Some have said that the Renewable Development Fund is sacred.  WRONG.  The Renewable Development Fund is profane, not sacred, all the way from its origins to its uses.  It’s now under scrutiny at Minnesota legislature, and institutional memory is nowhere to be found in this discussion.  See HF 235 and SF 214.

The Renewable Development Fund (RDF) came into being in the 1994 Prairie Island bill, and was to be a per cask compensation fund for the Prairie Island Indian Community for storage of nuclear waste next door and extension of Prairie Island nuclear plant life.  That compensation was turned into the RDF in a late night deal by “environmental” groups lobbying, of which Bill Grant (now Deputy Commissioner, Dept. of Commerce, formerly and then Izaak Walton League) was an integral part, Michael Noble (ME3, now “Fresh Energy”), and George Crocker (North American Water Office) too.  Prairie Island Indian Community was supposed to get priority in grants, but that never happened.  The RDF was administered by 3 from Xcel, plus Bill Grant, and one other “environmental” rep.  The composition of the group giving out the grants has changed, and there is now someone from PI on it, but that’s recent. (Full Disclosure: I represented Florence Twp. fighting the “in Goodhue County” alternate site mandate for nuclear waste and the Township worked very mindful of, and often in tandem with, PIIC, where it fiercely refused to acquiesce to Xcel and say “STICK IT THERE” to PIIC.  The working relationship continues and PIIC is now largest private  landowner in Florence Twp.).

1994 Prairie Island bill — Ch. 641, MN Session Laws (https://www.revisor.mn.gov/laws/?year=1994&type=0&doctype=Chapter&id=641).

The RDF was a material term of the 2003 Prairie Island bill, where as part of the deal millions of RDF money was to go to the Excelsior Energy Mesaba Project.  Bill Grant was primary again, and when the Mesaba Project was stricken in one House session, a red-faced Tom Micheletti came flying down the hall yelling at Grant “We had a deal, we had a deal!” That deal was later added back in, and Micheletti’s Excelsior Energy coal gasification plant, Mesaba Project, was added to the factors to keep PI open.  “Environmental groups” got massive grants to promote coal gasification.  Micheletti got $10-12 million from RDF for Mesaba (and lots more from IRRB and DOE) and other regulator perks in the 2003 law, like exemption from CoN, and a mandated PPA with Xcel.  (Full Disclosure: I represented MNcoalgasplant.com against Mesaba Project, and with CAMP and help from Xcel, we got the details of coal gasification, that project was killed, and the info killed others nationwide, but Mesaba still has a site permit in Taconite from PUC valid until 2019!)

2003 Prairie Island bill – Ch. 11, MN Session Laws (https://www.revisor.mn.gov/laws/?year=2003&type=1&doctype=Chapter&id=11

On Monday, January 23, the Red Wing City Council voted to accept a $2 million grant from RDF to install a garbage grinder, a project they’ve been lobbying for for years, where they’ll take in garbage from the whole county, grind it up, and burn it in Xcel’s garbage burner here, its air permit expired in 2009!  GARBAGE!!!  DOH!  GARBAGE is not clean, it’s toxic!  The purpose of all this is to keep the incinerators open and burning.  (Full Disclosure:  I have been representing clients being screwed by Xcel’s plan for “ash mining” in their incinerator ash landfill in Red Wing, part of which includes a plan to build a Red Wing laydown yard and crusher on a site half of which is designated Water Tower Burial Mounds — yeah, really. That’s been exposed:

My partner, Alan Muller, is an incineration expert and has worked with groups to stop RockTenn; Midtown Burner in Phillips, Rockford City and Township; HERC uprate, etc.  See the Tyler Hills Neighbors Comments: Comment Extension for Lab USA EAW & Xcel & Lab USA Solid Waste)

The RDF has been a slush fund for deals enabling nuclear, promoting coal gasification, and greasing the skids for scams of great financial and environmental magnitude and impact.  It should be shut down and turned over to Prairie Island Indian Community as originally intended.

An America First Energy Plan?

January 23rd, 2017

Contact Page for Trump’s White House

Comments: 202-456-1111
Switchboard: 202-456-1414

The Trump regime has published this “Energy Plan.”  WHAT?  Mitt Romney’s “Energy Plan” wasn’t much, and was grossly misguided, but it at least had SOME substance:

Romney’s Energy Plan – much ado about nothing

This is something a 5th grader could put together, nothing but blathering and slapped together code words.  It shows no thought or understanding of energy in the U.S. today.  I mean really, “clean coal” is so dead. During the Bush administration, they put billions in, between tax credits, grants, subsidies at state and federal levels — here’s a DOE announcement from 2006:

Energy Secretary and Secretary of the Treasury Announce the Award of $1 Billion in Tax Credits to Promote Clean Coal Power Generation and Gasification Technologies

The Bush Administration made coal gasification (IGCC) a priority, and even all that lobbying, subsidization, and wishful thinking couldn’t make it happen.  Minnesota’s Excelsior Energy’s Mesaba Project is one example of that abject failure (see also www.camp-site.info).  Delaware’s NRG coal gasification plant is another (note another NRG coal gasification plant proposed for NY went south too).

Meanwhile, existing coal is not economical, that’s why the older plants are being shut down, not anything to do with “Clean Power Plan,” and instead, that there’s a surplus of electricity and coal plants’ production costs a lot more than other available electric generation.  The market says no!  How does Trump think he can trump the market?  And even if he could, how is that in our interest?

Here’s a map of MISO market — note all the blue on these maps — I love using these as wallpaper, a constant reminder:

MISO LMP map

Here’s the PJM market map:

PJM LMP map

And the joint MISO/PJM market map:

Joint MISO/PJM LMP map

Coal cannot compete in the market, even with its outright and embedded regulatory subsidies, even the existing plants.  There’s a glut of electricity, has been for a decade now.  As Xcel’s Ben Fowkes says, recorded in the Seeking Alpha transcript of the XEL Earnings Call, January 31, 2013. 

So I think the economies are in decent shape across all our jurisdictions. Doesn’t necessarily mean it translates to high sales growth. And that’s consistent with our forecast. I mean, we’re not anticipating that we’re going to see a tremendous rebound in sales, even as the economies start to improve. I mean, I think, that’s our new normal, frankly.

So…. drumroll….  Here it is, cut and pasted from the White House site in its entirety (emphasis added in red)(and parenthetical comments):

Energy is an essential part of American life and a staple of the world economy. The Trump Administration is committed to energy policies that lower costs for hardworking Americans and maximize the use of American resources, freeing us from dependence on foreign oil.

For too long, we’ve been held back by burdensome regulations on our energy industry. President Trump is committed to eliminating harmful and unnecessary policies such as the Climate Action Plan and the Waters of the U.S. rule. Lifting these restrictions will greatly help American workers, increasing wages by more than $30 billion over the next 7 years.

Sound energy policy begins with the recognition that we have vast untapped domestic energy reserves right here in America. The Trump Administration will embrace the shale oil and gas revolution to bring jobs and prosperity to millions of Americans. (does he have no understanding of energy market?) We must take advantage of the estimated $50 trillion in untapped shale, oil, and natural gas reserves, especially those on federal lands that the American people own. (does he not know the havoc in ND during Bakken BOOM!, the many Bakken BOOM! train explosions, pollution, and deaths?  And he’d allow corporations to take OUR land?) We will use the revenues from energy production (a production tax increase?) to rebuild our roads, schools, bridges and public infrastructure. Less expensive energy will be a big boost to American agriculture, as well.

The Trump Administration is also committed to clean coal technology, and to reviving America’s coal industry, which has been hurting for too long.  (again market forces, coal is not least cost, and new coal is way beyond anything market would support.  “Clean” coal?  Don’t even think about it, it doesn’t exist!)

In addition to being good for our economy, boosting domestic energy production is in America’s national security interest. President Trump is committed to achieving energy independence from the OPEC cartel and any nations hostile to our interests. At the same time, we will work with our Gulf allies to develop a positive energy relationship as part of our anti-terrorism strategy.

Lastly, our need for energy must go hand-in-hand with responsible stewardship of the environment. Protecting clean air and clean water, conserving our natural habitats, and preserving our natural reserves and resources will remain a high priority. President Trump will refocus the EPA on its essential mission of protecting our air and water. (everything I’ve seen and heard from Trump and EPA pick points towards dismantling and defunding EPA.  What does this mean?)

A brighter future depends on energy policies that stimulate our economy, ensure our security, and protect our health. Under the Trump Administration’s energy policies, that future can become a reality.

How clueless can Trump be?  Well, we’re seeing… and it’s unbelievable… UNBELIEVABLE!

gasification_schematic

After this election, there are so many things to be concerned about, so many reasons to be utterly horrified… a Muslim database, Trump’s fraud trial to begin November 28th, promise of mass deportations, sharp increase in hate crimes, assaults and threats on the street and in the schools (and online, oh my!).  Trump’s “100 Days” plan was out in October, and has many points, full of words to decode, including a ‘clean coal’ reference, showing he’s clueless, just clueless:

Trump’s Contract with the American voter — the First 100 Days

In the 2nd and 3rd debate, Trump used those two words that have deep meaning to me, “clean coal,” because of Excelsior Energy’s Mesaba Project here in Minnesota, and because of the NRG proposed IGCC plant in Delaware, both of which were defeated after a long protracted fight.  There is no such thing as ‘clean coal.”

mesabaone

Coal gasification is one thing that my coal-plant designing Mechanical Engineer father and I had some bonding moments over, going over EPRI coal gasification reports from the 80s and the Mesaba application…  And I had the pleasure of meeting and working alongside my father’s boss’s son, who is also an engineer, formerly with NSP/Xcel, who knew what a bad idea coal gasification is.  Oh yeah, we who fought these projects have learned a lot about coal gasification, “carbon capture and storage,” and will not go there again (see Legalectric and CAMP – Citizens Against the Mesaba Project sites for more info).  We know it doesn’t work.  And experience with the few projects that did go forward, what a mess, cost overruns beyond the wildest SWAG estimate, inability to get the plant running…  Trump, don’t even think about it:

IGCC – Pipedreams of Green & Clean

IGCC, coal gasification, is nothing new.  And despite its long history, it’s a history of failure, failure to live up to promises, failure to operate as a workable technology, and failure to produce electricity at a marketable cost, failure to produce electricity at all!  On top of that, it’s often touted as being available with “CO2 capture and storage” which it is not.  That’s a flat out lie.  Check this old Legalectric post:

More on Carbon Capture Pipedream

A key to this promotion is massive subsidies from state and federal sources, and selection of locations desperate for economic jump-start, so desperate that they’ll bite on a project this absurd, places like Minnesota’s Iron Range, or southern Indiana, or Mississippi.  The financing scam was put together at Harvard, and this blueprint has been used for all of these IGCC projects:

Harvard I – 3 Party Covenant

That, coupled with massive payments to “environmental” organizations to promote coal gasification, and they were off to the races.

Joyce Foundation PROMOTES coal gasification

Doris Duke Charitable Foundation & IGCC – WHY???

VP-elect Mike Pence should know all about coal gasification, he’s from Indiana.  Indiana is coal generation central, and has had a couple of IGCC projects planned, construction started, and built.  Indiana’s Wabash Valley plant is a perfect example, a small IGCC plant that was built, and after it was “completed,” took 22 on-site engineers to keep it running, now and then, at a greatly reduced capacity.

Wabash River Final Technical Report (it was “routinely” in violation of its water permit for selenium, cyanide and arsenic)

When they tried to sell the Wabash Valley plant recently, of course no one wanted it:

Wabash Valley coal gasification plant closing!

And another Indiana plant, with huge cost overruns that never started operating:

Rockport coal gasification plant dies – Indianapolis Star

Coal News: $2.8B coal gasification plant in Indiana canceled

And then there’s Edwardsport IGCC plant, also in Indiana, what a disaster:

Edwardsport plant not at promised capacity

Settlement won’t be the last word on controversial Indiana coal plant

Duke Energy Edwardsport Plant Settlement Expanded

The original settlement in September was a response to the plant’s rising operating costs while failing to meet performance expectations.

In the new agreement, Duke Energy agrees not to charge customers for $87.5 million of the operating costs of the Edwardsport plant, $2.5 million more than the original agreement.

And note that problems with Edwardsport tie in to similar problems with the Kemper IGCC plant in Mississippi:

Indiana ‘cease fire’ could provide a model for Mississippi regulators

Yes, in Mississippi, the Kemper IGCC plant is proving to be a problem, and yes, folks, note the Obama promotion of IGCC — after all, Obama is from Illinois, a coal state, and had lots of support from coal lobbyists.  Check this detailed NY Times article:

Piles of Dirty Secrets Behind a Model “Clean Coal’ project: Mississippi project, a centerpiece of President Obama’s climate plan, has been plagued by problems that managers tried to conceal, and by cost overruns and questions of who will pay.

The sense of hope is fading fast, however. The Kemper coal plant is more than two years behind schedule and more than $4 billion over its initial budget, $2.4 billion, and it is still not operational.

The plant and its owner, Southern Company, are the focus of a Securities and Exchange Commission investigation, and ratepayers, alleging fraud, are suing the company. Members of Congress have described the project as more boondoggle than boon. The mismanagement is particularly egregious, they say, given the urgent need to rein in the largest source of dangerous emissions around the world: coal plants.

Trump, just don’t.

okla-quake_wide-df42df8a84055fe96e5682321e4b5cc937030c06-s1500-c85BIG earthquake in Oklahoma today, and are we surprised?   Naaaaah…  Here’s the info, including location, economic impacts, etc., from USGS:

CLICK HERE: USGS Pawnee, OK Earthquake Page

In the news, and they’re making the link between gas wells and earthquakes:

Earthquake Rattles Oklahoma; One Of Strongest Recorded In State

Earthquake Shakes Swath of Country Where Wells Have Drawn Scrutiny

Earthquake rattles Oklahoma, six neighboring states

VIDEO: Dogs react to Oklahoma earthquake

IMPORTANT: The Oklahoma Corporation Commission takes action!

Oklahoma Corporation Commission orders disposal wells shut down near quake epicenter

Consider why fracking and injection of frac waste is allowed…  Why is a pipeline route through earthquake prone area considered?  The impacts of fracking and waste injection is one thing they do NOT want to acknowledge.  From KOTV in June 2014 — USGS should know better:

OklahomaEarthquakes_June2014_KOTV

And when searching, look at this — can you believe:

OGS: Earthquake risk low for proposed disposal wells in Yukon

When the topic of earthquakes and other seismic activity comes up, I always recommend the “bible” of injection into the earth, because this is not a new phenomenon and we’re making this happen, putting people and our water supply at risk:

Gas Migration: Events Preceding Earthquakes, by Khilyuk

When I got this book, it was an older edition, though pricey, but with patience, it could be had for $20.  For about a decade now I’ve been recommending this book, and look at the price now.  Out of bounds for most of us… funny how that works.  I’d guess a library could find a copy, and here it is on google books, “only” $224.00 (GRRRRRRRRRR):

Gas migration: events preceding earthquakes

Elisa Young, a cohort in Ohio, has lived in the epicenter of frack injection triggered earthquakes around Youngstown.  There, after so many earthquakes, the causal connection was acknowledged, but it took too long.  Here’s a Legalectric post from four years ago:

Ohio Earthquakes & Fracking

And now for a complicated sidebar.  Elisa Young asked today how to get the state and federal agencies to communicate about this problem and take action.  How?  Damned if I know — impacts of injecting gas and liquids into the earth are well known.  Yet federal and state agencies are in serious state of denial.  And it’s very difficult at times to get the agencies to show up, to do their job.  It’s even difficult to get their analysis, their own reports, into project permit dockets.  I get really tired of this…

How to get them to weigh in?  In Public Utilities Commission dockets in Minnesota, I’ve had a hard time with state agencies, initially.  For example, in Excelsior Energy’s Mesaba Project docket, there was a claim that coal gasification was “clean” yet the Minnesota Pollution Agency had not, and would not, weigh in on the emissions projected for this coal gasification power plant.  WHAT?  We pushed and pushed, threatened to subpoena, raised this at a PUC meeting, and finally, the PUC issued an Order and wrote a letter to the PCA Commissioner requesting the MPCA lend its expertise to the Commission and show up!

3114835_PUC Letter to MPCA

And a Legalectric post about later subpoena requests on the Mesaba Project:

FOIAs to feds, subpoena requests to state agencies

And subpoena and Data Practices Act requests in that same docket for financial information:

Subpoena Request IRR September 7, 2006

IRRB Data Practices Act Request

Letter to IRRRB June 19, 2006

Letter to IRRRB July 26, 2006

I’ve had similar issues in transmission dockets, where the DOT and DNR would file Comments on environmental scoping, and/or the Draft Environmental Impact Statement, but those Comments would only be sent to the Dept. of Commerce, and were not posted in the PUC docket, so parties and the public had no idea the concerns the agencies may have.  NOT OK.  During the first CapX 2020 routing docket, Brookings 08-1474, it was so egregious, I asked the DOT General Counsel who was present to make comments at the public hearing, and to submit a copy for the routing docket record (the route ultimately turned on DOT easements and that DOT would not allow the transmission line to be built over those easements).   The matter was remanded by the Commission for rehearing based on their routing quandry.  Shortly after, on behalf of No CapX 2020, I subpoenaed testimony and Comments.

Subpoena requests sent! (DOT & DNR)

Subpoena plot thickens (Agreement to testify)

Subpoena request for US Fish & Wildlife

Subpoena Denied(tried to get USFWS, didn’t work.  USFWS Comments had been hidden in EIS Comments)

Notes from Friday

In the Goodhue Wind docket (permit granted, and then much later revoked!):

Goodhue Wind Truth – Subpoena Requests for Bjorklund and Bull

ALJ Sheehy’s Letter to Overland – Denial of Subpoena Requests

Goodhue Wind Docket … REFILE!

When this was attempted in the Sandpiper Pipeline docket, the ALJ denied the Subpoena request.  WHAT?

And an interesting back and forth with a hearing officer about getting information into the record and whether it would take a subpoena to get it, where ultimately, the ALJ agreed that the primary documents would be entered in the record:

NRG in hiding at DNREC hearing

And here’s an aside, use of subpoena regarding Xcel’s plans for coal, served by NY’s A.G.:

New York A.G. serves Xcel with subpoena

 

20160721_172836[1]

Well, that was interesting… and it took all evening!

First a sidebar, but an important one.  The Agenda CBS Public Meeting-Minneapolis caught my attention, seeing PUC Commissioner John Tuma named front and center. The PUC’s page  on Commissioner ex parte, conflict, and basic decorum has disappeared — I called the PUC about Commissioner Tuma’s appearance (fair warning, prior to event), and noted that the page had disappeared.  Here are the rules (the page was what stressed the importance of avoiding even the appearance of impropriety:

7845.0400 CONFLICT OF INTEREST; IMPROPRIETY.

Subpart 1. General behavior.

A commissioner or employee shall respect and comply with the law and shall behave in a manner that promotes public confidence in the integrity and impartiality of the commission’s decision making process.

Subp. 2. Actions prohibited.

Commissioners and employees shall avoid any action that might result in or create a conflict of interest or the appearance of impropriety, including:

A. using public office for private gain;

B. giving preferential treatment to an interested person or entity;

C. impeding the efficiency or economy of commission decision making;

D. losing independence or impartiality of action;

E. making a commission decision outside official channels; and

F. affecting adversely the confidence of the public in the integrity of the commission.

7845.0700 PROHIBITED ACTIVITIES.

Subp. 4. Outside employment.

A commissioner or employee shall not negotiate for or accept outside employment or other involvement in a business or activity that will impair the person’s independence of judgment in the exercise of official duties.

I registered this in a Comment section, provided copies of the rules, and expected something similar to Commissioner Koppendrayer’s response in a similar situation years ago (see below). Commissioner Tuma is new, and being there was not the worst of possible activities, other past and present Commissioners have done much worse, but it’s not OK.  His presence on the panel, on the stage, lends the impression of support of the DOE’s efforts, and nuclear waste, nuclear decommissioning funds, nuclear uprates and rehab, all are issues that have been and will be in front of the Commission in highly contested cases.  It lends the appearance of losing independence, impartiality, and impairment of judgment in future exercise of official duties.

I’ve seen this a few times.  One positive experience was at the Sawmill Inn when Commissioner Koppendrayer was named on a coal gasification love-fest panel when Excelsior’s Mesaba Project was before the PUC, and I’d called the Commission ahead of time and spoken to the then Asst. A.G. who said, not to worry, they knew ex parte and conflict of interest and rules of decorum.  Yet at that meeting, which Koppendrayer DID attend despite advance warning, I jumped up and objected from the back of the room, noting the PUC’s focus on avoiding even the appearance of impropriety, and Koppendrayer said something like “Overland’s got a point, and I should leave” and he did!  He earned quite a few “respect” points that day.   IEDC gets carried away  February 15, 2007.

On the other hand, I’m also remembering Commissioner Phyllis Reha’s coal gasification junket to Belgium via Great Plains Institute, a well-funded toady for coal gasification (and GPI was on panel last night, another cause for concern, how much were they paid!).  How blatant can you get?  MCGP Request for Recusal (Commission saw no problem!).

Reha-Europe2007GroupPhoto_1

… and there’s her stumping for CapX 2020 transmission: PUC Commissioner Reha: Enhancing the Nation’s Electricity Delivery System.  That was the basis of another Motion, but of course, Commissioner Reha and the Commission saw no problem with her actions!  NoCapX Motion to Recuse Commissioner Reha & Exhibit A – Reha Power Point Presentation.

And then there’s Great Plains Institute’s involvement.  After their intense and well funded toadying for coal gasification ($437,000 over 21 months), and transmission, and then Xcel Energy’s e21, Dog help us!  Anything GPISD in involved with has got my attention, and not in a good way!

Last night’s agenda was packed, and we got a lot done.  A guy name Scott Thomas (the NSP engineer perhaps?) was at my table and jumped up and objected when we had a bit of opposition theater, I jumped up to counter, DOH, every hear of freedom of speech.  I mean really, it took all of 5 minutes, let people speak up!

Here’s my comment, in large part based on “consent” a la SNUY’s approach for sexual consent, substituting “nuclear” for sexual — if we’re going to get screwed, this is the best possible of consent definitions:

DOE – Overland Comment 7-21-2016

Here’s the DOE’s Consent-Based Siting page.  Notice was in the Federal Register, who reads that? Invitation for Public Comment in the Federal Register.  Comments are being taken through July 31 or email to them at consentbasedsiting@hq.doe.gov.

Here’s how they’re framing it, with questions to be answered:

  • How can the Department ensure that the process for selecting a site is fair?
  • What models and experience should the Department use in designing the process?
  • Who should be involved in the process for selecting a site, and what is their role?
  • What information and resources do you think would facilitate your participation?
  • What else should be considered?

We broke into small groups and actually had a pretty good discussion.  Peggy Rehder, Red Wing City Council, was also at “Table 2” and of course we’re disagreeing.  She’s frustrated at having spent 6 years on this and getting nowhere, but in terms of nuclear waste, 6 years is but a second or two…  I’ve got 22 years in, and some there had many more.  A key point was that the DOE must restore trust if it wants to get anywhere, and how would that happen?  Stopping production of more nuclear waste is a key step.  Dream on… this process is a move to enable continued generation of nuclear waste, continued operation of nuclear plants, now being relicensed, uprated, nuclear waste expanded.

Prairie Island’s President Shelly Buck was on the panel, and that was good — PIIC is in such a mess, the plant and nuclear waste right next door, and they’ve been screwed over so many ways, so many times.  Will they be regarded as a “stakeholder” this time around?  They’ve intervened in so many nuclear matters, doing everything they can to protect the Community…

Parts of it were webcast.  There will be a video of the evening’s festivities sometime, LINK HERE (when it’s posted, scroll down to “Minneapolis”) and there was a photographer snapping shots every few seconds (hmmmm, well, I guess that will be added to all our files!).

Karen Hadden, SEED Coalition (that SEED Coalition grew from Energy Foundation funding, same as MN’s defunct “SEED Coalition” which morphed into “RE-AMP” about 2005), was present, and vocal (YES!), regarding their concerns about nuclear waste siting in Texas and New Mexico, particularly about a recent application to NRC for a nuclear waste storage facility in western Texas, near the New Mexico border. See www.NoNuclearWasteAqui.org for more info.

Alan Muller, environmental consultant in Minnesota, and Exec. Dir. of Green Delaware, spoke of his having TWO Prairie Island reactors on the other side of town here in Red Wing, and the THREE Salem and Hope Creek reactors, visible from the office window in Port Penn, Delaware.

AlanGreenDel

Here’s the Arizona meeting, CHECK OUT THE VIDEO HERE.  Well worth the listen, the panel is much better qualified than the one in Minnesota (with the exception of Prairie Island’s Shelly Buck, and Canada’s Kathryn Shaver from their Adaptive Phases Management Engagement and Site Selection, Nuclear Waste Management Organization, listen up to them when Mpls. video is released).

Take some time and consider the DOE’s informational booklet.  Put your thoughts together and send in comments: consentbasedsiting@hq.doe.gov.

I think it’s worth trotting out the EQB Citizens Advisory Task Force report on nuclear waste, from the Florence Township Nuclear Waste Daze:

Florence Twp Site – Citizens Advisory Task Force – Nuclear Dry Cask Storage

And also thing about the many casks on Prairie Island — those TN-40s and TN-29 have aluminum seals that need to be replaced EVERY 20 YEARS, and to my knowledge they’ve not been replaced, and there are casks that have been loaded and sitting there for more than 20 years.  What’s up with that?  What’s the plan?  Back when they were permitting that, there was no plan.  So…

Consider this 3 Stooges approach to cask unloading — don’t know of any other attempt to unload casks, maybe that’s one of the lessons learned here:

INEL TN-24P stuck

Here’s an INEL report on a TN24 leak:

10813-TN-24P leak

And an NRC report on unloading:

NRC INFORMATION NOTICE 97-51:  PROBLEMS EXPERIENCED WITH LOADING 
AND UNLOADING SPENT NUCLEAR FUEL STORAGE AND TRANSPORTATION                             CASKS

Here’s an EPRI report on (these technical reports are important!) Creep and Crud, which occurs with storage:

100217 – Creep & Crud

Here’s a report generated after the “ignition event” at Pt. Beach, where spent fuel was loaded in a cask, then set out of the pool, and let sit overnight, then they attempted to well it, well, welding cask full of bubbles of hydrogen from the interaction of zinc and the acidic solution the assemblies are sitting in, left overnight, BOOM!

NRC_ Bulletin 96-04_ Chemical, Galvanic, or Other Reactions in Spent Fuel Storage and Transportation Casks

Where are all the reports about the weld flaws on the VSC-24 casks?  They’re in Pt. Beach, Palisades, and Arkansas One.

Estimated Risk Contribution for Dry Spent Fuel Storage Cask

Failure Modes and Effects Analysis of Welded Stainless Steel Canisters for Dry Cask Storage Systems – EPRI

And here’s a report relevant to us here in Minnesota, given all our granite and our “2nd place” position in the federal site selection resulting in “choice” of Yucca Mountain:

Granite report SAND2011 6203