Palisades: Sample Talking Points for Jan. 14, 2025 NRC-Holtec meeting

[Photo of the thousands of exceedingly-thin (merely 0.042 inches thick!) walled tubes inside a typical pressurized water reactor steam generator. This photo is taken from the top looking down.]

Please click on this link to learn more about the very important January 14,* 2025 meeting between the U.S. Nuclear Regulatory Commission (NRC) and Holtec International. Please: pre-register for the webinar (it is required); prepare ahead of time (see sample talking points, below, for example), and take part in the hour-long public comment and Q&A session with NRC staff for the last hour of the scheduled meeting; and spread the word to others concerned about nuclear power safety risks! Thanks!

(*Note, this meeting was originally scheduled for Jan. 9, 2025. But on Jan. 6, NRC notified registered participants that the meeting had been postponed, until Jan. 14. NRC explained: “This meeting was rescheduled due to the federal government closing on January 9, 2025.” The reason the federal government was closed on Jan. 9, per the order of President Biden, was to honor former President Jimmy Carter, and mourn his passing.)

Sample talking points you can use to prepare your own comments/questions:

(1.) Doesn’t steam generator tube degradation, which is severe and rampant at Palisades, risk reactor core meltdown? If one or a few tubes fail, and then take out enough additional tubes, in a cascading failure, reactor core meltdown could result, right? In this sense, isn’t bad enough steam generator tube failure the most direct route for the large-scale, hazardous radioactivity at the core of a pressurized water reactor like Palisades to escape into the environment, harming humans and other living things downwind, downstream, up the food chain, and down the generations?

(2.) If Holtec wants to restart the closed (on May 20, 2022); 1960s-era (it was designed in the mid-1960s; ground was broken in 1967; operations began in 1971) Palisades reactor so badly, why doesn’t NRC require Holtec to completely replace Palisades’ severely degraded steam generators? Palisades’ original owner/operator, Consumers Energy, admitted to the Michigan Public Service Commission in spring 2006 that Palisades’ steam generators needed to be replaced (see page 2 in particular). Yet NRC has never required this, as during Entergy’s ownership and operation of Palisades (from 2007 to 2022), so it was never done. Why does NRC allow severely degraded steam generators to be run into the ground like this, given the potential for a reactor core meltdown and catastrophic release of hazardous radioactivity? Isn’t NRC’s supposed mandate the protection of public health, safety, and the environment? Doesn’t NRC’s decades-long, ongoing inaction violate the agency’s mandate?

(3.) Why is NRC entertaining Holtec’s proposals to do BAND-AID fixes on Palisades’ degraded steam generator tubes, such as sleeving? Why doesn’t NRC require Holtec to entirely replace the steam generators, if the company wants to restart Palisades so badly?

(4.) Is NRC considering allowing Holtec to operate Palisades at reduced power levels, as a supposed safety mitigation for the severely degraded steam generator tubes? If yes, why would this be allowed to happen at Palisades, when it was not allowed to happen at San Onofre in California? Granted, NRC was fine with Southern California Edison operating one of the San Onofre reactors at 70% power levels, due to severe steam generator tube degradation. But the grassroots groundswell of resistance to this scheme forced the owner/operator to pull the plug and close both San Onofre reactors, Units 2 and 3, in June 2013, despite NRC’s laissez-faire attitude toward public safety.*

(5.) What is the status of the steam generator tube plate? Is there corrosion and degradation at this interface — between the tubes and the plate, as well? Are there any ways to repair or even inspect such damage? Or is complete steam generator replacement the only way to ensure steam generator tube plate degradation doesn’t end in catastrophic failure, and possible reactor core meltdown, with consequent large-scale release of hazardous radioactivity into the environment, as a result?

(6.) If Palisades were to replace its steam generators, this would mean the third set of steam generators in Palisades’ history. The first set were operated from 1971 to 1990, then were replaced. The second and current set were installed in 1990-1991, and were operated from 1991 to 2022. Would a third set of replacement steam generators last till 2051, Holtec’s purported end date for 80 years of operations at Palisades? What if Holtec were to then decide to operate Palisades beyond 2051? Would the third set of steam generators safely last that long?

(7.) Why did Holtec include the option of replacing Palisades’ steam generators in its July 5, 2022 bailout application to the U.S. Department of Energy, at a cost of $510 million (the single largest price tag of any line item on the zombie reactor restart to-do list; see Table 3: Capital Projects, Item #3, Page 7 of 42 in the preceding link), only to backpedal in early 2024, saying the steam generators were just fine, and did not need replacement? —

“…In the application, Holtec also estimates a cost of $510 million for steam generator ‘design, fabrication, replacement (includes reactor coolant system redesign, cold-hot-fuel testing),’ but Culp said this week that recent ‘expert testing and analysis has validated the integrity of our steam generators to support continued safe and reliable operation,’ and the machines will not be replaced,” reported Jessica Sondgeroth in Nuclear Intelligence Weekly, on April 5, 2024, in an article entitled “Palisades Restart Still Faces Significant Hurdles.”)

Why did Holtec/Palisades spokesman Nick Culp say that last April, when by September 18, 2024, NRC issued a rare Preliminary Notification of Occurrence (PNO) regarding the severity of the steam generator tube degradation? NRC’s PNO stated: “…During Holtec’s analysis of the inspection data, preliminary results identified a large number of [Steam Generator] tubes with indications that require further analysis and/or repair. Further data analysis is in progress with additional tube inspections, testing, and repairs to be completed over the next few months…“. (Emphasis added) Also see NRC’s October 1, 2024 PALISADES NUCLEAR PLANT – SUMMARY OF CONFERENCE CALL REGARDING STEAM GENERATOR TUBE INSPECTIONS (EPID L-2024-NFO-0008), for more detailed information from a September 3, 2024 conference call between Holtec and NRC, about the severity, extent, and nature of the steam generator tube degradation at Palisades.

(8.) Given Palisades’ severe age-related degradation of multiple systems, structures, and components critical to safety in addition to the steam generators — such as the embrittlement of the reactor pressure vessel, the degradation of the reactor vessel closure head, the risk of emergency core cooling system sumps and strainers becoming clogged with containment building calcium silicate debris (again, as above, see Page 2 of Consumers Energy’s spring 2006 admissions to the Michigan Public Service Commission), the worst control rod drive mechanism seal leaks in industry, etc., ad nauseum — why would NRC allow Holtec to play such games with the steam generators as well?

(9.) Regarding the “leak-before-break” component of this meeting, how can NRC assume that safety-significant tubes, pipes, vessels, etc. will leak before they break? What if they don’t? What if a catastrophic failure occurs without any such convenient, overly-optimistically-assumed warning ahead of time, causing a reactor core meltdown, and large-scale release of hazardous radioactivity? As but one example, Palisades is essentially tied with Point Beach Unit 2 in Wisconsin for having the worst neutron-embrittled reactor pressure vessels in the country. NRC acknowledged this in an April 18, 2013 document (see item #4, on page 5 of 15 on the PDF counter, of this NRC document). Chances are very high that the reactor pressure vessel at Palisades would not leak before it broke. Pressurized thermal shock damage would strike in a split second. The reactor pressure vessel could fracture through-wall in an instant. There would be no warning ahead of time, such as a leak. (Of course, Palisades watchdogs have been warning the NRC and the reactor’s owners about this, time and time again, for more than three decades now!) The same thing could be true of the degraded steam generator tubes — they could break before they leak, with no warning. Or Holtec could also fail to adequately monitor for such leakage before breakdown, missing any warning in advance.

(10.) Shouldn’t Palisades be kept closed for good, in order to avert such catastrophic risks? Wouldn’t the more than $8 billion (with a B!), and still counting, of federal and state taxpayer funds, requested by Holtec, to be wasted on the unprecedented, unneeded, and extremely risky Palisades zombie reactor restart, be better spent on safe, secure, clean, reliable, and cost-effective renewables, such as wind and solar power, energy storage, and energy efficiency, and/or other societal betterment? Wouldn’t this be much better for human health, environmental protection, and the public good? Why does Holtec’s bottom line trump the public interest, both in terms of pocketbook impacts, as well as health, safety, security, and the environment?

(11.) See a Beyond Nuclear press release, dated September 26, 2024 (“Steam Generator Degradation Has Been Known at Palisades Nuclear Plant for Two Decades: Question Remains; Will NRC Require Safety-Significant System’s Replacement, or Not?”), regarding steam generator tube degradation at Palisades, for more talking point ideas.

(12.) It appears that the severity of the steam generator tube degradation is a self-inflicted wound by Holtec, aided and abetted by NRC, which allowed Holtec to carry out this self-inflicted damage. Our environmental coalition’s expert witness, Arnie Gundersen, chief engineer at Fairewinds, has warned for years that, if Holtec planned to restart Palisades, the company needed to actively maintain safety-significant systems, structures, and components — such as placing the steam generators into a chemically-preservative “wet lay up.” It is unclear at what point Holtec finally placed the steam generators into wet lay up, if ever. From the date of supposedly permanent shutdown — on May 20, 2022, by Entergy — until Holtec finally got around to placing the steam generators into wet lay up — if ever — degradation very likely took place at an accelerated rate. This is a reflection of Holtec’s incompetence, and also its inexperience in operating reactors (let alone restarting a long problem-plagued reactor from permanent shutdown). But Holtec’s — and NRC’s — willingness to take, and allow, such risks, shows a lack of concern for the potential adverse consequences to people and the environment, if and when enough steam generator tubes simultaneously fail badly enough.

(13.) Steam generator concerns were among the many reasons why our environmental coalition intervened against Holtec’s restart scheme at Palisades, long before the NRC’s Sept. 18, 2024 PNO was issued. The coalition’s expert witness, chief engineer Arnie Gundersen at Fairewinds, stated so in his declaration filed with the intervention.

As the coalition’s Oct. 7, 2024 intervention petition states:

[Gundersen] points out:

“First, Palisades’ safety and reliability have been diminished because systems and components were never placed in a layup. There is no record acknowledging the proper protocols of wet layup to protect the integrity of Palisades’ operating and safety
equipment and systems. Restarting a reactor after such a lengthy shutdown requires a layup and an updated engineered design for the entire reactor facility to assure its integrity and operational safety.”

Mr. Gundersen further notes that steam generators “are the most critical components that can rapidly degrade when not correctly placed in a wet layup.”

He continues:

“On October 1, 2024, a new report was issued by the Nuclear Regulatory Commission (NRC) that identifies severe damage in the two massive steam generators at the Michigan Holtec Palisades Nuclear Power Plant. If the plant were allowed to restart,
it would put one of the oldest U.S. nukes at risk of a meltdown.”

Mr. Gundersen points out that there is very significant stress corrosion cracking in the steam generator tubes and that an unexpectedly high number, 700, had to be plugged due to corrosion.

(Internal citations omitted.)

The Oct. 7, 2024 coalition intervention petition went on, quoting Gundersen:

“Holtec Palisades informed the Department of Energy that the Holtec Palisades Steam Generators were degraded and must be replaced in 2022. Instead of addressing the underlying damage from decades of operation under previous owners and new stress corrosion cracking in the steam generators caused by an improper wet layup, Holtec Palisades said it would unplug the 600 tubes plugged about thirty years ago. Now, the firm claims the aged and rundown steam generators will last for 30 more years. During my 53 years of professional experience, I am unaware of any steam generator, with so many previously known and newly identified flaws, that have not been replaced.”

Gundersen also warned that Holtec’s proposal to unplug 600 steam generator tubes may cause additional unforeseen troubles:

“Now, Holtec Palisades has decided it would be appropriate to unplug the tubes that Consumers Power preemptively plugged [more than three] decades ago. Yet six other Combustion Engineering steam generators have already experienced the internal
vibration problems that the plugged tubes were intended to prevent. Since the Holtec Palisades tubes are also experiencing stress corrosion cracking, unplugging additional tubes will create more unforeseen problems.”

See the section entitled “Plugging and Unplugging steam generator tubes is a major engineered change” in the coalition’s intervention petition (Pages 61-63). Also see Exhibit A: Arnold Gundersen Declaration and CV (the Declaration is 62-pages long, beginning on Page 77, and ending on Page 139, on the PDF counter.) Also see the coalition’s press release, dated October 8, 2024 — Gundersen provided a summary of his Declaration there.

(14.) If Holtec is required to replace the degraded steam generators, as should have happened nearly two decades ago, how will NRC guard against Holtec installing too many tubes within them? This very thing happened at San Onofre Units 2 and 3 in California. Southern California Edison and its contractor packed the brand new replacement steam generators to the gills, with extra tubes, in order to boost electricity production, and hence profits, at San Onofre 2 & 3. But the cram-packed tubes vibrated and rubbed against each other, causing severe degradation over a relatively short period of time. All of this went down on NRC’s watch, of course. So, how will NRC assure that Holtec won’t make similar mistakes at Palisades, if steam generator replacement is required, as it should be?

(15.) NRC’s 1982 CRAC-II report (also known as the 1982 Sandia Siting Study, after the national lab that carried out the NRC-commissioned study, or as NUREG/CR-2239, by its CR (Contractor Report) number) estimated the following consequences of a reactor core meltdown at Palisades: 1,000 peak early fatalities (acute radiation poisoning deaths); 7,000 peak early (radiation) injuries; 10,000 peak cancer deaths (latent cancer fatalities); and $52.6 billion in property damage. Adjusting for inflation alone from 1982 to 2024 dollar figures, property damage would now surmount $168 billion.

By the way, did CRAC-II account for economic impacts on the Great Lakes themselves? What about economic development since 1982, not accounted for in the CRAC-II figures?

And, as Associated Press investigative journalist Jeff Donn reported in 2012, populations have soared around U.S. atomic reactors since 1982, including at Palisades. So wouldn’t casualties from a Palisades reactor core meltdown be even worse today, as more people live, work, and recreate in harm’s way?

How can NRC allow Holtec to play such “radioactive Russian roulette” games at Palisades, as with the very high-risk, degraded steam generator tubes, given such irreparable stakes?!

(16.) Also see our environmental coalition’s press advisory about the Jan. 14, 2025 meeting. See in particular Arnie Gundersen’s backgrounder, dated Jan. 7, 2025, about the steam generator tube degradation at Palisades. This backgrounder is rich with ideas for additional talking points. Gundersen, Fairewinds’ chief engineer, serves as one of our environmental coalition’s expert witnesses, opposing Holtec’s restart scheme at Palisades.

(17.) The Great Lakes comprise 21% of the entire planet’s, 84% of North America’s, and 95% of the U.S.A.’s, surface fresh water. The Great Lakes serve as drinking and irrigation water supply (and so much more!) for more than 40 million people, in 8 U.S. states, 2 Canadian provinces, and a large number of Indigenous Nations. As Indigenous Nations have reminded us, “Water Is Life.” So how can such an irreplaceable planetary resource as the Great Lakes be put at existential risk by Holtec and NRC at Palisades?!

(18.) Even one tube failing in a steam generator at Palisades will result in a radioactive release to the environment. This is because steam generator tubes are primary coolant pressure boundaries. As affirmed by the U.S. National Academy of Science for many decades now, any exposure to ionizing radioactivity carries a health risk for cancer (and other diseases, truth be told), the higher the exposure the higher the risk, and these risks accumulate over the course of a lifetime. That is, there is no exposure to radioactivity, no matter how small, that is risk-free. This well-established scientific theory is called the “Linear, No Threshold” theory. Radioactivity releases from atomic reactors like Palisades, whether large or small, intentional or unintentional, do not disappear into nothingness. They linger in the living environment, contaminating drinking and irrigation water supplies like Lake Michigan, and bio-concentrating, bi0-magnifying, and bio-accumulating up the food chain. Humans, at the top of the food chain, can thus ingest much more concentrated, hazardous ionizing radioactivity, than what was initially released from Palisades.

These sample talking points were prepared by Beyond Nuclear’s radioactive waste specialist, Kevin Kamps, on Jan. 2, 2025. Additional talking points were added, and updates, as well as corrections, were made on Jan. 5, 6, 11, and 12, 2025. If you have questions, contact Kevin Kamps at: (240) 462-3216; [email protected]

Learn more about our environmental coalition’s resistance to Holtec’s Palisades zombie reactor restart scheme here.

{*Email from Donna Gilmore at San Onofre Safety, dated Jan. 3, 2025:

Regarding Item 4 [above] about San Onofre Steam Generators, please make corrections: