A.I. Criticism of Holtec’s Palisades Reactor Restart
| NEWS FROM BEYOND NUCLEAR For immediate release Contact: Kevin Kamps, radioactive waste specialist, Beyond Nuclear, Kalamazoo, MI, (240) 462-3216; [email protected] Arnie Gundersen, nuclear engineer/expert witness, (802) 238-4452; Michael Keegan, chair, Don’t Waste Michigan, Monroe, MI, [email protected]; Terry Lodge, environmental coalition co-counsel, Toledo, OH, [email protected]; Wally Taylor, environmental coalition co-counsel, Cedar Rapids, IA, [email protected] |
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A.I. Criticism of Holtec’s Palisades Reactor RestartDisclosed by Environmental Coalition Expert Witness,Nuclear Engineer Arnie Gundersen |
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Testimony at NRC Advisory Committee on Reactor Safeguards subcommittee meeting complements Gundersen’s previous declarations to agency’s licensing board
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| ROCKVILLE, MD, and COVERT TOWNSHIP, MI, AUGUST 21, 2025–Arnie Gundersen, a nuclear engineer with more than a half-century of experience, has disclosed Artificial Intelligence (A.I.) criticism of Holtec’s Palisades reactor restart scheme at a U.S. Nuclear Regulatory Commission (NRC) Advisory Committee on Reactor Safeguards (ACRS) Plant Operations Subcommittee meeting today. Gundersen delivered his testimony, focused on Holtec’s self-inflicted steam generator tube degradation, a reactor core meltdown risk, during the public comments section scheduled to begin at 11:45am ET, towards the end of the meeting.
ChatGPT, one of the artificial intelligence bots, warned of great danger if Palisades is allowed to restart power generation using the current half-century old steam generators (SGs, fabricated in the early 1970s, operated since 1991): “[T]he current condition suggests a non-trivial likelihood of tube leakage or even rupture if Palisades restarts without SG replacement. This is precisely why the plan is to sleeve and plug so many tubes; it’s an attempt to drive that likelihood back down. Nonetheless, until new SGs are installed, Palisades will be running closer to the edge of tube integrity than it ever did before, implying a higher probability of failure relative to its past operation.” Here is a link to Gundersen’s prepared remarks, as delivered to the ACRS subcommittee at the meeting. (2 pages) Here is a synopsis of the A.I. reports on the Palisades steam generators (“We Asked AI Five Questions About the Safety of Holtec Palisades — AI’s Answers Were a Cause of Great Concern“), along with links to the two full AI analyses. (4 pages) Here is Gundersen’s previously submitted expert report, dated June 16, 2025, expressing his concerns about the severely degraded condition of Palisades’ steam generators. (41 pages) Gundersen previously served as an expert witness for Friends of the Earth regarding dangerous steam generator tube degradation at San Onofre Units 2 and 3 in southern California, leading to both reactors’ permanent closure in 2013. Arnie Gundersen stated: “The Palisades steam generators have degraded under Holtec and are now unsafe and unreliable. I have shown that complete steam generator replacement is necessary and two different A.I. analyses agree with me. Holtec wants to put a Band-Aid fix on the Palisades steam generators to hold them together. But Band-Aids are useless since the steam generators are gangrenous. A complete steam generator replacement is necessary. On August 21 I made my case to the Nuclear Regulatory Commission. Hopefully the NRC will realize that public safety is more important than Holtec’s profit.” Gundersen has long warned that Palisades’ steam generators must be put into a wet layup, if Holtec planned to restart Palisades. Wet layup is a chemically preservative condition, involving filling the steam generators with ultra-pure water, combined with anti-corrosion chemicals, such as hydrazine (itself highly toxic, and alarmingly approved by the State of Michigan for eventual disposal, via dumping into Lake Michigan, in potentially very large amounts, as part of Palisades’ “routine” releases of radioactive, toxic, and thermal wastewater). But at a technical meeting between Holtec and NRC staff held on January 14, 2025, an NRC staffer admitted that Holtec had not implemented wet layup, from 2022 to 2024. Gundersen has called this long-term neglect of basic but critical safety maintenance a “rookie error,” one that could cause a catastrophic reactor core meltdown. Holtec has never operated, repaired, or restarted a reactor, nor built one. Gundersen has testified that, in his experience, he has never seen steam generators as badly degraded as Palisades’ that were not replaced in their entirety, rather than just being repaired. He has warned a tube could fail within months of Palisades’ restart, resulting in a release of hazardous radioactivity to the environment. If enough tubes burst, in a cascading failure, a full blown reactor core meltdown could occur. Gundersen previously warned a decade ago that a meltdown at Palisades would devastate the Great Lakes downstream. Palisades’ original owner, Consumers Energy, admitted to the Michigan Public Service Commission in 2006 that the steam generators needed to be replaced (see page 2 on the slideshow in particular). However, Palisades’ owner/operator from 2007 to 2022, Entergy, never did so, because NRC did not require it. Although Holtec gave lip service to replacing the steam generators on July 5, 2022, at a cost of $510 million, it has backpedaled ever since. (See Table 3, Capital Projects, Item #3, on “Page 7 of 42” — or page 9 of 42 on the PDF counter — of Holtec’s document.) On June 16, 2025, the environmental coalition, represented by co-counsel Terry Lodge of Toledo, Ohio, and Wally Taylor of Cedar Rapids, Iowa, petitioned to intervene, and requested a hearing, regarding Holtec’s License Amendment Request to sleeve 80% of the very large number of damaged tubes, plug the remaining 20% too damaged to sleeve, and unplug 617 tubes plugged 35 years ago as a precaution against damaging vibrations associated with Palisades’ steam generator design. The coalition argued that Holtec’s proposed repairs do not provide “reasonable assurance of adequate protection” of public health, safety, and the environment, as required by the Atomic Energy Act of 1954, as Amended. The coalition defended its petition and request on July 18, 2025. On July 21st, the coalition protested NRC’s having allowed Holtec to sleeve steam generator tubes, even though its petition and request in opposition had yet to be resolved. The coalition followed up by submitting an emergency enforcement petition to NRC on July 29, 2025. But on August 5th, the Atomic Safety and Licensing Board Panel reviewing the petition and request ruled against the coalition, and abruptly terminated the proceeding. The coalition plans to appeal this ruling to the NRC Commissioners by the September 2, 2025 deadline. Holtec’s scheme to restart the closed Palisades reactor is unprecedented, although closed reactors at Duane Arnold, Iowa, and Three Mile Island Unit 1, Pennsylvania, are now following Palisades’ precedent. Palisades is located in Covert Township, Van Buren County, Michigan, on the Lake Michigan shoreline. Gundersen serves as an expert witness for the environmental coalition intervening against Holtec’s Palisades restart scheme in the NRC licensing proceedings. The coalition includes: Beyond Nuclear; Don’t Waste Michigan; Michigan Safe Energy Future; Nuclear Energy Information Service of Chicago; and Three Mile Island Alert of Pennsylvania. Beyond Nuclear’s one-stop-shop of website posts re: Palisades (both Holtec’s zombie reactor restart scheme, as well as its “Small Modular Reactor” new builds scheme) are posted here. See Beyond Nuclear’s previous press advisory for information about attending the meeting, either in person, via Microsoft Teams online, or via teleconference. NRC staff’s slideshow is linked here. The meeting is scheduled to begin at 8:30am ET, and end at 1pm ET. [NRC actually ended the meeting at 12pm ET, an hour early, despite numerous members of the public still requesting to speak during the public comment portion of the meeting. No explanation was given.] Following is more detail about the meeting from NRC staff:
A preview of NRC NRR / Region III slides.
Docketed 8/19/2025 @ 2:32pm
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Beyond Nuclear is a 501(c)(3) nonprofit membership organization. Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic. The Beyond Nuclear team works with diverse partners and allies to provide the public, government officials, and the media with the critical information necessary to move humanity toward a world beyond nuclear. Beyond Nuclear: 7304 Carroll Avenue, #182, Takoma Park, MD 20912. [email protected]. www.beyondnuclear.org. |
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