Entergy and NRC have just discovered that, at Palisades, plant diagrams are not accurate depictions of "as-built" reality

As recently as April 25, 2013, in a submission to NRC, Entergy gave engineering credit to structures which, in reality, didn't even exist: "Pressure stress loads are carried by the sand base, concrete grout ring, and concrete foundation beneath the tank bottom."

The discrepancy between Palisades' blueprints (see image, left), and the actual "as-built" reality, raises serious safety significant questions about the entire atomic reactor.

The Herald-Palladium, for whom Palisades unquestionably could do no wrong for decades on end, published a blistering editorial on May 23rd. The editorial board concluded:

"Burning Money" image by Gene Case, Avenging Angels

"Edison International (EIX)’s decision to abandon its San Onofre nuclear plant in California is the latest blow for an industry already facing questions about its long-term survival.

Edison, based in Rosemead, California, announced June 7 it will permanently shut the plant’s two reactors, trimming total U.S. operating units to 100 from 104 at the beginning of the year and 110 at the peak in 1996. The announcement brings to four the number of units permanently removed from service this year, the most in any year since the nation embraced nuclear power.

Other facilities are nearing the end of their projected lifespans and may need costly renovations while cheap natural gas has siphoned off market share. Potentially expensive regulations to bolster safety in response to a triple meltdown at Japan’s Fukushima Dai-Ichi plant in 2011 have raised the concerns of investors...

The last wave of U.S. plant closures was in the late 1990s, when falling gas prices helped tilt economics in favor of retiring rather than attempting large-scale repairs. Six reactors were closed from 1996 to 1998, according to Nuclear Regulatory Commission data, and peaked in 1996 when Haddam Neck in Meriden, Connecticut; Maine Yankee in Wicasset, Maine; and Unit 2 at the Zion plant in Illinois shut...

“The decision to shut down rather than retrofit the San Onofre nuclear plant shows the changing economics of the power market,” Howard Learner, executive director of the Environmental Law and Policy Center, a Chicago-based advocate of cleaner energy, said in a telephone interview. “We suspect other nuclear plant owners may start reaching the same decision.”

In fact, Dominion Nuclear made just such a decision, to permanently shutdown its Kewaunee atomic reactor on the Lake Michigan shoreline of Wisconsin last month. 

The Milwaukee Journal Sentinel reported on October 22, 2012 that Dominion, referring to its losing battle to remain competitive in a deregulated electricity market, could not afford the needed safety repairs at Kewaunee:

'We looked at all alternatives to keep the unit operating, but we could not make the reductions in the cost without it affecting safety,' [Dominion spokesman Richard] Zuercher said." (emphasis added)

As Howard Learner stated above, such market realities begs the question, which reactors will close next? On Feb. 8th, Entergy's brand new CEO, Leo Denault, when asked why several reactors in his fleet were so financially strapped, admitted in an interveiw with Reuters that:

"...some plants are in the more challenging economic situations for a variety of reasons, including 'the market for both energy and capacity, their size, their contracting positions and the investment required to maintain the safety and integrity of the plants.'" (emphasis added)

Terry Lodge speaks out against Davis-Besse in August 2012 at an NRC public meeting held at Oak Harbor High School

Toledo attorney Terry Lodge (photo, left) represents the coalition, and Fairewinds Associates, Inc's Chief Engineer, Arnie Gundersen, serves as its expert witness. Gundersen also serves as Friends of the Earth's (FOE) expert, which just successfully forced Edison International to permanently shutdown the San Onofre 2 & 3 atomic reactors due to fatally flawed replacement steam generators.

WTOL's Jennifer Steck quoted Beyond Nuclear's Kevin Kamps (print article; television report):

'..."We want to prevent a Chernobyl or Fukishima on the shoreline of the Great Lakes," said Kevin Kamps, of Beyond Nuclear. "There is no reactor in this country that's come closer to that as many times as Davis-Besse has."

Davis-Besse is licensed for operation through 2017, and in the process of a 20-year license renewal. Delaying that renewal and preventing a steam generator replacement in 2014 are the main goals of Beyond Nuclear.

"We've long strived to shut down Davis-Besse, and we're not going to give up now," Kamps said. "We're just going to re-double our efforts."...'

The Toledo Blade's Roberta Gedert also quoted Kevin:

“They went way out of their way to avoid a license amendment on this major organ transplant,” said Kevin Kamps, radioactive waste watchdog for Beyond Nuclear. “If they have made any mistakes, they have wasted hundreds of millions of dollars because we are going to challenge them at every turn.”

U.S. Sens. Levin and Stabenow

For example, you can contact U.S. Senators Carl Levin and Debbie Stabenow (see photo, left), both Michigan Democrats, and senior Democratic Party leaders (committee chairs) in the U.S. Senate. Their full contact information is listed below. Read on for ideas on what you can say to them.

Urge them to do all they can to force Palisades' shutdown, for safety's sake.

Urge them to work together to request an investigation by the Government Accountability Office (GAO) into the U.S. Nuclear Regulatory Commission's (NRC) regulatory rollbacks on safety standards, enabling the age-degraded Palisades atomic reactor to keep operating. Specifically, urge them to launch a GAO investigation on Palisades' embrittled reactor pressure vessel, at risk of rupturing due to pressurized thermal shock if the emergency core cooling system is ever activated. This would lead to a loss of coolant accident, reactor core meltdown, and catastrophic radioactivity release, potentially killing and injuring tens of thousands, and causing over $100 billion in property damage downwind and downstream.

Palisades has the worst embrittled reactor pressure vessel in the U.S., as admitted by senior staff at a Feb. 29, 2012 public meeting in South Haven. Michael Keegan of Coalition for a Nuclear-Free Great Lakes documented that Palisades had violated NRC safety standards just 10 years into its operations, by 1981. In June 2011, the Associated Press pointed to reactor pressure vessel embrittlement as the top example of NRC weakening safety standards in order to enable dangerously degraded atomic reactors to keep operating.

A coalition of dozens of Michigan environmental groups asked for this GAO investigation from Sens. Levin and Stabenow in spring 2006 -- yes, 7 years ago. Concerned citizens and environmental group representatives again asked them to do this in early 2012. Yet they never have.

You could also urge Sen. Stabenow to hold hearings in the Senate Agriculture Committee, which she chairs, regarding the risks to Michigan's agricultural economy from a catastrophic radioactivity release at Palisades.

You could also urge Sen. Stabenow to call for hearings on the Water and Power Subcommittee of the Senate Energy and Natural Resources Committee on which she serves, to look at the risks to Lake Michigan -- source of drinking water for tens of millions -- if Palisades were to unleash a Fukushima-like catastrophe on its shoreline.

Here are the two Senators' contact information:

U.S. SENATOR DEBBIE STABENOW:

Click on this link for Sen. Stabenow's Webform, where you can send her an email. 

Washington, D.C. Office

Senate Hart Office Building #133, U.S. Senate, Washington, D.C. 20510; phone (202) 224-4822; Fax (202) 228-0325.

Flint/Saginaw Bay Office

432 N. Saginaw St, Suite 301, Flint, MI 48502; Phone: (810) 720-4172

In 2010, tremendous controversy was generated throughout the Great Lakes, in both the U.S. and Canada, as well as in Europe, when Bruce Nuclear Generating Station in Kincardine, Ontario proposed shipping 64 radioactive steam generators, by boat, to Sweden. Bruce wanted to "recycle" the radioactive steam generators' outer shells into the metal recycling steam. Bruce CEO, Duncan Hawthorne, admitted at Canadian Nuclear Safety Commission hearings in Sept. 2010 that there were no emergency plans in place if one of the shipments sank. 

Dr. Edwards documented the radiological hazards contained in the steam generators. TheGreat Lakes and St. Lawrence Cities Initiative documented that the breach of a single steam generator, and release of even a fraction of its radioactive contaminants, could cause a federal radiological emergency in Canada, leading to the shutdown of nearby drinking water intakes. The Great Lakes are the drinking water supply for 40 million people in 8 U.S. states, 2 Canadian provinces, and a large number of Native American First Nations.

The Bruce shipping plan was stopped dead in its tracks, thanks in large part to a resolution,signed by scores of Quebec municipalities representing hundreds of thousands of residents along the St. Lawrence leg of the route, as well as pledges by Mohawk First Nations to not allow the shipment to pass through their territory.

Image by J. DeStafano, 2012

"This is very good news for the people of Southern California," said [a] statement from Friends of the Earth president Erich Pica. "We have long said that these reactors are too dangerous to operate and now Edison has agreed. The people of California now have the opportunity to move away from the failed promise of dirty and dangerous nuclear power and replace it with the safe and clean energy provided by the sun and wind." 

Steam generator tube ruptures, as occurred at San Onofre Unit 3 on Jan. 31, 2012, are very safety significant. Enough tube ruptures all at once (a "cascading" failure) can lead to a Loss of Coolant Accident in the core, reactor meltdown, and a catastrophic radioactivity release. In fact, a steam generator tube rupture at Indian Point near New York City in Feb. 2000 was considered one of the worst "breakdown phase" accidents at a U.S. reactor, only to be eclipsed two years later by the Hole-in-the-Head reactor lid corrosion hole at Davis-Besse near Toledo. 

Despite the clearly known safety significance of steam generator tube ruptures, New York Times reporter Matt Wald asked repeatedly what the safety significance of steam generator tube ruptures are to Friends of the Earth on a telephone press conference about the San Onofre closures. Wald's question was all the more ironic, given the near-miss at Indian Point 13 years ago, so close to New York City and the New York Times HQ office.

Beyond Nuclear has compiled comprehensive media coverage on, and other reactions to, the San Onofre 2 & 3 closures at its Nuclear Retreat page.

Arnie Gundersen, Chief Engineer at Fairewinds Associates, Inc

Today, the coalition issued a media release, pointing out the similarities between their intervention at Davis-Besse, and the Friends of the Earth (FOE) intervention at San Onofre, CA. Earlier today, Southern California Edison threw in the towel, and announced the permanent shutdown of San Onofre Units 2 & 3, due to the fatal degradation of their replacement steam generators. Gundersen (pictured, above left) serves as FOE's expert witness at San Onofre.

On Dec. 27, 2010, an overlapping environmental coalition, including Beyond Nuclear, intervened against Davis-Besse's 20-year license extension. The U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board in that proceeding has rejected all of the coalition's contentions, except for its Nuclear Waste Confidence Decision contention. That one has led to an inevitable two-year delay in NRC's finalization of the license extension, until the agency completes its court-ordered Environmental Impact Statement on the risks of long-term storage of high-level radioactive waste at on-site pools and dry casks.

MI Radio image showing location of chronically leaking SIRWT above Palisades' control room

Beyond Nuclear's Kevin Kamps stated: “When I raised the SIRWT [Safety Injection Refueling Water Tank] leak into the control room at Entergy’s public open house in South Haven on May 14^th, and on an NRC [U.S. Nuclear Regulatory Commission] Webinar May 23^rd, I was told by company and agency spokespeople that that issue was a thing of the past, that an installed moisture barrier had taken care of the problem. But as William Faulkner famously said, ‘The past is never dead. It's not even past.’ If Palisades can’t even prevent basic leakage through the ceiling of the control room, which has now been going on for over two years, what does that say about its reactor and radioactive waste safeguards? Entergy’s use of buckets, tarps, and ineffective sealant against this leak into the safety-critical control room begs the question, is it prepared to prevent large-scale radioactivity releases into the environment from a long list of severely age-degraded, critical safety systems, structures, and components?”

The leak, which was detected on June 3rd, was made known to the public in an NRC document released on June 6th.

Environmental coalition attorney Terry Lodge of Toledo

The rebuttal includes expert witness testimony by Gundersen, and an"Intervenor's Rebuttal Statement of Position" legal filing by Lodge.

Lodge and Gundersen filed their rebuttal on behalf of an environmental coalition comprised of Beyond Nuclear, Citizens for Alternatives to Chemical Contamination, Citizens Environment Alliance of Southwestern Ontario, Don't Waste Michigan, and the Sierra Club's Michigan Chapter.

Fermi 3 is a proposed new General Electric-Hitachi so-called "ESBWR" ("Economic Simplified Boiling Water Reactor"), targeted at the Lake Erie shoreline in Monroe County, Michigan, 8 miles as the crow flies (or the radioactivity blows) from Ontario, Canada.

NRC Atomic Safety and Licensing Board hearings are set for Halloween on not only this QA contention, but also an Eastern Fox Snake threatened species contention. In addition, Fermi 3's combined Construction and Operation License Application (COLA) cannot be finalized until NRC completes its court-ordered Environmental Impact Statement on its so-called [High-Level] Nuclear Waste Confidence Rule, a proceeding that could take years.

When Rep. Upton and NRC Commissioner Svinicki refused to meet with the coalition, Beyond Nuclear's Kevin Kamps helped organize a vigil at Palisades' front entrance. He dressed as the Little Dutch Boy. His sign reads "Have Finger--Will Plug Radioactive Leak," and "Wooden Shoe Rather Use Wind Power?!" Palisades' latest leak happened amidst west Michigan's Dutch American annual tulip time festivals. Photo credit Lindsey Smith / Michigan Radio.

Upton and Svinicki were visiting the atomic reactor in the aftermath of a 82.1-gallon spill of radioactive water into Lake Michigan. The leak came from the Safety Injection Refueling Water (SIRW) storage tank, which has been leaking for over two years. Although the investigation continues, it appears that a crack in a weld on a tank floor nozzle is at least partly to blame this time around. For the first year, the leak had been kept quiet by Entergy and NRC staff. Even the Chairman of NRC, Greg Jaczko, was not told about it, even during his tour of the troubled plant on May 25, 2012. A few weeks later, based on whistleblower revelations, U.S. Congressman Ed Markey (D-MA) made public that the leakage was into the control room, and that safety culture among the workforce had collapsed at Palisades: 74% of the workforce, including management, felt that reporting safety problems would solve nothing, while inviting intimidation and harassment -- and so do not report safety problems!

WNDU TV NBC Channel 16 South Bend quoted Beyond Nuclear's Kevin Kamps on its 11 PM coverage, that replacing the leaking Safety Injection Refueling Water (SIRW) storage tank would not make sense, if a number of other vital safety systems are not also either repaired, replaced, or upgraded.

As Kevin had conveyed on Western Michigan University's NPR station, WMUK, the list long-overdue repairs, replacements, and upgrades includes: the worst embrittled reactor pressure vessel in the U.S., steam generators in need of replacement for the second time in the reactor's history, a badly corroded reactor lid, and extensive fire safety upgrades, not to mention component cooling water and service water systems that have failed repeatedly in recent years.

ABC57 TV News South Bend also quoted Kevin about Palisades' Control Rod Drive Mechanisms (CRDMs), that have been leaking through seals for 41 years, and through-wall in 2001 and 2012. David Lochbaum of Union of Concerned Scientists documented this chronic problem, uniquely bad in industry, in his July 2010 report "Headaches at Palisades: Broken Seals & Failed Heals." Lochbaum also addressed the 2012 through-wall CRDM housing leak during Beyond Nuclear-sponsored events in west Michigan, noting that -- under NRC regulations -- Palisades should have been shut down within 6 hours, but instead operated for an entire month with primary coolant leakage through the pressure boundary, an unacceptable safety risk. Lochbaum reported that NRC could have fined Palisades $140,000 per day for the violation, but, over a half-year on now, has fined Entergy not one penny.

WSBT TV South Bend quoted concerned local resident, Barbara Pellegrini, who said “There’s no use in patching and fixing anymore. It just isn’t working.” Barbara knows what she's talking about: she has a PhD. and specializes in materials science education.

On May 25, 2012, after touring the problem-plagued Palisades reactor and meeting with an environmental coalition, including Beyond Nuclear, NRC Chairman Greg Jaczko personally asked Barb to write the agency about her concerns regarding age-related degradation at Palisades. A major agenda item at the coalition meeting with Jaczko had been neutron embrittlement of the reactor pressure vessel (RPV), which makes it vulnerable to pressurized thermal shock, a risk of RPV breach, loss of coolant accident, meltdown, and catastrophic radioactivity release.

NRC took 11 months to respond to Dr. Pellegrini. The agency essentially implied that it does not perform independent analysis of materials degradation at Palisades, but rather relies on Entergy's analyses -- essentially taking the company's word for it.

WOOD TV 8 NBC Grand Rapids reported that the press conference, which was supposed to feature Rep. Upton and NRC Commissioner Svinicki, was largely taken over by Entergy's Chief Operating Officer. TV 8 also provided links to its coverage of numerous past leaks over the last year (a third of them involving the SIRW storage tank), as well as a map of the 50-mile radiological ingestion emergency planning zone around Palisades (which extends to within close proximity to Chicago, which draws its drinking water, for many millions of people, from Lake Michigan).

WZZM TV 13 quoted Kevin as saying that any exposure to radioactivity carries a health risk for cancer, and that these risks accumulate over a lifetime. The higher the dose, the higher the risk, but even so-called "diluted" radioactivity or "low-doses" of exposure to radiation cannot be called "safe," despite repeated Entergy and NRC statements to the contrary. In fact, Kevin pointed out, Palisades has been releasing radioactivity into the air and water "routinely" for 42 years now, sometimes intentionally, with a permit from the government, but other times un-intentionally, due to "accidental" (although chronic and repeated) spills or leaks. Another "little problem" with the "dilution is the solution to radioactive pollution" delusion is bio-concentration: the food chain re-concentrates radioactivity in the environment. Humans are at the top of the radioactively contaminated food chain.

Michigan Radio reported on the effort by a coalition of concerned local residents and environmental groups to request a meeting with Rep. Upton and NRC Commissioner Svinicki. As soon as the government officials' emergency tour of Palisades was announced in the news media, Michigan Safe Energy Future-Shoreline Chapter's Bette Pierman emailed a request to Congressman Upton, and followed up with a hardcopy of the letter delivered to his local St. Joe, MI office. A hardcopy was also delivered to his Capitol Hill office. The letter was emailed to NRC Commissioner Svinicki. Follow up phone calls were made to Rep. Upton's local St. Joe and Kalamazoo offices, as well as to NRC Commissioner Svinicki's HQ office in Rockville, MD. Despite this, Michigan Radio reports, Upton claimed to have been "unaware of any attempts to meet with him."

Michigan Radio reported: “We thought we had some common ground,” Kamps said of Upton, “We certainly follow these issues closely and I think that Upton needs to hear from us and I hope that he will sit down with us.”

Given the apparent rejection of their meeting request, the coalition decided to hold an all day vigil at Palisades' front entrance.

Michigan Radio reported that Upton "was dismissive of the protesters, saying they were mostly from out of town." Quite to the contrary, every single protestor was from west Michigan. The majority were from within the 10-mile EPZ (Emergency Planning Zone) surrounding Palisades, from such communities as South Haven, less than 5 miles north, and Bangor, about 10 miles to the northeast. Others were from Benton Harbor, about 15 miles south, and Kalamazoo, about 35 miles, downwind, to the east "as the crow flies," or as the radioactivity blows.

Michigan Radio reported: “We demand the tank be replaced and a dozen other systems be replaced,” Kevin Kamps of Beyond Nuclear said. “I hate to be harsh but talk is cheap and actions speak a lot louder than words,” Kamps said, “[Upton, the Chairman of the U.S. House Energy and Commerce Committee, with direct oversight on NRC] could pressure them to shut this plant until all dozen of those safety critical systems are repaired, replaced, upgraded. He’s not doing that.”

But, Michigan Radio reported: “(The NRC) is entrusted to do the right thing and certainly I’m not going to be looking over their shoulder,” Upton said.

Of course, "looking over [NRC's] shoulder," also known as congressional oversight, is Upton's job as Energy and Commerce Committee Chairman!

The Kalamazoo Gazette reported:

'Kamps said, "Upton has long been one of the nuclear power industry's best friends in Congress."

According to Federal Election Commission data, individuals and PACs representing the New Orleans-based company gave the congressman $24,600 during the 2012 election cycle, making Entergy the third-largest donor.'

Since 2008, Beyond Nuclear has published exposés on Upton's favors in return to the nuclear power industry for its campaign contributions: a 2-page summary; 22-page full report; list of nuclear industry PAC campaign contributions to Upton; and list of campaign contributions from nuclear industry-related individuals.

For her part, NRC Commissioner Svinicki almost always votes in the nuclear power industry's interests, often against the public interest. Most recently, she cast the single worst of the four bad votes against requiring radiological filters on the "new and improved" hardened vents to be installed on the 31 Fukushima twin GE Mark I and II boiling water reactors in the U.S. While only NRC Chairwoman Allison Macfarlane voted for immediate installation of filters, and NRC Commissioners Ostendorff, Magwood, and Apostalakis voted to study the issue for years on end, Commissioner Svinicki simply voted to never require installation of filters. While NRC Chairman Greg Jaczko in May 2012, and Commissioner Magwood in March 2013, reached out to Beyond Nuclear to set up meetings with concerned locals while they toured Palisades, Commissioner Svinicki's office didn't even respond to the coalition's request for a meeting in May 2013.

WKZO Radio also reported on this story, and a Facebook page, "Palisades Nuclear Plant Watch," has been established.