ML24212A016

Comment (146) E-mail Regarding Palisades Restart Scoping

ML24212A016
Person / Time
Site:	Palisades
Issue date:	07/29/2024
From:	Public Commenter Public Commenter
To:	NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
89FR53659
Download: ML24212A016 (9)

Text

From:

Herbert Moyer <herb.moyer@comcast.net>

Sent:

Monday, July 29, 2024 1:55 PM To:

PalisadesRestartEnvironmental Resource

Subject:

[External_Sender] Testimony Opposing the Restart of the Closed Palisades Reactor Attachments:

Docket ID NRC-2024 - 0076.doc Please accept this "Echoed and Supported Testimony by the Seacoast Anti-Pollution League:

Herbert S. Moyer - SAPL President 51 Westside Drive Exeter, NH 03833-4220 603-772-6910 cell 603-231-3083 herb.moyer@comcast.net

Federal Register Notice:

89FR53659 Comment Number:

146 Mail Envelope Properties (1435755276.131090.1722275686709)

Subject:

[External_Sender] Testimony Opposing the Restart of the Closed Palisades Reactor Sent Date:

7/29/2024 1:54:46 PM Received Date:

7/29/2024 1:55:10 PM From:

Herbert Moyer Created By:

herb.moyer@comcast.net Recipients:

"PalisadesRestartEnvironmental Resource" <PalisadesRestartEnvironmental.Resource@nrc.gov>

Tracking Status: None Post Office:

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Docket ID NRC-2024-0076 Comments echoed and reinforced by the Seacoast Anti-Pollution League (SAPL)

Submitted by Herbert S. Moyer, SAPL President SAPL PO Box 1136 Portsmouth, NH 03802 Herbert S. Moyer 51 Westside Drive Exeter, NH 03833 herb.moyer@comcast.net 603-772-6910 REACTOR RISKS AND IMPACTS ON THE ENVIRONMENT The Palisades zombie reactor restart is unprecedented, extremely high-risk, insanely expensive for taxpayers and ratepayers, and unneeded. NRCs Environmental Assessment is nowhere near enough. A full-blown Environmental Impact Statement is called for regarding this major federal action a very hard look is required. In fact, because the Palisades closed reactor restart precedent is now being applied elsewhere Three Mile Island Unit 1 in Pennsylvania, Duane Arnold in Iowa, etc. a Generic or Programmatic EIS is necessary. Along the same lines, a 30-day public comment period is insufficient.

NRC should extend the public comment period to 180 days. Holtecs rush to restart Palisades is no excuse for a short public comment period in fact, the rush job itself could significantly increase the environmental risks and worsen the impacts.

The No Action Alternative is preferred. The nearly 60-year old (ground was broken in 1967) Palisades atomic reactor should remain closed for good, as it has been since May 20, 2022. Renewables like wind and solar power, efficiency, and storage are much more preferable alternatives. They can readily replace Palisades 800 Megawatts-electric (MWe),

and do so much more cost-effectively, cleanly, safety, securely, promptly, and reliably than the zombie reactor restart scheme, and Holtecs inextricably connected SMR-300 (so-called Small Modular Reactors of 300 MWe each) new builds scheme at Palisades, as well as at its sibling closed Lakeside reactor site, Big Rock Point near Charlevoix.

Concerns, usually framed as safety-related, are also most relevant to negative environmental impacts, including LARGE ones. A reactor core meltdown at the Palisades zombie reactor would have extremely LARGE negative environmental impacts, in the National Environmental Policy Act (NEPA) lingo. Palisades has long had multiple high-risk pathways to meltdown. They include the single worst neutron-embrittled reactor pressure vessel in the country, and perhaps the world, at risk of through-wall fracture. They also include steam generators, and a reactor vessel closure head, or lid, that have needed replacement for two decades. Fire protection and containment coating/sump strainer

upgrades, also needed 20 years ago, have likewise been largely to entirely neglected.

According to retired Union of Concerned Scientists nuclear safety director Dave Lochbaum, fire represents 50% of the risk of core meltdown at atomic reactors. And inadequate sump strainers mean that containment coating debris could clog emergency cooling water flow pathways, as former Entergy senior engineer Alan Blind, who worked for six years at Palisades, has explained. All these admissions about safety-significant systems, structures, and components in need of replacement, or significant upgrade, were made by Palisades initial owner, Consumers Energy, to the Michigan Public Service Commission, in spring 2006. Yet Entergy never fixed any of this, during its ownership tenure from 2007 to 2022 because the industry-captured NRC, in full regulatory retreat, did not require it. Now Holtec plans to continue to run Palisades into the ground, with at best inadequate monitoring and minimal repairs. In mid-2022, Holtec had paid some lip service to repairing tubes, or even entirely replacing the stream generators (at a cost of $510 million), in a secret bailout application to DOE, obtained from the State of Michigan via a Freedom of Information request submitted by Beyond Nuclear. But recently, Holtec spokesman Nick Culp revealed the company no longer plans to repair or replace the dangerously age-degraded steam generators. (Palisades Restart Still Faces Significant Hurdles, by Jessica Sondgeroth, NUCLEAR INTELLIGENCE WEEKLY, Vol. 18, No. 14, April 5, 2024.)

Palisades has also had the worst Operating Experience of any reactor in the U.S.,

regarding Control Rod Drive Mechanism seal leakage. The first leaks were in 1972, in the first year of full power operations. They have continued since. In fact, Entergys decision to close Palisades for good on May 20, 2022 was 11 days earlier than scheduled, because of the most recent CRDM seal leak. Palisades owners, now Holtec, have never determined the root cause, nor taken comprehensive corrective action, to solve this problem, instead relying on mere, short-lasting BAND-AID fixes. Given their location very near the reactor core, replacement of CRDM seals exposes workers to significant doses of hazardous radiation, putting their health at risk. In just one episode a decade ago, nearly 200 workers including women of child-bearing age got on average 2.8 Rem of exposure on a month-long CRDM seal replacement job. Internationally, nuclear workers are limited to 2 Rem of exposure for an entire year. CRDM seal leaks involve reactor core primary coolant water, so represent yet another pathway to meltdown.

These risks have actually increased since permanent shutdown on May 20, 2022, due to lack of active maintenance by Holtec which has no experience operating an atomic reactor on safety-significant systems, structures, and components. This includes: lack of chemically-preservative wet layup on the steam generators, accelerating already severe corrosion; no testing of valves and pumps to ensure reliability; and no regular rotation of the turbine-generator shaft, which is thus bending under its own immense weight. The latter could lead to a mechanical explosion, hurling chunks of shrapnel weighing hundreds of pounds each outwards, including into the control room, where operators could be injured or killed, and safety/cooling systems could be rendered inoperable. Such a mechanical explosion of the bent turbine-generator shaft at Fermi Unit 2 in Monroe County, MI on Christmas Day, 1993, led to two million gallons of radioactive wastewater being dumped into Lake Eries biologically rich but shallow, and fragile Western Basin.

The extremely LARGE negative environmental impacts of a meltdown at the Palisades zombie reactor would include large-scale airborne fallout and water-borne outflow of hazardous radioactivity into Lake Michigan, as well as wind-driven/precipitation-delivered fallout onto land. Such airborne fallout from Chornobyl in 1986 severely contaminated not just the breadbasket of Europe (Ukraine), but also sheep farms in Scotland, Sámi reindeer herding grounds in the Scandinavian Arctic, Lake Constance bordering Bavaria, Germany, and elsewhere not just hundreds, but even thousands of miles downwind.

Radioactive fallout and wastewater discharges into the Pacific Ocean from Fukushima Daiichi in Japan did not end in spring 2011 the tritiated wastewater discharges will now continue for decades, intentionally, despite the risks to humans via Pacific fisheries. These are cautionary tales for Van Buren, as well as Berrien, Allegan, and Kalamazoo counties a major agricultural breadbasket of Michigan, not to mention tourism/recreation Mecca. The late, great Maynard Kaufman, a Bangor farmer-author, co-founder of Michigan Organic Food and Farm Alliance, and watchdog on Palisades since before ground was even broken in 1967, warned about these impacts on Palisades-area agriculture for decades on end.

And, as an expert witness for the environmental coalition opposed to Palisades restart Arnie Gundersen, chief engineer at Fairewinds warned a decade ago, a Fukushima-scale radioactive disaster at Palisades would be catastrophic for Lake Michigan, and the rest of the Great Lakes downstream and downwind. The Great Lakes comprise 21% of the worlds surface fresh water, 84% of North Americas, and 95% of the U.S.A.s. The Great Lakes serve as drinking water for more than 40 million people in eight U.S. states, two Canadian provinces, and a large number of Indigenous Nations. To put this all at risk with the unneeded Palisades zombie reactor restart is nuclear madness. The hazardous persistence of artificial radioactive pollutants that would escape into the environment due to a reactor core meltdown are nightmarish: Tritium (radioactive Hydrogen, which can go anywhere in the human anatomy, right down to the DNA molecule), 123 to 246 years of hazard; Cesium-137 (a muscle-seeker), around 300 to 600 years of hazard; Strontium-90 (a bone-seeker), around 300 to 600 years of hazard; Carbon-14 (which can also go anywhere in the human body, right down to the DNA molecule), 55,000 to 110,000 years of hazard; Plutonium-239, 240,000 to 480,000 years of hazard; Iodine-129, 157 to 314 million years of hazard; to name but a small number of the more than 200 hazardous artificial radioactive isotopes contained in irradiated nuclear fuel.

Risks at the zombie reactor, and their impacts on the environment, will be exacerbated by reactor risks at the SMR-300s Holtec also proposes building on the tiny, 432-acre Palisades site. In addition to having no experience operating atomic reactors, Holtec also lacks any experience building atomic reactors. The nearly 60-year old reactor will have worsening age-related degradation, breakdown phase risks, from August 2025 to 2051 (Holtec has announced application for a 2031 to 2051 license extension, amounting to 80 years of operations, twice the initial 40 years.) The so-called Small Modular Reactors, of 300 Megawatts-electric each, will have their own break-in phase risks. Chornobyl Unit 4 in Ukraine in 1986, Three Mile Island Unit 2 in Pennsylvania in 1979, and Fermi Unit 1 in Monroe County, Michigan in 1966, are examples of break-in phase reactor disasters. Three reactors operating on the tiny, 432-acre Palisades site would also represent a risk of multiple, domino-effect reactor core meltdowns, as happened at Fukushima Daiichi, Japan in March 2011.

SMR-300s are not small. They are 4.5 times larger than Big Rock Points previous reactor one of the worst radioactive polluters in the entire country, despite its relatively small, 67-MWe size. Fermi Unit 1, also a relatively small 67-MWe, partially melted down on October 5, 1966 and we almost lost Detroit. As Holtec CEO Krishna Singh himself has pointed out, the two SMR-300s at Palisades would nearly double the nuclear mega-wattage on the 432-acre site (800 MWe + 600 MWe). This would represent a very concentrated amount of nuclear risk and radioactive environmental impact on the tiny site.

But it doesnt take an accident. Palisades so-called routine releases of hazardous radioactivity since 1971 have been significant. These include planned and permitted radiation releases, but also unplanned/unpermitted leaks and spills. Palisades routine releases of radioactive and toxic chemical wastewater into Lake Michigan including seasonal batch releases are harmful to Lake Michigan, its fisheries and ecology. Lake Michigan serves as the drinking water supply for a very large number of shoreline communities, from South Haven, to Chicago, and beyond. Some 16 million people drink Lake Michigan water, not only in Michigan, but also Indiana, Illinois, and Wisconsin. Such discharges of artificial radioactive substances from Palisades into Lake Michigan do not dilute they increase the concentration of such artificial radioactive hazards in the Lake, and in fact the radioactivity bio-accumulates, bio-concentrates, and bio-magnifies up the ecosystem and food chain, as via fisheries, harming animals at the top of the ecosystem/food chain, from predators to people. As the U.S. National Academies of Science have repeatedly confirmed for decades, citing the long-established Linear, No Threshold theory which forms the very foundation of the Biological Effects of Ionizing Radioactivity reports, any exposure to ionizing radiation, no matter how small, still carries a health risk, such as cancer causation; and such risks accumulate over a lifetime. Truth be told, such risks are not limited to cancer, but also include radiogenic birth defects, genetic damage, and a very long list of other health risks, maladies, and morbidities. Given that Lake Michigan water is also used for agricultural irrigation, hazardous radioactive contamination of the food supply can also occur via this exposure pathway.

The environmental impacts at the nearly 60-year old zombie reactor cannot legally be segmented from the environmental impacts at the SMR-300 new builds. These are not only radiological but also physical. For example, the construction of two 300-MWe reactors on the tiny, 432-acre Palisades site would wreak further havoc with the fragile, endangered forested dunes ecosystem there. It would also threaten Indigenous cultural properties very likely located there, including sacred ancestral burial sites.

The Palisades zombie reactor restart will involve cumulative effects, on top of the 1971-2022 operational impacts on the environment thus far. This will include not only routine releases of hazardous radioactivity and toxic chemicals (planned/permitted, as well as unplanned/unpermitted leaks, spills, etc.) from 2025 to 2051 at the restarted zombie reactor (likely worse than in the past, given the nuclear power plants severe age-related degradation), but also routine releases from the SMR-300 new builds. The environmental impacts are not only cumulative, but also synergistic. As Rachel Carson warned in her iconic book Silent Spring in 1962, credited with helping launch the environmental protection movement, hazardous ionizing radioactivity and toxic chemicals have synergistic negative

impacts on the environment the harm from the synergistic hazardous exposures is greater than the sum of their parts.

Palisades location, in Covert Township, Michigan, raises serious Environmental Justice concerns. The Palisades Park Country Club resort community, over 125-years old, is located immediately south of the nuclear power plant, sharing property lines. There are reportedly elevated rates of cancer and thyroid pathology in that 200-cottage community.

Covert Township itself has a large African American population, and also a high rate of low income households. Covert Twp. has a rich African American cultural history. The area is also Anishinaabe aki, specifically Pokagon Potawatomi traditional land. The Palisades zombie reactor restart, as well as the SMR new builds, put this all at risk, including from extremely LARGE environmental impacts.

Making all the risks and impacts LARGER and worse is the fact that, in addition to its inexperience (the company has never operated, nor constructed, an atomic reactor), it is also incompetent, corrupt, and even criminal. Newly revealed scandals swirl around Holtec on a frequent and continuing basis. As but the latest example, a long-serving, top Holtec advisory board member, George E. Norcross III, was recently indicted by the State of New Jersey Attorney General on 13 racketeering felony charges. For more background info.,

see: Holtec: Criminality, Corruption, Incompetence, and Inexperience (2 pages, published March 27, 2024). Also see an earlier annotated bibliography, Radioactive Skeletons in Holtecs Closet, chronicling the companys countless misdeeds.

RADIOACTIVE WASTE RISKS AND IMPACTS ON THE ENVIRONMENT The actual past and potential present and future environmental impacts resulting from the ongoing (1971 to the present, and counting) radioactive waste crisis at Palisades are also LARGE. More than 800 metric tons of highly radioactive irradiated nuclear fuel have accumulated on-site at Palisades. Around two-thirds is still stored in the wet indoor storage pool; one-third is stored in a growing number of outdoor dry casks, very near the Lake Michigan shore. As with operating reactor core meltdowns, catastrophic amounts of hazardous radioactivity can also be released into the environment from radioactive waste disasters, such as a fire in the pool-stored waste, or a dry cask breach. As a matter of fact, Palisades narrowly averted catastrophe in October 2005 under previous owner Consumers Energy, due to the near-drop of a 107-ton load into the pool: the floor could have been pierced, draining cooling water, leading to overheating and ignition of the zirconium metal cladding of the stored highly radioactive irradiated nuclear fuel. Since the pool is not located within a radiological containment structure, radioactivity releases from the hundreds of metric tons of densely packed fuel would be large-scale, and directly into the environment. Princeton University researchers reported in 2016 that a radioactive waste pool fire could contaminate a large region of the United States downwind, leading to millions of nuclear evacuees, and trillions (with a T) of dollars in property damage. A near-miss waste pool fire at Fukushima Daiichi Unit 4 in March and April 2011, very narrowly averted through sheer luck, led the then-serving Japanese Prime Minister, Naoto Kan, to order an emergency contingency plan to evacuate 35 to 50 million people from northeastern Japan and metro Tokyo. He said it would have been the end of the Japanese

state. The Palisades pool is more densely packed with irradiated nuclear fuel than was the pool at Fukushima Daiichi Unit 4.

Dry cask storage at Palisades has been controversial and risky from the start in 1993.

The fourth cask to be loaded, in summer 1994, was quickly announced by then-owner Consumers Energy to be defective. Consumers Energy had assured the public that any problems with casks would be easily resolved by simply returning the highly radioactive waste to the indoor wet storage pool. NRC backed this up, including under oath in a federal court room in Grand Rapids, MI, when State Eternal General (Attorney General) Frank Kelley legally challenged the loading of the casks in the first place. (By 1997, Dr. Mary Sinclair of Dont Waste Michigan pointed out that perjury had likely been committed.)

Although Consumers Energy initially assured the public it would live up to its previous promise, and promptly at that, 30 years have now passed, and the defective cask still sits fully loaded, 150 yards or less from the shoreline of Lake Michigan. Complications previously identified and warned about by environmental watch-dogs proved accurate.

Grinding through welds on the lid, and removing pressure fit shims, would contribute to missing the 40-hour deadline for transferring the fuel from the defective dry cask back into the pool convection air current cooling would be disrupted violating Technical Specifications related to fuel-and cask-overheating. Even then, lowering the thermally hot (up to 750-degree Fahrenheit) containerized fuel into the 100-degree F pool water would cause a thermal shock to fuel and container, exacerbating degradation. It would also cause a radioactive steam flash, most hazardous to nearby workers and local residents.

In February 1994, Dr. Ross Landsman, dry cask storage inspector at NRC Region 3 in Chicago, warned the agency that the original storage pad at Palisades for dry casks, just 150 yards or less from the water of Lake Michigan, violated NRC earthquake safety regulations. This was due to the pad floating on 55-feet of loose sand underneath, anchored to nothing. He warned that even a mild earthquake could part the beach, allowing the Lake to fill the void. One or more dry casks could be buried under sand, leading to overheating. Or, they could tumble into the Lake, submerging. Breaches of casks could then lead to radioactive releases into the Lake. Dr. Landsman, then retired from NRC and serving as an expert witness for the environmental coalition opposing Palisades, warned in 2006-2007 that the second pad at Palisades, located somewhat further inland from the Lake, also violated NRC earthquake safety regulations. In Holtecs own December 2020 Post-Shutdown Decommissioning Activities Report, the company seemed to lend credence to Dr. Landsmans warning about the nearer-Lake, older pad Holtec proposed transferring all the dry casks to the newer pad, further inland. But given Dr. Landsmans 2006-2007 warning about the newer pad, this could simply be jumping from the frying pan into the fire.

A breached, submerged cask could also lead to an inadvertent nuclear criticality in the highly radioactive waste. If the waste formed a critical mass during the disaster, infiltrating Lake water could serve as a neutron moderator, sparking a chain reaction. This would worsen radioactive releases into the Lake, and would make emergency response operations a potential suicide mission, given the fatal radiation emissions due to breach of radiation shielding, as well as containment. Another pathway to such a catastrophe is Holtecs, and DOEs, proposed barge shipments of highly radioactive waste, from

Palisades to the Port of Muskegon. The more waste Palisades generates, the more pressure Holtec will exert, and the more shipments there would be, involving barging highly radioactive wastes on Lake Michigan, bound for the companys proposed dumpsite in New Mexico.

The closure-for-good of Palisades by Entergy on May 20, 2022 meant that no more radioactive waste would be generated there. But the proposed restart would mean that the highly radioactive waste inventory stored on-site at Palisades would grow by around 15 metric tons per year, from 2025 to 2051. Thus, the associated LARGE impacts on the environment would also grow. Holtecs proposed SMR-300 new builds at Palisades (and also at Big Rock Point), due to loss of economy of scale, would each generate more highly radioactive waste, per unit of electricity generated, than the zombie reactor. Drs. Allison Macfarlane, and Rodnew Ewing, President Obamas NRC chair and U.S. Nuclear Waste Technical Review Board chair, respectively, reported recently that, depending on their specific design, SMRs will generate 2 to 30 times the radioactive waste, as compared to current reactors, per unit of electricity generated. But similar things can be said regarding thermal wastewater discharges, cost per unit of electricity generated, etc. Thus, Holtecs SMR new build schemes would exacerbate its zombie reactor restart scheme.

CLIMATE DESTABILIZATION Exacerbating the LARGE and worsening nuclear risks for and radioactive impacts to the environment described above is the issue of extreme weather and natural disasters due to climate chaos. In 2020, Lake Michigan had historic high water levels. This meant that the Lakeside dry cask storage was significantly closer than the often cited 150 yards to the waters of Lake Michigan. Whether it is tornadoes, hurricanes (like the deadly White Hurricane (blizzard) of 1913 on Lake Huron, the natural disaster causing the largest loss of life on the Great Lakes and its shores in history), floods, Lakeside erosion of fragile sand dunes and beaches, wildfires, etc., the list of extreme weather threats to the reactor(s) and radioactive wastes at Palisades is already long, and growing with worsening climate destabilization. Institutions such as the Government Accountability Office (GAO, Congresss investigative arm), and a Yale University scholar, have excoriated NRC for neglecting climate risks, and have questioned the U.S. nuclear power industrys ability to operate reactors (and on-site radioactive waste storage, for that matter) safely, during ever more extreme weather conditions. NRC cannot be allowed to ignore such climate risks in the context of the Palisades zombie reactor restart and SMR new build schemes, nor their inevitable potential for extremely LARGE negative impacts on the environment.