Entergy Palisades taking major safety shortcuts with degraded steam generators, with NRC complicity
Entergy Nuclear's Palisades atomic reactor in Covert, MI on the Lake Michigan shoreline in s.w. Michigan.In 2006, the previous owner of the problem-plagued Palisades atomic reactor (see photo, left) -- Consumers Energy -- persuaded the Michigan Public Service Commission (MI PSC) to approve its sale to Entergy Nuclear. (See Consumers Energy slide from spring 2006 presentation to MI PSC.) Consumers Energy argued that it lacked the wherewithal to fix major problems -- to anneal the badly embrittled reactor pressure vessel, and to replace the age-degraded reactor lid and steam generators -- but that the new owner, Entergy, would do so.
(The steam generator replacement would be the second in Palisades' history, the first having been in 1991. Arnie Gundersen, Chief Engineer of Fairewinds Associates, Inc. and an expert witness for Beyond Nuclear and a coalition of environmental groups intervening against Palisades on safety issues, has confirmed that no other pressurized water reactor in the U.S. has replaced its steam generators twice.)
A decade after Consumers Energy told the MI PSC that Entergy would do so, none of these fixes have been made. Nor is there any plan to do so. But then again, Entergy's merchant nuclear fleet unwritten business model seems to be "Buy reactors dirt cheap, and run them into the ground!"
And U.S. Nuclear Regulatory Commission (NRC) is guilty of complicity and collusion in allowing such safety risks to fester to the breaking point.
A breach of the reactor pressure vessel due to pressurized thermal shock; a breach of the corroded reactor lid; or a cascading failure of steam generator tubes -- each of these could lead to a reactor core meltdown. Failure of containment structures, systems, and components could then cause a catastrophic release of hazardous radioactivity to the Great Lakes environment.
In 2012, the Japanese Parliament's independent investigation concluded that the root cause of the Fukushima nuclear catastrophe was collusion between industry, safety regulator, and government officials. Such collusion exists in spades at Palisades, between Entergy, the Nuclear Regulatory Commission, and government officials like U.S. Rep. Fred Upton (R-MI), who chairs the powerful U.S. House Energy and Commerce Committee, with direct oversight on NRC and nuclear safety, and in whose district Palisades is located.
Michael Keegan of Don't Waste Michigan has prepared the following docket of documentation regarding steam generator risks at Palisades:
Arnie Gundersen, Chief Engineer of Fairewinds Associates, Inc., has reviewed the NRC-Entergy communications and documentation, and concluded: "...[T]hese inspection and repair changes make it a greater risk to operate Palisades in this condition...".
With a License Amendment Request comes the opportunity for a request for public hearing.
There were some questions that the NRC did ask known as Requests for Additional Information or RAIs. Today in ADAMS [NRC's Agency-wide Documents Management System] I found Entergy's Response to those RAIs - this document has not yet been reviewed by looks to provide review of the criteria by which the tubes will be plugged or not plugged:
June 7, 2016, Entergy Palisades to NRC; SUBJECT: Response to - Palisades Nuclear Plant - Request for Additional Information Regarding the License Amendment Request for Implementation of an Alternate Repair Criterion on the Steam Generator Tubes (CAC No. MF7435) [PNP 2016-037]
The document I found today, June 20, 2016, has the ML#: ML16159A230. It is dated June 7, and was docketed June 13.
Bottom line results in increased risk to public.
The above documentation was compiled by Michael J. Keegan with Don't Waste Michigan on June 20, 2016.
Also, on May 19, 2016, Michael Keegan shared the following (the documentation below is also posted here as a PDF):
Palisades Steam Generator Reviewers,
Below is a reverse chronology (with hot links) of documents pertaining to License Amendment Request at Palisades regarding components of the Steam Generators at Palisades which were announced in 2006 to be in need of total replacement. This Steam Generator replacement was to have occurred in 2016 it did not.
ML16130A076 5/11/2016
Palisades Nuclear Plant - Request for Additional Information Regarding the License Amendment Request for Implementation of an Alternative Repair Criterion on the Steam Generator Tubes (CAC No. MF7435).
ML16084A333 4/04/2016
Palisades Nuclear Plant - License Amendment Request - Revision to the Requirements for Steam Generator Tube Inspections and Repair Criteria in the Cold Leg Tube Sheet Region (CAC No. MF7435).
ML16043A485 3/14/2016
Palisades Nuclear Plant - Relief Request Number RR 4-24 - Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination (CAC No. MF6755).
ML16075A103 3/03/2016
Palisades - License Amendment Request - Revision to the Requirements for Steam Generator Tube Inspections and Repair Criteria in the Cold Leg Tube Sheet Region.
ML16035A425 3/01/2016
Summary of January 25, 2016, Pre-Application Teleconference Meeting with Entergy Nuclear Operations to Discuss a Forthcoming License Amendment Request Regarding Steam Generator Cold Leg Alternate Repair Criteria at Palisades Nuclear Plant (CAC No. MF7060
ML13149A052 4/25/2013
April 25, 2013 Letter to Tim Mitchell, Entergy from William Magwood re: Palisades.
The next four documents are REFERENCES for LICENSE AMENDMENT REQUEST of 3/03/206 (ML16075A103 - Above)
Entergy Nuclear Operations, Inc., letter to NRC, PNP 2011-035, Withdrawal of License Amendment Request for Steam Generator Cold-Leg Tubesheet Inspection, dated April 19, 2011 (ADAMS Accession Number ML 111090424) ML111090424
NRC letter to Entergy Nuclear Operations, Inc., Palisades Nuclear Plant-Supplemental Information Needed for Acceptance of License Amendment Request for Steam Generator Cold-Leg Tubesheet Inspection (TAG No. ME5780), dated April 5, 2011 (ADAMS Accession Number ML 110910558) ML110910558
Entergy Nuclear Operations, Inc., letter to NRC, PNP 2011-11, License Amendment Request for Steam Generator Cold-Leg Tubesheet Inspection, dated March 3,2011 (ADAMS Accession Number ML 110680342) ML110680342
NRC letter to Entergy Nuclear Operations, Inc., Palisades Nuclear Plant-Issuance of Amendment Re: Tubesheet Inspection Depth for Steam Generator Tube Inspections (TAG No. MD2125), dated May 31, 2007 (ADAMS Accession Number ML071420216) ML071420216
Historical documents pre-dating sale.
ML062640588 10/16/2006
G20060792 - John T. Larkins Ltr. re Questions Raised by Members of the Public During the ACRS Subcommittee Meeting on Palisades Nuclear Plant License Renewal Application.
ML061560407 5/30/2006
Palisades - License Amendment Request Regarding Tubesheet Inspection Depth for Steam Generator Tube Inspections.
ML061560408 5/31/2006
Enclosure 5, LTR-CDME-06-80-NP, Rev 1, "Palisades Tubesheet Inspection Depth."
The Michigan Public Service Commission document referenced below is not hot linked, it does not appear in NRC system documents other than by citation in Magwood document.
http://efile.mpsc.state.mi.us/efile/docs/14992/0001.pdf
CMS letter to MPSC August 18, 2006 provides reasons for selling Palisades (see pdf page 188 for Steam Generator Replacement discussion) The need to replace the Steam Generators was known in 2006 and scheduled for replacing by 2016. Exemptions now being sought in 2016 to avoid Inspections of Cold Leg Tubes permanently. Is Entergy looking to avoid having to plug additional tubes by avoiding Cold Leg Inspections?
Cover Letter:
August 18, 2006
Ms. Mary Jo Kunkle
Executive Secretary
Michigan Public Service Commission
6545 Mercantile Way
P.O. Box 30221
Lansing, MI 48909
Re: Case No. U-14992
Dear Ms. Kunkle:
Enclosed, for electronic filing in the above-captioned case, are Consumers Energy Company’s Application and the testimony and exhibits of Consumers Energy Company’s witnesses William E. Garrity, David W. Joos, John J. Reed, Michael A. Torrey and Stephen T. Wawro. The Application seeks relief in connection with the sale of the Palisades Nuclear Power Plant.
Consumers Energy respectfully requests that the Commission act on the Application in an expeditious manner. This case is being filed only in PDF format.
Sincerely,
Jon R. Robinson
June 20, 2016