COVERT TOWNSHIP, MICHIGAN AND WASHINGTON, D.C., JULY 29, 2025--Following up on its initial protest, decrying U.S. Nuclear Regulatory Commission (NRC) actions, the environmental coalition opposing Holtec’s unprecedented Palisades atomic reactor restart scheme has filed an emergency enforcement petition with the agency. The coalition (also known as Petitioners, or Complainants) again challenge the adequacy, from a safety perspective, of Holtec’s proposed repairs to severely degraded steam generator tubes, namely sleeving by contractor Framatome. Complainants' emergency enforcement petition also objects to Holtec’s proceeding with sleeving repairs, even before final, or even preliminary, NRC approval, albeit, ironically enough, with NRC's knowledge and complicity. The coalition is engaged in an official legal proceeding before an NRC Atomic Safety and Licensing Board Panel regarding the adequacy of Holtec's proposed sleeving repairs on the dangerously degraded steam generator tubes.

The coalition’s expert witness, nuclear engineer Arnie Gundersen, has warned that restarting the reactor could result in the failure of one or more steam generator tubes, due to operational temperature and pressure, as well as accelerated corrosive attack, from chemical “hide out” in crevices, such as at tube-to-tubesheet, and tube-to-tube support plate, interfaces. Gundersen has dubbed Holtec’s failure to implement wet layup (submersion in ultra-pure water, with anti-corrosion chemicals, such as hydrazine, added) on the steam generators from 2022 to 2024 a “rookie error,” the tube cracking and degradation "self-inflicted," with potentially catastrophic consequences.

The failure of a single steam generator tube would result in the release of hazardous ionizing radioactivity into the environment. But a cascading failure of a large enough number of steam generator tubes could cause a full blown reactor core meltdown, with catastrophic amounts of hazardous radioactivity released into the environment, potentially up to large distances downwind and downstream. Gundersen first warned of Palisades' existential threat to the Great Lakes a decade ago.

Nuclear engineer Arnie Gundersen, the environmental coalition’s expert witness on nuclear safety issues, such as the dangerously degraded steam generators, stated:

“The NRC is not an Elliot Ness tough cop regulator. Instead, NRC's complicity with Holtec at Palisades shows the agency is more like Ness joining in with Al Capone on the St. Valentine’s Day Massacre. If the existing ‘defueled’ Technical Specifications are in effect, Holtec cannot do any sleeving. Sleeving requires a Tech Spec change. So if Holtec has already sleeved, then they violated the current Tech Specs. Holtec may claim that they did it at their own risk, but last I looked, you can’t break the law anticipating the law might change in the future. And the NRC tacitly acknowledges they knew the law was being broken.” 

Coalition attorney Terry Lodge of Toledo, Ohio stated: 

"The historical record on Palisades suggests that Framatome, the sleeving contractor, made the sleeving plans based on damage assessments that do not appear to account for the lack of timely wet layup and drainage of corrosive water from the primary and secondary cooling loops. The collusion between Holtec, which has undertaken sleeving without preliminary or final license amendment approval, and the NRC Staff, which is inspecting this construction but obviously not enforcing NRC regulations at this point, exemplifies confirmation bias and reinforces concerns that there may be danger inherent in the Palisades restart."

Coalition attorney Wally Taylor of Cedar Rapids, Iowa added:

"Complainants are not merely insisting on doing things by the book; they are attempting to ensure that each step on this unprecedented path is scientifically warranted and consonant with the public health and safety obligations inscribed in the Atomic Energy Act. NRC and Holtec see the pathway to restart as a comparatively simple reversal of the shutdown decision. Complainants maintain that there would inevitably be changed circumstances in the simple passage of more than three years since shutdown, even if the stabilization of equipment had been done correctly -- but that there may be ominous consequences from the flawed efforts by Holtec following shutdown."

Kevin Kamps, radioactive waste specialist at Beyond Nuclear, based in Kalamazoo, Michigan, stated:

"A year after the beginning of the Fukushima Daiichi nuclear catastrophe, the Japanese Parliament published the first independent investigation in its post-World War Two history. It concluded that the root cause of the nuclear catastrophe, the reason the three reactors that melted down were so very vulnerable to the earthquake and tsunami that destroyed them, was collusion, between the safety regulatory agency, the company, and government officials. Frighteningly, there is just such potentially catastrophic collusion in spades at Palisades."

Michael Keegan, chair of Don't Waste Michigan in Monroe, Michigan, stated:

"Palisades' original owner, Consumers Energy, admitted to the Michigan Public Service Commission in 2006 that the reactor's steam generators needed to be entirely replaced. Several other $100 million plus components needed replacement, and so Consumers Energy decided to sell the plant. Entergy purchased Palisades and did not replace any of those big ticket items from 2007 to 2022, because NRC did not require it. Now Holtec, which gave lip service to replacing the steam generators in 2022, is looking to avoid that $510 million expense, by making unsafe, inadequate band-aid fixes on degraded tubes. Holtec, playing with 'other people's money' and without financial skin in the game, intends to roll the dice and risk the entire Great Lakes Basin."  

The environmental coalition opposing Holtec's Palisades reactor restart scheme includes: Beyond Nuclear; Don't Waste Michigan; Michigan Safe Energy Future; Nuclear Energy Information Service of Chicago; and Three Mile Island Alert of Pennsylvania.

For more information, see Beyond Nuclear's "Newest Nuke Nightmares at Palisades, 2022 to Present" -- a one-stop-shop of webposts 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.

Beyond Nuclear is a 501(c)(3) nonprofit membership organization. Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic. The Beyond Nuclear team works with diverse partners and allies to provide the public, government officials, and the media with the critical information necessary to move humanity toward a world beyond nuclear. Beyond Nuclear: 7304 Carroll Avenue, #182, Takoma Park, MD 20912. Info@beyondnuclear.org. www.beyondnuclear.org.