August 22, 2005

Chief, Rules and Directives Branch
Division of Administrative Services
Office of Administration
Mailstop T-6D 59
U. S. Nuclear Regulatory Commission
Washington, DC 20555-0001

Public Comments: Environmental Impact Statement re: Proposed 20 Year Extension of the Operating License for the Palisades Nuclear Power Plant [Docket No. 50-255; License No. DPR-20; Palisades owner is Consumers Energy/CMS; Palisades' operator is Nuclear Management Company, LLC]

Comments submitted by:
Gary Karch 

A process that appears designed to intentionally disenfranchise a population with which it is supposed to promote dialogue can only be looked at with skepticism and must be considered a ruse and a sham.  Although the model as presented for public comment regarding the request for a twenty year license extension for the Palisades Nuclear Plant in Van Buren County, Michigan, meets guidelines as established by the NRC, it provides little opportunity and draconian deadlines for true citizen participation to exist.  Such restrictions may have been dismissed by communities in which other license renewals have been requested and approved, but I submit that Southwest Michigan holds itself to higher standards and wishes to challenge the industry paradigm and demand a more reasonable and humane response to this license renewal process than the flawed one that has been foisted upon us.  

Current standards only allow for easy participation from persons living within the industry-designated ten mile radius emergency planning zone.  Obviously radiation travels far greater distances than that, and even the extended 50 mile radius does not realistically encompass the distance a radiation release can travel.  Meetings have been scheduled only in the South Haven area with limited publicity and at times that impede a working public's ability to attend.  These dates and locations may be convenient for Palisades representatives and NRC staff but not to residents in the greater area affected by the plant's existence.  For example, the next public meeting in which these and other comments submitted by today's deadline will be discussed is scheduled for the Friday before Labor Day.  This insults the public, inhibits participation by interested citizens and denigrates the integrity of the process.
Materials pertinent to the license currently available only at the South Haven library should be made available in a majority of libraries located within the 50 mile radius.  The whole process needs to be expanded to include public meetings and comment opportunities in all communities within the entire 50 mile radius who wish to request them.  If the plant owners and managers have nothing to hide and take pride in their operation, then they should have no reservations about taking their meetings on the road and extending the process to a more reasoned pace.  And if the NRC believes in the integrity of their process, they should likewise be up to this challenge.  It is six years before the current license expires.  There is no need to rush through the process.  In fact, a more lengthy approach that is truly inclusive of citizen participation from affected communities should be encouraged.  

Let us not forget that we are discussing the continued production for another 20 years of a lethal waste that requires extreme safety control measures.  We are not talking about a tootsie roll factory here.  The waste product is being stored on the shores of a body of water that constitutes one fifth of the earth's surface fresh water and which provides potable water to millions of people.  Another twenty years of accumulated waste added to the already existing lineup of outdoor dry cask storage situated on unstable sand dunes is a major concern.

It has been recently confirmed by the National Academy of Science that there is no safe level of exposure to radiation and that even very low doses can cause cancer.  I am therefore disturbed by nuclear industry corporate culture that has a ubiquitous record of dismissing legitimate concerns about radiation exposures.  In the case of Three Mile Island, it has been found by more recent independent analysis of the 1979 accident that placement and frequency of monitoring devices were highly inadequate and unable to establish accurate data from which to establish radiation release patterns.  For residents of Harrisburg and the surrounding area, that meant their reported symptoms of metallic taste, erythema, nausea, vomiting diarrhea, hair loss, deaths of pets and farm animals were attributed to stress brought on by the accident, not radiation releases from the accident.  Apparently if no monitors were present in any given neighborhood and therefore no radiation data could be collected, then no radiation had been released.   People were treated as though they had psychological problems, not legitimate symptoms of radiation exposure.  

Exactly how will the citizens of Michigan be treated should a similar accident occur at Palisades?  I simply refuse to accept my community being treated in such an insulting and degrading manner.   I therefore ask that a complete map showing existing radiation detection locations for Palisades be provided and frank discussion on this monitoring methodology be initiated.  I also ask that public health data regarding cancer rates in surrounding communities of the Palisades Nuclear Plant be included in the discussion, and participation by Michigan Department of Community Health epidemiologists be present at future hearings.

I also request that information reflecting the true financial taxpayer economic burden of the plant, including all anticipated guaranteed loans, tax incentives, and any other additional financial deals expected to be requested by plant owners that are contingent upon Palisades' continued operation, be provided at some point in the proceedings, or the means and process to obtain such data be provided.    While I realize that this is not germane to the Environmental Impact Statement, disclosure of this information is vital to assessing Palisades' true financial worth to the community.
Palisades nuclear reactor: Archives info:

This aging, embrittled nuke needs to be shut down. The NRC re-licensed the aging nuclear reactor for another 20 years. That will be 60 years running, if it doesn't blow up first. The reactor was designed and built for 20 years. The NRC is rubber-stamping the re-licensing of nuclear reactors throughout the USA. Nuclear energy is not a solution to global warming. In the process of mining uranium, processing uranium, transporting nuclear fuel, building and running nuclear power plants, nuclear waste production, transportation, and dumping....tremendous amounts of fossil fuels are used, and the lake/river waters used to cool down nuclear reactions creates water heating, atmospheric heating and radioactive elemental releases into the environment.

A coalition of environmental groups, including Don't Waste Michigan has filed a lawsuit in federal courts because the re-licensing did not take into account some very important issues. 

The area surrounding Palisades is a cancer pocket. If you live in that area, and have cancer, know someone with cancer, or someone who has died from cancer, your testimony is especially crucial to the shut down. The goal of DWM is to shut it down before it melts down. Members of DWM have regularly attended meetings with the NRC with the purpose of bringing issues to light, getting testimony on the federal record, and to shut down unsafe nuclear reactors.

A former Palisades worker gave his opinion: that  'within the nuclear industry, it is well known that Palisades is the most likely to blow of all nuclear reactors in the United States....they don't necessarily cover things up, they just don't report them' 
 ~name withheld by request~

DWM members have brought it to the attention of the NRC and Homeland Security the need for more security surrounding and within nuclear reactors. Even without a terrorist attack, the mere operation of a nuclear reactor is a potential terrorist act, if a meltdown should occur.

Consumers Energy sold Palisades to Entergy.*

DWM feels that a sustainable future can only be realized with safe, renewable energy systems, such as wind, water, and solar power.

At a November 2004 meeting, the public was given time to speak.
When the South Haven mayor spoke out that the people of South Haven wanted the nuclear power plant, citizens rose in protest. "He does not speak for us! There is a cancer pocket here!"
In November, he was not re-elected, losing by 70%...
The people have spoken!

Palisades issues:
Global warming caused by nuclear energy
Cask problems (nuclear waste storage)
Nuclear accidents
The threat of terrorism 
etc......public comments were truncated and edited in the EIS. by the NRC.

UPDATE  2007: The NRC rubberstamped the re-licensing of Palisades without allowing the public meetings as promised in winter/spring of 2007. The NRC never answered all of the questions put forth by DWM re: embrittlement, cask #4 (bad welds), nuclear waste buildup, rad waste spills, terrorism, and other issues. 

*UPDATE 2008: ENTERGY  sold Palisades to ENEXUS, a subsidiary of itself. It is seeking the license transfer. So far problems have NOT been fixed: i.e. reactor head, snuffer valves, embrittlement etc. On August 5, there was an incident now under NRC investigation. 

2011: Palisades continues to have major issues. December: 2 sump pump failures: hot shutdown, plant tremors with major  gas releases. Enough is enough! Shut it down for good before it blows.!!  WRITE YOUR CONGRESSPERSON, THE NRC, THE PRESS...SHUT IT DOWN. SHUT IT DOWN NOW!!!


Immediate Release: Nov. 10, 2004

5 Groups Sue Dept. of Transportation for New Rules that

Allow Nuclear Waste to Move Unregulated, Unmarked

 Five public interest organizations filed suit in a Northern California federal district court against the US Department of Transportation (DOT) for its adoption of rules which reduce public protections by allowing more radioactivity to move on roads, rails, planes and waterways without regulatory control. The groups are Nuclear Information and Resource Service, Sierra Club, Public Citizen, Redwood Alliance and Committee to Bridge the Gap. The groups are calling for withdrawal of the portions of the rule that exempt and weaken nuclear transport controls and for full environmental impact review. 
The regulations exempt various amounts of every radionuclide (all the radioactive forms of each element) from radioactive labeling, tracking, and control. They also allow some nuclear materials to be shipped without packaging. The groups will also challenge, in a separate case, the Nuclear Regulatory Commission (NRC) which simultaneously adopted the same regulations. A whole new category of exempt quantities has been adopted, allowing radioactive packages (called consignments) to be considered not radioactive in transport. The exempt concentration limits have changed, exempting higher concentrations for more than half of the hundreds of radionuclides listed. 
"At a time of heightened concern about dirty bombs, the federal government should not increase the amount of nuclear material that can be transported without any labeling or tracking. This is the exact wrong time to let go of nuclear materials and wastes," stated Diane D'Arrigo, Radioactive Waste Project Director at Nuclear Information and Resource Service. "Watching for and detecting dirty bombs will be harder if more radioactive materials are shipped routinely without placards or manifests." 
"Workers and the public will be exposed to radiation without their knowledge or consent. It is forced radiation exposure," charged Wenonah Hauter, director of Public Citizen's Critical Mass Energy and Environment Program. 
Truck drivers, rail workers, loaders, emergency responders, even postal workers could be exposed routinely to more radioactivity than before without warning. Workers in the transport and shipping industries will get the highest doses but everyone who lives, works and travels along the routes could come into regular contact with unidentified nuclear waste. According to calculations in the DOT rule, truck drivers could get more radiation from hauling unmarked radioactive materials than one is allowed living next to a nuclear reactor or weapons site. DOT admits workers and the public will have more exposure to radioactivity but discounts the dangers of radiation, failing to consider the impacts on those more susceptible to radiation like children, the fetus, women and those with reduced immunity.
The transport rule fits into a larger picture of deregulating nuclear waste. Other federal agencies including the NRC, the Environmental Protection Agency (EPA) and the Departments of Energy and Defense (DOE, DOD) are in various stages of deregulating nuclear wastes and sites over which they have jurisdiction. If they proceed with deregulating nuclear wastes as now proposed, radioactive materials could go to municipal and industrial landfills, incinerators and scrap recycling centers. Workers at those sites would be regularly exposed to more man-made radiation. Changing the transport regulations makes taking unmarked nuclear loads to unregulated destinations possible once they are cleared by those other agencies.
"Removing existing requirements for labeling in transit will make it easier for other agencies to let nuclear wastes get out into commerce. The public will be exposed both during transport and then again from the products, buildings and roads made from nuclear contaminated materials," explained Dan Hirsch, President of the Committee to Bridge the Gap.
"That is the real motivation," said Dr. Judith Johnsrud of the Sierra Club, "to assist the nuclear industry in treating some nuclear waste as if not radioactive. This saves the nuclear generators money and pushes the economic and health burden onto unsuspecting transporters, recyclers, local governments, the public and the environment."
No meaningful justification for the exemptions is provided by either DOT or NRC for relaxing restrictions on nuclear materials transport. The exempt concentrations and amounts adopted are the same as those recommended by international nuclear advocacy organizations to allow nuclear waste to be cleared for commercial recycling. 
"It is not a coincidence. This weakening of the nuclear transport laws is a deliberate attempt to bypass the American public's opposition to nuclear waste deregulation and release into everyday commerce. DOT and NRC are teaming up with the global nuclear industry to make nuclear power appear cheaper while putting transport workers, the public and environment at unnecessary radioactive risk." said Michael Welch of the Redwood Alliance.

For more information on Nuclear Information and Resource Service (NIRS), go to

For more information on Public Citizen, go to

For more information on Sierra Club, go to

A great anti-nike website: www.beyond


No need to build new U.S. coal or nuclear plants -- FERC chairman


No new nuclear or coal plants may ever be needed in the United States, 
the chairman of the Federal Energy Regulatory Commission said today.

"We may not need any, ever," Jon Wellinghoff told reporters at a U.S. 
Energy Association forum.

Building nuclear plants is cost-prohibitive, he said, adding that the 
last price he saw was more than $7,000 a kilowatt -- more expensive than 
solar energy. "Until costs get to some reasonable cost, I don't think 
anybody's going to [talk] that seriously," he said. "Coal plants are 
sort of in the same boat, they're not quite as expensive."

There's enough renewable energy to meet energy demand, Wellinghoff said. 
"There's 500 to 700 gigawatts of developable wind throughout the 
Midwest, all the way to Texas. There's probably another 200 to 300 
gigawatts in Montana and Wyoming that can go West."

He also cited tremendous solar power in the Southwest and hydrokinetic 
and biomass energy, and said the United States can reduce energy usage 
by 50 percent. "You combine all those things together ... I think we 
have great resources in this country, and we just need to start using 
them," he said.

But planning for modifying the grid to integrate renewables must take 
place in the next three to five years, he said.

"If we don't do that, then we miss the boat,"Wellinghoff said. "That 
planning has to take place so you don't strand a lot of assets, a lot of 
supply assets."

/Senior reporter Ben Geman contributed./

Don't Waste Michigan members protest nuclear dangers
For immediate use 
Monday, May 5, 2008 

Kevin Kamps, Beyond Nuclear 
Dave Kraft, NEIS  
CHICAGO—The much ballyhooed “Nuclear Renaissance” is nothing more than a PR fraud foisted upon an unsuspecting and uninformed public, charge two safe-energy groups today.
<>Kevin Kamps, nuclear researcher for Beyond Nuclear ( of Takoma Park, MD, and Dave Kraft, director of the Chicago-based Nuclear Energy Information Service – two organizations critical of nuclear power – maintain that the Nuclear Energy Institute (NEI – the trade group for the US nuclear power industry) has long been inflating the alleged benefits of nuclear power, while keeping the public in the dark about the downsides.  
“We refuse to allow the NEI to come to Chicago to perpetuate its fake ‘Nuclear Renaissance’ without a public challenge of its bogus claims,” says Kamps.  “This is no ‘renaissance.’  It’s a relapse.” Kamps asserts.
<>The NEI is in Chicago for its 3-day annual conference at the Fairmont Hotel.  Exelon Chair John Rowe is chairman of the NEI.  Exelon has 14 reactors in Illinois (11 operating), more than any other state.  
“At a time when high energy costs and the prospect of catastrophic climate change call for radical changes in how we get our energy, we will not sit by quietly or patiently while PR hacks spew the falsehoods that nuclear power is either economical, or able to help solve the global warming problem,” says NEIS’ Kraft.  “The people like the NEI who deliberately spread these falsehoods to make a short-term buck will find that there will be consequences from now on,” Kraft warned.
<>Reality has been very unkind to the Nuclear Renaissance, formally launched at an industry conference at the Palmer House, Chicago, in December 2001.  From the heady days of Vice President Cheney’s 2001 call for 150 new reactors and NEI’s claims of reactors costing $1 billion/GW each, today’s headlines talk of maybe 8-10 reactors being built in the US by 2020; and Wall Street and utilities themselves talking about reactors costing $6-$12 billion each.  
“Every cost prediction the NEI and the nuclear industry have made has been wrong.  Yet, this industry keeps coming back to feed at the public trough,” Kamps points out.  “The 2005 energy bill granted over $21 billion in actual and guaranteed subsidies for the nuclear industry, with an additional $30 billion possible in the next year.  And even the Lieberman-Warner bill – touted as a bill to support and invest in clean energy sources to fight global warming and due for a vote in early June -- has as much as $500 billion in hidden benefits for the nuclear industry, even though the word nuclear appears no where in the bill,” Kamps notes.  “This kind of fraud would make Al Capone blush.”

While nuclear industry predictions about costs have always been undervalued, its claims about its role in fighting global warming seem to trend in the opposite direction according to Kraft.
  <>“If global warming is the ‘Titanic’ of all environmental issues, one threatening civilization, then the nuclear industry and NEI are selling seats to the life-boats, and leaky life-boats at that,” Kraft claims.  “Nuclear power is simply too slow, too expensive, less carbon-effective and adds other equally dangerous risks compared to other viable choices that exist already to reduce atmospheric carbon.  It must be rejected as a ‘solution’ or even a ‘helper’ in the fight against global warming,” Kraft asserts.  “It is unconscionable that the NEI continues to perpetuate such a fraud on an ill-informed public.”  
Both Kamps and Kraft are quick to point out that as dire as the energy and climate situation appear, viable cost- and environment-effective means already exist to deal with the two crises -- simultaneously.
<>“The nation simply must launch a Manhattan Project-style effort to move this nation away from increasingly expensive and environmentally damaging nuclear and fossil fuel power,” states Kamps.  
“Fortunately, such a program has already been researched,” notes Kraft.  “It is called, ‘Carbon Free – Nuclear Free by 2050: A Roadmap for US Energy Policy,’ developed by Dr. Arjun Makhijani of the Institute for Energy and Environmental Research (IEER; ).  His calculations show that this country can get off of BOTH fossil and nuclear fuels by mid-century, using technology already largely invented and available, and do so in a cost-effective manner.  The economic and environmental benefits of Carbon Free – Nuclear Free are extraordinary, far surpassing those of nuclear power,” Kraft concludes.
<>Both agree that the real barriers to such an energy program are largely political, not technological.  
“The influence of the NEI and nuclear industry over the Congress and the regulators at the Nuclear Regulatory Commission is enormous,” Kamps points out.  “The tail wagging this dog needs to be swatted hard,” he says.
<>“An old saying notes that, ‘If we keep doing things the same way we’ve always done them, we’re likely to get a whole lot more of what we already got.’  If the NEI and its clients get their way, that means more nuclear waste, higher cost electricity, more nuclear proliferation, and more global warming, since the money used on the fake nuclear ‘renaissance’ would not get spent on more effective means of removing atmospheric carbon,” Kraft asserts.  
“All of the candidates running for President are simply more-of-the-same fence sitters,” Kraft says.  “Sen. Obama is tragically misguided in his belief that nuclear power needs to be ‘kept on the table’.  In spite of the heavy campaign contributions to all the candidates from the nuclear industry people, they all need to break away from this dead-end industry, and launch a real sustainable energy future,” says Kraft
“One that doesn’t suffer from the continual paid PR exaggerations of the NEI,” Kamps concludes.

Paul Gunter, Beyond Nuclear
David Lochbaum, nuclear engineer, Union of Concerned Scientists,
Michael Mariotte, Nuclear Information and Resource Service,
“Nuclear Power Costs: High and Higher,” Dr. Arjun Makhijani, Science for Democratic Action, January, 2008.          
CARBON FREE – NUCLEAR FREE BY 2050: A Roadmap for US Energy Policy
Dr. Arjun Makhijani, Inst. for Energy and Environmental Research,
(note: a summary newsletter and the entire book is downloadable for free in .pdf format at 
“What Nuclear Renaissance?”, Christian Parenti, The Nation, May 12, 2008, 4 pages. 
“Forget Nuclear,”   Amory B. Lovins, Imran Sheikh, and Alex Markevich, April, 2008, 7 pages with footnotes. 
“Insurmountable Risks:  Can Nuclear Power Solve the Global Warming Problem?,” by Brice Smith, Science for Democratic Action, August, 2006.  
“Isn’t it time we forgot about nuclear power? Informed capitalists have. Politicians and pundits should too. After more than half a century of devoted effort and a half-trillion dollars of public subsidies, nuclear power still can’t make its way in the market.” – Amory Lovins, Rocky Mt. Institute, “Forget Nuclear.”  April 2008. (see above)
<>“This much seems clear: a handful of firms might soak up huge federal subsidies and build one or two overpriced plants. While a new administration might tighten regulations, public safety will continue to be menaced by problems at new as well as older plants. But there will be no massive nuclear renaissance. Talk of such a renaissance, however, helps keep people distracted, their minds off the real project of developing wind, solar, geothermal and tidal kinetics to build a green power grid.”  -- Christian Parenti The Nation, May 12, 2008  
“It does not make economic sense.”  --Warren Buffet, on explaining his decision to end plans to construct a nuclear reactor in Idaho, January, 2008.
-- end --

Radiation-Laced Groundwater Could Be More Widespread 
than Entergy Nuclear Palisades Knows or Admits 

Concerned Citizens Demand Compulsory Testing in Area and Lake Michigan 

On Dec. 10 and 13, the Entergy Nuclear Palisades atomic power plant found concentrations of radioactive hydrogen, called tritium, in groundwater between the reactor and Lake Michigan that violate U.S. Environmental Protection Agency (EPA) Safe Drinking Water Act limits. Entergy Nuclear Palisades detected concentrations of 22,000 picoCuries per liter in the groundwater, above EPA’s 20,000 picoCurie per liter Safe Drinking Water Act limits. 
However, technical expert Dr. Arjun Makhijani, President of the Institute for Energy and Environmental Research, reports that "[t]he scientific models used to evaluate the adverse health impacts of tritium have a number of serious weaknesses." Dr. Makhijani reports that "...tritium can cross the placental barrier. This tritium can then be incorporated into an embryo/fetus and irradiate rapidly dividing cells, thereby raising the risk of birth defects, early miscarriages, and other problems. Tritium therefore provides an important case study for examining how radiation protection standards need to be changed in light of risks to those who are not adult men." Dr. Makhijani, citing the vulnerability of embryos and fetuses to tritium’s radioactivity, is calling for Safe Drinking Water Act protections to be strengthened as much as 50 times, as has happened in the State of California; the State of Colorado and U.S. Department of Energy have agreed to protective levels for tritium in groundwater 40 times stronger than the EPA regulations in place at Palisades. 
Statement of Kevin Kamps, Radioactive Waste Watchdog at Beyond Nuclear, and board member of Don’t Waste Michigan representing the Kalamazoo chapter, regarding Entergy Nuclear Palisades’ admitted radioactive contamination of groundwater and the necessity for extensive testing of the area’s groundwater, surface water, and drinking water supply, including Lake Michigan itself. 
“Entergy Nuclear Palisades’ admitted detections are likely but the tip of a radioactive iceberg in the form of tritium contamination spreading throughout the groundwater below, perhaps even into Lake Michigan itself. Palisades’ admission merely confirms what we have long known – that this nuclear reactor is far from benign, but rather generates and releases harmful radioactivity into the environment. These leaks have undoubtedly worsened as this now forty year old reactor deteriorates and degrades with age. 
In our view, it is criminal for Entergy Nuclear Palisades to trivialize, downplay, and explain away the potential health consequences of such tritium contamination in an attempt to deceive the unsuspecting public. 
Area residents and visitors near Entergy’s Palisades atomic reactor – especially children, the most vulnerable of all – are at risk from drinking radioactively-contaminated well water or Lake Michigan water. The U.S. Nuclear Regulatory Commission (NRC), EPA, and the State of Michigan should do their job, and determine the health risks to the residents of Palisades Park resort community, CovertTownship, the City of South Haven, visitors to the Van Buren State Park, and other area residents. 
As Dr. Arjun Makhijani at the Institute for Energy and Environmental Research has reported, tritium increases the risk not only of cancer, but also of non-cancerous diseases and maladies in pregnant women and the embryo/fetus, including ‘early miscarriages, malformations, and genetic defects. Risks can also be multi-generational given that a woman’s ova are produced while she is in her mother’s womb.’ 
Poisoned water has been leaking from the Palisades atomic reactor for who knows how long. Radiation has now been detected escaping as an underground radioactive plume, but the question must be asked, has it begun to contaminate Lake Michigan as well? Nearby residents, and visitors at the Van Buren State Park, may very well have unknowingly consumed, cooked in, and bathed with radioactively contaminated water, risking cancer and birth defects with repeated and prolonged exposure. Those swimming and fishing near Palisades, as at Van Buren State Park, may also be at increased risk due to radioactivity releases into the Lake Michigan environment. 
Area residents and visitors should not be deceived nor satisfied by hollow claims from Entergy or NRC that exposure to tritium is harmless. This propaganda has already been debunked by the U.S. National Academy of Sciences, which has declared that there is no safe dose – no matter how small – of radiation. 
Area residents and visitors to Van Buren State Park must demand their drinking water be independently and fully tested. Neither Entergy Nuclear nor the NRC can be trusted to protect human health against corporate greed. Currently, South Haven’s drinking water authority collects samples of Lake Michigan water from the City’s water intake system, but then hands them over to Entergy Nuclear for safety testing. This is a flagrant violation of basic chain of custody protocols designed to prevent fraud and falsification in scientific safety testing. Extensive on-site and off-site groundwater monitoring should be undertaken immediately. It must be conducted by legitimately independent and trustworthy third parties. 
Entergy deceptively reported that the contaminated ‘well is located inside the owner controlled area and inside the protected area. This well is not a drinking water source.’ But they apparently have not even checked off-site groundwater, nor Lake Michigan. Of course, if they do not look for off-site contamination, they will not find it. And of course, all groundwater is potentially drinking water. The Van Buren State Park’s campground, immediately adjacent to Palisades nuclear reactor, uses well water for drinking. And the City of South Haven uses Lake Michigan as a drinking water supply, so leaking tritium entering Lake Michigan could flow from residents’ kitchen sink and bathroom taps as radioactively contaminated drinking, cooking, and shower water. 
NRC has allowed Palisades’ now-closed sister atomic reactor, Big Rock up north in Charlevoix, to discharge 20,000 gallons of tritium contaminated water into Lake Michigan first via the soil, then via the groundwater, like a radioactive septic field. Given the proximity of area drinking water supply intakes in Lake Michigan, this outrage cannot be repeated at Palisades.” 


"Nuclear Power – Hope or Hoax?"  hear Professor Edward's talk on YouTube 

Read the Press Release about the "Nuclear Renaissance"

Visit the new website

Read A Sample Chapter From
Radioactive Baby Teeth


The Canadian nuclear industry and government are proposing to bury all of Ontario's "low" and "intermediate" level radioactive wastes 1 kilometer (0.6 miles) from the Lake Huron shoreline at the Bruce Nuclear Complex, just 50 miles east across Lake Huron from Michigan. Ontario has a whopping 20 nuclear reactors (by comparison, Illinois is the U.S. state with the most reactors, with "just" 12 operating reactors; Michigan has "just" 4 still-operating reactors, and 1 permanently shutdown reactor). 
That's a lot of radioactive waste targeted for burial on Canada's Lake Huron shoreline! 

These so-called "low" and "intermediate" level radioactive wastes contain all of the same radioactive poisons as high-level radioactive waste, only in lesser concentrations. The long-lasting radioactive poisons in these wastes include cesium-137, strontium-90, plutonium-239, iodine-129, and nickel-59, to name but a few of the hundreds of radioactive poisons present in the waste. They have a hazardous persistence of about (or longer than) 300 years, 300 years, 240,000 years, 170 million years, and 800,000 years, to give you an idea how long they will remain dangerous to human and ecosystem health. Given the fact that Lake Huron is the drinking water supply for many millions of people downstream  including in Michigan  this plan is unacceptable, given the risk that a dump that close to the lake would leak over such long time periods.

Such a dump would also set a precedent for dumping radioactive wastes on the shorelines of the Great Lakes elsewhere. And at the Bruce Nuclear Complex in Canada, it could pave the way for all of Canada's high-level radioactive wastes to be dumped at Bruce as well. 

This dump needs to be stopped in its tracks, and the Michigan environmental movement is just the group of folks to do it!

Group Statement to Canadian Nuclear Safety Commission:

September 22, 2006

on behalf of Lone Tree Council, West Michigan Environmental Action Council, Michigan Coalition on the Environment and Jewish Life (MI-COEJL), Coalition for a Nuclear-Free Great Lakes, Don't Waste Michigan, Citizens Resistance at Fermi Two (CRAFT), Nuclear-Free Great Lakes Campaign, Green Party of Michigan, Van Buren County Greens, Citizens for Alternatives to Chemical Contamination, Environmental Coalition on Nuclear Power, Environment Michigan, Voices for Earth Justice, and additional concerned citizens (see full contact information listed at the end of this submission) 


Canadian Nuclear Safety Commission
Attn: Michael Rinker, Environmental Assessment Specialist
Environmental Assessment and Protection Division
P.O. Box 1046, Station B
Ottawa, ON  K1P 5S9
Phone: 1-800-668-5284   Fax: (613) 995-5086  
E-mail: [email protected]

Re: Comment on the Proposed Scoping Document (Environmental Assessment Guidelines) for Ontario Power Generation's Proposal for a Deep Geologic Repository for disposal of "low" and intermediate level radioactive wastes in Kincardine, Ontario, Canada

[Submitted via email to [email protected], as well as via Fax to (613) 995-5086]

Dear Mr. Rinker,

We are writing to express our concern about Ontario Power Generation's proposal for a deep underground radioactive waste dump at its Bruce nuclear site in Kincardine, Ontario, Canada only one kilometer (0.62 miles) from the shore of Lake Huron.

We are very disappointed that the staff of the Canadian Nuclear Safety Commission (CNSC) has failed to support an upgrade of the current environmental assessment from a Comprehensive Study to an independent Panel Review. There are three important reasons to do so. First, an independent review panel would ensure a fair hearing, keeping the process at arm's length from the CNSC, which is too close to the nuclear industry. Second, until now, radioactive waste has only been kept in temporary storage facilities, and this proposal would set an historic precedent for permanent deep underground disposal of radioactive waste in Canada and the Great Lakes Basin. Thirdly, because it is so long-lived and has the potential to affect human health and the environment for many generations to come, the public has always been very concerned about radioactive waste disposal, both in Canada, the United States, and in First Nations and Native American Nations throughout the Great Lakes Basin.

While I understand that CNSC staff has expanded the alternatives being considered, alternatives should include monitored, retrievable "interim" storage at the nuclear sites that generated the wastes in the first place, and "reduction at source" of radioactive waste through nuclear phase-out. 

In terms of the study area for the assessment, the proposed dump has potential environmental impacts not just locally and regionally, but internationally as well. Because the radioactive wastes will remain toxic for hundreds of thousands of years, the dump is a threat not only to this generation, but to thousands of human generations into the future, and not only to the locality and the region around the Bruce nuclear complex, but also to downstream communities on the Great Lakes in Canada and the United States of America, as well as to First Nations and Native American communities.  CNSC staff has rejected any possibility that the dump could have trans-boundary impacts. However, research and documents published by the International Joint Commission on Great Lakes Water Quality make it clear that Canadian nuclear facilities on the Great Lakes have had measurable trans-boundary effects, as have U.S. nuclear facilities. The study area should be expanded to include communities on the Lake Huron shoreline in both the U.S. and Canada, as well as extended to include communities downstream of Bruce that draw their drinking water from Lake Huron and points downstream.

The following important issues also need to be addressed: 

-- the lack of Canadian federal policy on the long-term management of low and intermediate level radioactive waste;

-- inclusion of decommissioning waste in planning for the Bruce facility; 

-- extension of the assessment time to one million years because of the long lifetime of some radioactive elements in low and intermediate level radioactive waste; 

-- detailed examination of the safety of radioactive waste transportation from the Pickering and Darlington sites to the Bruce site; 

-- alternatives to radioactive waste incineration; 

-- municipalities on transportation routes should be consulted on the initiation of further decades of radioactive waste transportation through their communities; and 

-- costing and economic analysis of the main proposal and all alternatives should be mandatory. 

We would also like to tentatively reserve speaking slots for the submission of oral presentations at the Monday, October 23, 2006 CNSC hearing in Kincardine, Ontario, Canada regarding this matter, for representatives of our organizations that may be able to attend this hearing despite the very long travel distances that would be required to attend. 

Whether as written or oral submissions, we will continue to communicate to the CNSC our deep concerns about, and objections to, the concentration of radioactive wastes from a score of nuclear reactors across Ontario, and the risk of catastrophic radioactive contamination to Lake Huron and points downstream, if these accumulated wastes begin to leak out from the proposed burial dump just 1 kilometer (0.6 miles) from the shoreline of Lake Huron. Our coalition of groups and individuals deeply troubled about this dangerous proposal continues to grow in Michigan, and we will share with CNSC and other Canadian, U.S., and First Nations decision-makers an updated list of organizations objecting to this radioactive waste dump in the heart of the Great Lakes by the time of the October 23rd CNSC hearing.

We would also like to express our endorsement of the comments submitted by Dave Martin, Energy Coordinator, Greenpeace Canada and S. (Ziggy) Kleinau, Coordinator, Citizens for Renewable Energy, to CNSC as a part of this proceeding.

We also request a copy of the revised scoping document, CMD 06-H22. Our postal and email addresses are given below, so that you can either mail a hard copy of this document, or email us an electronic version or Internet link. This document is not posted on the CNSC web site, which has unfortunately made our participation in this proceeding more difficult. We respectfully request that all documents pertaining to this proceeding be posted to CNSC's website, as well as provided directly to us either through the mail or email, to facilitate our participation in this proceeding.

Please also send us any information or application forms pertaining to intervener funding, for those of us who wish to intervene in this environmental assessment proceeding.

Please consider our concerns. Thank you.


This letter was signed by many environmental groups and concerned citizens.


Earthquakes, Cracks....

California is not alone in earthquakes.
After recent earthquakes and aftershocks in the Midwest...the biggest ever....nuclear waste officials reportedly checked the Palisades and DC Cook nuclear power plants for cracks and fissures.
Since then there have been plant shut downs.

The possibility of earthquakes and the shifting sands that the nuclear waste storage casks are on was one of the concerns of DWM members at the relicensing talks with the NRC.

As time goes on, DWM concerns are becoming a reality.

Prior to September 11, 2001, DWM members voiced and wrote concerns to the NRC about the threat of terrorism if a large airplane was run into a nuclear power plant or a bomb dropped on them.
Other concerns were about ground terrorism.
There are yet numerous concerns about the lack of adequate security to protect the public from terrorism.  DWM members believe these concerns have not been adequately addressed, nor have nuclear power plant safety issues.
email me
Public comment:

I am against the transfer of nuclear licenses. When the NRC issues a license to a particular corporation or entity it is with the understanding that the will of the NRC towards needed improvements etc. be done. When the licensee sells or transfers those licenses, the next entity should be required to either fulfill the obligations set forth or to supplicate the NRC again.
It would be best not to allow a transfer. That would stop some of the deceptions and help protect the public and the environment more. This is not the sort of thing to leave open loopholes on.
Kathryn Barnes

Uranium claims spring up along Grand Canyon rim

RESOURCE: Contamination of the Colorado River is just one concern about the claims. “If you can’t stop mining at the Grand Canyon, where can you stop it?” asks one opponent.
A rush to extract uranium on public lands pits environmentalists, who worry about the local effect, against mining companies, which point out that nuclear power wouldn't contribute to global warming.
By Judy Pasternak, Los Angeles Times Staff Writer 
May 4, 2008 
GRAND CANYON NATIONAL PARK, ARIZ. -- Thanks to renewed interest in nuclear power, the United States is on the verge of a uranium mining boom, and nowhere is the hurry to stake claims more pronounced than in the districts flanking the Grand Canyon's storied sandstone cliffs.

On public lands within five miles of Grand Canyon National Park, there are now more than 1,100 uranium claims, compared with just 10 in January 2003, according to data from the Department of the Interior.
Related Content
Seeking to mine uranium 
Western claims
In recent months, the uranium rush has spawned a clash as epic as the canyon's 18-mile chasm, with both sides claiming to be working for the good of the planet.

Environmental organizations have appealed to federal courts and Congress to halt any drilling on the grounds that mining so close to such a rare piece of the nation's patrimony could prove ruinous for the canyon's visitors and wildlife alike.

Mining companies say the raw material they seek is important to the environment, too: The uranium would feed nuclear reactors that could -- unlike coal and natural gas -- produce electricity without contributing to global warming.

And uranium is in short supply. In recent years, mines closed in Canada and West Africa, yet the United States as well as France and other European countries have announced intentions to expand nuclear power. Predictably, the price of uranium has soared -- to $65 a pound as of last week, from $9.70 a pound in 2002.

In the five Western states where uranium is mined in the U.S., 4,333 new claims were filed in 2004, according to the Interior Department; last year the number had swelled to 43,153.

The push to extract more uranium has caused controversy not just involving federal land but private and state land as well. In Virginia, a company's plan to operate in a never-mined deposit spurred a hearing in the Legislature. In New Mexico, a Navajo activist group is challenging in federal court a license issued just over the reservation's east border.

Uranium claims are also encroaching on stretches of Western parkland such as Arches National Park, Capitol Reef National Park and Canyonlands National Park, all in Utah, as well as a proposed wilderness area in Colorado called the Dolores River Canyon.

But by far the most claims staked near any national park are in the vicinity of the Grand Canyon, which draws 5 million people a year. The park is second in popularity only to the Great Smoky Mountains of North Carolina and Tennessee.

"If you can't stop mining at the Grand Canyon, where can you stop it?" asked Richard Wiles, executive director of the Environmental Working Group.

The energy-versus-environment debate is apparent within the Interior Department, which granted the mining claims through its Bureau of Land Management. Among the mining critics is Steve Martin, superintendent of the Grand Canyon park and an Interior Department employee himself. "There should be some places that you just do not mine," Martin said.

Uranium is "a special concern," he added, because it is both a toxic heavy metal and a source of radiation. He worries about uranium escaping into the local water, and about its effect on fish in the Colorado River at the bottom of the gorge, and on the bald eagles, California condors and bighorn sheep that depend on the canyon's seeps and springs. More than a third of the canyon's species would be affected if water quality suffered, he said.

Martin is not the only one uneasy about potential water contamination. Add to the list the Metropolitan Water District of Los Angeles, which sells wholesale water throughout Southern California from its Colorado River Aqueduct. "In addition to the public health impacts, exploration and mining of radioactive material near a drinking water source may impact the public's confidence in the safety and reliability of the water supply," the district's general manager, Jeffrey Kightlinger, wrote in March to Interior Secretary Dirk Kempthorne.

No one is mining near the Grand Canyon yet, but wooden claim stakes can be spotted throughout the brush-covered plains north and south of the park.

Vane Minerals, a British company, applied last year to start exploratory drilling on seven sites in the Kaibab National Forest, near the canyon's popular South Rim.

Under current mining law the Forest Service had no choice but to allow the drilling, Regional Forester Corbin Newman testified in March to Congress. The mission of a national forest is different from that of a national park, he pointed out. Indeed, signs at the Kaibab Forest's border proclaim that visitors are entering the "Land of Many Uses."

In response to the approval, the Grand Canyon Trust, the Center for Biological Diversity and the Sierra Club sued in federal court, alleging that the Forest Service didn't thoroughly investigate the environmental effect of drilling and prospective mining. In April, a judge issued a temporary restraining order until the case could be heard, probably in the summer.

Drilling had already begun near Deer Tank Wash just off a dirt road about five miles from the canyon park's east entrance. Now, the only signs of that activity are a 6-inch pipe sticking up half a foot from the ground near a large piñon tree, and hay scattered in the mud.

The wash is prone to flooding, said Taylor McKinnon, a public lands advocate for the Center for Biological Diversity. "Would the water from a flash flood go through the bore hole to the aquifer? We don't know because there wasn't an analysis," he said.

Meanwhile, five additional proposals for exploratory drilling have recently been submitted to the Kaibab National Forest, according to Newman. And three old uranium mines near the canyon park are on standby, ready to resume operations.

Many of the companies are based abroad, said McKinnon, so their directors don't understand the special place that the Grand Canyon holds in this country's lore: "What if an American company went to drill at Stonehenge?"

But the region is special in another way, said Kris Hefton, chief executive of Vane's American uranium operation. The uranium is found in "breccia pipes," contained geological formations that hold higher-grade deposits than elsewhere in the U.S., he said.

Breccia pipe mines can be compact, less than 20 acres in size, and uranium producers say they are among the easiest to restore after mining is done. And because the ore holds so much uranium, it's cheaper to mine. "They're not as susceptible if the price drops," Hefton said, adding that mining can be profitable in the region even if uranium fetches only $20 a pound.

"You won't have to depend on foreign uranium," he said. Though higher-grade deposits are found in Canada, and more mines are opening in the next five years, "you never know what the Canadians will do. It just makes sense to protect our industry from a national security standpoint."

Nevertheless, Rep. Raul M. Grijalva (D-Ariz.) has introduced a bill that would withdraw a million acres of federal land around the Grand Canyon park from future mining and mineral leases. The bill would not affect the claims already staked if they are found to contain uranium deposits.

And so uranium mining could end up being part of the view at Gunsight Point, a promontory north of the park at the end of a rutted dirt road on public land. There, two striking gorges merge into one, with a dry wash at the bottom of Snake Gulch coming in from the east and Kanab Creek flowing in from the west.

Overlooking the creek are 14 uranium claims, according to an analysis of Interior Department data by the Environmental Working Group. The claims are held by companies such as Energy Metals and Uranium One Ventures, and by an official with Quaterra Resources Inc., which boasts to investors that it is "one of the largest claim holders in the Arizona Strip District."

On a hazy morning, the canyon is still visible downstream. And Martin, charged with its protection, is apprehensive. His experience with uranium mines is confined to one that actually operated right at the canyon's edge, grandfathered in because it opened before Congress created the national park in 1919. The U.S. bought the site in 1962, and mining stopped in 1969.

Now the remains of the aerial tram that carried the ore can be seen at the South Rim. Special strips have been placed atop the structure to keep California condors from resting there, to protect them from lightning strikes. And a chain-link fence keeps hikers away from mine wastes.

Elevated radiation has been detected in Horn Creek below, and signs have been posted warning visitors not to drink the water. A National Park Service sign explains to the public that uranium deposits also lie just outside the park.

"What does the future hold?" the note asks, and concludes: "Mines and other industry near parks often bring unforeseen impacts on park resources."
Taylor McKinnon
Center for Biological Diversity

Past Meetings with the NRC:

Members of Don't Waste Michigan brought up the following issues:
*The reactor lid has not been replaced
*The reactor is operating with potentially flawed snubber valves
^Defective cask 4
*Shifting sands under the high-level radioactive waste pad
*Plant security issues
*Tritium Groundwater contamination
from a leak at Palisades
*Checking for cracks after the earthquake. Is a "walk through" enough? DWM felt that cracks could not be detected within the concrete without radiological testing.

The public was also concerned that Entergy did not stay to respond to the public's concerns and many felt that the NRC does not do enough to safeguard the public or make Entergy spend money to do the repairs Consumer's Energy had promised to do in order to relicense the aging plant. After the re-licensing, CE sold the plant to Entergy.

Entergy announced they plan to close the plant in 2018 due to business liability issues.

In 2021 rising waters of the Great Lakes pose a threat to nuclear power plant beach erosion is a serious issue. 
DWM and other environmental groups are attempting to include the state governments and the public to demand a safe immediate decommissioning of nuclear power plants because of the extreme changes from global warming.
Kevin Kamps

Chief, Rules and Directives Branch
Division of Administrative Services
Office of Administration
Mailstop T-6D 59
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555-0001

Submitted electronically via: [email protected]

August 22, 2005

Public Comments re: Environmental Impact Statement re: Proposed 20 Year
Extension of the Operating License for the Palisades Nuclear Power Plant [Docket
No. 50-255; License No. DPR-20; Palisades' owner is Consumers Energy/CMS;
Palisades'Comments on "Applicant's Environmental Report - Operating License Renewal Stage,
Palisades Nuclear Plant, Nuclear Management Company, March 2005" submitted by:

Michael J. Keegan, Chairperson, Coalition for a Nuclear Free Great Lakes
(CNFGL), Monroe, MI

Alice Hirt, Board Member, Don't Waste Michigan, Holland, MI

Dave Kraft, Director, Nuclear Energy Information Service, Evanston, IL

Keith Gunter, Co-Chair, Citizen's Resistance at Fermi Two (CRAFT), Livonia, MI

Kevin Kamps, Nuclear Waste Specialist, Nuclear Information and Resource Service,
Washington, D.C.

Henry W. Peters, director, Radiological Evaluation & Action Project, Great Lakes
(REAP, GL), Ewen MI

Our Public Comments:

Beyond Design Basis Aspects/Crisis of Embrittlement. 

The embrittlement of the Palisades reactor pressure vessel and the unresolved
Pressurized Thermal Shock  ("PTS") with ever increasing likelihood of the
failure of the  reactor pressure vessel ("RPV") warrant special environmental
considerations.  This type of  accident is "Beyond Maximum Credible Accident"
scenarios, a beyond design basis -- and yet all too possible -- accident for the
reactor.  Any EIS which is conducted must incorporate the outcome of such a
catastrophic accident.  A 1982 NRC report (Calculation of Reactor Accident
Consequences or CRAC- 2) predicted that a meltdown and large-scale radiation
release from the Palisades reactor would cause 1,000 fatalities and 7,000
injuries in just the first year, 10,000 cancer deaths over time, $52.6 billion
in property damage (based on 1980 census, expressed in 1980 dollars, thus
significantly underestimating current and future impacts due to population
growth and inflation).  The Palisades nuclear power station has been identified
as prone to early embrittlement of the reactor pressure vessel, which is a vital
safety component.  The longer Palisades  operates, the more embrittled its RPV
becomes, with decreasing safety  margins in the event of the initiation of
emergency operation procedures, such as activation of the emergency core cooling
system. Moreover, there are rumored problems with the safety culture at the
plant which might inhibit candor in staff communications about
embrittlement-related problems in operations and procedures. Therefore, given
the public health and safety effects of a prospective additional twenty years of
operation, and given the present and prospective embrittlement trend of the RPV,
it is imperative to protect the interests of the public by denying such a 20
year license extension.

Excessive radioactive and toxic chemical contamination in local drinking water
due to emissions from Palisades nuclear power plant as part of its daily,
"routine" operations. 

The radioactive and toxic chemical emissions from the Palisades nuclear power
plant into the waters of Lake Michigan contaminate the recently-installed
drinking water supply intake for the City of South Haven, built just offshore
from Van Buren State Park and just downstream from the Palisades reactor, due to
the direction of the flow of Lake Michigan's waters and the very close proximity
of the Palisades reactor to the South Haven drinking water supply intake. 
U.S. National Oceanographic and Atmospheric Administration models confirm the
direction of water flow in Lake Michigan toward the intake. 

The Palisades reactor has no place to store its overflowing  irradiated nuclear
fuel inventory within NRC regulations. 

Electricity is but the fleeting byproduct of the Palisades nuclear reactor. The
actual product is forever deadly radioactive  waste.  This cannot be excluded
from the EIS because if there is no license extension there will not be an
additional 20 years of high level nuclear waste generated by Palisades.  The
indoor irradiated fuel storage pool reached capacity in 1993, thus necessitating
the utilization of a shoddy technology of outdoor dry cask storage pads at
Palisades.  Both the older pad nearer Lake Michigan and the newer pad further
inland, are in violation of NRC earthquake regulations. 10 CFR §
72.212(b)(2)(i)(B) requires that: Cask storage pads and areas have been designed
to adequately support the static and dynamic loads of the stored casks,
considering potential amplification of earthquakes through soil-structure
interaction, and soil liquefaction  potential or other soil instability due to
vibratory ground  motion. . . . 

According to expert, Dr. Ross Landsman, former U.S. Nuclear Regulatory
Commission Region III dry cask storage inspector, the older pad violates the
liquefaction portion of this regulation, and the newer pad violates the
amplification portion of the regulation.   Neither the older nor newer dry cask
storage pads at the Palisades plant are in compliance with this cited
regulation.  Nuclear Waste and Dry Cask storage cannot be omitted from EIS
considerations because they are a inevitable, adverse outcome of continued
operation of Palisades for an additional 20 years on top of the original 40 year
Additionally, in 1993, Consumers Power (now Consumers Energy) assured a  federal
district judge that if it encountered problems with loaded dry casks at
Palisades, it would simply reverse the loading procedure and return the
high-level radioactive waste to the storage pools. But  the fourth cask loaded
at Palisades, in June 1994, was shortly thereafter admitted by Consumers Power
to be defective, having faulty welds. However, eleven years on, Consumers has
yet to unload the defective cask, because it cannot.  Don't Waste Michigan,
which actively opposed the loading of the dry casks in the first case in 1993,
holds that Consumers perpetrated a fraud upon the court and the public, with the
complicate support of the NRC, and that Consumers has critically undermined its
credibility as to any pledges about the safety of dry cask storage.  The
significance of this problem with cask #4 is considerable.  For example, the
configuration of the 18 to 19 dry casks currently  stored on the older pad
nearer Lake Michigan is such that the casks 
furthest back cannot be moved or unloaded until all other casks in  front of
them have been moved out of the way first. This configuration  increases the
risks, making it very difficult to address  emergencies involving certain casks
in the configuration in a timely manner.

Another issue that demands attention by NRC in its environmental impact
statement is the disconcerting proximity (just several hundred feet away,
according to maps appearing in the Environmental Report) of the Van Buren State
Park campground to the newer, more inland dry cask storage pad for high-level
radioactive wastes at Palisades. What are the radiation dose rates that families
camping at the State Park would suffer from those nearby dry casks? What are the
security and safety implications of having high-level radioactive waste stored
so close to a campground? 

In its Environmental Impact Statement, NRC should also consider another
environmental impact concerning high-level radioactive waste ignored by
NMC/Consumers in its Environmental Report: the proposed shipment by barge of 125
or more rail-cask sized containers of irradiated nuclear fuel from Palisades to
the Port of Muskegon as part of the Yucca Mountain, Nevada nuclear waste dump
proposal. The U.S. Department of Energy describes and documents this proposal on
page J-83 of its Final Environmental Impact Statement for Yucca Mountain, in
table J-27 ("Barge shipments and ports"). 125 barge shipments may very well be
an underestimate, for DOE assumes only 10 year license extensions, whereas
NMC/Consumers is requesting a 20 year extension from NRC. Specifically, what if
a barge shipment goes down in the Lake, whether due to accident or attack? What
about the potential for a nuclear chain reaction inside the cask involving the
still fissile U-235, Pu-239, and other fissile radio nuclides present in the
waste? What about radioactive contamination of 20% of the world's surface fresh
water, the drinking water supply for 35 million people downstream?

Property Rights    

Property rights of home owners on the shoreline and inland from Palisades have
been compromised by the "de facto" permanent high level waste site created. 
This amounts to implementation of eminent domain without any compensation to
property owners.  The constant threat of a nuclear accident or act of sabotage
has violated property owners' rights.
Additionally, any waste generated at Palisades after 2010 would be excess to the
capacity of the proposed national dump at Yucca Mountain, Nevada according to
U.S. Department of Energy projections in its Yucca Mountain Final Environmental
Impact Statement (Feb. 14, 2002), as  revealed in Tables A-7 and A-8 on pages
A-15 and A-16 of Appendix A.  In fact, the waste generated at Palisades from
1971 to 2010 may also be excess to Yucca, in that the proposed but highly
troubled and long delayed dump may never open. The State of Nevada maintains
that NRC's "Nuclear Waste Confidence Decision" is erroneous, in that it biases
NRC to favor approval of the Yucca  Mountain dump license lest it, NRC, be
proven wrong in its assurance to the  public that a high-level radioactive waste
geologic repository will open in the U.S. by 2025. Because so much uncertainty
surrounds the Yucca Mountain dump proposal, as well as other high-level
radioactive  waste dump proposals (such as the Private Fuel Storage, LLC dump
targeted at the Skull Valley Goshute Indian Reservation in Utah), it is our
collective contention that waste generated at Palisades during the 20 year
license extension could very well be stored at Palisades indefinitely, a
scenario inadequately addressed  by the applicant and NRC.  Because the casks
cannot be transported, because the casks cannot be unloaded, what has been
created is a "de facto" permanent high level waste site.  

Given that a severe radiation release from Palisades due to accident or attack
would significantly damage the economic base of  western Michigan, not only
within the 50 mile zone around the
reactor, but even beyond it, due to crops and products that would  have to be
destroyed, as well as the lingering stigma attached to western Michigan
agricultural products after such a release, a comprehensive Severe Accident
Mitigation Analysis must be performed, publicized and circulated for public
review and comment as a precondition to considering whether or not to grant a
license extension. The Severe Accident Mitigation Alternatives Analysis
presented in the Consumers/NMC "Environmental Report" is woefully inadequate,
ignoring as it does the full implications and significance of such risks as RPV
embrittlement, PTS, and the consequent potential of RPV rupture and catastrophic
radiation release.

Intensifying Sand Erosion and Avalanche Risk Compromise Integrity of Dry Storage
Pads and Casks

The more casks loaded on the storage pads at Palisades, the more risk of erosion
to the sand supporting the pads, given the large weight of the casks themselves
(VSC-24 casks weigh 132 tons each), weather related erosion of the sand dunes,
as well as the erosion that will occur due to more severe weather impacts from
the global climate crisis and climate de-stabilization.  Arresting erosion at
both pads is important to safety and radiation containment over the long haul, 
given the proximity of the waters of Lake Michigan. The State of  Michigan and
the U.S. Army Corps of Engineers have designated the  sand dunes upon which the
older pad is located -- so close to the waters of Lake Michigan -- as a
high-risk erosion zone.  The Lake Michigan dunes are subject to "blow-outs"
where entire  dunes are blown out during wind storms and lighting strikes.  See
Nori, P. Sholtz, and M. Bretz (Department of Physics, The University  of
Michigan), "Sound-Producing Sand Avalanches," Scientific American  Vol. 277, No.
3 (September 1997). At Warren Dunes, some 35 miles  south of Palisades, sand
blowouts have been estimated to travel as much as one-quarter mile per day,
exposing 5,000-year-old trees that  have long since turned to charcoal. "Some
chilling facts about Dunes  history," See:
The Palisades dunes could, in a wind storm or lightning strike, shift, blow and
cover the dry cask storage area. This would in turn block the ventilation vents
on the dry casks, causing the irradiated fuel within to overheat beyond
technical specifications. As weather patterns intensify (as anticipated, due to
global warming) this potential for erosion will increase.  Additionally, the
dunes and shoreline are geologically prone to sand avalanches.  A sand avalanche
coupled with a seismic event could  compromise the integrity of one or more
casks at Palisades. In fact, an earthquake at the older pad nearer the lake
could cause casks to fall into the waters of Lake Michigan. Not only could
radioactive contamination of Lake Michigan result, but, given the Uranium-235,
Plutonium-239, and other still-fissile radio nuclides present in the irradiated
nuclear fuel, the infiltrating water could cause a nuclear chain reaction in the
submerged cask itself, further endangering Palisades workers, emergency
responders, the public, and the Lake Michigan ecosystem, source of drinking
water - and so much more - to 35 million people downstream throughout the Great
Lakes Basin. NMC documents the potential for sand dune blow-outs at Palisades in
its Environmental Report, such as on Page B-6, where sand dune blow-outs are
described as comprising part of the overall Palisades nuclear power plant site.
NMC/Consumers also acknowledges sand dune blow-outs on Page 2-19 of its
Environmental Report: "Sand Dune Blow-out Communities (see Table 2.3-2,
Community 10) occur where wind action has resulted in dune destabilization." On
Table 2.3-2, the Environmental Report acknowledges that 4% of the Palisades site
comprises "Sand Dune Blow-Out Community." Of the remaining 13% of the Palisades
site comprised of Beach Grass Stabilized Dune Community, Beach Grass Stabilized
Flats, and Open Sand, one must wonder not if but when future sand dune blow-outs
will occur.

Non-Radiological Persistent Toxic Burdens to Area Water  Sources

The impact of 20 additional years of pollution by toxics disclosed but not
adequately controlled under requirements of the  National Pollutant Discharge
Elimination System (NPDES) will directly affect water quality of nearby sources,
including Lake Michigan. In 2000,  for example, Palisades was found to be in
"continuing noncompliance" for its apparent multiple misuses of Betz Clam-Trol
in Lake Michigan for the dispersion of mussels and clams affecting the reactor's
water intakes. See 
NPDES violations also contradict the spirit, intention and explicit
recommendation of the International Joint Commission (IJC). In its "Ninth
Biennial Report on Great Lakes Water Quality," the  Commission's Recommendation
#16 (at p. 42) urges that "[g]overnments monitor toxic chemicals used in large
quantities at nuclear power  plants, identify radioactive forms of the toxic
chemicals and analyze their impact on the Great Lakes ecosystem." Consumers
Energy and Nuclear Management Company admit, in Section "Biofouling
Control" on Page 3-7 of their Environmental Report that NMC uses biocides such
as chlorination, bromination, and amine formulations. The IJC also called for
virtual elimination of toxic discharges into the Great Lakes, and identified
radio nuclides as persistent toxins that also needed to be virtually eliminated
from the Great Lakes. The IJC commissioned two reports, the first on the
radionuclide inventory in the Great Lakes, and the second on the
bio-accumulation of radio nuclides in Great Lakes biota. The third report in the
series, on radioactivity's impact on human health, was never completed. This
study on radiation's impact on human health in the Great Lakes Basin should be
completed prior to granting Palisades an additional 20 years of operations,
especially in light of the National Academy of Science Biological Effect of
Ionizing Radiation Panel's recent report (BEIR VII), which found that no amount
of radiation is too small to not have an adverse impact on human health.
Baseline health studies are necessary before NRC grants Palisades a license
extension, especially considering that the National Cancer Institute's report on
cancer near nuclear reactors, published in 1990, is now 15 years old. It does
not account for cancers occurring over the past 15 years, and is in addition
methodologically flawed. Independent base line health studies must be performed
before NRC grants Palisades a 20 year license extension. 

Increased Degradation of Fuel Rods Excessively Utilized
To mitigate the prospect of increased embrittlement of the  reactor pressure
vessel (RPV), the Palisades operator uses previously-irradiated fuel to create a
buffer next to the RPV wall.  The second-use of irradiated fuel assemblies in
the reactor core tends to weaken and damage the cladding on the fuel rods,
making future waste handling, storage, transport, and ultimate disposal -
whether onsite at Palisades, in transport, or at future storage/dump sites -
problematic. It poses an elevated risk for the safety of Palisades workers and
the general public. Moreover, the U.S. Department of  Energy ("DOE") depends on
the integrity of the fuel cladding as a means of preventing or minimizing the
risk of unanticipated  fissioning in storage and transportation casks or other
units, as well as a means of delaying radiation releases from waste burial into
the groundwater at the proposed Yucca Mountain (Nevada) dumpsite. 

Environmental Justice / Nuclear Racism

Palisades nuclear generating station is the source of environmental justice
violations.  Located
within a predominantly African-American and low-income township, Palisades
provides woefully  inadequate tax revenues to the host community, considering
the large adverse impacts and risks the reactor inflicts. Palisades'
African-American employees have traditionally been stuck in the dirtiest and 
most dangerous jobs at the reactor, with little to no prospects for 
promotion. Some of Palisades' African American employees have also experienced
death threats at the work place, including nooses hung in their lockers or in
public places to symbolize lynching, an apparent attempt to silence their public
statements for workplace justice.  

Palisades' license extension application also has inadequately addressed the
adverse impacts that 20 additional years of operations and waste generation
would have on the traditional land uses, spiritual, cultural, and religious
practices, and treaty rights of various  federally-recognized tribes in the
vicinity of the plant and beyond,  as well as effects upon non-federally
recognized tribes governed by international law. Only three tribes were
contacted by the NRC by August 8th, 2005, and invited to participate in the
license extension  proceedings, which effectively excluded a number of tribes
within the  50-mile zone around the reactor, as well as additional tribes beyond
the 50 mile zone which have historic and traditional ties to the Palisades site
and sites along the electric transmission line connected to Palisades. Despite
the Michigan State Historic Preservation Office's concern pertaining to possible
unreported archaeological properties present on, or with the vicinity of, the
Palisades site (see Page C-2, Cultural Resources Correspondence of the
Environmental Report), NMC and Consumers persist in opposing a survey of the
project area as unnecessary. But, if unreported Native American archaeological
sites are present at or near the Palisades nuclear power plant (which is very
possible, given the very close proximity of a large creek in Van Buren State
Park just to the north of the power plant, as well as the very close proximity
of Brandywine Creek just to the south of the power plant in Palisades Park -
rivers and creeks being common sites for encampments and villages amongst the
indigenous peoples of Michigan since time immemorial), then 20 additional years
of nuclear operations, radioactive waste generation, and daily radiation
emissions would have a significant and severe adverse impact on Native American
cultural and religious values at those sites, values which strive to protect
sacred areas from such degradation. The fact that NRC contacted only the
Nottawaseppi Huron Potawatomi, the Little Traverse Bay Band of Odawa Indians,
and the Match-E-Be-Nash-She-Wish Band of Potawatomi, but did not contact the
Pokagon Potawatomi (just 30 miles or so from the Palisades site), the Little
River Band of Odawa Indians, the Grand River Band of Ottawa Indians, the Saginaw
Chippewa Tribe, and the Grand Traverse Band of Ottawa and Chippewa Indians,
means that this Environmental Scoping proceeding should be suspended until all
stakeholder Native American tribes and bands are contacted and alerted to the
opportunity to not only comment on the Environmental Scoping, but to intervene
against the Palisades 20 year license extension. Given the sovereignty of these
tribes and bands, and the treaty rights that exist between them and the United
States federal government, the NRC has a government-to-government responsibility
to consult with these tribes and bands on such significant federal actions as
granting the Palisades reactor an additional 20 years of operations. An
archaeological survey must be conducted before NRC grants a 20 year license
extension to assure that Native American archaeological sites are not negatively
impacted by future Palisades reactor operations. Such impacts as harm to lake
sturgeon - sacred to some Great Lakes tribes - must also be evaluated. It is
interesting and telling that NMC's Environmental Report assigns no "importance"
to lake sturgeon (in Table 2.3-1, Page 2-47), despite its State of Michigan
Threatened Status, and its sacred status in the cultures and traditions of
various Great Lakes Native American Tribes, not to mention its importance to the
natural history of Lake Michigan as an ancient indigenous species in the
ecosystem. This is an indication that NMC/Consumers is not acknowledging or
addressing environmental justice impacts of 20 more years of operations at
Palisades on Native Americans. 

Also, Palisades' license extension application inadequately addresses the
disproportionate adverse socioeconomic impacts of a catastrophic radiation
release, such as due to reactor core embrittlement leading to core rupture, to
the low-income Latin American agricultural workforce of the Palisades area. 
Synergistic effects of such chronic and catastrophic radiation releases 
combined with the toxic chemical exposures these low income Latin-American
agricultural workers already suffer on their jobs have not been evaluated. 
Finally, there is an unacceptable lack of Spanish language emergency evacuation
instructions and notifications to serve the  Spanish speaking Latino population
within 50 miles of the Palisades reactor, especially migrant agricultural

A potential flaw in the NMC/Consumers Environmental Report is its exclusion of
census block groups with greater than 50 percent of their area outside the 50-
and 20- mile radii from Palisades. Not including these groups in calculating
total population, minority or low-income estimates effectively excludes
significant minority and low-income populations in Grand Rapids and Battle
Creek, particularly African American and Latin American communities living in
these major urban centers.

In addition, it is odd that NMC/Consumers writes in the Environmental Report
(page 2-32) that "Berrien and Van Buren Counties host moderate numbers of
migrant workers," when 3,677 and 6,733 temporary farm laborers (many of them
Latino) were employed in Berrien and Van Buren Counties, respectively, according
to the U.S. Department of Agriculture in 2004. These numbers represent
populations as large as the county seats and even the biggest towns in these
counties. It is also not clear in the Environmental Report whether those numbers
include the families which very often accompany the migrant farm laborers, which
would boost the Latino population even higher.

It is ironic that NMC/Consumers acknowledges on Page 2-36 of the Environmental
Report that "Only one block group with a low-income population is located in Van
Buren County. This block group is located in the western portion of Covert
Township, which is a largely rural area." Why is it that the largely
African-American population of Covert Township is still low-income after 38
years of Palisades nuclear power plant's presence in the township? Wasn't the
presence of the reactor supposed to help its home town to thrive economically?
What are the environmental justice implications of such an ironic history? 

The fact that "The amount of future property tax payments for Palisades...are
dependent on future market value of the plant" seems ripe for manipulation and
abuse - such as artificially lowering the market value of the plant in order to
lower future property tax payments -- by the politically and economically
powerful Palisades nuclear power plant on its host township, county, and region,
yet another environmental justice violation.

Chronic Emergency Unpreparedness Within the EPZ (Emergency Planning Zone). 

Emergency responders in the 50 mile zone around the Palisades nuclear reactor
are inadequately trained and inadequately equipped to respond to a major
radioactivity release during an accident or attack at the plant.  Even with its
modern fire trucks, Covert, Michigan does not  have the staffing, equipment,
training nor preparedness for a major radiological emergency.  Covert's best,
good as it is, is still no match for a Chernobyl-scale fire. The remainder of
the emergency 
planning and even 50 mile zone is mostly occupied by rural, volunteer fire
departments, which  have even less equipment and training with which to work.
Radiation  monitors and radiation-protective gear are in short supply or unheard
of.  Isolation wards for radioactively contaminated victims (so they don't harm
the doctors and nurses and other patients) are very rare, nearly non-existent at
most hospitals within 50 miles.  A 1982 NRC report (Calculation of Reactor
Accident Consequences or CRAC- 2) predicted that a meltdown and large-scale
radiation release from the Palisades reactor would cause 1,000 fatalities and
7,000 injuries in just the first year, 10,000 cancer deaths over time, $52.6
billion in property damage (based on 1980 census, indexed to 1980 dollars, and
thus a significant underestimate of impacts given population growth and
inflation over the past 25 years).  Clearly the community is ill equipped for
this risk of catastrophic radiation release which grows more likely the longer
the Palisades reactor operates.

Threats of Terrorist Attack and Sabotage at Palisades Nuclear Power Plant. 

Located on the shoreline of Lake Michigan, the source of tourism, drinking
water, fish, recreation, and other economic value to tens of  millions of people
downstream, Palisades represents a target for potentially catastrophic terrorist
attack or sabotage intended to release large amounts of radioactivity into the
Great Lakes basin.  Palisades represents a radioactive bull's eye on the shore
of 20% of the planet's surface fresh water, the Great Lakes. The operating 
reactor (containing many billions of curies of radioactivity) and  high-level
waste storage pool (containing tens to hundreds of millions of curies) are
vulnerable to such attack, as are the outdoor dry storage casks, so highly
visible, stored in the open air, in plain sight. 

Economic Impact Statement

As part of any NRC Environmental Impact Statement, there is need for an Economic
Impact Statement. This must include loss of "Opportunity Costs" such as tourism,
fishing, recreation, housing, other real estate, drinking water, etc. from
ongoing "routine" radiation releases into the waters, air and soil of the Lake
Michigan ecosystem, as well as the potential lost "opportunity costs"associated
with a major radiation release due to an accident or attack at the Palisades

Baseline Public Health Study Regarding Rates of Cancer and other Diseases.
There is a current need for a baseline public health study to establish cancer
and other disease rates prior to consideration of the proposal for a 20 year
license extension. The NRC has relied on the National Cancer Institute (NCI)
Study of 1990 to address cancer rates near nuclear power plants. However, the
only data considered by the NCI was the county that reactor is located in, not
other downwind and downstream counties. Thus, that study is methodologically
flawed. It is also 15 years old, and thus does not include data on occurrences
of cancer over the past 15 years, rendering it outdated. In addition to studying
cancer, other diseases associated with radiation exposure must also be studied.

Aging of Component Parts
The aging of component parts must be taken into consideration and evaluated for
potential safety-significant failures over the course of a 20 year license
extension. Examples of such age-related failures at Palisades just in the recent
past include: failure of the Control Rod Drive Mechanism (see PNO-III-04-010
August 11, 2004); Relief Requests for Reactor Vessel Head Penetration problems
(NMS Request 10/4/04); Manual Reactor Trip / Main Condenser Vacuum (See Event #
41319); Emergency Declared on Primary Coolant System Integrity (See Event #
41681). Age-related failure of safety-significant systems could initiate the
sequence of events that leads to PTS that ruptures Palisades' dangerously
embrittled reactor vessel, causing catastrophic radiation releases into the
Great Lakes basin. Frighteningly, NMC repeats countless times in its
Environmental Report (as an excuse for not having to do any additional
environmental impact analysis on various issues) that "NMC does not plan to
undertake major refurbishment for Palisades license renewal." (As discussed in
Section 3.2, and elsewhere throughout the Environmental Report)
Potential of Renewable Energy, Energy Efficiency, and Energy Conservation to
Displace Palisades Nuclear Power Plant's Electricity Generation

In Section 7.0, "Alternatives to the Proposed Action," renewable energy sources
such as wind power and solar power, as well as alternatives to Palisades such as
energy efficiency and conservation, are given remarkably short shrift by
NMC/Consumers. In fact, polluting electricity sources such as fossil fuels are
given by NMC/Consumers as the only realistic alternatives to a 20 year license
extension at Palisades. This is self-serving, in that Consumers owns and
operates fossil fuel fired facilities. In fact, in 2002 nearly three-quarters of
Consumers electricity generation came from fossil fuel facilities. Such reports
as "Repowering the Midwest" by the Union of Concerned Scientists and
Environmental Law and Policy Center; a recent analysis by Amory Lovins at the
Rocky Mountain Institute published in the organization's summer 2005 newsletter
(see; cutting edge research and development conducted by the
Midwest Renewable Energy Association; deployment by Mackinaw Power of modern,
large capacity wind turbines on the northern tip of Michigan's lower peninsula,
and plans to deploy more wind turbines on the Lake Michigan shoreline of west
Michigan; long-established Lake Michigan shoreline wind power operation by the
Traverse City, Michigan municipal power company; advances in solar electricity
by Solar Ovonics in Troy, Michigan (which manufactures solar electricity
generating roofing shingles, which could be installed unobtrusively over huge
surface areas atop families' homes); advances in solar power technology
documented by Steve Strong at Solar Design Associates; and a recent report
commissioned by the U.S. Public Interest Research Group ("Redirecting America's
Energy: The Economic and Consumer Benefits of Clean Energy Policies," Feb. 2005)
all clearly show that renewables, efficiency and conservation not only are ready
to go, reliable, safe, clean and affordable options for electricity generation
and savings, but also the source for tremendous job growth and cost savings.
Whereas NMC/Consumers may have a business agenda to ignore and downplay the
potential for such promising alternatives to polluting sources of electricity
such as fossil fuels and nuclear power, the NRC should fully examine such
alternatives in its environmental impact statement.

Climate Change Impacts on Palisades reactor operations during license extension

A number of times in its Environmental Report, NMC/Consumers mentions, and
affirms the now globally accepted fact that the collective activity of the human
race is in the process of altering the climate of the planet (Climate Change).
But the Nuclear Energy Institute, of which NMC/Consumers are members, actively
suggests that nuclear power may be a strategy to lower the impact of electrical
energy generation on this process. But it is also widely understood that
mitigation can only change processes in the future, beyond the coming decade or
two (and that is optimistic).  The effects of past air emissions will govern the
changes in weather patterns now documented, and those in the 20 year license
extension period. The outlook globally is increasing severity in weather,
particularly storms, both in number and intensity and for the Great Lakes basin,
such impacts as increased frequency and severity of tornadoes, rain and
lightning storms, temperature extremes in summer and winter, etc.

NMC/Consumers fails to analyze the multiple impacts these accelerating changes
will have on reactor operations, as well as the ways that it will change the
type and magnitude of impact that the reactors have on their external

Analysis of Climate Change must include an analysis of increased potential for
Station Blackout by virtue of projected increased numbers and intensity of
tornados and other severe weather. Other factors of Climate Change impact are
discussed below with respect to inadequacy of NMC/Consumers Environmental

These factors may be seen as too complex to project and accurately analyze
twenty years in the future, however they are really no more complicated than the
complex interactions of NMC/Consumers' financial position, work force
capabilities and human factors, cumulative and synergistic events in aging
systems and multiple failure pathways that should be factored in the analysis of
whether component aging will be successfully managed to meet an ever moving
target called "current license basis."

Global warming could also alter the water levels and water temperatures in Lake
Michigan over the course of the 20 year license extension, impacting Palisades
nuclear reactor operations. Similarly, large-scale water diversion from Lake
Michigan or inland groundwater that feeds into the Great Lakes - proposed by
southwestern states, for example, to address their drinking water and other
needs in current drought conditions (perhaps also attributable to global
warming) and water bottling companies - could also impact water levels in Lake
Michigan over the next 20 years.

Endangered Species

NMC/Consumers Environmental Report identifies numerous federal and State of
Michigan endangered, threatened, candidate or species of special concern - such
as eastern box turtle, lake sturgeon, lake herring, creek chubsucker, Pitcher's
thistle, prairie warbler, prairie vole, eastern massasauga rattlesnake, spotted
turtle, Indiana bat, globe-fruited seedbox, scirpus-like rush, bald rush,
Carey's smartweed, and sedge that either already live at or near the Palisades
reactor, or very likely could in the future. 20 more years of reactor operations
threatens these already threatened, endangered, or candidate species, including
daily "routine" radiation releases and/or potential large-scale radiation
releases harmful impact on the threatened, endangered, or candidate genetics of
these species. In addition, the dunes upon which Palisades is built and operates
are recognized as Critical Dune Areas under Michigan's Natural Resources and
Environmental Protection Act, and are recognized by Covert Township as an
Environmentally Sensitive Area, and thus should be protected against 20 more
years of daily "routine" and potential large-scale accidental radioactive
contamination. Likewise, the Mesic southern forest on the south end of the
Palisades site is recognized as a prime example of this ecosystem type by the
Michigan National Features Inventory, and should be protected against ongoing
radioactive contamination for another two decades past 2011.

Findings of BEIR IIV Must Be Incorporated into EIS 

The BEIR VII report has recently been published.  The recent BEIR scientific
conclusion that there is no "safe" level of radiation - no matter how low the
exposure - requires reconsideration of the "legal" operation of Palisades at
all.  The Palisades acknowledges routine "lawful"   radiation releases.  The new
scientific conclusion compels reconsideration of the feasibility of continuing
to allow Palisades to operate at all, especially given the related issues of
drinking water pollution via radiation. 

Need For Independent / Verifiable Monitoring of Palisades

There is no independent verifiable monitoring of Palisades.  The community of
Covert and surrounding communities are dependent upon the operators of Palisades
to provide notification of radiological releases.  There is an implicit public
relations and financial incentive for the operators not to be forthcoming
regarding radiological events and accidents.  Therefore these communities must
be equipped with independent verifiable radiological monitoring to protect

Evacuation Issues - Reliance on Dated Census Data

Current Radiological Emergency Response Plan must be re-examined to incorporate
population trends and development projecting 20 years forward.  Highway systems
including construction projects must be carefully planned.  Transitory
populations of migrant workers must be considered.  Bi-lingual notifications and
dissemination of information must be made not only available but as a condition
of operation.

Civil Liberties and Plant Security Issues / Community Security      

In the post September 11, 2001 era of heighten concern about national security,
there exists a great potential for the violation of civil liberties of the
citizenry of the surrounding area.  What will be the ramifications and
implications to the peoples of these environs when there are enhanced security
measures taken regarding Palisades.  For example: walking along the beach; 
recreational use of the Lake and adjacent parks; driving down the highway;
public protest and rights of assembly.  Civil Liberties must be considered in
this EIS process. 

Sabotage and Internal Dissent at Palisades Due to Nuclear Management Company
Whistle Blower Mistreatment

There are current legal actions being taken by whistle blowers at Palisades. 
One such case has identified systematic abuse by Nuclear Management Company of a
Health Physicist worker who had reported what he believed to be various
violations of safety protocols to the U.S. Nuclear Regulatory Commission. 
Plaintiff discussed over the telephone certain concerns of his about safety and
his fear of retaliation for bringing up safety concerns and by cooperating with
the Nuclear Regulatory Commission with Andrea Kock and Ryan Alexander of the
United States Nuclear Regulatory Commission. This resulted in the generation of
United States Nuclear Regulatory Commission Allegation Number RIII-03-A-0051. 
This worker has been dismissed from employment.  This culture of intimidation
sets the stage for internal dissent.  When workers fear that they will be
dismissed for reporting safety concerns there is a serious problem with the
"Safety Culture" at Palisades with potential grave consequences.  These concerns
must be addressed in the EIS process. 

Need for Full Cost Accounting Principals regarding "No Action"of Re-license

Principles of Full Cost Accounting must be taken into consideration when
examining the No Action option (denial of re-licensing).  Negative impacts on
public health, civil liberties curtailed, impact on realty, contamination of the
water and air, etc., etc.

Invasive Species Impact of: Zebra Mussels; Quagga Mussels; Alewife & Other Fish

What has been the impact of Zebra Mussels and Quagga Mussels on the Palisades
plant.  How have these species been controlled at Palisades and how have the use
of toxics such as Betz Clam-Trol impacted the water quality on which the public
relies.   What would be the consequences at Palisades if these toxics were not
used.  What has the been the history and mitigation attempts regarding fish
kills at Palisades.  What game fish have been impacted by the operation of the
Palisades.  What has been the bio-accumulation and bio-concentration of
persistent toxics both radiological and non-radiological contamination in
recreational and commercial game fish.

Request for Sixty Day Extension on EIS Comment Period

There are a multitude of environmental concerns in addition to those raised
above that we will like to address but lacking adequate time to digest and
respond to voluminous NRC documents have been unable to do so.   By letter dated
August 19, 2005 to Andrew L. Bates, Acting Secretary, Office of the Secretary
U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001.  A request was
made for 60 day extension.  Again, we respectfully request that NRC grant an
additional 60 days to the concerned citizens of Michigan, Indiana, and Illinois,
and the organizations, which represent them, in which to file scoping comments
on NRC's Environmental Review of the Palisades nuclear power plant 20-year
license extension proposal.

Thank you for your review of this document

Public Meeting with the NRC re: Palisades at Lake Michigan College, South Haven. IGE and DWM members attended. NOTES from Corrine. 

Eunice Hendricks

Eunice was an educator and environmentalist who won legislation to create environmental areas in the public schools. A gentle, gracious person, Eunice was deeply mourned by other DWM members. She thought one of the most important things we need to do it to educate children about the natural world and provide living, natural environments where children can learn about the Creation as a living thing to care for beyond the realm of books.

LeRoy Wollins

LeRoy became involved with the DWM fight to stop the re-licensing of Palisades Nuclear Power plant. A member and founder of Veterans for Peace, LeRoy fought to end the cold war and to create a world of peace. 
He was active up to the day he passed away on his way to a meeting with the Nuclear Regulatory Agency to try to stop the relicensing of Palisades. LeRoy was an epic hero. All who knew him realized his greatness, his big heart, his courage.
He will be missed by all members of DWMi.

John Clark, PhD. Biochemist

John fought for standards for organic farming and was a Professor at Michigan State University and on an advisory panel to the Governor (Blanchard)…always against the use of pesticides and for environmental integrity. John was a true friend.

Corinne Carey, Film Producer, Peace Activist, Board Member: Don't Waste Michigan

Corinne was a lifetime member of DWM and a friend to all. She also volunteered her time at the IGE, a peace group. Corinne passed away during the global pandemic of the Covid virus in 2020. Corinne's public access TV program, her tenacity to ask pertinent questions, to not back down, her bravery and cheerful disposition made her a valued friend to all who were lucky enough to know her. 


Please enter this comment in the Federal Register re: Palisades re-licensing.
Thank You,
Kathryn Barnes

As a Michigan resident, I have seen the environment deteriorate around the Great Lakes in my lifetime. The water in Lake Michigan near the Palisades nuclear power plant is full of algae, even though it is cold. The plant has operated for almost 40 years, and wants a 20 year extension. 

I believe because of the embrittlement of Palisades, and because of the history of problems with the plant, including staff/management problems and repair backlogs, and after speaking with local residents and finding that there is a cancer pocket in the beach community, and that Palisades has repeatedly asked for safety exceptions to keep operating,  one can only conclude that this is a nuclear reactor that is past due, and should not be re-licensed.

The accumulation of nuclear waste along the shore of Lake Michigan is not only a potential terrorist target, as is the reactor itself, but there are also problems with the casks themselves, and the geological strata of the area, which includes the unstable sands which the cask pad sets on. Nuclear waste that is headed for dumpsites built on native lands is "environmental racism" and more operation and creation of wastes should be considered as such. 

The NRC analysis and data collection I believe is a flawed system. Too much is left to the reporting by the nuclear industry itself, and the use of generic models to project aging features is not realistic, as each nuclear reactor has a specific set of unique problems, and differentials including weather, changes in staffing, and a host of other issues not projected by generic analysis.

The public is not given enough notification about the meetings, and the meetings are few and poorly scheduled for times most can not attend.  The public is expected to offer comments on the EIS and scope and screening etc. without adequate preparation. 

Although the current license is valid through 2011, at this time, 2005, an extension is being sought and the time allotted for public comment, debate, and even awareness is under pressure and time constraints. What is the rush?  

I would like to request an extension beyond August 22 for public comment on the scope of the Palisades-specific supplement to the generic environmental impact statement for a much later date after the public is aware of such documentation and such is offered.

Further, I would ask as I have at public meetings, that the certain essential elements not be excluded from evaluation.

1.The public health records of the surrounding counties and downwind regions of Palisades. Also, the correlation between the cancer and infant mortality rate as it parallels the plant in operational mode v. shut down status. 

2.The track record of Palisades.  The lack of reporting problems, and the problems that have been found.

3. The history of the standards by which Palisades has been overseen by the NRC, including a list of the times when the NRC made concessions to the facility in lieu of prior standards and regulations.

4. The actual  and complete analysis of the plant by a scientific and independent agency, and not by Palisades or its subsidiaries, and an analysis not dependent on documentation by Palisades, but based on the actual scientific evaluation of the current status of the facility, including, but not limited to embrittlement.

5.Since the water of the Great Lakes is being bottled and sold as drinking water, it is an invaluable resource to the citizens of the region and the world. It is not enough to repair problems as they occur, but it is imperative  to put an end to the premise that such repairs will always be possible, and in acknowledging that with a cracked and aging nuclear facility i.e. Palisades, it is not worth the risk to keep it running. The plant can be replaced by wind turbines which will not be a public liability and which will not endanger the environment and which will produce a profit and not need taxpayer subsidies to maintain.

Email comments to the NRC at  [email protected] 
Tell them they made a mistake in rubberstamping the re-licensing of Palisades nuclear power plant! Then Tell Congress to investigate the way the NRC is doing business.

Here are some comments sent in:
DWM Karch comment 
Coalition Comment Prepared by Kevin Kamps (Thank You, Kevin, this is full of facts and detail)
DWM Barnes comment
Don't Waste Michigan members attended the 2008 meeting held by the Nuclear Regulatory Agency
(Three of the NRC officials are in the photo here) at Lake Michigan College in South Haven. 

This meeting was also attended for a brief time by members of ENTERGY, which operated Palisades until they formed a new company within themselves, with a new name. i.e.Enexus Energy Corporation, the nation's first stand-alone, publicly traded nuclear-energy generating and marketing company. Enexus was created by the spin-off of six reactors at five of Entergy Corporation’s nuclear plant sites into a new company and is based in Jackson, Mississippi. It owns approximately 5,000 megawatts nuclear power generation.

DWM members brought up issues about safety and security at Palisades. The NRC did a follow up on nuclear power plant security issues, and the security team at DC Cook was laid off because they were not watching the security cameras. Later issues at Palisades included an incident when workers were locked down and unable to exit a reactor area where they were working as all the exit doors were closed and the telephone did not work. They were locked in for five hours until the next shift came on.
In previous incidences, there have been safety valves that did not function at Palisades because they were glued down, trespassing on the reactor site area, missing nuclear waste, etc. 
Internal sabotage?

DWM members brought up issues about the reactor vessel head which needed replacing and has not been replaced, and of cracking snuffer valves, a defective nuclear waste storage cask, shifting sands/instability of the site etc.

It is unclear what the NRC will do to remedy these problems. The representatives of Enexus, AKA Entergy, did not stay long enough to answer any of the issues.

The NRC will hold another yearly public meeting-Palisades review in 2009. TBA...if it is like that past, DWM members will have little time as notification is often a day or two ahead of a meeting. With little advance notice, it is difficult to get the public involved. DWM has mentioned this problem/issue before, and the NRC has defended itself. If a major accident occurs at Palisades, there will be little justification or defense for Palisades existence and operation or the way the NRC has handled issues.

Don't Waste Michigan is working to:
1. Shut down aging, dangerous nuclear power plants: Palisades, Davis Besse, Fermi. etc.
2. Stop the construction of new nuclear power plants: Fermi 3 etc.
3. Educate the public about the dangers of nuclear power and nuclear waste, its deadly by-product.
4. Stop the burial of nuclear waste in dumps.

2008 meeting with the NRC re: Palisades
Take Action! Stop Fermi 3:
Fire in the Hole! DC Cook fire rages for nearly a half hour before fire fighters were able to quench the blaze..the nuclear plant released gas into the atmosphere and the fuel rods were kept in the H2O pool while the fire blazed in the generator site.....Palisades leaks tritium into groundwater......DC Cook security fired for not watching security cameras.....Palisades workers go to repair broken valves and fuel leaks...workers are locked in with no telephone access or way out for five hours until the next shift came on......the NRC is investigating........Canada pumps up for its great nuclear waste dump on the edge and under Lake Huron...FERMI SHAKES DOWN

In 2021 there are many environmentalists attempting to stop Japan from dumping radioactive waste into the ocean. Fukushima has continued to be a problem for Japan and the world.

9462 kb download size, pdf. file 
DWM  Don't Waste Michigan  v Fermi 3

Dedicated to Environmental Quality and Integrity and Service to the Great  Lakes Region, a Biodiverse Home of Fresh Water Resources

Palisades atomic reactor tied for worst in the U.S. on yet another nuclear safety test    
Organs of nuclear workers secretly harvested for 40 years, report finds
FYI   Resource and Information links page   
The next Chernobyl? 
Canada's Plans to Create a radioactive waste dump on Lake Huron: First Nations Say "NO WAY!"
No need to build new U.S. coal or nuclear plants -- FERC chairman

History of DWM: Don't Waste Michigan (DWM) is a group of concerned citizens and organizations initially formed to prevent Michigan from becoming a nuclear waste dump for the entire region. Citizens throughout the state organized to stop the federal government in conjunction with the nuclear power industry from targeting Michigan to become a nuclear waste dump. DWM organized town meetings and rallies at the state Capitol and convinced legislators that a nuclear dump in Michigan was not acceptable. The campaign was successful, not only in stopping Michigan from becoming a nuclear waste dump, but in also educating the public. DWM continues to be active and to educate the public about nuclear waste, Mixed Oxide Fuel, Palisades Re-licensing and other nuclear issues. DWM frequently joins in coalition with environmental groups and conducts a series of conference under the banner Nuclear Free Great Lakes Action Camps from 1999, 2000, 2001, 2002. DWM has intervened in Federal Court with regards to weapons grade plutonium in the form of Mixed Oxide Fuel (MOX). DWM has intervened in Re-licensing hearings at Palisades and Big Rock. DWM continues to monitor nuclear power related issues in Michigan. Don't Waste Michigan is comprised of an active membership of 40 researchers and educators. Membership frequently swells during campaigns. Membership was in the thousands during the height of the nuclear waste dump struggle.

photojournalism site : NTS journey 
in Chicago: educational conference
Palisades: issues 

What you can do:. Write to your representatives and stress the importance of shutting down aging and unsafe nuclear reactors, securing reactor sites from the threats of terrorism and accidents, tracking down loose nukes here in the US, and of supporting the implementation of safe, renewable energy technologies, i.e. wind, water, solar, and geothermal power...
Live in Harmony with the earth...plant a garden, listen to the sounds of nature, learn about nature and interconnectedness....  Free email, webspace etc...environmentally friendly and secure. FYI lots of info, great interactive and educational stuff

DWM members attended the Peace Conference in Grand Rapids, March 2005. Over 20 groups were represented, including the Women in Black, IGE, KNOW, Green Party, Greater Grand Rapids Food Systems, Peace Presence, Friends Committee, Holland Peacemakers, Tibet Michigan, and others. DWM members Corrine Carey and Kathryn Barnes spoke and gave a slide presentation about peace actions at the Nevada test site and other areas. The conference was a great success.

DWM members attended the Binational Forum in Monroe, Michigan in 2007. Guest speakers included: Kevin Kamps of Beyond Nuclear, Professor Edwards Ph.D., President, Canadian Coalition for Nuclear Responsibility, Ziggy Kleinhaus of Citizens for Renewable Energy, David Gard, Energy Program Director, Michigan Environmental Council, Lansing, Alexis Raney, Director of Save the Wild U.P, Doris Allen, President of Voices for Earth Justice and Great Lakes songwriter and troubadour, Victor McManemy. The forum was a great success. It was educational and inspiring and free with refreshments and music, thanks to sponsors Harold Stokes and CACC and others.

More recently, Don't Waste Michigan has worked with the Sierra Club and other groups to stop Fermi 3 and to protect the Great Lakes from nuclear waste transport and dumping.

Don't Waste Michigan members protest nuclear dangers
THIS IS IMPORTANT  Help is needed to stop Fermi 3!!!

The agency has extended the public comment period so that it will accept comments sent to it through Jan. 11, 2011
Please send your comments

1. Online Written comments may be submitted through the federal rulemaking Web site at using Docket ID NRC-2008-0566 

or by 

2. e-mail at [email protected] 

or by 

3. regular mail addressed to 

Chief, Rulemaking, 
Directives and Editing Branch, 
Division of Administrative Services, 
Office of Administration, 
Mailstop TWB-05-B01M, 
Nuclear Regulatory Commission, 
Washington, D.C., 20555-0001.

January 2012: Press Releases regarding the proposed new nuclear reactor, Fermi 3:

Legal Challenges Mount For Proposed Fermi 3 Reactor


Monroe, MI...   Last night filing deadline to comment on the proposed Fermi 3 Reactor did not pass without a flurry of complex legal challenges being launched.  Several dozen Interventions were filed as both comments on the Draft Environmental Impact Statement (DEIS) and more formalized legal contentions were filed with the Atomic Safety and Licensing Board (ASLB).  The DEIS comments fall under the jurisdiction of the National Environmental Policy Act (NEPA) and the more legal contentions filed with the ASLB fall under the jurisdiction of the Atomic Energy Act.* 


The legal contentions ran the gamut including challenges on the actual need for a Fermi 3 reactor and the economics; wetlands decimation; water intakes at risk; health impacts; First Nation treaty rights; fisheries in jeopardy; thermal pollution of Lake Erie; dangerous fuel enrichment.  The comments addressed areas that were clearly overlooked and omitted from the Environmental Review process, and areas which were poorly evaluated.  Once again these comments were robust and comprehensive.  Please find attached just a small sample of the comments made.  The legal contentions before the ASLB are attached as 'Intrvnrs Comment letter Complete'.   The legal Intervenors will be posting several dozen comments to the Beyond Nuclear webpage in the next few days. 

For more detailed information, there are six downloadable documents to the left in pdf and ms word format.


March 2021 view as an image or pdf.
Palisades was sold from Consumers Power to Consumers Energy to Entergy to Holtec. Holtec has delayed decommissioning and is trying to secure funds set aside for it to reopen Palisades. The truth is it was shut down for a reason, and the contamination on the site needs to be cleaned up. 

Best website on nuclear issues:









Michigan AG moves to intervene in Palisades nuclear plant transfer
ZOMBIE PROTEST October 25, 2022 against the re-opening of Palisades. This aging, dangerous nuclear reactor needs to be decommissioned not reopened!!
Holtec is awarded 1.5 billion in a loan from the government to restart Palisades but must meet safety requirements.
Our objections are many.....
Objections to reopening Palisades

The aging nuclear power plant came within five minutes to a meltdown and has put the public in dire risk throughout its history.

The aging nuclear plant is embrittled. It could crack if it started to heat up and had to be cooled like a glass pot of boiling water put in a cold water bath.

There are many known and unknown faults with the plant that need repair. 

There are tritium leaks under that plant that need to be cleaned up but the only way to clean up the mess is to take the old nuclear reactor down.
When tritium combines with water it makes the water radioactive forever. This endangers Lake Michigan and the Great Lakes watershed.

Holtec has never run a nuclear power plant. A plant that was shut down to be decommissioned has never been restarted. Holtec does not have the ability
or experience to do this safely. The money could be used for safe alternative energy instead of creating more pollution and danger. Nuclear power has had 
far too many disasters to ever be considered safe or non toxic. It is deadly.

Holtec plans on building 2 SMRs on the site next to the old nuclear reactor, making more nuclear waste and endangering the lake and residents for many more years.

Kevin Kamps, a radioactive-waste specialist with Beyond Nuclear, also argued the 53-year-old plant is too old and unsafe to withstand more years in operation. His group has long expressed concerns about nuclear meltdown risks at the plant.

Kamps said the unprecedented attempt to restart a shuttered plant raises more fears about how Holtec will address a lack of maintenance and inspections while the plant was closed.

“It’s radioactive Russian roulette on the Lake Michigan shoreline,” said Kamps. “The safety risks are hard to overstate.”