Consumers Energy’s briefing to State of Michigan regulators regarding its intention to sell the Palisades reactor as quickly as possible, revealing important problems afflicting the plant.

Notes/Remarks/Thoughts by Kevin Kamps, NIRS nuclear waste specialist, on Consumers briefing above, prepared June 20, 2006:

On page 1, note the sale would also include the high-level radioactive waste at Consumers’ permanently shutdown Big Rock Point reactor in Charlevoix, MI. Why would another company want to “buy” and become liable for the high-level radioactive wastes that Consumers’ generated? A big question mark hangs over the growing quantity of overflowing high-level wastes at Palisades – who would be liable for it into the future?

On page 2, Consumers admits to problems with Palisades, including the need to replace the reactor vessel head (not mentioned is the fact that penetrations elsewhere on the vessel are also vulnerable to corrosion); the need to replace the steam generator (again – they’ve already done this once before at Palisades!); “embrittlement concerns,” the main safety issued raised by the coalition opposed to the license extension; “fire protection requirements,” an issue NIRS Reactor Watchdog Project Director Paul Gunter has followed closely for decades; “Containment coatings and sump strainers,” an issue Dave Lochbaum at Union of Concerned Scientists has highlighted for years. With all these problems afflicting the plant, how can NRC grant Palisades a 20 year license extension?!

On page 3 and 4, Consumers speaks very disparagingly about the future of Nuclear Management Company (NMC), current operator of Palisades, as one major reason it wants to sell Palisades. How can NMC be allowed to operate Palisades, as well as the Point Beach reactors in Wisconsin, and the Monticello and Prairie Island nuclear plants in Minnesota, when it’s future is so uncertain? How safely can a company whose future existence is in doubt operate nuclear reactors?

On page 5, Consumers all but admits it lacks the expertise to operate Palisades well.

On pages 6 and 7, Consumers mentions “nuclear risks.” Do they include risks for public health and safety and the environment, or merely financial risks to the company owning Palisades?

On page 8, Consumers mentions that “Various options are available to use excess funds [from the sale] to benefit customers.” We would have to hold their feet to the fire on that one!

Also on page 8, Consumers mentions “Decommissioning risk avoidance…Funds which would otherwise be “trapped” in the decommissioning trusts can be returned to customers.” Is that accomplished by doing little to know radioactivity contamination clean up, thus pocketing the money while leaving the contamination on the site to poison the soil and Lake Michigan over time? How can we be sure the companies wouldn’t just pocket the “excess” funds left over after decommissioning is declared finished (regardless of how much radioactive contamination remains on site)?

On page 9, Consumers lists all of the “nuclear ownership and operating risks” it would shed by selling Palisades: operating risk; financial risk; nuclear risk; industry risk; NRC risk; potentially significant future capital expenditures; employee attraction and retention; exposure to NMC uncertainties.” We’d agree that operating Palisades till 2031 would be risky, indeed! Especially, risky to the health, safety and environment of the public!

On page 10, Consumers speaks of “closing [the sale] expeditiously.” Why is Consumers in such a rush to sell the reactor? Why is NRC in such a rush to approve the 20 year license extension? Potential buyers should beware – they should “look under the hood” before buying this lemon! And potential buyers should also realize that, along with the reactor and waste already piled up there, they would also inherit one fired up coalition of concerned citizens and environmental groups that want Palisades shut down at the end of its current license – 2011 and no later!

On page 11, Consumers predicts it will select a buyer to sell to by July 2006. They predict the sale will be finalized, with all regulatory approvals obtained, by early 2007. And they expect NRC to rubberstamp the 20 year license extension by early 2007 as well. Curious, isn’t it, that another company would buy Palisades even before the 20 year license extension is granted? Seems like all the nuclear utilities are VERY confident in receiving those extensions from NRC…

On page 12, Consumers states that the environmental assessments and site surveys it is conducting are geared toward the sale. Nevermind the license extension safety and environmental impact proceedings, which NRC and Consumers seem to regard as perfunctory processes ending in an expedited rubberstamped approval. One site survey that Consumers has never performed – and NRC is not requiring of them before it grants the license extension – is for Native American archaeological and cultural resource sites, such as ancient village sites, burial sites, etc. NRC even admitted in its draft Env. Impact Statement that 15 Native American sites have been identified within 1 mile of Palisades, including one site 0.3 miles south, and another right on its eastern property line. NRC also admitted that the presence of additional sites on Palisades property is highly likely. A Consumers-hired cultural resource assessment team concluded that operations at the plant could damage or destroy such sites, if a careful, comprehensive site survey is not conducted. Such a survey should be required by NRC before granting the license extension, and should be conducted in close and meaningful consultation with affected tribes. NRC is requiring none of that, granting Consumers carte blanche to proceed without doing any site survey.

On page 14, Consumers predicts that bids from potential buyers will be due by the end of June, 2006. Consumers then hopes to conclude the sale “as quickly as practicable.” Again, why the rush? Consumers also hopes to rush the regulatory approvals “ASAP.” Is safety and security getting short shrift in this rush?

On page 15, Consumers states that “existing decommissioning funds are in excess of requirements and may be retained after sale for ratepayer benefit.” Again, there could only be an excess of decommissioning funds because NRC decommission regulations allow for radioactive contamination to remain on the site. And the public must remain vigilant to make sure the companies don’t simply pocket the money, rather than return it. Consumers also collected well over $100 million for long-term high-level radioactive waste management at Palisades, before the Nuclear Waste Policy Act became federal law in 1983. Again, that ratepayer money must go towards its intended purpose, not into the pockets of the nuclear utilities.