27 years.

 

Entergy Nuclear has announced permanent closure of the Palisades atomic reactor in 1.7 years from now, by May 31, 2022. However, Entergy had previously announced, in December 2016, an October 2018 date certain closure for Palisades, only to later renege. NRC has rubber-stamped a 60-year operations license at Palisades, which does not expire until 2031.

 

"Entergy is looking for the NRC to approve a 'loophole' in the ASME code," stated Arnold Gundersen, nuclear engineer with Fairewinds Energy Education. Gundersen has previously served as Beyond Nuclear and Don't Waste Michigan's expert witness, regarding Palisades's reactor pressure vessel neutron radiation embrittlement pressurized thermal shock risks.

 

The ASME code is the national boiler and pressure vessel code. Any industrial application holding pressure must meet the ASME code. The ASME code is well thought out, and worked out, by experts, and dates back to the era of steam engines, but also applies to nuclear power plants.

 

In spite of the poorly noticed “Public Meeting,” several members of the public did attend the September 21 teleconference. The public watch-dogs and concerned citizens included: Kraig Schultz of Michigan Safe Energy Future (MSEF) in Grand Haven, MI: Michael Keegan of Don't Waste Michigan in Monroe, MI; Jan Boudart of Nuclear Energy Information Service (NEIS) in Chicago, IL; and Kevin Kamps of Beyond Nuclear in Takoma Park, Maryland.

 

MSEF's Kraig Schultz spoke out in opposition during the meeting, sharing his concern about undue, excessive risk being incurred by the public.  In a letter to NRC, dated Monday, Sept. 28, Mr. Schultz wrote: "On Monday, September 21, 2020, Palisades Nuclear Power plant operators announced that they are planning to skip important steps in repairing the cracks that have developed since 2018.  Palisades operators are asking the NRC to give it permission to skip these steps. …The NRC should not allow Palisades operators to bully it or force the approval of lower quality repair procedures.  Catastrophic failure events often do not happen in isolation.  They can result from cascading failures of seemingly tiny things that snowball into major events...”.

 

NEIS board member Jan Boudart expressed frustration with the NRC creating silos, and in doing so refusing to answer her questions, and avoiding meaningful dialogue on the extreme neutron radiation embrittlement of the Palisades reactor pressure vessel.  Her comments can be heard at the following link to an audio recording of the September 21 NRC-Entergy Palisades public meeting (the recording takes less than a minute to download and open): https://drive.google.com/file/d/17w2c2Elzi4t3Fnjqvx4Zf2wLIiqPI5Ki/view  

 

The comments by the four members of the public begin with Kraig Schultz at the 39 minute and 25 second mark on the audio recording. In addition to Schultz and Boudart, public comments also came from Kevin Kamps of Beyond Nuclear, and Michael Keegan of Don't Waste Michigan.  

 

"As we've documented for decades, Palisades has one of the worst neutron-embrittled reactor pressure vessels in the country, and in the world," said Kevin Kamps of Beyond Nuclear, based in Takoma Park, Maryland. "Activation of the emergency core cooling system, as due to failure of this 'Band-Aid' repair job proposed for the vessel head, could cause a pressurized thermal shock of the reactor pressure vessel, resulting in a through-wall fracture, and inevitable reactor core meltdown," Kamps added.

 

"Band-Aid" is not hyperbole, but an actual quote. It is the phrase that some workers at Entergy Nuclear Palisades are using, to refer to the proposed repair. The quote was overheard by an anonymous source in a position to know, and communicated to Kevin Kamps.

 

A 1982 report, commissioned by NRC, and carried out by Sandia National Laboratory in Albuquerque, New Mexico, estimated shocking casualty figures, and property damage, downwind and downstream of Palisades, in the event of a reactor core meltdown. The report is most commonly referred to as CRAC-II (CRAC is short for Calculation of Reactor Accident Consequences), but is also known as the Sandia Siting Study, or NUREG/CR-2239 (NUREG refers to Nuclear Regulation; CR is short for Contractor Report).The CRAC-II report estimated 1,000 "peak early fatalities" (acute radiation poisoning deaths), 7,000 "peak early [radiation] injuries," and 10,000 "peak cancer deaths" (latent cancer fatalities), to be expected downwind and downstream of a reactor core meltdown at Palisades, and consequent large-scale release of hazardous ionizing radioactivity into the environment. The CRAC-II study also estimated $52.6 billion in property damage downwind and downstream of a Palisades meltdown.

 

However, as reported by Associated Press investigative reporter Jeff Donn after the Fukushima nuclear catastrophe in Japan, in 2011, in a four-part series entitled "Aging Nukes," populations have soared around atomic reactors like Palisades since 1982, so casualty figures would be significantly worse in 2020. And when adjusted for inflation alone, the property damage figures, expressed in Year 2019 dollar figures, would surmount $141 billion. Donn also cited reactor pressure vessel neutron embrittlement safety standard rollbacks as a top example of NRC regulatory retreat, and capture of the so-called regulator by the industry.

 

Michael J. Keegan with Don’t Waste Michigan stated “This alternative repair amounts to an experiment that the NRC should not condone.  Entergy is a Limited Liability Company (LLC), and with tens of thousands of lives, all of Lake Michigan, and hundreds of billions of dollars in property damage on the line, the NRC must not approve this make-shift 'Band-Aid' repair.  This experiment must not be approved.”

 

For comprehensive documentation, please visit the Beyond Nuclear webpage at this link, http://www.beyondnuclear.org/safety/2020/9/26/documentation-re-entergy-palisades-request-to-nrc-for-permis.html, or reach out to the contacts listed above.