Nuclear safety is, of course, an oxymoron. Nuclear reactors are inherently dangerous, vulnerable to accident with the potential for catastrophic consequences to health and the environment if enough radioactivity escapes. The U.S. Nuclear Regulatory Commission, Congressionally-mandated to protect public safety, is a blatant lapdog bowing to the financial priorities of the nuclear industry.



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.

How do we best pin the NRC down on the need to replace the steam generators and what will be the inspection schedule, disclosure, criteria under which NRC allows them to operate. Is this merely a function of Entergy determining law of diminishing efficiency returns? Or will the NRC ever shut it down because of increased public risk?


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.  


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.



Jon R. Robinson


Beyond Nuclear challenges safety & security risks at Point Beach atomic reactors on Lake Michigan shore in WI

The Point Beach atomic reactors, north of Two Rivers, WI on the Lake Michigan shore.As reported by Chuck Quirmbach at Wisconsin Public Radio, regarding the U.S. Nuclear Regulatory Commission's (NRC) annual performance review of the two-reactor Point Beach nuclear power plant, owned by NextEra/Florida Power & Light, on the Lake Michigan shore:

In Wisconsin, critics and proponents of nuclear power disagree on whether the state’s sole operating nuclear plant, Point Beach, located north of Two Rivers, meets safety standards to prevent the release of potentially harmful radiation in an emergency.

The precautions that have been put in place at Point Beach may still not ward off threats like bad weather, said Kevin Kamps from the non-profit group Beyond Nuclear.

"It doesn't necessarily take an earthquake and a tsunami to catastrophically wreck a nuclear power plant. In the Great Lakes region, you have ice storms and tornados," Kamps said. "All that you need to have is loss of the electric grid – the primary source of electricity for safety systems at a nuclear power plant – and simultaneous loss of the emergency diesel generators."

If a terrorist got into a nuclear power plant, Kamps said, there's not enough protection of the radioactive waste stored in in-plant pools,

"(In-plant pools) have no robust radiological containment around them. They are simply industrial warehouse-type buildings and are mega-catastrophes waiting to happen," he said.

Kamps advocates taking more spent fuel out of the pools and placing it into concrete and steel casks in fenced-off areas outside the plant.

Beyond Nuclear, along with hundreds of environmental groups across the U.S., representing all 50 states, actually calls for Hardened On-Site Storage of existing irradiated nuclear fuel, and reactor permanent shutdown of atomic reactors ASAP, to stop the generation of any more high-level radioactive waste.

Point Beach Unit 2, and Palisades in Michigan (owned by Entergy) -- on opposite sides of Lake Michigan -- are the two worst embrittled reactor pressure vessels (RPVs) in the U.S. The Great Lakes are the drinking water supply for 40 million people in the U.S. and Canada, as well as a large number of Native American First Nations. RPV embrittlement increases pressurized thermal shock risks, a pathway to core meltdown.

WI NPR's on air report also mentioned that Beyond Nuclear's Kevin Kamps will attend the annual Midwest Renewable Energy Association festival, info. tabling and presenting "Nuclear Power Is Not the Answer" workshops alongside John LaForge of Nukewatch Wisconsin.


Our Lives are on the Line: Protestors Blockade Planned Pipeline Site Near Nuclear Plant Outside NYC

As reported by Democracy Now!:

In Peekskill, New York, just about an hour north of New York City, residents have launched a blockade in efforts to stop the construction of a gas pipeline slated to run only hundreds of feet from the aging Indian Point nuclear power plant. The proposed project has sparked concerns from residents and nuclear experts that a pipeline break could cause a catastrophic nuclear disaster that would threaten the entirety of New York City. The pipeline is being built by Spectra Energy and is officially known as the Algonquin Incremental Market Project, or AIM pipeline. Well, only hours ago, Peekskill residents and activists escalated the campaign to stop this pipeline’s construction by installing a fully sustainable shipping container at the entrance of Spectra’s work yard—complete with two activists living inside [see photo, above]. Democracy Now! was there as the blockade was launched. (Emphasis added)

The video of the news broadcast, as well as the transcript, are posted on Democracy Now!'s website.

Democracy Now! interviews Paul Blanch, an expert on nuclear power safety with decades of experience. Blanch and other interviewees discuss the risks to 20 million people within a 50-mile radius of Indian Point, should the pipeline release high-pressure fracked natural gas, and/or explode.

The interview also mentions the emergency petition just filed by Friends of the Earth (FOE) at the U.S. Nuclear Regulatory Commission (NRC), seeking to block Indian Point Unit 2's restart next month, as well as to force the shutdown of Unit 3 for an emergency inspection. FOE demands assurance that the root cause of unprecedented levels of safety-significant bolt degradation in Unit 2's reactor core be understood and addressed, before reactor restart. FOE also demands that Indian Point's owner, Entergy Nuclear, be required by NRC to inspect the currently operating Unit 3 reactor for similar, or perhaps worse, bolt degradation.


Indian Point and the Mystery of the Missing Bolts

Arnie Gundersen serves as Chief Engineer at Fairewinds Associates, Inc.As reported by Fairewinds Energy Education:

Missing bolts and “nuclear reactor” are words one generally does not want in the same sentence. However, when more than one quarter of the bolts inside an atomic reactor core go missing, the risk and concern multiply.  Listen to this breaking news Fairewinds Energy Education podcast of a formal press conference hosted by Friends of the Earth regarding its Emergency Petition to the Nuclear Regulatory Commission to Prohibit Restart of Indian Point Unit 2 and Inspect Indian Point Unit 3.

In this press conference you’ll hear Damon Moglen, Sr. Strategic Advisor with Friends of the Earth, Attorney Richard Ayers, Founder of the the Ayers Law Group, Arnie Gundersen, Chief Engineer with Fairewinds Associates [see photo, above left], and David Freeman, former chair of the NY Power Authority, the prior owner of Indian Point Unit 3, and an advisor to Friends of the Earth.

In addition to the audio recording of the press conference, Fairewinds Energy Education has also posted two reports:

Filed with the Nuclear Regulatory Commission: Friends of the Earth's Emergency Petition to Prohibit Restart of Indian Point Unit 2 and Inspect Indian Point Unit 3, May 24, 2016, Friends of the Earth

The Mystery of the Missing Bolts: New York City's Stricken Indian Point Nuclear Plant, May 24, 2016, Friends of the Earth and Fairewinds Associates.

(Gundersen has served as Beyond Nuclear's expert witness in NRC proceedings at the proposed new Fermi 3 reactor in MI, as well as the age-degraded reactors at Palisades, MI and Davis-Besse, OH.)


NRC lets Entergy get away with murder at Palisades atomic reactor

NRC file photo, showing Entergy Nuclear's Palisades atomic reactor, located on the Lake Michigan shore in Covert, MichiganBeyond Nuclear’s Radioactive Waste Watchdog, Kevin Kamps, has issued the following statement in response to the U.S. Nuclear Regulatory Commission’s (NRC) years-late and meaningless Confirmatory Order, dated May 16, 2016, regarding Entergy employees’ “willful violation” of safety regulations at the Palisades atomic reactor in Covert, Michigan on the Lake Michigan shore (see photo, left):

“NRC’s Office of Investigations’ (OI) conclusion – although it took three and a half years too long to arrive at – that Entergy employees’ violations of safety regulations at Palisades, vis-à-vis the Safety Injection Refueling Water Tank, were willful, is most significant. The cover-up of the crisis in the control room – the leakage of radioactive and acidic water from the ceiling – took place at the very same time as a very serious close call with catastrophe at Palisades.

NRC has, however, yet again betrayed its mission, to protect public health, safety, and the environment, by disregarding its own OI’s conclusions. Having ‘agreed to disagree on the issue of willfulness,’ NRC has let Entergy off the hook. These willful violations were only brought to light in the first place thanks to courageous Palisades whistleblowers, who turned to U.S. Senator Ed Markey (D-MA) for help. U.S. Representative Fred Upton (R-MI), whose job as U.S. House Energy and Commerce Committee Chairman is to oversee NRC, is entirely derelict in his duty at Palisades, putting his own constituents at increasing risk of a radioactive catastrophe. Not only Entergy, but the rest of the nuclear power industry, can thus learn the dangerous lesson that even willful violations of safety regulations, as at Palisades, will be tolerated by NRC, with no meaningful enforcement actions taken.

Despite gouging ratepayers via an exorbitantly expensive Power Purchase Agreement, with the blessing of the Michigan Public Service Commission; and despite cancelling long overdue, astronomically expensive, major safety repairs, with the complicity of NRC; Entergy is nonetheless losing money at Palisades.

As investment advisors at UBS pointed out a month ago, Entergy would do its own shareholders, Consumers Energy’s shareholders, and especially ratepayers, a huge favor, by closing Palisades.

Three years ago, Dr. Mark Cooper, an energy economist at Vermont Law School, predicted that Palisades was at high, near-term risk of permanent closure, due to: economic costs; age-degradation; its “merchant” status, that is, having to compete in a deregulated market; less than 25 years left on its operating license, even with an NRC-approved extension; numerous long-term outages (as due to unplanned shutdowns and breakdowns); and ‘multiple safety issues.’ Dr. Cooper’s similar shutdown predictions have proven correct, as at Entergy’s Vermont Yankee, FitzPatrick New York, and Pilgrim Massachusetts atomic reactors, as well as at a number of others owned by other nuclear utilities across the country.

Let’s hope Entergy does shut down Palisades, before it melts down. For NRC’s Confirmatory Order has shown, worse than ever, that ‘Nobody Really Cares’ about public health, safety, and the environment at the agency. In its collusion with Entergy to avoid any added costs, no matter how serious the resulting risks, the agency is now ‘Notoriously Rotten to the Core,’ with 'No Remaining Credibility.'

George Orwell and Adam Smith are spinning so fast in their graves, they should be connected to turbo-generators and hooked up to the electric grid. The residents of west Michigan, downwind and downstream from the dangerously age-degraded and non-competitive Palisades atomic reactor, are being gouged in order to perpetuate this worsening ‘game’ of radioactive Russian roulette on the Lake Michigan shore.”

Kamps has prepared a backgrounder, responding to the NRC Confirmatory Order, in the context of Palisades’ problem-plagued history, which has worsened significantly in recent years, as the 45-year-old atomic reactor descends ever more deeply into its “breakdown phase.”

Beyond Nuclear, a national watchdog group on the nuclear power industry, is based in Takoma Park, Maryland, just outside Washington, D.C. NRC's Region 3 headquarters, which issued the Confirmatory Order, is located in Lisle, Illinois, near Chicago. NRC's national headquaters, in Rockville, Maryland, is also just outside Washington, D.C.