Environmentalists' Expert Witness Warns NRC of Yet More Cracking in Palisades Atomic Reactor's Primary Coolant System: Nuclear Engineer Arnie Gundersen Fears Steam Generator Tubes and Tube Sheets May Fail Within Six Months

 NEWS FROM BEYOND NUCLEAR


  For immediate release 

  Contact: Kevin Kamps, radioactive waste specialist, Beyond Nuclear, Kalamazoo, MI, (240) 462-3216, kevin@beyondnuclear.org

  Michael Keegan, chair, Don’t Waste Michigan, Monroe, MI, mkeeganj@comcast.net

Terry Lodge, attorney, Toledo, OH, tjlodge50@yahoo.com

Wallace Taylor, attorney, Cedar Rapids, IA, wtaylor784@aol.com

Arnie Gundersen, nuclear engineer/expert witness, (802) 238-4452

 

Environmentalists' Expert Witness Warns NRC of Yet More Cracking in Palisades Atomic Reactor's Primary Coolant System

Nuclear Engineer Arnie Gundersen Fears Steam Generator Tubes and Tube Sheets May Fail Within Six Months

COVERT TWP., MI and WASHINGTON, D.C., SEPTEMBER 10, 2025--Arnold Gundersen, a nuclear engineer with more than 50 years of relevant experience who serves as expert witness for an environmental coalition opposing Holtec International’s unprecedented restart of the previously closed Palisades atomic reactor, has sent an open letter to the U.S. Nuclear Regulatory Commission’s (NRC) Advisory Committee on Reactor Safeguards (ACRS)

Gundersen invoked the safety engineers who warned in 1986 that the cold temperature launch of the Space Shuttle Challenger was not safe, but were nonetheless overruled by NASA superiors more concerned about meeting the arbitrary launch schedule, with catastrophic consequences.

Gundersen wrote “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 added: “My concern initially started with the condition of the steam generators, but new Holtec relief requests have identified significant PWSCC [Primary Water Stress Corrosion Cracking] at eight other locations within the reactor coolant system.  The loss of the reactor coolant pressure boundary can lead to previously unimaginable impacts to the general public. I respectfully suggest that the ACRS imagine what could happen in the event of primary coolant system failure or a steam generator tube failure due to years of improper wet layup by Holtec at Palisades.  I pray that you will thoroughly question the integrity of the reactor coolant pressure boundary caused by failure to meet Electric Power Research Institute (EPRI) primary and secondary water chemistry standards before allowing Palisades to restart and set a new licensing precedent.”

The letter warns against inadequate analysis of steam generator tube degradation, the safety risk that has dominated attention for the past year. But Gundersen also warns about an additional degradation mechanism, Primary Water Stress Corrosion Cracking (PWSCC), only recently revealed by Holtec, which appears to have impacted multiple locations in Palisades’ Primary Coolant System, also vitally important for safety.

Gundersen added “[t]his is a generic issue, as there are other decommissioned reactors now in the queue to be resurrected that have also not maintained adequate water chemistry during closure.”

Constellation Energy at Three Mile Island Unit 1 in Pennsylvania, and NextEra at Duane Arnold in Iowa, are following Palisades’ closed reactor restart precedent.

As cited by the NRC’s Atomic Safety and Licensing Board (ASLB), “Wet layup consists of filling the steam generator completely with water that has been treated with hydrazine and ammonium hydroxide. The high steam generator level minimizes the amount of secondary metal that [sic] exposed to air during cold shutdown.” (United States Nuclear Regulatory Commission Technical Training Center, Combustion Engineering Technology Cross Training Course Systems Manual at 2.3.9.1, Sept. 19, 2002, ADAMS Accession No. ML022840127; see footnote #59, on Page 14, of ASLB’s August 5, 2025 ruling.)

Gundersen has dubbed Holtec’s 2022-2024 neglect of such basic safety maintenance as taking precautions against corrosive chemical attack on vulnerable steam generator tubes as a “rookie error” that risks a reactor core meltdown, if enough cracked tubes fail in rapid, cascading succession.

Gundersen has 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.” 

Gundersen also warned that in the event of even a single steam generator tube’s failure, “Palisades’ 60-year old design would use Atmospheric Dumps to discharge hazardous radioactivity directly into the atmosphere.”

Gundersen added: “Now, new information of degradation has become available. In addition to all the steam generator tube and tube sheet indications, on August 20, 2025 Holtec filed a series of relief requests (ML25232A195) indicating that it has discovered Primary Water Stress Corrosion Cracking (PWSCC) in numerous dissimilar metal welds in Palisades’ Primary Coolant System. The affected welds include indications in two hot leg welds, four cold leg welds and two pressurizer welds.”

Gundersen concluded: “Holtec has previously admitted that it did not analyze either primary or secondary water chemistry at Palisades for two years and that it was not in compliance with EPRI water quality guidelines.  Clearly the absence of adequate water chemistry control at Palisades and its effect on the primary coolant system boundary are issues that deserve the thorough attention of the ACRS before allowing Palisades to restart.” 

NRC staff and ASLB panels have already signed off on most, although not all, required approvals for Holtec to restart Palisades, perhaps yet this year the company still claims. This is despite the environmental coalition’s efforts to challenge safety shortcomings at every twist and turn in the ASLB proceedings for the past two years. ACRS sign off is among the very last hurdles before Holtec’s Palisades restart is officially approved by NRC, as is final approval by the NRC Commissioners. The agency’s normally five — but currently three — directors have yet to rule on the environmental coalition’s many appeals of adverse ASLB rulings, regarding multiple Holtec License Amendment Requests, an Exemption Request, a License Transfer Request, and the adequacy of agency environmental reviews, all of which the coalition has contested. 

The intervening coalition includes Beyond Nuclear, Don’t Waste Michigan, Michigan Safe Energy Future, Nuclear Energy Information Service of Chicago, and Three Mile Island Alert of Pennsylvania. The coalition’s co-counsel are Terry Lodge of Toledo, Ohio, and Wallace Taylor of Cedar Rapids, Iowa. Dr. Mark Z. Jacobson, Stanford University professor and author of a large number of technical publications on reducing greenhouse gas emissions that cause global warming and climate change, also serves as an environmental coalition expert witness opposed to Holtec’s Palisades restart scheme.

For more information, see Beyond Nuclear’s “Newest Nuke Nightmares at Palisades, 2022 to Present” — 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.

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