Nuclear Engineer with 54 Years of Experience Evokes Space Shuttle Challenger Disaster to Warn NRC Holtec Palisades Atomic Reactor's Degraded Steam Generators are Unsafe: Second Nuclear Engineer with 40+ Years Experience Warns Operability Assessment only 50% Confident Tube Failure Won't Occur in First 18-Months
Michael J Keegan
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NEWS FROM BEYOND NUCLEAR Michael Keegan, chair, Don’t Waste Michigan, Monroe, MI, mkee...@comcast.net, (734) 770-1441 Terry Lodge, attorney, Toledo, OH, tjlo...@yahoo.com Wallace Taylor, attorney, Cedar Rapids, IA, wtayl...@aol.com (Interviews with nuclear engineer Arnie Gundersen can be arranged through Kevin Kamps. Interviews with nuclear engineer Alan Blind can be arranged though Michael Keegan.) |
| Nuclear Engineer with 54 Years of Experience Evokes Space Shuttle Challenger Disaster to Warn NRC Holtec Palisades Atomic Reactor's Degraded Steam Generators are Unsafe |
| Second Nuclear Engineer with 40+ Years Experience Warns Operability Assessment only 50% Confident Tube Failure Won't Occur in First 18-Months |
| COVERT TOWNSHIP, VAN BUREN COUNTY, MICHIGAN, and WASHINGTON, D.C., NOVEMBER 13, 2025*--Two nuclear engineers with nearly a century of combined relevant experience have warned U.S. Nuclear Regulatory Commission (NRC) staff, and the agency’s Advisory Committee on Reactor Safeguards (ACRS), that one or more degraded steam generator tubes at the Palisades atomic reactor on southwest Michigan’s Lake Michigan shoreline are at high-risk of failure within a short period of time after the previously closed nuclear power plant undergoes an impending, unprecedented restart. However, the documents containing the warnings have not been publicly released by NRC staff or the ACRS. Given the significance of the warnings, an environmental coalition has today released the documents to the news media, in the public interest. Arnold Gundersen, with 54 years of relevant nuclear engineering experience, serves as expert witness for the coalition (Beyond Nuclear, Don’t Waste Michigan, Michigan Safe Energy Future, Nuclear Energy Information Service of Chicago, and Three Mile Island Alert of Pennsylvania). He previously served as expert witness for Friends of the Earth at the San Onofre nuclear power plant in southern California, contributing to the permanent shutdown of two reactors there in 2013, due to steam generator tube degradation. (See: <https://www.fairewinds.org/san-onofre>. And see Gundersen's Curriculum Vitae at Exhibit B, pages 94 to 117 on the PDF counter, here.) Gundersen has provided previous statements and documentation to the ACRS in August and September, 2025. This included an open letter evoking the Space Shuttle Challenger disaster: in January 1986, two NASA contract engineers warned about the catastrophic potential of a cold weather launch due to defective O-rings, but were ignored by their superiors, who were fixated on sticking to the launch schedule. This should serve as a cautionary tale regarding Palisades’ steam generators presently, as Holtec rushes to restart the reactor, apparently in order to accommodate its announced Initial Public Offering early next year, where it hopes to raise $10 billion in private investment. Gundersen had also planned to engage with ACRS again, at public meetings scheduled for October 10, as well as November 5-7. However, the former was cancelled, and the latter’s agenda postponed discussion of Palisades, likely not until after the closed reactor has been restarted, and the degraded steam generators put back into operation. The cancellation and postponement were reportedly due to the federal government shutdown that began October 1st, according to NRC staff. Gundersen’s four-page "Additional Written Information" is posted here, and his "Two-Minute Verbal Summary," is posted here. These documents have been in the possession of ACRS and NRC staff for more than a month already. Gundersen had long warned that Holtec, which has never operated a reactor, could cause severe degradation of the steam generator tubes if they were not put into a proper, chemically-preservative wet layup. On January 14, 2025, an NRC staffperson acknowledged Holtec had not done so from 2022 to 2024, causing widespread damage to the exceedingly thin-walled (just 0.042 inch-thick) steam generator tubes. Gundersen has also testified that while a single tube rupture would cause a release of some quantity of hazardous ionizing radioactivity into the environment, a cascading failure of enough tubes all at once could lead to a full-blown reactor core meltdown, with potentially catastrophic consequences for the entire region. Alan Blind is another nuclear engineer, with more than 40 years of nuclear engineering experience, who has been long critical of the Palisades' restart. He represents a number of residents of the Palisades Park Country Club, to the immediate south of the atomic reactor. Blind also submitted previously unpublished testimony to the ACRS, entitled "Comment on Holtec’s Use of 95/50 Probability Criteria in the Palisades Steam Generator Operational Assessment." Blind served as Engineering Director at Palisades itself under the previous owner, Entergy, from May 2006 to February 2013. Blind also served at Indian Point nuclear power plant near New York City, where he was working when a steam generator tube actually did burst on February 15, 2000. Blind's previously unpublished comments to ACRS and NRC staff begin: “Holtec’s 2025 Steam Generator Operational Assessment (OA) for the Palisades Nuclear Plant concludes that tube structural and leakage integrity will be maintained for a 1.5 Effective Full Power Year (EFPY) operating interval—i.e., one nominal 18-month cycle. However, this conclusion is based on a 95 percent probability at 50 percent confidence (95/50) statistical criterion. This represents a material departure from the higher-confidence 95 percent probability at 95 percent confidence (95/95) standard more often used by the nuclear industry and the NRC when determining the acceptable interval between inspections—particularly when the projected period to the next inspection is 1.5 EFPY or less. Such shorter intervals inherently carry greater uncertainty because crack-growth variability, probe sizing errors, and environmental effects have proportionally larger impacts when little or no operating margin remains before the next inspection.” (Emphasis added.) In short, Blind has pointed out that Holtec itself can only be 50% confident that the Palisades steam generators will operate for just 18 months without a tube failure. Blind's comments to the ACRS go on to list numerous additional criticisms of the steam generator tube safety reviews. "As with the cautionary tale of the deadly Space Shuttle Challenger catastrophe of 1986, the same year as Chornobyl exploded and burned, NRC would be wise to heed the warnings of Gundersen and Blind, two nuclear engineers with nearly a century of combined relevant experience on critical safety concerns such as steam generator tube integrity," said Terry Lodge, co-counsel for the environmental coalition. (*November 13, 2025 marks the 51st annual commemoration of the death of nuclear whistleblower Karen Silkwood. For more information, please see this tribute posted on the 50th annual commemoration on November 13, 2024.)
ADDITIONAL BACKGROUND INFORMATION On June 16, 2025, an environmental coalition (Beyond Nuclear, Don't Waste Michigan, Michigan Safe Energy Future, Nuclear Energy Information Service of Chicago, and Three Mile Island Alert of Pennsylvania) opposed to Palisades' unprecedented restart from closed, decommissioning status had challenged the unsafe inadequacy of Holtec’s degraded steam generator tube repair plan License Amendment Request (LAR) with a petition to intervene and request for hearings to NRC's Atomic Safety and Licensing Board (ASLB) panel. The petition and request included a 41-page Declaration prepared by coalition expert witness, nuclear engineer Arnie Gundersen. On July 18, 2025 the coalition's co-counsel, Terry Lodge of Toledo, Ohio and Wally Taylor of Cedar Rapids, Iowa defended the intervention against challenges filed by the NRC staff. But on August 5, the ASLB's three administrative law judge-panel dismissed the coalition’s intervention and immediately terminated the licensing proceeding. The environmental coalition on September 3 then appealed the ASLB's adverse ruling to the NRC Commissioners. The NRC Commissioners have yet to rule on that particular appeal, and many additional coalition appeals, regarding adverse rulings by ASLB panels in Palisades restart-related licensing proceedings dating back years. In late July, the coalition also submitted a 10 Code of Federal Regulations Part 2.206 emergency enforcement petition to NRC, objecting to the fact that Holtec had already implemented the sleeving repairs on the degraded steam generator tubes even before the agency had officially granted the go-ahead to do so, even while the related ASLB proceedings were still underway. (See: <https://beyondnuclear.org/environmentalists-protest-nrc-cover-up/> and <https://beyondnuclear.org/palisades-steam-generators-enviros-object-to-nrc-holtec-conspiracy/>.) The coalition has also engaged in NRC Advisory Committee on Reactor Safeguards (ACRS) subcommittee and full committee meetings regarding Palisades' degraded steam generator tubes beginning in August, 2025. The environmental coalition's expert witness on this critical subject matter is Arnie Gundersen, a nuclear engineer with 54-years of relevant experience. Gundersen provided written documentation, as well as a verbal summary, to the ACRS subcommittee on August 21, 2025. (See the related coalition press release, here; his three-page written presentation, here; see Gundersen's four-page A.I. analysis, here.) He followed up with submissions to the full ACRS committee on September 10, 2025. (See his open letter, including Gundersen’s invoking of the Space Shuttle Challenger disaster of 1986 as a cautionary tale for Palisades’ restart, here; see the related coalition press release, here.) Regarding the November 5-7, 2025 meeting, ACRS staff member Lawrence "Larry" Burkhart informed Gundersen in an October 22, 2025 email that: "...the topic of the Palisades SG [Steam Generator] operational assessment has been pulled from the November ACRS Full Committee meeting. This is because the focus of the NRC staff and Committee during the continued government shutdown is limited to only those activities that support key licensing activities for high priority projects. The ACRS review of the Palisades SG operational assessment is not tied to a high-priority licensing decision (it is considered informational for the Committee). Consequently, the Committee will not be hearing from the staff on this topic...We plan to include your written comments in our summary report of the meeting that would recognize that this topic was on the agenda but was pulled off due to the continued government shutdown...I am not sure if or when the Committee may reschedule a session on this topic." (Emphasis added.) In response, Kevin Kamps, radioactive waste specialist at Beyond Nuclear, who resides 35 miles downwind of Palisades in his hometown of Kalamazoo, Michigan, said: "It's outrageous ACRS has repeatedly ducked, dodged, and punted on Holtec's dicey Palisades degraded steam generator tube Band-Aid fixes, as the zombie reactor restart has been a top priority licensing decision for the agency for the past several years, with the rushed fire up still scheduled to occur sometime in the next several weeks, according to Holtec, just in time for its Initial Public Offering, where it hopes to raise $10 billion in private investment. But then again, the ASLB, and the rest of the NRC staff, have thus far rapidly rubber stamped every single Holtec request, including during the government shutdown, showing how little the agency actually cares about protecting public health, safety, security, and the environment. The wholesale dereliction of duty at NRC regarding Palisades' high-risk restart is shocking, although not surprising, given its long and significantly worsening collusion and complicity with the radioactively hazardous industry it is supposed to regulate." In January 1986, two NASA contract engineers identified that the Challenger Space Shuttle was endangered if it were to be launched in cold weather. Those engineers used all the professional channels available to prevent the launch. But the bureaucratic inertia within NASA to maintain the launch schedule caused those NASA engineers to be overruled. We all know the outcome of that safety lapse. I write to you today in the spirit of those two NASA engineers as I continue to express my safety concerns to the members of the ACRS. You provide the last possible public safety oversight before resurrecting the Palisades nuclear plant. Gundersen continued: "Never in my 54 year professional career have I been more concerned about the integrity of the reactor coolant pressure boundary than I am about the condition of Palisades." Gundersen warned the ACRS that “[i]t is not clear that the steam generator (SG) tubes or the SG tube sheet will survive for even half a year after Palisades’ ‘resurrection’ — Holtec’s word choice — is complete.” In June, 2025, Gundersen warned the ASLB that the likely burst of a single steam generator tube would release hazardous ionizing radioactivity into the Lake Michigan shoreline environment, but a cascading failure of enough steam generator tubes could lead to a full-blown reactor core meltdown. Gundersen had previously warned in 2015 how catastrophic that could be for the Great Lakes, in an essay entitled "Downstream," focused on yet another pathway to meltdown at Palisades -- the worst neutron-embrittled reactor pressure vessel in the country, according to NRC, at risk of pressurized thermal shock through-wall fracture. (See point number four, on page 5 of 15 on the PDF counter, in this April 2013 NRC document. Tied for worst-embrittled is Point Beach Unit 2 in Wisconsin, with Lake Michigan, direct source of drinking water for 16 million people in four states, wedged between.) In a presentation to the Michigan Public Service Commission (MPSC) in spring 2006 (see Page 2), Palisades' original owner, Consumers Energy, cited the reactor pressure vessel embrittlement as a top reason for selling the nuclear plant to Entergy. For years, Gundersen warned NRC and Holtec that neglect of basic yet safety-critical maintenance, namely chemically-preservative "wet layup," would result in dramatic worsening of already bad steam generator tube degradation at Palisades. (In the same documented cited just above, Consumers Energy admitted to the MPSC nearly two-decades ago that the steam generators needed to be completely replaced at that time; again, see Page 2.) At a January 14, 2025 NRC-Holtec technical meeting watchdogged by the environmental coalition, an NRC staffer admitted that Holtec had failed, from June 2022 to May 2024, to implement "wet layup," resulting in the shockingly widespread worsening of steam generator tube degradation at Palisades. (See the related coalition press release, here.) Another nuclear engineer critical of the Palisades' restart, Alan Blind, also submitted testimony to the ACRS, entitled "Comment on Holtec’s Use of 95/50 Probability Criteria in the Palisades Steam Generator Operational Assessment." Blind, with more than 40 years of nuclear engineering experience, served as a senior engineer at Palisades itself under the previous owner, Entergy, from May 2006 to February 2013. Blind also served at Indian Point nuclear power plant in New York, where a steam generator tube did burst on February 15, 2000. (Indian Point Unit 2 closed in 2020. Indian Point Unit 3 closed in 2021. Recently, Holtec proposed also restarting these two reactors, although already partially demolished by the company. Holtec has estimated it would cost the public $10 billion to rebuild and restart the closed and partially demolished Indian Point reactors. The cost to taxpayers and ratepayers for the restart of the single reactor at Palisades has already surmounted $3.12 billion, and could top $8 billion, if Holtec gets all the bailouts it has requested.) Blind's comments, dated November 5, 2025 begin: Holtec’s 2025 Steam Generator Operational Assessment (OA) for the Palisades Nuclear Plant concludes that tube structural and leakage integrity will be maintained for a 1.5 Effective Full Power Year (EFPY) operating interval—i.e., one nominal 18-month cycle. However, this conclusion is based on a 95 percent probability at 50 percent confidence (95/50) statistical criterion. This represents a material departure from the higher-confidence 95 percent probability at 95 percent confidence (95/95) standard more often used by the nuclear industry and the NRC when determining the acceptable interval between inspections—particularly when the projected period to the next inspection is 1.5 EFPY or less. Such shorter intervals inherently carry greater uncertainty because crack-growth variability, probe sizing errors, and environmental effects have proportionally larger impacts when little or no operating margin remains before the next inspection. (Emphasis added.) In short, Blind has pointed out that Holtec itself is only 50% confident that the Palisades steam generators will operate for just 18 months without a tube failure. At the January 14, 2025 technical meeting between NRC staff and Holtec representatives on the proposed sleeving repairs, Blind corrected an NRC staffer who claimed that a tube burst in a Palisades steam generator would not result in a release of ionizing radioactivity to the environment. Blind pointed out that due to its design, a tube burst at Palisades would result in an environmental release of radioactivity. Blind, who represents a number of residents of the Palisades Park Country Club, a 120-year old resort community with 200 cottages which shares a fence line with the Palisades nuclear power plant to the atomic reactor's immediate south on the Lake Michigan shoreline, has filed numerous interventions at the ASLB over the past couple years, including the most recent concerning further requested postponement of enforcement of fire protection regulations at Palisades, already previously delayed for many decades. (See Blind petition to intervene and request for hearing, 428-pages, dated September 7, 2025; Blind filed a 264-page "Supplement" on November 1; yet again, Consumers Energy's spring 2006 presentation to the MPSC acknowledged the decades-neglected fire protection issue as yet another reason it was selling Palisades to Entergy -- see Page 2.) Blind has also submitted many 2.206 emergency enforcement petitions with NRC staff regarding the restart, including one, in May 2025, regarding the steam generator tube degradation. Blind has been featured on the ten-episode, 2024-2025 Palisades-restart focused podcast "The Nuclear Reactor Next Door," hosted by Roger Rapoport. Other guests have included Beyond Nuclear's Kamps, as well as Palisades Park residents, Radiation and Public Health Project director Joe Mangano, and the environmental coalition's second expert witness, climate expert Dr. Mark Z. Jacobson of Stanford University (see the February 1, 2025 UPDATE at <https://beyondnuclear.org/intervention-against-palisades-zombie-reactor-restart/>). For more information, see Beyond Nuclear’s “Newest Nuke Nightmares at Palisades, 2022 to Present”. It is a one-stop-shop of web posts dating back to April 2022, when Holtec CEO Krishna Singh first floated “Small Modular Reactor” construction and operation at Palisades, and Michigan Governor Gretchen Whitmer first floated restarting the closed-for-good reactor. These schemes replaced the promise to decommission Palisades, which Entergy had made in 2016, and which Holtec had made since late 2020, the bait and switch trick which enabled Holtec to acquire Palisades in the first place. |
