Legalectric

Yes, that’s the Prairie Island plant back behind Ken’s rump!

Comments are due on the big picture for the Prairie Island power uprate and siting of more dry casks. yes, the notice says today:

Public Meeting Notice & Comment Deadline

And it says:

Deadline for written public comments to the Administrative Law Judge on the Certificate of Need (CON) and Site Permit applications must be received by May 25, 2009.

And here’s what the hearing and what comments should address:

Purpose of Hearing. The purpose of the public hearing is to compile the record for the Commission to consider in making a final decision on the CON and the Site Permit requests. The ALJ will write a report and make a recommendation to the Commission on (1) the need for the extended power uprate (EPU) project, (2) the need for the Additional Dry Cask Storage project, and (3) on site selection, including any appropriate site permit conditions. The Commission will make a final decision on the need and site permit at a subsequent Commission hearing. The Commission must issue a Certificate of Need prior to issuing a Site Permit.

Remember Xcel isn’t too happy about the City of Red Wing intervening?  See “Xcel not a happy camper” from last month.

Maybe it’s because Red Wing has a stake in this, as host to Xcel’s Prairie Island nuclear generating plant.

Here we see that in Information Requests in the Prairie Island uprate and dry cask docket at the PUC, the City of Red Wing is asking the right questions:

Information Requests 19-29

Here’s a couple that I find extremely amusing, starting with IR-21:

or this one… IR-22:

and IR-23:

and IR-24:

Yes, we are having fun now.

I wonder… will they give the City of Red Wing a copy of EPRI’s “The TN-24P PWR Spent-Fuel Storage Cask: Testing and Analyses” report?  That’s EPRI report NP-5128.  Let’s see the results of that “Three Stooges” INEL unloading attempt where the assembly got stuck half out, half in, and wouldn’t move… HILARIOUS, I’ve never seen such a rip-snortin’ report, hard to read between the lines without busting a gut!

And what do you see waaaaay in the background?  Why, it’s the Prairie Island nuclear plant!  It’s been there so long that now they want to relicense it, but at the state, there’s an uprate and dry cask docket, and so there’s a state proceeding, not that there’s much chance of impact, but it’s there…

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Seems Xcel had a bit of a problem with an equipment shipment from Prairie Island Nuclear Generating Plant… oops… it was too radioactive at the receiving end of the line… how was it before and during???  Hmmmmmm…

Here’s the NRC report:

Prairie island Preliminary Yellow Findings Report

Bottom line?

…. the NRC concluded, that the elevated ratiation levels, although on the underside of the package, had the potential to adversely affect personnel who would normally receive the package and/or respond to an incident involving the package with the reasonable expectation that the package conformed to DOT radiation limitations.

and, regarding Title 49 CFR 173.44(a) which sets out specific shipping requirements …

Contrary to these requirements, on October 29, 2008, Northern States Power – Minnesota (Prairie Island) shipped a package containing radioactive material that was not sufficiently designed nor prepared to assure that, under conditions normally incident to transportation, the radioation level on the external surface of the package would not exceed 200 mrem/hour.  When received and surveyed at the shipping destination (Westinghouse in Waltz Mill, Pennsylvania), on October 31, 2008, the external surface of the package exhibited radiation levels of 1630 mrem/h [i.e. package radiation levels greater than five and less than ten times the regulatory limit].

Prairie island Preliminary Yellow Findings Report, see p. 9-11.

Here’s the story from the Red Wing Republican Beagle, also posted as AP in STrib and StPPP:

Shipments radioactivity was too high

Anne Jacobson
The Republican Eagle – 02/16/2009

A radioactive piece of equipment passed muster when it left Prairie Island nuclear plant, but the package exceeded safe radiation shipping levels by eight times when it reached Pennsylvania.

Plant Vice President Mike Wadley called it a serious and rare event.

The Nuclear Regulation Commission officials notified him by mail last week that they have issued a preliminary “yellow” finding in the matter. Yellow is the third highest of four safety risk rankings.

The NRC defines a yellow as an incident of substantial safety significance that will require additional inspections.

The plant immediately reported the incident to the NRC, Wadley said Monday. Westinghouse Electric Co., which received the shipment, also filed a report.

Investigators determined that a small particle moved during shipping, coming to rest on the steel shipping container’s bottom. That spot exceeded by eight times the 200 millirem radiation limit set by the U.S. Department of Transportation.

The equipment, which workers used during the plant’s Unit 2 refueling outage last fall to test the integrity of fuel rods in preparation for moving them, is always shipped by itself on a flatbed truck.

“It isn’t migrated or commingled with any other shipment,” Wadley said. “The trucker, no workers, no members of the public were affected.”

The plant promptly stopped all shipments so staff could evaluate what went wrong and modify procedures. Limited shipments resumed Feb. 6.

“We think we’ve eliminated the possibility going forwarded,” he said.

The plant ships potentially radioactive items, from oil to equipment, once a month.

Xcel Energy owns the plant. The utility’s officials as well as plant managers are reviewing the NRC’s preliminary yellow determination and will decide if they wish to respond in person or in writing. A final NRC determination is expected within 90 days.

There’s something about a Citizen Advisory Task Force, and that something is that when people are “forced” to sit down and actually read a utility application for significant utility infrastructure, be it nuclear waste storage, transmission line, coal gasification plant or nuclear waste storage once again, they, and WE in the cosmic sense, all learn something. What is usually learned makes the Dept. of Commerce squirm… too bad, these applications are full of unsupported justifications for their infrastructure, projects that will make them money but that are not in the public interest, and “the Department” just takes what they say and works with it, no independent verification, as they’ve testified to over and over and over again. That’s where a Task Force is helpful — a Task Force has a way of recognizing the inconsistencies, factual errors (remember “Lake Pepin was formed by Lock and Damn #3” from the Goodhue Co. Alternate Site application?). Task Forces have a way of coming up with system and site/rout alternatives to meet the need claimed by a utility in ways that they hadn’t brought forth (didn’t discover or don’t want discovered). Task Forces have a way of finding a better way, or two, or three. Task Forces have a way of taking a disparate and diverse group of public officials and NGO representatives and citizens and jelling them into cohesive, informed and thoughtful questioners and advocates.

Here are a couple of significant Task Force Reports for background:

Report of the Site Advisory Task Force: Goodhue County Dry Cask Storage Alternate Site Project (I’m downloading this, zzzzzzzzzzzzzz, very, very, very slow – in the meantime, CLICK HERE FOR LINK)

Expanding Horizons – Chisago I Task Force Report 1997

Expanding Horizons – Appendices – Chisago I

Here are some recent attempts of Task Forces to struggle to evaluate a big project with insufficient time, to wrap their heads around system and site/route alternatives, and with laudable results:

Chisago II Task Force Recommendations – May 2007

(Authored by Task Force. Note there are no Appendices — Commerce jettisoned them, they were not included with the Report!!!)

Mesaba Energy Project – Citizen Advisory Task Force Report

(Authored by staff, where Comments on each aspect of charged were solicited from Task Force and report compiled — report shows resulting lack of cohesiveness). Note AGAIN there are no Appendices — Commerce jettisoned them, they were not included with the Report!!!)

For the Chisago II Task Force, we had to fight Commerce to get it. Notices/invitations were not sent out to all affected communities, there wasn’t enough time for a governmental unit to appoint a representative, they didn’t have enough members and local communities were not represented so they weren’t legally sufficient to be a “Task Force” so it was a “work group… Not enough time… appendices “disappeared.”

For the Mesaba Task Force, we had to file a petition in this one too, Commerce didn’t want it. Meetings were “facilitated” by Commerce staff and provided with incorrect guidance, i.e., told they could not address cumulative impacts, GRRRRRRRRRR. Report prepared by staff with comments by members… not enough time… appendices “disappeared.”

For this most recent one, the Prairie island uprate and dry cask storage, once again Commerce fought against a Task Force, very few were sent solicitations, there was nearly no time to apply, and only three meetings are planned, cut short already by 1/2 hour because the library closes at 8:30, not 9:00.m. Bill Storm, Commerce Staff, has unilaterally decided the “charge” of the Task Force, and despite Commission emphasis on the importance of vetting the application (which I raised at the PUC meeting) and independent review and analysis, there’s no mention of vetting the application; he’s unilaterally decided that public comment is not allowed (there has been time at end of meeting for public comment in past Task Forces); he stated that the PUC Ordered that he is to “preside” over the meeting (OH, PUH-LEEEZE, the PUC did no such thing) and when challenged insisted that was the case (“HAVE YOU SEEN THE ORDER?” Well, I have seen the PUC Order, and it does not state that Storm is to preside over the meeting); he stated that there will be no report (OH? The PUC specifically stated that the Task Force could do a report if it wanted to, and if it does not, how will its work be entered in the record… oh, it won’t be… right, funny how that works and how convenient where the public’s work and issues raised aren’t even part of the proceeding?) Good way to delegitimize and dismiss our efforts… I realize that’s just what he wants, it’s his job to “remove the impediments” and “streamline,” but speaking as an “impediment,” I’ve got my job too.

And the good news, other than it’s such a lovely day that it’s easy to forget the economy is imploding, on my doorstep just now is the FedEx package with the tape of that PUC meeting, so now there’s a transcript to do.

And that Goodhue County Task Force Report is still downloading, like molasses…