Consumers Energy’s briefing to State of Michigan regulators
regarding its intention to sell the Palisades reactor as quickly as possible,
revealing important problems afflicting the plant.
Notes/Remarks/Thoughts by Kevin Kamps, NIRS nuclear waste
specialist, on Consumers briefing above, prepared June 20, 2006:
On page 1, note the sale would also include the high-level radioactive
waste at Consumers’ permanently shutdown Big Rock Point reactor
in Charlevoix, MI. Why would another company want to “buy”
and become liable for the high-level radioactive wastes that Consumers’
generated? A big question mark hangs over the growing quantity of overflowing
high-level wastes at Palisades – who would be liable for it into
the future?
On page 2, Consumers admits to problems with Palisades, including
the need to replace the reactor vessel head (not mentioned is the fact
that penetrations elsewhere on the vessel are also vulnerable to corrosion);
the need to replace the steam generator (again – they’ve already
done this once before at Palisades!); “embrittlement concerns,”
the main safety issued raised by the coalition opposed to the license
extension; “fire protection requirements,” an issue NIRS Reactor
Watchdog Project Director Paul Gunter has followed closely for decades;
“Containment coatings and sump strainers,” an issue Dave Lochbaum
at Union of Concerned Scientists has highlighted for years. With all these
problems afflicting the plant, how can NRC grant Palisades a 20 year license
extension?!
On page 3 and 4, Consumers speaks very disparagingly about the
future of Nuclear Management Company (NMC), current operator of Palisades,
as one major reason it wants to sell Palisades. How can NMC be allowed
to operate Palisades, as well as the Point Beach reactors in Wisconsin,
and the Monticello and Prairie Island nuclear plants in Minnesota, when
it’s future is so uncertain? How safely can a company whose future
existence is in doubt operate nuclear reactors?
On page 5, Consumers all but admits it lacks the expertise to
operate Palisades well.
On pages 6 and 7, Consumers mentions “nuclear risks.”
Do they include risks for public health and safety and the environment,
or merely financial risks to the company owning Palisades?
On page 8, Consumers mentions that “Various options are
available to use excess funds [from the sale] to benefit customers.”
We would have to hold their feet to the fire on that one!
Also on page 8, Consumers mentions “Decommissioning risk
avoidance…Funds which would otherwise be “trapped” in
the decommissioning trusts can be returned to customers.” Is that
accomplished by doing little to know radioactivity contamination clean
up, thus pocketing the money while leaving the contamination on the site
to poison the soil and Lake Michigan over time? How can we be sure the
companies wouldn’t just pocket the “excess” funds left
over after decommissioning is declared finished (regardless of how much
radioactive contamination remains on site)?
On page 9, Consumers lists all of the “nuclear ownership
and operating risks” it would shed by selling Palisades: operating
risk; financial risk; nuclear risk; industry risk; NRC risk; potentially
significant future capital expenditures; employee attraction and retention;
exposure to NMC uncertainties.” We’d agree that operating
Palisades till 2031 would be risky, indeed! Especially, risky to the health,
safety and environment of the public!
On page 10, Consumers speaks of “closing [the sale] expeditiously.”
Why is Consumers in such a rush to sell the reactor? Why is NRC in such
a rush to approve the 20 year license extension? Potential buyers should
beware – they should “look under the hood” before buying
this lemon! And potential buyers should also realize that, along with
the reactor and waste already piled up there, they would also inherit
one fired up coalition of concerned citizens and environmental groups
that want Palisades shut down at the end of its current license –
2011 and no later!
On page 11, Consumers predicts it will select a buyer to sell
to by July 2006. They predict the sale will be finalized, with all regulatory
approvals obtained, by early 2007. And they expect NRC to rubberstamp
the 20 year license extension by early 2007 as well. Curious, isn’t
it, that another company would buy Palisades even before the 20 year license
extension is granted? Seems like all the nuclear utilities are VERY confident
in receiving those extensions from NRC…
On page 12, Consumers states that the environmental assessments
and site surveys it is conducting are geared toward the sale. Nevermind
the license extension safety and environmental impact proceedings, which
NRC and Consumers seem to regard as perfunctory processes ending in an
expedited rubberstamped approval. One site survey that Consumers has never
performed – and NRC is not requiring of them before it grants the
license extension – is for Native American archaeological and cultural
resource sites, such as ancient village sites, burial sites, etc. NRC
even admitted in its draft Env. Impact Statement that 15 Native American
sites have been identified within 1 mile of Palisades, including one site
0.3 miles south, and another right on its eastern property line. NRC also
admitted that the presence of additional sites on Palisades property is
highly likely. A Consumers-hired cultural resource assessment team concluded
that operations at the plant could damage or destroy such sites, if a
careful, comprehensive site survey is not conducted. Such a survey should
be required by NRC before granting the license extension, and should be
conducted in close and meaningful consultation with affected tribes. NRC
is requiring none of that, granting Consumers carte blanche to proceed
without doing any site survey.
On page 14, Consumers predicts that bids from potential buyers
will be due by the end of June, 2006. Consumers then hopes to conclude
the sale “as quickly as practicable.” Again, why the rush?
Consumers also hopes to rush the regulatory approvals “ASAP.”
Is safety and security getting short shrift in this rush?
On page 15, Consumers states that “existing decommissioning
funds are in excess of requirements and may be retained after sale for
ratepayer benefit.” Again, there could only be an excess of decommissioning
funds because NRC decommission regulations allow for radioactive contamination
to remain on the site. And the public must remain vigilant to make sure
the companies don’t simply pocket the money, rather than return
it. Consumers also collected well over $100 million for long-term high-level
radioactive waste management at Palisades, before the Nuclear Waste Policy
Act became federal law in 1983. Again, that ratepayer money must go towards
its intended purpose, not into the pockets of the nuclear utilities.
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