I was unable to speak during the public comment portion of the Public Pre-Submittal Meeting which was held today by the Nuclear Regulatory Commission to Discuss Palisades Relief Request 5-14 (Pressurizer Spray Nozzle Safe End and Safety Nozzles Flange Welds). However, participants could also submit comments in writing, so this was what I submitted to the Nuclear Regulatory Commission earlier today (images added):
I am in strong agreement with Michael Keegan's comment about the unanswerable risks due to loss of operating data (specifically, documents relating to the operating history of the plant that had been kept since the plant opened but have already been destroyed by staff, thinking the plant would never open again).
There is no way to rely on data that no longer exists. Yes, the plant was "operational" (but not profitably) when it was shut down. But since that time essentially nothing was maintained, and prior to shutdown, there were numerous problems over the years, resulting in steam generator tube plugging, planned replacement of same, and reactor pressure vessel head wear, along with pipe, pump and valve wear throughout the plant.
Numerous records relating to THIS particular topic have been willfully destroyed. It is reasonable to assume the same is true regarding records for other critical parts throughout the plant. What valves (if any) tended to leak? Which air filters tended to clog with rust? (The Davis-Besse reactor had an unnoticed problem with that, which was caused by the slow growth of their infamous reactor pressure vessel "hole in its head". Had an employee not leaned against the control rod during a reactor shutdown, it would almost surely have caused a meltdown the next time the reactor was operated.)
Most importantly at Palisades: Were any specific records purposefully destroyed first? Perhaps a whole filing cabinet or two of "industry secrets"? Why were the records destroyed at all, if the physical plant was still largely in operational or near-operational condition? That's a RED FLAG right there that "dirty secrets" were contained in those records which were destroyed!
Lastly, it is a "given" that an operating reactor is for more likely to have a catastrophic accident than spent fuel, especially spent fuel that has been out of the reactor for a few years or more. What is the comparative risk for the public, and the taxpayer, from restarting this particular reactor and creating additional spent fuel with nowhere to put it? The last major nuclear accident in the United States (Three Mile Island) practically killed the nuclear industry. The whole industry will take an enormous public-relations "hit" if the plan to restart Palisades fails in any way.
If it fails in a not-catastrophic way, such the way San Onofre failed, that would actually be a good thing! The more reactors that shut down permanently without a catastrophic accident, the better for America.
But that is a side issue to the reputational damage a failure at Palisades would do to the rest of the nuclear industry, which is hanging by a thread as it is, because its electricity is so much more expensive (and far less reliable) than numerous alternatives, such as (at the high-tech end) deep geological thermal energy, to (at the low-tech end) household heat pumps and solar rooftops. Behemoth power plants with a catastrophic risk requiring immoral immunity from full responsibility for catastrophic industrial accidents makes no sense in a democracy. In a democracy, the entity causing the damage pays. If nuclear can't get insurance, it's because it's far too dangerous.
Offer to let Holtec restart Palisades ONLY without the exemption of Price-Anderson and see what happens...
Thank you in advance for sharing these comments with the rest of the Nuclear Regulatory Commission team.
Ace Hoffman, Carlsbad, California USA
Note: The author has been studying nuclear safety independently since his teen years, including discussing safety issues with nuclear reactor designers and operators, three top Manhattan Project scientists, numerous health professionals, engineers, statisticians, economists, and many other experts in related fields. This writer actually believed, when it happened (and he was already concerned with reactor safety issues), that merely the separation of the Atomic Energy Commission into the Department of Energy (who would promote and develop nuclear power) and the Nuclear Regulatory Commission (which would be solely responsible for nuclear safety at commercial nuclear power reactors, since the AEC wasn't doing that part of its job very well) would result in shutting the entire industry down, because if you (the NRC) are NOT responsible for making sure the industry MAKES A PROFIT, there's NO WAY you can endorse the CHEAP-SKATE way the nuclear industry operates and has always operated. Too cheap to find insurance for themselves. Too cheap to restart Palisades without billions of dollars from the federal government and hundreds of millions more from the state. Too cheap to replace the worn-out steam generators and half a gazillion other parts that undoubtedly ought to be replaced but the combined cost and time loss would make it all look far too ridiculous for anyone to endorse. Too cheap to find a solution to storing the waste, other than to sue the government to pay Holtec to continue to store the waste on-site forevermore. Too cheap to cut their losses before a catastrophic accident happens (again) that's far worse than Three Mile Island, which was practically a nothing on a log scale where Chernobyl is a seven and Fukushima's triple meltdowns only a six.
But one thing nuclear was never too cheap about was this: It was never too cheap to meter, as originally promised. Nuclear power never was and never will be cheap, or competitive with cleaner alternatives. Currently the claim by the nuclear industry is that it is "green." But with all the mining, milling, transport, shutdown, repairs, concrete and steel (than can never be recycled), nuclear never was and ever will be the least bit "green". And despite Holtec's claims that a Palisades restart can be done safely, the reality is that nobody can be sure that restarting Palisades won't result in a catastrophic American meltdown. And if that happens, the Nuclear Regulatory Commission, and the members of this committee specifically, will be as much to blame as Holtec will be. But it will be the public and the taxpayer who suffers and pays.
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Contact information for the author of this newsletter:
Ace Hoffman
Carlsbad, California USA
Author, The Code Killers:
An Expose of the Nuclear Industry
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acehoffman.org
Blog:
acehoffman.blogspot.com
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Email: ace [at]
acehoffman.org
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