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