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Comment #17 Pacific Gas & Electric Company - Notice of Intent to Prepare an Environmental Impact Statement and Conduct the Scoping Process for Diablo Canyon Nuclear Power Plant, Units 1 and 2
	ML110840123
Person / Time
Site:	Diablo Canyon
Issue date:	01/27/2010
From:	; Mothers for Peace
To:	; Rulemaking, Directives, and Editing Branch
References
	75FR4427 00017
	Download: ML110840123 (36)
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J PO Box 3608 San Luis Obispo, CA 93403-3608 www. mothersforpeace.org NRC public meetings, March 3 in San Luis Obispo, are an opportunity for the public to state environmental concerns about the proposed 20 year license renewal for Diablo Canyon Nuclear Power Plant.

BACKGROUND:

As part of the license renewal process, this "Scoping" meeting will focus on environmental issues that the public wants the NRC to consider when reviewing PG&E's license renewal application.

" The current operating licenses are in effect until 2024 for Unit 1 and 2025 for unit 2; PG&E has applied to extend operations until 2044 and 2045.

SCHEDULE:

Embassy Suites Hotel 333 Madonna Road, San Luis Obispo 1 st Meeting:

12:30pm "Open House" to speak informally with NRC Staff 1:30 - 4:30prm NRC Presentation followed by public comments 2 nd Meeting:

6:00pm "Open House", to speak informally with NRC Staff 7:00 - 10:00pm NRC Presentation followed by public comments NRC PLANNED PROCEDURES:

Members of the public who wish to make comments are asked to register within 15 minutes of the start of each meeting. (MFP has received verbal assurances that persons deciding later that they would like to speak will be able to fill out a speaker card and to be called upon in the order of sign-ups.)

NRC rules include a limited number of issues within the 'scope' of the environmental review. These are the items that the NRC calls 'Category 2' which are site-specific.

These include: aging of components, degradation of the marine environment

(entrainment and impingement of fish, thermal effects), severe accident scenarios, new and significant information, air quality, groundwater-use conflicts, archaeological resources, threatened or endangered species...

'Category 1' issues are those the NRC considers generic - meaning common to all plants and thus not reevaluatedin the environmentalimpact statements for license renewal for each site. The issues that concern SLOMFP most are considered generic:

disposal of high level radioactive waste, safety, geology (seismic), security and safeguards, emergency preparedness, need for power, economic feasibility...

However, if you can tie your concern to a Category 2 issue, it might be considered within the scope. Examples:

Seismic concerns (Category 1) + severe accident scenario + new information (Shoreline Fault) (Category 2)

Terrorism + severe accident scenario On-site high-level radioactive waste storage + seismic + severe accident scenario For more information on scoping, refer to... Frequently Asked Questions on License Renewal:

http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/srl850/srl850 faq Ir.pdf PG&E's Environmental Report is recommended reading:

http://www.nrc.gov/reactors/-perating/licensing/renewal/applications-/diablo-canyon/dcpp-er.pdf PG&E's License Renewal Application:

http ://www.nrc.gov/reactors/ol2perating/licensing/renewal/applications/diablo-canyon/dcpp-Irapdf OBJECTIONS OF SAN LUIS OBISPO MOTHERS FOR PEACE TO PG&E'S APPLICATION FOR ANOTHER 20 YEARS OF DIABLO OPERATIONS:

Earthquakes:

The license renewal application is premature since the results of many studies requested by the California Public Utilities Commission (CPUC) and the California Energy Commission (CEC) are not complete. These studies include a 3D study of the new Shoreline Fault (to be completed sometime in 2013),

,economic and environmental costs and benefits of extended operation, plant reliability, available alternatives, and other studies as required by AB 1632.

It is contrary to NRC regulations to license a nuclear facility next to an active, major earthquake fault. However, the NRC "grandfathered" the license for Diablo, accepting PG&E's excuse that it was unaware of the Hosgri Fault, located within 3.5 miles of the plant, when it first invested billions of ratepayer dollars in building

the plant. The NRC is prohibited by its own regulations from taking into account corporate profits rather than public safety, but that is exactly what it did.

The recently discovered Shoreline Fault, less than one mile offshore of the Diablo site, has not been thoroughly studied, and it clearly exacerbates an already precarious situation. The central coast of California is riddled with earthquake faults, including the Hosgri, Shoreline, Pecho, Olson, San Luis Bay, Crowbar, N40W, Los Osos, San Miguelito, Cambria, West Huasna, Oceano, and Widmer Avenue.

The Diablo Canyon facility includes two nuclear reactors and the storage of all the high-level radioactive wastes generated by those reactors since licensing in1984. Most of the spent fuel (which is much more radioactive than the fuel in the reactors) is stored in over-crowded pools. During an earthquake there is the potential of a loss of coolant crucial to preventing uncontrolled fission or a fire, either of which would release radiation into the air.

Radioactive Waste:

California law prohibits new plants until/unless the waste issue is resolved. To allow an existing plant to generate radioactive wastes for an additional 20 years would contradict the intent of this law.

Ross Landsman, NRC inspector for the Midwest region, made the following comments on the Holtec casks of the type being used at Diablo Canyon: "I remain concerned about the safety of the Holtec Dry Casks. The NRC should stop the production of the casks, but they do not have the chutzpah to do it. This is the kind of thinking that causes space shuttles to hit the ground."

Safety :

" Recent NRC inspection reports on Diablo (August, 2009) indicate that PG&E is not meeting industry standards in its identification and resolutions of problems at Diablo. One recent example is that in October, 2009, it was discovered that for 18 months the Diablo Canyon plant had operated with defective control of some of the valves relied upon to flood the Unit 2 reactor with essential cooling water in the event of a serious accident or sabotage. An investigation by the Nuclear Regulatory Commission identified three violations of NRC regulations as the cause of the problem.

There are an unacceptable number of human performance problems at Diablo, leading to violations of NRC regulations as well as failures to comply with safety requirements. Extensive re-training has not been effective in reducing the number of incidents.

In the event of a major radiation release, those advised or choosing to evacuate would all have to drive in the direction opposite the wind carrying the radioactive material. Our few available roads are woefully inadequate.

Terrorism:

MFP is currently pursuing a legal challenge in the Ninth Circuit of the U.S. Court of Appeals involving the dry cask storage facility for storing nuclear waste and its vulnerability to terrorist attack, especially from the air. If the court rules in favor of MFP as it did in 2006, the NRC might be ordered to require PG&E to make design changes. [Go to mothersforpeace.org for detailed information.]

The air space over Diablo Canyon Nuclear Power plant is NOT a no fly zone.

Instead of the casks being under berms or concrete and spread out in different locations, they are grouped in clear view from the air or ocean.

The spent fuel pools are not protected by containment structures, making them vulnerable to terrorist attack.

The proliferation of fissile material is a constant concern, as these materials have the potential to be used to make weapons if stolen.

Aging and Degradation:

Diablo was designed in the 1960's. In the ensuing half century, not only have innumerable fixes been deemed necessary to keep the plant running, but replacement parts have become unavailable.

Uranium Supply:

Optimistic projections of the availability of uranium fuel supplies show that resource running out in about 2020'- BEFORE the period at stake in the possible Diablo license extensions. [See December 1, 2009 publication of an article by Brian Wang titled "Uranium Supplies are Likely to be Adequate until 2020,"

available at www.theoildrum.com/]

Cost Concerns:

Diablo is an out-dated and over-priced plant by any measure. By the time Diablo Canyon was licensed in 1984, it had cost PG&E's ratepayers some $5.5 billion -

more than 10 times the original projected cost. Designed in the 1960's, it has needed constant updating and replacement of defective or worn-out parts. The earthquake bracing for Unit 2 was originally installed in mirror image of the plans and was re-done at huge expense. The rate-payer funds that would be required to keep the plant operating an additional two decades would be better spent on alternative technologies that would create additional jobs instead of nuclear waste.

The dry casks will have to be relicensed every 20 years and, eventually, the waste will have to be transferred to another cask. This is very expensive since each cask costs about $1 million.

" The California Public Utilities Commission (CPUC) and the California Energy Commission (CEC) are in the process of determining whether or not continued reliance on nuclear energy is in the best economic interests of the people of California. PG&E's decision to apply for license extensions 14 and1 5 years in advance of the expiration of th' current licenses raises questions regarding PG&E's intentions toward the coming CPUC and CEC conclusions.

PG&E spent $16.8 million on a feasibility study analyzing plant equipment and operation to determine whether to apply for a license extension. The study was paid for by PG&E's ratepayers but, even though PG&E has filed the application, the results of the study have not been published.

A new once-through cooling system, to reduce the unacceptable loss of sea life, is projected to cost $3 billion. Replacement of Diablo Canyon's once-through cooling system, to reduce the unacceptable loss of sea life, is projected to cost

$3 billion.

The costs for relicensing have conservatively been estimated at $85 million.

CONCLUSION:

The history of Diablo Canyon shows that in terms of safety, security, and economics, it is not in the public interest to add an additional 20 years to the operating life of the two reactors at Diablo Canyon. The only advantage would be to the corporate profits of PG&E. PG&E should, instead, apply its considerable resources toward establishing itself as a leader in the development of renewable sources of energy.

Contact persons for questions or feedback on this advisory:

Jane Swanson, (805) 595-2605; ianeslo@kcbx.net Jill ZamEk, (805) 710-1143 after 3 pm on weekdays

Karen Swift, 3698 Clark Valley Rd. Los Osos, Ca, 93402 Public commentary regarding PG&E's Diablo Canyon renewal: 2010-03-03 Thank you NRC staff for hopefully taking into consideration public commentary on the relicensing of PG&E's Diablo Canyon plant application.

I am not affiliated with any organization though as a citizen of San Luis Obispo county, my views may reflect those of a larger group.

In the public commentary session between 1:30- 4:30 PM March 3, 2010 we heard views from those who wish to immediately shut down the Diablo Canyon nuclear plant due to safety concerns, particularly derived from there being not one, but two fault lines in the close vicinity of the plant-one a mere 1800 feet from the plant itself.

We also heard views from others who wished for relicensing with minimum delay.

without further seismic studies to be completed prior to relicensing.

Yet there are two points of concern that reverberate between the conflicting views.

- One is a concern about the economy,

- The second is a concern about climate change and non-fossil fuel based energy All are in favor of economic stability, more jobs, money flowing into the school system, and money flowing into the tax base. This in mind, I would like to look at a few studies regarding renewable energy and job creation:

A study released by Navigant consulting shows that if utility companies in the United States were required to produce 25% of energy from renewable sources, up to 274,000 jobs could be created.

Another study conducted by the University of Massachusetts Political Economy and Research Institute shows that per $ 1 million investment, the following number of jobs would be created in the following sectors:

Solar: 13.72 Biomass: 17.36 Smart grid: 17.36 Wind: 13.3 Coal: 6.86 Oil and gas: 5.18 Nuclear: 4.2 In regards the NRC's want to hear other options for renewable energy, I would like to name the German renewable energy act as an example. This was designed as a means of encouraging cost reductions based on improved energy efficiency. In this. feed in tariffs have been used to generate more competition and more jobs by giving incentives to every company involved in the energy generation business. This is especially to incentivize small and medium sized companies to invest in, andgenerate energy from renewable energy sources. Feed in tariffs decreases the initial market barrier for businesses and reduces the cost of production & consumption over a period of time. In Germany.

individual households can sell their energy to the grid and make money on it.

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Job Creation per $1 Million Investment INDUSTRY, :, i, ., DIRECT INDIRECT ** _iNDUCED 70TAL Reforestation. Land and Watershed Restoration. and Sustainable Forest Manaement 17.55 121.95 9.2 39.7 Crop Agriculture 98B 6.5 8.5 22.8 Liestock~ 8.4 ,.1 8.2 21.7 Gas (heavy and civil construction for pipelines - 501. new and 501{,

repair) 12.05 3.93 5.012 21.888 Mass transit and freight rail constru*tion 13 3.70 '1 5.038 21.738 Reads and bridges: repair 11.1 3.80 5.527 20.317 Conservation (Parks and Land and Water Conservation Fund) 11.45 4.15 4:7 20.3 Water infras'tructure ____9.96 4.3 5.427 19.764 Aviation 0.7 4.30 5.284 19 266 Sdhool buildings 8.65 5.38

-31322 5.233 Building retrofts 7.7 430 4.96 17.36 Roads and bridges. new 8.7 3.,4 4.8:34 14.,474 Solar 5.4 4.40 3 02 13.72 Biomass 7.4 5.0O 4.09 17.36 Smart grid 4.3 4.60 3.&5 1236 Belctricity generation, transmission. distibution 5.32 450u 4.090 14.512 Coal 1.d 34 1.08,.86 Financial Industry 3.22 2.34 1 .888 7-228

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Steve White P.O. Box 630 Cambia, CA 93428 earth works@att.net earthworks@

Prepared for U.S.NRC Environmental scope meeting March 3, 2010 Re: PG&E Application License Renewal DCNPP One of my concerns is the threat of the continued operation of the OTC system at DCNPP with regards to the accumulated death and injury to marine life, specifically the Green Sea Turtle...an endangered species.

Not only because of entrainment and thermal effects but additionally due to underwater noise pollution caused by the massive impeller/pumps used to move the estimated 2.5 billion gallons of sea water each day through the system. Many researchers are becoming concerned including the U.S.

Navy, who witnessed detrimental effects to sea mammals during sonar data transmission experiments. I heard a marine biologist interviewed telling us that in busy shipping lanes, the acoustic effect on sea life who depend on sound extensively, such as whales, would be similar to "running a vacuum cleaner in your house 24/7". I saw no mention of underwater noise pollution due to round the clock operation of OTC impeller/pumps listed in PG&E's Environmental Report.

Another area of concern is a major accident at DCNPP due to catastrophic seismic event such as the greatest California earthquake ever recorded, the Fort Tejon Quake, that occurred on January 9, 1857. The 7.9M quake was centered 48 mile NE of Diablo near Parkfield on the San Andreas Fault. Approximately 400 times more energy was released in that quake than was released during the 6.5M 2003 San Simeon event. U.S.G.S. has tracked an occurrence history of earthquakes of this magnitude in the nearby vicinity at a frequency of 143 to 200 years.

According to the Southern California Earthquake Data Center, this immense quake left an amazing surface rupture scar over 225 miles along the San Andreas fault. As a result of the shaking, the current of the Kern River (125 mi. East of epicenter, approx.) was turned upstream, and water

ran four feet over its banks. The waters of Tulare Lake were thrown upon its shores, stranding fish miles from the original lake bed. The waters of the Mokelumne River (150 miles North of epicenter approx.) were thrown upon its banks, leaving the bed dry in places. The Los Angeles River was reportedly flung out of its bed, too. In Ventura the mission sustained considerable damage. Displacement of 30 feet in the Carrizo Plain area.

Elsewhere I read an account by otter hunters offshore the Santa Cruz Island south of Santa Barbara, reporting extensive sections of sea cliffs falling into the ocean.

These descriptions of the 7.9M quake along with the knowledge of the two faults in the immediate area, along with all the other concerns surrounding the dirty, dangerous, expensive Diablo Canyon Nuclear Power Plant, are more than enough justification to not only deny license renewal, but also suspend the current license.

I have heard many say that we need PG&E's Diablo Canyon power, that it supplies 8% of California's electric needs (550,000 homes), although aren't the reactors shut down 10% of the time for refueling and maintenance?

And isn't 7% of electric energy lost to resistance in transmission and distribution? And I also hear that San Luis Obispo County acquires so much revenue from PG&E. Yet in PG&E's Environmental Report it is stated the company's contribution to San Luis Obispo County is "SMALL".

When I looked at the county assessor's revenue summary and the SLO County Chamber of Commerce data, PG&E contributed approx. 4% of SLO County $12.1 billion gross product. For comparison, tourism generates $1.1 billion of that amount and employs 16,610 SLO County residents. Diablo employs about 1,200 people or a little over 1% if the 101,000 workers in SLO County. (REC Solar employs 400 people and they do not have to pay for guarding solar panels for 100,000 years.) Yes, recent annual property taxes PG&E paid were close to $22 million of the county's $425 million property tax revenues, yet the tourist generated transient occupancy tax in unincorporated San Luis Obispo County (basically my area.. .Cambria) generated $21.8 million tax revenue. It really does looks like if Diablo Canyon is shut down there would be no significant impact to the local economy and then there is the Bloom Box, asking the question ...is the grid on the way out anyway?

SCEDC I Fgrt Tejon Earthquake (1857) 2112110 10:25 AM sc-thorr. calif Home Southern California Earthquakes Chronological Earthquake Index > before 1900 Fort Tejon Earthquake TIME January 9, 1857 / about 8:20 am PST LOCATION 350 43' N, 1200 19' W about 72 km (45 miles) northeast of San Luis Obispo, about 120 km (75 miles) northwest of Bakersfield, as shown on the map (epicenter location uncertain).

MAGNITUDE Mw 7.9 (approx.)

TYPE OF FAULTING right-lateral strike-slip - ANIMATION FAULT RUPTURED San Andreas fault LENGTH OF SURFACE RUPTURE about 360 km (225 miles)

MAXIMUM SURFACE OFFSET about 9 meters (30 feet)

The Fort Tejon earthquake of 1857 was one of the greatest earthquakes ever recorded in the U.S., and left an amazing surface rupture scar over 350 kilometers in length along the San Andreas fault. Yet, despite the immense scale of this quake, only two people were reported killed by the effects of the shock -- a woman at Reed's Ranch near Fort Tejon was killed by the collapse of an adobe house, and an elderly man fell dead in a plaza in the Los Angeles area (?).

The fact that only two lives were lost was primarily due to the the nature of the quake's setting; California in 1857 was sparsely populated, especially in the regions of strongest shaking, and this fact, along with good fortune, kept the loss of life to a minimum. The effects of the quake were quite dramatic, even frightening. Were the Fort Tejon shock to happen today, the damage would easily run into billions of dollars, and the loss of life would likely be substantial, as the present day communities of Wrightwood, Palmdale, Frazier Park, and Taft (among others) all lie upon or near the 1857 rupture area.

As a result of the shaking, the current of the Kern River was turned upstream, and water ran four feet deep over its banks. The waters of Tulare Lake were thrown upon its shores, stranding fish miles from the original lake bed. The waters of the Mokelumne River were thrown upon its banks, reportedly leaving the bed dry in places. The Los Angeles River was reportedly flung out of its bed, too. Cracks appeared in the ground near San Bernadino and in the San Gabriel Valley. Some of the artesian wells in Santa Clara Valley ceased to flow, and others increased in output. New springs were formed near Santa Barbara and San Fernando. Ridges (moletracks) several meters wide and over a meter high were formed in several places. In Ventura, the mission sustained considerable damage, and part of the church tower collapsed. At Fort Tejon, where shaking was greatest, damage was severe. All around southern and central California, the strong shaking caused by the 1857 shock was reported to have lasted for at least one minute, possibly two or three!

http://www.data.scec.org/chrono-index/forttejo.htmi Page

SCEDC I Fon. TejOn Earthquake (1857) 2/12/10 10:25 AM I The surface rupture caused by the quake was extensive. The San Andreas fault broke the surface continuously for at least 350 km (220 miles), possibly as much as 400 km (250 miles), with an average slip of 4.5 meters (15 feet), and a maximum displacement of about 9 meters (30 feet) (possibly greater) in the Carrizo Plain area. Kerry Sieh (1978) noted that the Elkhorn Thrust, a low-angle thrust fault near the San Andreas, may have slipped simultaneously in the 1857 quake -- an observation that a team of researchers (1996) have recently used to support the idea that future movements along the San Andreas fault zone might produce simultaneous rupture on thrust faults in and near the Los Angeles area, causing a terrible "double earthquake".

The location of the epicenter of the Fort Tejon earthquake is not known. As the name suggests, one idea is to locate it near the area of strongest reported shaking -- Fort Tejon. However, because there is evidence that foreshocks to the 1857 earthquake may have occurred in the Parkfield area, it is located on this map near the northwestern end of the surface rupture, just southeast of Parkfield, near Cholame.

(Note: locating it near Fort Tejon would also have caused interference on the map between this quake's symbol and that of the 1952 Kern County quake. Hence, for both these reasons, the Cholame location was chosen.)

Below is a map of southern California with various place names marked, and the surface traces of major faults drawn in blue-green. The theoretical "Cholame" epicenter of the 1857 earthquake is marked with the large red dot -- Fort Tejon is shown by a white 'xY on black -- and that part of the San Andreas fault which exhibited surface rupture UA during the earthquake is shown in red.

REFERENCES http://www.data.scec.org/chrono index/forttejo.html Page

Thank you for holding these public hearings.

When the Diablo Canyon plant was built, it was known that there are at least four earthquake faults in the area. Then in 2008, an additional fault was discovered one half mile off-shore from the power plant.

After that fault was discovered, in a letter written April 8, 2009, an NRC Project Manager wrote ... "based on the currently available information, the NRC staff concludes that the design and licensing basis evaluations of the DCPP structures, systems, and components are not expected to be adversely affected and the current licensing basis remains valid and supports continued operability of the DCPP site."

I am not reassured by the phrase "based on currently available information". I am concerned about the effect of an earthquake on the reactor and on the storage tanks for the spent fuel.

And, to digress for a moment, it looks to me as though spent but still highly radio-active fuel will always have to be stored at the sites of nuclear power plants. Let's face it -- no one wants to have that stuff in their neighborhood - and for very understandable reasons.

So, the safety of the radio-active spent fuel storage will need to be considered for the next

..well, I don't know how many years. But I know that at the proposed Yucca Mountain site, one of the criteria for the signs informing people of the radioactive danger was that signs had to be something that a future civilization could understand. That would be a civilization that comes so long after us that they don't recognize our words or our symbols. That indicates a very, very long time.

Diablo Canyon's current licenses allow them to operate for the next 15 years. You are now considering whether to renew Diablo Canyon's operating licenses for the 20 year period between 2025 and 2045. Since their current licenses allow them to operate for the next 15 years anyway, it seems to me there is no need to rush.

I request that you postpone consideration of their license renewals until definitive seismic studies, particularly of this new fault, are complete.

Thank you.

Ct ýA 'lU

Nuclear Power: Climate Fix or Folly?

Arnorv B. Lovins, Imran Sheikh, and Alex Markevich April 2008 RM/ Sohlittis article "Forget Nuclear," updated and expanded by ABL 31 Dec 2008 Nuclear power, we're told, is a vibrant industry that's dramatically reviving because it's proven, necessary, competitive, reliable, safe, secure, widely used, increasingly popular, and carboa-free

-a perfect replacement for carbon-spewing coal power. New nuclear plants thus sound vital for climate protection, energy security, and powering a vibrant global economy.

There's a catch, though: the private capital market isn't investing In new nuclear plants, and without finalnCing, capitalist utilities aren't buying. The few purchases, nearly all i Asia, are all made by central planners with a draw on the public purse. In the United States, even new 2005 governnent subsidies approaching or exceedilng new nuclear plants' total cost failed to entice Wall Street to put a penny of its own capital at risk during what were, until autunul 2008, the most buoyant markets and the most nuclear-favorable political and energy-price conditions in history--conditions that have largely reversed since then.

This semi-technical article, sununarizing a detailed and documented technical paper', compares the cost, climate protection potential, reliability, financial risk, market success, deploynient speed, and energy contribution of new nuclear power with those of its low- or nio-carbon coni-petitors. It explains why soaring taxpayer subsidies haven't attracted investors. Capitalists in-stead favor clhinate-protecting competitors with lower cost, construction time, and financial risk.

The nuclear industry claims it has no serious rivals, let alone those competitors-which, how-ever, already outproduce nuclear power worldwide and are growhig enormously faster.

Most remarkably, comparing all options' ability to protect the earth's climate and enhance en-ergy security reveals why nuclear power could never deliver these promised benefits even if it ou'/id find free-market buyers-while its carbon-free rivals, which won more than $90 billion of private investment in 2007 alone', do offer highly effective climate and security solutions, far sooner, with higher confidence.

Uncompetitive Costs The Economist observed in 2001 that "Nuclear- power, once claimed to be too cheap to meter, is now too costly to matter"--cheap to ni but very expensive to build. Since then, it's become severalfold costlier to build, and in a few years, as old fuel contracts expire. it is expected to be-come severalfold costlier to run.3 Its total cost now markedly exceeds that of coal- and gas-fired power plants, let alone the even cheaper decentralized competitors described below.

A.B. Lovins & I. Sheikh. 'The Nuclear Ullusion.' Amhio,, forthcoming, 2009. RMI Publ. #EO8-01. preprinted at

\wW*-rimiore.'im aes!PDFs/iEnerov/EOS-0C I AnibioNuclillusion.xif. to be updated in early 2009 for publication.

2 Justin Winter for Michael Liebreich (New Energy Capital. London). personal conmmiunication. I Dec 2008. updat-ing that firm's earlier figure of S71b for distributed renewable sources of electricity. The $90b is bottomll-up. transac-tion-by-transaction and excludes M&A activity and other double-counting. Reliable estimates of investment in no-carbon (recovered-waste-heat) or relatively low-carbon (fossil-fueled) cogeneration are not available, but total global cogeneration investment in 2007 was probably on the order of S20b or more.

3 Due to prolonged mismanagement of the uranium and enrichment sectors: Nuclear Power .hMinl Fai't-F'imling I

Construction costs worldwide have risen far faster for nuclear than for non-nuclear plants. Tills is not, as counnonly supposed, dug chiefly to h igher metal and cemnent prices: repricig the main materials in a 1970s U.S. plant (an adequate approximation) to March 2008 conunodity prices yields a iowl Bill of Materials cost only -1% of today's overnight capital cost. Rather, the real capital-cost escalation is due largely to the severe atrophy of the globaliinfrastructure for making, building, mnanaging, mid operating reactors. This makes U.S. buyers pay in weakened dollars, since most components miust now be imported. It also lnakes buyers worldwide pay a stiff premi-um for serious shortages and bottlenecks in engineering, procurement, fabrication, and construc-tion: some key components have only one source worldwide. The depth of the rot is revealed by the nidustry's flagship Fiulish project, led by France's top builder: after tiree years' construc-tion, it's at least three years behind schedule and 50% over budget. Ani identical second unit, gra-tuitously bought in 2008 by 85%-state-owned tlectricitd de France to support 91%-state-owned vendor Areva (orderless 1991-2005), was bid -25 % higher than the Finnish plant and without its fixed-price guarantee, and suffered promipt construction shutdowns for lax quality.

The exceptionally rapid escalation of U.S. nuclear capital costs can be seen by comnparing the two evidence-based studies3 '4 with each other and with later industry data (all including financing costs, except for the two "'overnlight" costs, but with diverse financing models--l: cols. 3 rs. 4):

Dale Source Caipilalcost (2007 S/net el. W) Lei'eliZed bitsbar Cost. 2007 $/MVWih 4

7/03 MIT 2.3 77-91 6/07 Keystone3 3.6-4.0 83-111 5/07 S&P '4 8/07 AEP '4 10/07 Moody's 5-6 11/07 Harding 4.3-4.6 -180 3/08 FPL filing -'4.2-6.1 [3.1-4.5 overnight]

3/08 Constellationi [3.5-4.5 overnright]

5/08 Moody's '7.5 150 6/08 Lazard 15.6-7.4 96-123 1 1/08 Duke Power [4.8 overnight]

As the Director of Strategy and Research for the World Nuclear Association candidly put it, "[I]t is completely impossible to produce definitive estimates for new nuclear costs at this tine....

By 2007, as Figure 1 shows below, nuclear was the costliest option among all main competitors, whether using MIT's authoritative but now low 2003 cost assessment, the Keystone Center's mfid-2007 update (pink bar), or later and even higher industry esthiates (pink arrow). 6 For plants ordered hi 2009, formal studies haven't yet caught up with the latest data, but it appears that their (June 2007. Keystone Center.,.vx,,v kev%.oijero/s_1?1)docp - emltsFinalReport

'- NJFF6 12 2007(1) 1p*lf) esthiated new fuiel contracts will rise from the canonical -00.5c/kWh to - 1.2-1.7c for open or -2.1-3.5c for closed fuel cycles.

This is very conservatively used as the basis for all comparisons in this article, but we show some later variants.

S. Kidd. Nui.l. lEg. Indl.. 22 Aug 2008. .- '50690.

6 All monetary values in this article are hi 2007 U.S. dollars. All values are approximate and representative of the respective U.S. technologies in 2007 except as noted. Capital and fuel costs are levelized over the lifespan of the capital investment. Analytic details are in ref. 1. and for the underlying 2005 analysis. in A.B. Lovins. -'Nuclear Power: Economics and Climate-Protection Potential," RMI Publ. #E05-14, 6 Jan 2006.

N-iNuke PwrEcon.odf. sununarized in A.B. Lovins. "'Mighty Mice.~ Nu'l.

Eng. Intl.. pp. 44-48. Dec 2005. ---- 5 ty%*it*d

new electricity would probably cost (at your meter, not at the power plant) around 10-13e/kXWh for coal rather than the 9o shown, about 9-13e/kVh for combined-cycle gas rather than the7 nearly 100 shown, but around 15-21 /kWli for new nuclear rather than the 11-15¢ shown.

However, nuclear's decentralized competitors have suffered far less, or even niegative, cost esca-lation: for example, the average price of electricity sold by new U.S. windfarnsfeil/ slightly in 2007.8 The 4.0¢/k\Vh average windpower price for projects installed in 1999-2007 seenis more representative of a stable forward market, and corresponds to -7.4e/kXVh delivered and firned-just one-half to one-third of new nuclear power's cost on a fully comparable basis.

mon-cenral-.dtalion ComlhpI/lilOrl' Cogeneration and efficiency are "distributed resources," located near where energy is used.

Therefore, they don't incur the capital costs and energy losses of the electric grid, which links large power plants and remote wind farms to customers. 9 Wind farns, like solar cells"°, also re-quire "firming" to steady their variable output, and all types of generators require some backup for when they inevitably break. Figure 1 reflects these costs.

Making electricity from fuiel creates large amnounts of byproduct heat that's normally wasted.

Combined-cycle industrial cogeneration and building-scale cogeneration recover most of that heat and use it to displace the need for separate boilers to heat the industrial process or the build-ing, thus creating die economic "credit" shown mi Figure 1. Cogenerating electricity and some useful heat from currently discarded industrial heat is even cheaper because no additional fuel is needed, so no additional carbon is released-only what the factory was already enmitting."

End-use efficiency, by far the cheapest option, wrings more (and often better) services from each kilowatt-hour by using smnarter teclhologies--substituting brains for dollars and carbon. That's niainily how California has held per-capita electricity use flat for the past 30 years, saving -S100 7 Based. as in Figure 1, on the June 2007 Keystone findings adjusted to Moody's May 2008 capital cost, on the as-suniption that a somewhat stronger dollar inight partly offset escalation. Anecdotal reports suggest that real capital cost escalation remains rapid in Europe and Asia. depending on exchange rates: for example. eight recent Asian plants look to end tip costing -$4/WV. consistent with mnid-2007 U.S. cost estinates.

8 Fronm 4.8 in 2006 to 4.5e/kWh. 0.9c higher than shown in Figure 1. U.S. wind turbines became 9% costlier duringl 2006-07, and may rise another - 107 in 2008. largely because rapid growth bottlenecked sonie key component sup-plies, but capacity factors improved too: e.g.. the average kW of Heartland wind projects installed in 2006 produced 35% more electricity than one installed in 1998-99, due maimily to better-designed turbines. htigher hub heights. and better siting. All windpower data in this paper are from R. Wiser & M. Bolinger. "Annual Report on1 U.S. Wind Power Installation. Cost, and Perfornance Trends: 2007," USDOE/EERE. LBL-43025. May 2008, wwwl .eere.eneroy.oov/winida]idhvdroipdfs/43025.pdlf. All windpower prices are net of some minor Renewable En-ergy Credit trading and of the U.S. Production Tax Credit whose levelized value is I.Oc/kWh. far smaller than sub-sidies to central thermal power plants: D. Koplow, "'Energy Subsidy Links Pages.: Earthtrack (Washington DC).

2005. http:/Hearthtrack.ne iearthtrack, index.ajY)paoe id=177&catid=66.

9 Distributed generators may rely on the power grid for emergency backup power. but such backup capacity. being rarely used, doesn't require a marginal expansion of grid capacity. as does the construction of new centralized power plants. Indeed. hi ordinary operation. diversified distributed generators fiee up grid capacity for other users.

'0 Or an' other plant. Solar power isn't included in Figure 1 because its delivered cost varies greatly by installation type and financing method. As will be shown in Fi2ure 5 below, photovoltaics (PVs) are currently one of the smaller sources of renewable electricity, and solar thermal power generation is even smalUer. However. PVs have probably ulreadxy passed cost crossover with new coal, gas, or nuclear plants, as sunmnarized on p. 6 below.

"A similar credit for displaced boiler fuel can even enable this teclmology to produce electricity at negative net cost. The graph conservatively omnits such credit (which is very site-specific) mid shows a typical positive selling price. The cogeneration results shown are based on actual projects considered representative by a leading developer.

Cost of new delivered electricity A .. .. .

!5 . -. ____

13 i , .'* :CreI: 'ior I-u54d heat 12 -____.._Imi__l,* l LI, ]T -2..--0---.----

............ ~~~~............................................................-I................................. T Io:'

.3; ll..lts~I 11 G*I

. . . ... . . . . . . . .. . . . . .q i. i V

-1I, dr- 77 e Figure 1:An c~ipples-to-tipples comparison of the cost of mnaking and delivering ai neii~irin kWh f

of electrical services in the United States, baised on emnpirical -2007 market costs aind prices.

billion of *investmentto supply electricity, while per-capita real income rose 79% (1975-2005).

Its new houses, for example, 110w use one-fourth the energy they used to. Yet California is fur-ther accelerating all its efficiency efforts, because there's so much still to save. McKinsey has found that efficiency can profitably offset 85% of the normally projected growth in U.S. electric-ity consumption to 2.030.12 Just using all U.S. electricity as productively as the top ten states now do (in terms of Gross State Product per k~Vh consumed, roughly adjusted for economic imix and 3

climate) would save about 1,200 TWhi/y - -"62% of the output of U.S. coal-fired plants.'1.

Saving electricity costs far less than producing and delivering it. even from existing plants. Cali-forni'a investor-owned utilities' efficiency programs cost an average of 1 v/kWhi in 2004, and 83 Pacific Northwest utilities' cost 1 .30/kWh.1' The national average is about 20, but hundreds of utility programs (mainly for businesses, where most of the cheap savings are) cost less than 1 1 12McKinsey&Conipany, "Reducing U.S. Greenhouse Gas Emissions: How Much at What Cost?." National Acade-niues Summit on Amnerica's Energy Future. Washington DC. 14 Mar 2008.. slide 7.

"Preliminary RMI analysis (K. Wang. La'iugij .m- ý. personal communications, Dec 2008).

'~C. Rogers. M. Messenger. & S. Bender. "Funding and Energy Savings from Investor-Owned Utility Energy Effi-ciency Programs in California for Program Years 2000 Through 2004,- Aug 21005.

wx~ .energ) .0.412- _ k'F\pIdhTom Eckman, 1May 21008 Northwest Power Planning Council memo -Conservation Savinigs -Status Report for 2005-07'

' coII I.... .. 111C. 0,....

I. f. For-- total societal cost,. add -.30-80% depending on the sector.

15E.g., S. Nadel, Lessons Learned. NYSERDA 90-8. ACEEE, 1990. These 1980s results remain valid today because most U.S. utilities have invested so little in efficiency that their opportunities are more like those of the 58 firms 4

A major power engineering firm helped hilvestment fimn Lazard compare observed U.S. prices, finding that efficiency and many renewables cost less than a new central plants (Figure 2):16 Lcvclizcd Cost of Energy Comparison

{. .'l~ ~i

!, tl 'S=.I*'lJ~ * . ' *, '.', 'r *'~ l i, ll t* '] ll ,J ,...i

. l' , ]i*' *J . .. ', tl[. ,,......." .' ,, ,..,l t*

h !, I,

h '

, 1 I F.' I" I t 1 - 1 1 1 fi ' 1

'J." ý IIq $1;4 7" "!o". 124 ALTERNAMt.

ENERGY W I PONVM-MONAL 13" A; 11 T-.% z.\ i? i)

-- __j Figure 2: LU Zal-11's recent comparison shows "lost decentraliZedoptions beating all new central stations: this chart ontils cogeneratioll,overstates wind costs, and understates1111cqeal- costs.

WhY these comparisons understate 1111clearpower's unconipelitiveness These conventional results and assessments greatly understate the size and profitability of to-day's electric-efficiency potential. in 1990, the litil-t- S, think-tank EPRI mid RMI, i i a _oi I I i ie n j int ar-assessed that potential respectively as -.40-60% and -75%, at respective average 2007-$

le, costs of about 3 and I 0/kWh. " Now both those estimates look conservative, for two reasons:

whose 237 programs through 1988 yielded median program costs of 0.30k-Wh for mdustrial savings, 0.9c for motor rebates, 1.2o for loans, and 1.4 for new construction rebates.

16 Lazard (Ne%%.- York), '-Levehzed Cost of Energy Analysis,

v. 2.0 _- June 2008.

w.narucilieel ill E.ýý.Cll '011etfh-e&_('Q 17 A. Fickett. C. Geffings, & A.B. Lovins, -'Efficient Use of Electricity," Sci. Amer. 263(3):64-74 (1990). The differ-ence, analyzed by E. Hirst in ORNL/CON-312 (1-001), was nearly all methodological. not substantive (A.B. & L.H.

Lovins, "Least-Cost Climatic Stabilization," Ann. Rei%En. Em,/. 16:433-531 (1991)ý at pp. 8-11): e.g., EPRI excluded but RMI included saved maintenance cost as a credit against efficiency's capital cost, so their respective average costs of commercial lighting retrofits (- 1986 $) were + 1.2 and - l.4g/k-VVh: EPRI examined potential savings only to 2000 5

" As EPRI agrees, efficiency technologies have improved faster than they've been applied, so the potential savings keep getting bigger and cheaper."s

" As RMI's work with many leading finls has demonstrated, integrative design can often aclhieve radical energy savings at lower cost than small or no savings.19 That is, efficiency can often reduce total mivestment "I new buildings and factories, and even in some retro-fits that are coordinated with routine renovations.2 ° Wind, cogeneration, and end-use efficiency already provide electrical services more cheaply than central thernal power plants, whether nuclear or fossil-ftielled. This cost gap iwill oilyv widen, since central thernal power plants are largely mature and getting costlier, while their competitors continue to improve rapidly. Indeed, a good case can be made that photovoltaics (PVs) can a!-

ready beat new thermal power plants: if you start in 2010 to build a new 500-MW coal-fired power plant in New Jersey, plus an adjacent photovoltaic (PV) power plant, then before the coal plamt comes online in 2018, the solar plant will produce a slightly larger amount of amnual elec-tricity at lower levelized cost, but with 1.5x more onpeak output, and the PV manufacturing ca-pacity used to build your plant cma then add 750 more MW each year.- Of course, the high costs of conventional fossil-fuelled plants would go even lhigher if their large carbon enmissions had to be captured-but thlis coal/solar comparison assumes a carbon price of zero.

The foregoing cost comparison is also conservative for four important additiontal reasons:

End-use efficiency often has side-benefits worth 1- 2 orders of magnitude (factors of ten)

(including 9-15% expected to occur spontaneously) wlhile RMI counted the hill long-tern retrofit potential: and EPRI assumed drivepower savings 3x smaller and 5x costlier than EPRI adopted elsewhere in the same Sci. Anter.

article. RMI's assessment summarized a 6-volune 1986-92 analysis of -1.000 teclhologies" measured cost and performance (RMIICOMPETITEK. I/ .c State !fthc .lrt series. 2,509 pp.. 5.135 sourcenotes, later sununarized in the ici/hnoh),g Atlas series now maintained by spinoff firn E SOURCE. wwn.esource.com).

's RMI estimated that during 1984-89, U.S. efficiency potential roughly doubled while its real cost fell by threefold.

Since 1990, mass production (often in Asia). cheaper electronics. competition. and better technology, according to James K. Rogers PE. cut the real cost of electronic T8 ballasts by >90% to 2003 (whlile lumens per watt rose 30%).

turned direct/indirect luminaires fromn a premium to the cheapest option, and cut the real cost of industrial variable-speed drives by 97% (some vendors of midsize motors now give them away). Compact fluorescent lamps be-came 85-94% cheaper during 1983-2003: window air-conditioners got 69% cheaper since 1993 while becoming 13%7cmore efficient: and low-emnissivity window coatings became -84% cheaper in just five years.

19Integrative design produces these expanding (not diminishing) returns to efficiency hilvestments: A.B. Lovins,

"'Energy End-Use Efficiency." 2005. wwxv s Euerov/E95-28 Stm.EffBldgFrontierA1_df, firther yI.i.iruii.o/iii,_/2res,PDFa elucidated in the senior author's five public lectures. -Advanced Energy Efficiency." delivered at Stanford's School of Engineering in March 2007 and posted at ywwrmi.org/stanford. RMI's recent redesigns of over $30 billion worth of industrial projects consistently found 60% energy savh2gs on retrofit, typically paying back in 2-3 years. and 90% savings in new projects. nearly always with lhwer capital cost.

20 For example, an RMI design for retrofitting a 200.000-ft' curtainwall office building when it needed reglazing anyhow could save three-fourths of its energy at slightly hlwer cost than the nornial 20-year renovation that saves nothing: A.B. Lovins, "'The Super-Efficient Passive Building Frontier,' ASItRAI-.I.. pp. 79-81. June 1995.

.....~ .-...- -- iirorE~-S SuperlEffBldo2Fronitiei-1ýf 21This is simply because PVs can ride down the cost curve (they'll clearly continue to get 18% cheaper for each doubling of cumulative global production volume, which is nearly doubling every year). they produce the most out-put on summer afternoons when most utilities' loads peak. and they can start producing energy and revenue in year one, reducing their financial risk. Many technological and institutional breakthroughs are in view that could well make PVs' costs drop even faster than their historic cost curve. Thomas Dinwoodie. SunPower Corporation. Sys-tems (Founder and CTO), Richnmond CA. "Price Cross-Over of Photovoltaics vs. Traditional Generation,_- 2008.

6

more than the saved energy.-

End-use efficiency and distributed generators have 207 "distributed benefits" that typi-cally increase their economic value by an order of magnitude. 3 The only "distributed benefit" counted above is reusing waste heat in cogeneration.

Integrating variable renewables with each other typically saves over half their capacity for a given reliability-"-; indeed, diversified variable renewables, forecasted and integrat-ed, typically need less backup hilvestment than big thermal plants for a given reliability.

" Integrating strong efficiency with renewables typically makes both of them cheaper and more effective.'

New nuclear power's uncomnpetitiveness is clear without these five conservatisms and over-whelming with them. As we'll see, the marketplace concurs-and that's good news for climate.

Uncompetitive CO, Displacement Nuclear plant operations enmit no carbon directly and rather little indirectly-6 . Nuclear power is therefore touted as the key replacement for coal-fired power plants. But this seeminlgly straight-forward substitution could instead be done using non-nuclear technologies that are cheaper and faster, so they yield more climate solution per dollar and per year.

-- E.g.. -'6-16%higher labor productivity in efficient buildings. higher throughput and quality in efficient factories.

better clinical outcomes in efficient hospitals. fresher food in efficient refrigerators, better visibility with efficient lighting. etc. Just counting such side-benefits can. for examnple, double the efficiency gains in a U.S. steel mnill at the samle cost.

23 The biggest of these come from financial economics: e.g., small fast modular projects have lower financial risk than big slow lunpy projects. and renewables hedge against fuel-price volatility risk. These 207 phenomena are ex-plained and documented in all Ecuounmi..i book of the year: A.B. Lovins, E.K. Datta. T. Feiler. KR. RAbago, J.N.

Swisher, A. Lehmann. & K. Wicker, Smnai Is Pru/itltl/e:Di/e Hidden baa'*mt tic Belefh s 0/ Making /e'lericalRe-

.unr'A.N tihe Rig/la Size. 2002. Rocky Mountain Institute (Snowmnass CO). www .smallisprofitable.org.

_4 For windpower in the three power pools that span the central U.S. friom Canada to Texas: J. Traube. L. Hansen. B.

Pamlintier, & J. Levine, "'Spatial Interactions of Wind and Solar in the Next Generation Utility." Windpower 2008, 3 Jun 2008 (to be posted shortly at ert.rnpi.org).

2s E.g.. an integrated retrofit of efficiency, demand response, and 1.18 MW of PVs at the Santa Rita Jail in Alameda County CA easily met a 10%/y IRR hurdle rate--the $9-nfillion project achieved a present-valued 25-year benefit of

$15 nmillion and hence would have made money even without its S4-niillion state subsidies -because on the hot af-ternoons when the PVs produced the most power, the efficient jail used little, leaving a bigger surplus to resell to the grid at the best price. Or my own household can run on - 120 average W (a tenth the U.S. norm). obtainable from 3 m-1of PVs--a systemn cheaper than connecting to wires 30 mi away. If built today, my household would need only

-40 average W. from I m-2 of PVs--a system cheaper than connecting to wires already on the side of the house.

Both these comparisons assume free electricity: their point is that superefficient end-use can make the breakeven distance to the grid. beyond which it's cheaper to go solar than to connect. drop to about zero.

26 We ignore here the modest and broadly comparable amounts of energy needed to build any kind of electric gen-erator, as well as possible long-run energy use for nuclear deconfnissioning and waste management or for extracting uranium friom low-grade sources and restoring ironed land afterwards. B.K. Sovacool, 1En. Pol. 36:2490-2953 (Aug 2008) surveyed these issues. He screened 103 published studies of nuclear power's energy inputs and indirect car-bon emnissions: excluded the 84 studies that were older than 10 years, not in English. or not transparent; and found that the other 19 derived gCOze/busbar kWh figures ranging from 1.4 to 288 with a inean of 66. which is roughly one-seventh the carbon intensity of combined-cycle gas but twice that of photovoltaics or seven times that of mod-em onshore windpower. This comparison, or its less favorable dynamic equivalent described by A.B. Lovins mid J.

Price in 1977 (Nn-Nwllear I"tunre., Ballinger. Cambridge MA, Part H1). is however scarcely relevant, since the unarguable etwn',mi" m'pl,'mniiix rot shown iii this section is far more important and clear-cut.

7

As Figure 27 shows, various options emit widely differing quantities of CO2 per delivered kilo-watt-hour: 2 Figure 2: Operating C02 emitted per delivered kWh 0.9 0.8 Re.covere-d heat: credit 0.7 0.6 _

0. 0.5 0

V 2TM0.4 0.3 0.2 0.1

<0. 01 0 00 N*kIuCa"

ýtant Ccal il1n[ Large com irned- La,*e mrd farm C* bmed-cv..e Lbuddng-cale kecoviec -Peat Lnc-ttse _ff en,:.y

,rlrI q.,. plar

.'ta.r.s rl. rlrl0~f Coal is by far the most carbon-intensive source of electricity, so displacing it is tie yardstick of carbon displacement's effectiveness. A kilowatt-hour of nuclear power does displace nearly all the 0.9-plus kilograms of CO, emitted by producing a kilowatt-hour from coal. But so does a kilowatt-hour from wind, a kilowatt-hour from recovered-heat industrial cogeneration, or a kilo-watt-hour saved by end-use efficiency. And all three of these carbon-free resources cost far less than nuclear power per kilowatt-hour, so they save far more carbon per dollar.

Combined-cycle industrial cogeneration and building-scale cogeneration typically burn natural gas, wlhich does emit carbon (though half as much as coal), so they displace somewhat less net carbon than nuclear power could: around 0.7 kilograms of CO, per kilowatt-houro. Even though cogeneration displaces less carbon than nuclear does per kilowatt-hour, it displaces more carbon than nuclear does per dollar spent on delivered electricity, because it costs far less. With a net delivered cost per kilowatt-hour approximately half of nuclear's (using the most conserva-tive comparison from Figure 1), cogeneration delivers twice as many kilowatt-hours per dollar, and therefore displaces around 1.4 kilograms of CO, for the same cost as displacing 0.9 kilo-gramns of CO, with nuclear power.

Figure 3 compares different electricity options' cost-effectiveness in reducing CO2 enuissions, counting both their cost-effectiveness (kilowatt-hours per dollar), and any carbon emissions:

2 Conservatively assuming industry claims that nuclear power indirectly emits about one-seventh as much carbon as the mean of the 19 studies analyzed by Sovocool's literature review (ref. 26). and similarly omitting the probably even smaller carbon footprint of renewables. recovered-heat cogeneration. and efficiency.

28 Since its recovered heat displaces boiler fuel, cogeneration displaces more carbon emissions per kilowatt-hour than a large gas-fired power plant does.

Coal-fired C0 2 emissions displaced per dollar spent on electrical services 1c.: 9" kq C02/'$ *..

'C 4 7 k9 I 2,'

Cai borp -la -ret aL valioC , efficiency cwA-, kV ,, .

30

,25 0

'U '4C 0 20 j 0,

LU

-- I o".

0 "

15 LN/

Nuclear plant Coal plant Large combined- Large wind farm Combined-cycle Buildmg-scale Recovered-heat End-use efficiency cycle gas plant industrial cogen cogen industial cogen Figure 3: Hoiw much net carbon emissionws/iom coal-firedloitcrpinmts can be displaced by buying a dollar's irorlh ofuneir electrical services using difklerem technologies. Note I/l realislic e.Ijiciency im'.esmnewls' carbon savings arefar above i/e upper-right corner (/I/ihe chart.

Nuclear power, being the costliest option, thus delivers less electrical service per dollar than its rivals. So not surprisingly, it's also a climate-protection loser, surpassing in carbon emissions displaced per dollar only centralized, non-cogenerating combined-cycle power plants burnilg natural gas 29. Firmed windpower and cogeneration are at least 1.5 times more cost-effective than nuclear at displacing CO,-or about 3 times using the latest nuclear cost estimates. So is effi-ciency at even an alnost unheard-of seven cents per kwVh. Efficiency at normally observed costs, say around one cent per kwh, beats nuclear by about 10-20-fold.

New nuclear power is so costly that shifting a dollar of spending from nuclear to efficiency pro-tects the climate severalfold more than shlifting a dollar of spending friom coal to nuclear. Indeed, under plausible assumptions, spending a dollar on new nuclear power insiead of on efficient use of electricity has a worse climate effect than spending that dollar on new coal power!

If we're serious about addressing climate change, we must invest resources wisely to expand and accelerate climate protection. Because nuclear power is costly mad slow to build, buying niore of it rather than of its cheaper, swifter rivals will instead reduce and retard climate protection.

9 However. at long-ni natural-gas prices lower than assumed here (a levelized 2007-S cost of $7.72 per million BTU) and at today's high nuclear costs. tie conbinled-cycle plants may save more carbon per dollar than nuclear plants do. This may be trne even at the prices assumed here. if one properly counts combined-cycle plants' ability to load-follow, thtus complementing and enabling cleaner, cheaper variable renewable resources like windpower.

9

Questionable Reliability A/l sources of electricity sometimes fail, differimg only in how predictably, why, how often, how much, and for how long. Even the most reliable giant power plants are intermittent: they fail un-expectedly in billion-watt chunks, often for long periods. Of all 132 U.S. nuclear plants built (52% of the 253 originally ordered), 21% were permanently and prematurely closed due to reli-ability or cost problems, wlhile another 27% have completely failed for a year or more at least once. The survivilg U.S. nuclear plants produce --90% of their full-time full-load potential, but even they are not fully dependable. Even reliably operathig nuclear plants must shut down, on average, for 39 days every 17 months for refuieling and maintenance, and unexpected faihues do occur too. To cope with such hilternmittence by both nuclear and centralized fossil-fuelled power plants, which typically fail about 8% of the time, utilities must install a roughly 15% "reserve margin" of extra capacity, some of which must be contnmuously fulelled, spinning ready for in-stant use. Heavily nuclear-dependent regions are particularly at risk because drought, a serious safety problem, or a terrorist incident could close many plants simultaneously.

Nuclear plants have an additional disadvantage: for safety, they must instantly shut down in a power failure, but for nuclear-physics reasons, they can't then be quickly restarted. Durmg the August 2003 Northeast blackout, mine perfectly operating U.S. nuclear units had to shut down.

Twelve days of painfully slow restart later, their average capacity loss had exceeded 50 percent.

For the first three days, just when they were most needed, their output was below 3% of normal.

The big transmission lines that highly concentrated nuclear plants require are also vulnerable to lightining, ice storms, rifle bullets, cyberattacks, and other hnternuptions.3 The bigger our power plants and power lines get, the more frequent and widespread regional blackouts will become.

Because 98-99 percent of power failures start ill the grid, it's more reliable to bypass the grid by slhifting to efficiently used, diverse, dispersed resources sited at or near the customer.

A portfolio of many smaller ulnits, too, is unlikely to fail all at once: its diversity makes it more reliable even if its individual units are not.' The same logic applies to the two renewable elec-tricity sources - windpower and photovoltaics - whose output varies with weather or daytune.

Of course the sun doesn't always slhine on a given solar panel, nor does the wind always spin a given turbine. Yet if properly finned, both windpower, whose global potential is 35 times world electricity use 32, and solar energy, as much of wlhich falls on the earth's surface every -.70 mimi-utes as humankind uses each year, cal deliver reliable power without significant cost for backup or storage." These variable renewable resources become collecivm'ely reliable when diversified in type and location and when integrated with three types of resources: steady renewables (geo-thermal, small hydro, biomass, etc.), existing fuelled plants, and customer demand response.

" A.B. & L.H. Lovins. report to DoD republished as Britrjh PNicer: kI-erg.\ Strale,gyj'or Nafi nal Securit . Brick House (Andover MA). 1981, posted with sunnnaries #S83-08 and #S84-23 at wwwrImi.or2/sitepaoes/!id114.1_hp:

Defense Science Board. ,,0re F"ight. Les%Fidl. 13 Feb 2008. . .O.:ESTF pf 31These arguments are elaborated and documented in ref. 23.

3-C.L. Archer and M.Z. Jacobson. "Evaluation of global windpower." calculated at 80 mihub height.

w-_w-.tanfor_:edu2rot_~u,~ff~inh/_y l'global winds.hmfl.

3* Wiser & Bolinger. ref. 8. p. 27. document II recent U.S. utility studies showing that even variable-renewable penetrations up to 31%, generally cost <0.Sc/kWh to "firni' to central-plant reliabihty standards. The two studies that found costs up to 0.8c didn't assume the sub-hourly market-clearing that most grid operators now use.

Such integration uses weather forecasting to predict the output of variable renewable resources, just as utilities now forecast demand patterns and hydropower output. In general, keeping power supplies reliable despite large wind and solar fractions will require less backup or storage capac-ity than utilities havie alread' boutght to manage big thermal stations' intermittence. The myth of renewable energy's unreliability has been debunked both by theory and by practical experience ."

Large Subsidies to Offset High Financial Risk The latest U.S. nuclear plant proposed is estimated to cost $12-24 billion (for 2.2-3.0 billion watts), mlany tines industry's claims, and off the chart in Figure 1 above. The utility's owner, a large holding company active in 27 states, has annual revenues of only $15 billion. Even before the current financial crisis, such high, and highly uncertain, capital costs made financing prolhibi-tively expensive for free-market nuclear plants in the half of the U.S. that has restructured its electricity system, and prone to politically challenging rate shock in tie rest: a new nuclear kilo-watt-hour costing, say, 18 cents "levelized" over decades implies that the utility must collect -30 cents to fund its first year of operation.

Lacking investors, nuclear promoters have turned back to taxpayers, who already bear most nu-clear accident risks, have no meanfingful say i licensing, and for decades have subsidized exist-ing nuclear plants by 5¢/kWh. In 1005, desperate for orders, the politically potent nuclear industry got those U.S. subsidies raised to --5-9¢/kWh for new plants, or -.60-90 percent of their entire projected power cost, including new taxpayer-funded insurance against legal or regulatory delays. Wall Street still demurred. In 2007, the industry won relaxed goverunent rules that made its 100 percent loan guarantees (for 80%-debt financing) even more valuable--worth, one util-ity's data revealed, about $13 billion for a single new plant, about equal to its entire capital cost.

But rising costs had meanwhile made the $4 billion of new 2005 loan guarantees scarcely suffi-cient for a single reactor, so Congress raised taxpayers' guarantees to $18.5 billion. Congress will soon be asked for another $30+ billion Bi loan guarantees, or even for a blank check. Mean-while, the nonpartisan Congressional Budget Office has concluded that defaults are likely.

Wall Street is ever more skeptical that nuclear power is as robustly competitive as claimed. Start-ing with Warren Buffet, who recently abandoned a nuclear project because ".itdoes not make economic sense," the smart money is heading for the exits. The Nuclear Energy Institute is there-fore trying to damnp down the rosy expectations it created. It now says U.S. nuclear orders will come not in a tidal wave but in two little ripples-a mere 5-8 units coming online In 2015-16, then more if those are on tnie and within budget. Even that sounds dubious, as many sernor en-ergy-industry figures privately agree. In today's capital market, governments can have at most about as many nuclear plants as they can force taxpayers to buy. Indeed, the big financial houses that lobbied to be the vehicles of those gigantic federal loan guarantees are now largely gone; a new Admfinistration with many other priorities may be less supportive of such largesse; and the 34The nuclear industry's claim that because a modern economy needs highly reliable electricity, it also needs "'24/7" power .%tations of billion-watt scale is absurd. No power source is 100% reliable: that's why utilities must use redun-dancy and elaborate operating techniques to ensure reliable supply despite unpredictable failures, which are espe-cially damaging when the failed units are large. The same proven techniques apply similarly, but more easily. to large numbers of diverse renewables whose variable elements can be readily forecast. Without exception, more than 200 international and 11 U.S. studies have found this (see ref. 1, pp. 22-27). Wind-rich regions of Germany, Spain.

and Demnark have already proven it by meeting 20-39% of all annual electrical needs (and at times over 100% of regional needs) with variable renewables, without encountering instability nor significant integration costs.

II

"'significant" equity investment required to qualify for the loan guarantees seems even less likely to come from the same investors who declhied to put their own capital at risk at the height of the capital bubble. The financial crisis has virtually eliminated private hivestment in big, slow, risky projects, while not materially decreasing hivestmuent hi the small, fast, granular ones that were already walloping central plants in the global marketplace.

The Micropower Revolution Wlhile nuclear power struggles in vain to attract private capital, hilvestors have switched-and the financial crisis has accelerated their slhift 35-to cheaper, faster, less risky alternatives that The Economiisi calls "micropower" -distributed tu-rbies and generators in factories or buildings (usually cogenerating useful heat), and all renewable sources of electricity except big hydro damns (those over ten megawatts). These alternatives surpassed nuclear's global capacity in 2002 mid its electric output in 2006. Nuclear power now accounts for about 2 percent of worldwide electric capacity additions, ivs. 28 percent for imicropower (2004-07 average) and probably a good deal more in 2007-0836 Despite subsidies generally smaller than nuclear's, and many barriers to fair market entry and competition37, negawatts (electricity saved by using it more efficiently or timely) and nficro-power have lately turned in a stunning global market performance. Figure 5 shows how iucro-power's actual and industry-projected electricity production is runnilg away from nuclear's, not even counting the roughly comparable additional growth in negawatts, nor any fossil-fuielled generators under 1 megawatt.

The nuclear industry nonetheless claims its onfly serious competitors are big coal and gas plants.

But the marketplace has already abandoned that outmoded battleground for two others: central thermal plants v's. micropower, and megawatts 's. negawatts. For example, the U.S. added more windpower capacity in 2007 than it added coal-fired capacity in the past five years combined. By beating all central thernal plants, micropower and negawatts together provide about half the world's new electrical services. Micropower alone now provides a sixth of the world's electric-ity. and from a sixth to more than half of all electricity in twelve industrial countries, though the U.S. lags with -6%.

In this broader competitive landscape, high carbon prices or taxes can't save nuclear power from its fate. If nuclear did compete only with coal, then far-above-market carbon prices inight save it; but coal isn't the competitor to beat. Higher carbon prices will advantage all other zero-carbon resources - renewables, recovered-heat cogeneration, and negawatts -as much as nuclear, mid will partly advantage fossil-fueled but low-carbon cogeneration as well. The nuclear idustry doesn't understand this because it doesn't consider these competitors important or legitimate.

35New Energy Finance found only a 4% drop in 3Q08 renewables financing. and recent data suggest a robust, even growing. solar sector despite grave financial distress and accelerating decline in the central-station business.

36 A thorough database of industry and official data sources is posted and updated at wwwrmiu.or.isitepaIes/lid256.php#E5-04. Sinmilar renewable energy data are at ww.ren21 .net.

37 A policy agenda for removing many of these obstacles is in the last section of Small IA Pro/itabh' (ref. 31).

s Data for decentralized gas turbines and diesel generators exclude generators of less than I megawatt capacity.

Low- or no-carbon worldwide electrical output (except large hydro) 4500 4000

-. ~ l~ze"*d ae n e ra tio n 3500, 3000. Nuclear 2500 -

. 2000

I.-

1500 Geother mai 1000 Photovoltaics 500 .. *. I "y' .W

, }

Wind 0

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 Year Figr'e5. Globalb lecricilv produced. or l)ojecled bY il(u.hirY to be produced, by decentralized lowt- or no-carbon ,iI(o'it(,es-(-yogen'er-('ijO/it ("'CHP"), mosll" iga.%-lired, and "distributed- re-newahles (lhose olher Ihan b~i I.whdroelectric dehin.t. Micropower got oier $100 billion o/nel privale capital in 2007-roughlY an eighlh q'flola! global energy it'eslmenl.

Small Is Fast, Low-Risk, and High in Total Potential Small, quickly built units are faster to deploy for a given total effect than a few big, slowly built units. Widely accessible choices that sell like cellphones and PCs can add up to more, sooner, than ponderous plants that get built like cathedrals. And smnall units are much easier to match to the many smuall pieces of electrical demand. Even a inulti-megawatt wind turbine can be built so quickly that the U.S. will probably have a hundred billion watts of them (matching its nuclear capacity) installed before it gets its first one billion watts of new nuclear capacity, if any. As noted earlier, this speed reduces financial risk and thus makes decentralized, short-lead-time pro-jects more financeable, especially in hard tines.

Despite their small individual size, and partly because of it, nuicropower generators and electrical savings are already adding up to huge totals. Indeed, over decades, negawatts and imicropower can shoulder the entire burden of powening the economy. The Electric Power Research Institute (EPRI), the utilities' thlink-tank, has calculated the U.S. negawatt potential (cheaper than just running an existing nuclear plant and delivering its output) to be two to tluee tines nuclear power's 19 percent share of the U.S. electricity market; RMI's more detailed analysis found even

more. Cogeneration ill factories call make as much U.S. electricity as nuclear does39 , plus more ill buildings, which use 69 percent of U.S. electricity. Windpower at acceptable U.S. sites can cost-effectively produce several times the nation's total electricity use'°, and other renewables cal make even more without siginficant land-use, variability, or other constraints. Thus just cogen-eration, windpower, and efficient use- all profitable today--can displace nuclear's current U.S.

output 14' times over. This ratio becomes arbitrarily large when photovoltaics are included.

Nuclear power, with its decade-long project cycles, difficult siting, and (above all) unattractive-ness to private capital, simply cannot compete. In 2006, for example, it added less global capac-ity than photovoltaics did, or a tenth as much as windpower added, or 30-41 tines less than mi-cropower added. Renewables other than big hydro damns won $56 billion of private risk capital; nuclear, as usual, got zero. Clhina's distributed renewable capacity reached seven times its nu-clear capacity and grew seven times faster. And in 2007, Clhina, Spain, and the U.S. each added more windpower capacity than the world added nuclear capacity. The nuclear industry does trumpet its growth, yet micropower is already bigger and is growing 18 times faster."

Security Risks President Bush has nightly identified the spread of nuclear weapons as the gravest threat to America. Yet that proliferation is largely driven and greatly facilitated by nuclear power's flow of materials, equipment, skills, and knowledge, all wrapped in an hinuocent-looking civilian dis-guise. (Reprocessing nuclear fuiel, which President Bush tried to revive, greatly complicates waste management, increases cost, and boosts proliferation.) Yet acknowledging nuclear power's market failure and moving on to secure, least-cost energy options for global development would unmask and penalize proliferators by making bomb ingredients harder to get, more conspicuous to try to get, and politically costlier to be caught trying to get. This would make proliferation far more difficult, and easier to detect in time by focusing scarce intelligence resources on needles, not haystacks." The new Adlfimiistration has an extraordinary opportunity to turn the world away from its rush toward a "nuclear-armed crowd" by setting a good example in domestic energy pol-icy and by helping all developing countries with the nonviolent, cheaper, faster energy alterna-tives that are already wimufing in the market."3 Nuclear power has other unique challenges too, such as long-lived radioactive wastes, potential for catastroplhic accidents, and vulnerability to terrorist attacks. But 'i a market economy, the teclmology couldn't. proceed even if it lacked those issues, so we needn't consider them here.

39 0. Bailey and E. Worrell, "Clean Energy Teclhologies: A Preliminary Inventory of the Potential for Electricity Generation." LBNL-57451. Apr 2005, ii.r!p:!r:r.po ýiccnes.cdiii buiiLBNL-57"45i_.

.t U.S. Department of Energy. 201; Winl lEnergy hw 2030. www.20percetwi nd.org/20p.aspxpaoe=Repoli. Ch. 2.

p. 2 .

41 All documented in ref. 1.

4- A.B. and L.H. Lovins and L. Ross, "Nuclear power and nuclear bombs." Foreign,1 i.4tirs 58(5):1137-1177 (Sum-mer 1980). ww.fokeionaffairs.cr o19_lO_1 .*esS _.-

power-aI-iniclear-bombs~htm1 or www.nri.or2oiiulneslother/Eierov/E05-0S NiikePwrEco'u.j-f. and loucigii

,Iffiiir. 59:172 (1980). Had that paper's market-driven strategy been adopted 28 years ago. the world would not to-day be worrying about Iran and North Korea.

13 This would satisfy the intent of the "'nuclear bargain" in Article IV of the Non-Proliferation Treaty. See also CA.

Ford (Hudson Institute). "Nuclear Technology Rights and Benefits: Risk. Cost. and Beneficial Use under the NPT's Article IV." Conference on "Comparing Electricity Costs." NPEC/Canegie Corporation of New York. 1 Dec 2008.

14

Conclusion So why do otherwise well-ifforned people still consider nuclear power a key element of a sound climate strategy? Not because that belief can withstand analytic scrutiny. Rather, it seems, be-cause of a superficially attractive story, an i enunsely powerful and effective lobby, a new gen-eration who forgot or never knew why nuclear power failed previously (ahnost notlhing has changed), sympathetic leaders of nearly all main governuents simultaneously, deeply rooted habits and rules that favor giant power plants over distributed solutions and enlarged supply over efficient use, the market winners' absence from many official databases (which often count only big plants owned by utilities), and lazy reporting by an unduly credulous press.

Isn't it time we forgot about nuclear power? Informed capitalists have. Politicians and pundits should too. After more than half a century of devoted effort and a half-trillion dollars of public subsidies, nuclear power still can't mnake its way in die market. If we accept that unequivocal verdict, we can at last get on with the best buys first: proven and ample ways to save more car-boln per dollar, faster, more surely, more securely, and with wider consensus. As often before, the biggest key to a sound climate and security strategy is to take market econionics seriously.

Copyright C.2009 Rocky Mountain histitute. To be posted at wvv.'w.rmi.oi. Publications. Librar'y. Energy. Nuclear Energy.

Mr. Lovins. a physicist, is cofounder. Chairman. and Chief Scientist of Rocky Mountain Institute (v,'ww.i.oorg).

where Mr. Sheikh. an engineer, was a Research Analyst (now a graduate student in the Energy and Resources Group at the Universit" of California at Berkeley). and Dr. Markevich. a physicist and nianagenment consultant. was a Vice President until mid-2008. Mr. Lovins, a student of this subject for over four decades, has consulted for scores of electric utilities, many of them nuclear operators. Published in 29 books and hundreds of papers, his wide-ranging inmovations in energy, security, enviromnent. and development have been recognized by the Blue Planet. Volvo.

Onassis, Nissan, Shingo, and Mitchell Prizes. a MacArthur Fellowship. the Benjamin Franklin and Happold Medals.

ten honorary doctorates, an Hon. AIA and FRSA. Foreign Membership of the Royal Swedish Academy of Engineer-ing Sciences. and the Heinz, Lindbergh, Right Livelihood, and World Technology Awards. He advises governments and major firms worldwide on advanced energy and resource efficiency and its integration with energy supply. and recently led the tecluhical redesign of more than $30 billion worth of facilities in 29 sectors to achieve very large energy savings at typically lower capital cost.

The authors are grateful to RMI Senior Fellow Dr. Joel Swisher PE for insightful connments and to many cited and uncited sources for research help. A technical paper (ww.-mi.or2!sitepagesipid257 .php1EOS-01) preprinted for Amhio (Royal Swedish Academy of Sciences) supports this sunmmary with full details and documentation (ref. 1).

and will be updated for press in early 2009. RMI's annual compilation of global mficropower data from industrial and governmental sources is periodically updated at www rni.or2,iopesil256.1hp#EOS-04.

I5

To:- NRC Scoping Meeting Committee, SLO 3 rd Mar '10 From :- W.H. Wadman PhD 805-782 0766 232 Broad St whuwad@gmail.com SLO CA 93405 Re :- Long term safety of spent nuclear fuel I am concerned that as the protective shield of rapidly decaying fission products diminishes the potential for attempts to divert the transuranics for antisocial or terrorist uses will increase since the deterrent radiation shield diminishes by a factor of ten every hundred years. The plutonium content remains essentially undiminished and mature 'Purex' type technologies might become more easily implemented to isolate bulk plutonium. I am aware that the plutonium from current reactors falls well below preferred weapons grade by virtue of too low a ratio of the 239/240 isotopes. However even this spent fuel grade of plutonium is capable of supporting criticality events. While problems of higher thermal output of the 240 isotope, together with poorer control of ignition triggering, make it a very difficult, but not impossible source, for a nuclear weapon.

For the forgoing reasons I would argue that as we consider the relicensing of Diablo reactors this is an appropriate time to consider how the spent fuel might be made less attractive as a source for misuse. Is one possible method to require some modification of core geometry so that at each refueling fuel elements that are near the end of their useful life are exposed to higher fast neutron fluxes? The more obvious route is to require reactor operators to include sufficient plutonium from recycled fuels to raise the proportion of the 240 isotope to a level making the plutonium in their spent fuels unusable for bomb devices. Obviously if,or when, FBR s become widespread the problem will largely be over.

While I realize that the NRC regulatory mandate may be unclear that it currently allows you to respond very energetically to this concern may I suggest this could be a time to ask for the necessary expanded jurisdiction.

I would appreciate any opportunity you can afford to enable me to contribute more to this fairly widely recognized concern.

Thanks! ( -(. Lc

V *' *OL

-n o Befor Yo.ouBei Intllto & Cofgrto Trulsotn 0A 0lssr 00i0ense

-Introduction

NOTICE This is to announce the publication of a forthcoming book, "Protest Diablo, Living and Dying Under the Shadow of a Nuclear Power Plant", by Judith Evered.

This personal memoir begins with an English power plant accident and the protests to the construction of another plant: Diablo Canyon Nuclear Power Plant (DCNPP).

The explosion in 1957 of the Windscale Atomic research experiment, (now named Sellafield) caused a huge personal tragedy for the author.

Judith had first-hand experiences during the 1981 protests to PG&E's opening of DCNPP. It includes blockading, arrests and jail. This set her on a mission to expose irrational decisions by the NRC which impact areas even over 100 miles from DCNPP, putting all our lives at risk. We need to know. The truth is in this book.

My thesis and reasons for writing the book are:

Radiation kills.

" Accident conditions exist at Diablo Cove.

" Helen Caldicott's book "Nuclear Power is not the answer" covers all the reasons why we should shut down the world's dangerous nuclear plants.

Judith Evered 805 685-8822 3 rd March 2010

February 9, 2010 To: The Nuclear Regulatory Commissioners.

RE: the application to extend the two reactors at Diablo Canyon Nuclear Power plant a further 20 years.

Dear Commissioners,

There are three compelling studies/ reasons for you to deny this application.

1. Radiation kills surrounding populations. The precise research shows statistical evidence of increasing deaths downwind from nuclear plants. This is in a book by Jay Gould and others called "The Enemy Within".

2. Conditions conducive to accidents are present at Diablo Canyon especially in regard to the earthquake factor and the two aging plants. Charles Perrow, the author of "Normal Accidents", maintains the absence of an accident at Diablo Canyon Nuclear Plant is because not sufficient time has yet elapsed for an accident to happen. He advocates these reactors should be closed down immediately.

3. Compelling arguments to not continue expanding nuclear power are found in the book: "Nuclear Power is Not the Answer", by Helen Caldicott. Her research covers almost all the reasons why Diablo Canyon reactors should not be given longer lives.

Waste is an overriding problem. Environmental racism and enormous costs are also well exposed by this researcher.

The arguments found in the above three books involve outstanding thinking about these reactor flaws and potential damage to humans.

Please facilitate the reading of these books by your staff and aides who will I trust write at least a one page conclusion of the results outlined for your honest attempt to predict the future and rationally decide on no extension time for reactors Diablo I and 2.

This is morally imperative.A precautionary action is needed now.

Judith Evered, a member and co-chair of the Santa Barbara Women's International League for Peace and Freedom.

Contact information:

(805) 685-8822 (805) 720-4336 PO Box 8153 Goleta CA. 93118

I.

Statement of U.S. Representative Lois Capps Statement at NRC Scoping Meeting on the Diablo Canyon Nuclear Power Plant Relicensing Application March 3, 2010 I would like to read the following statement from U.S. Representative Lois Capps:

Thank you for the opportunity to comment on the environmental issues the Nuclear Regulatory Commission should consider in its review of the proposed license renewal application for the Diablo Canyon nuclear plant.

I represent the 23rd Congressional District, in which this facility is located.

As a member of the House Energy and Commerce Committee, I am very interested in issues relating to the relicensing process of nuclear power plants.

I appreciate the NRC holding this forum to assess all of the environmental impacts that would result if this plant were to be relicensed.

Given the scale of this renewal, as well as the complex technical issues contained in the licensee's application, it is critically important that this assessment be comprehensive and independent.

The NRC must fully assess and address safety and security impacts, including any measures available to mitigate them, as they relate to the environment.

That means the assessment must include updated and completed analyses to ensure:

the surrounding natural and marine environment is protected,

" the plant-including aging infrastructure-can withstand potential earthquakes and is not vulnerable to a terrorist attack, and

that any on-site storage of waste be done safely.

I believe failure to fully assess these issues would do a disservice to the review process by disallowing a look at the overall, collective impacts of this renewal on the environment.

For example, the recently discovered Shoreline Fault, less than one mile offshore of the plant, has not been thoroughly studied.

This clearly exacerbates an already precarious situation. The central coast of California has a number of major and active earthquake faults.

To reduce the likelihood or severity of a severe accident due to these faults, the NRC must include severe accident mitigation alternatives-supported by new seismic hazard data-as part of this review process.

Only with an all-inclusive review of the safety and security impacts will the NRC ever be able to come to an accurate conclusion as to the degree of the severity of a planned or unplanned event at the plant.

Accordingly, the NRC must require site-specific assessments to address the potentially catastrophic and far-ranging impacts on the environment during the license renewal process.

Again, I urge the NRC to act deliberatively in this matter, based on a thorough public record.

My constituents deserve assurance that everything possible is being done to insure this facility is operated in a safe and sound manner, and that the relicensing process is focused on protecting their health and safety.

Thank you for this opportunity to comment on this proposal.

Comments on the U.S. NUCLEAR REGULATORY COMMISSION'S ENVIRONMENTAL SCOPING FOR..

DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION REVIEW March 3, 2010 Barbara Byron Senior Nuclear Policy Advisor California Energy Commission Good afternoon/evening. My name is Barbara Byron. I am the Senior Nuclear Policy Advisor with the California Energy Commission. We appreciate the opportunity to provide comments here today regarding the scope of the environmental review for the Diablo Canyon Nuclear Power Plant license extension application. My comments will be brief, since we plan to submit written comments later this month.

In November 2008, as required by California statutes Assembly Bill 1632, the California Energy Commission completed a comprehensive assessment of the Diablo Canyon and San Onofre Nuclear Power Plants. This assessment included studies of the seismic hazards at the Diablo Canyon and San Onofre sites and the seismic vulnerabilities of these plants. We found through this assessment that important data on Diablo Canyon's seismic hazard and vulnerabilities are incomplete or outdated. In addition, just prior to the completion of this assessment, PG&E announced the discovery of the Shoreline Fault less than half a mile offshore from Diablo Canyon. As a result, the Energy Commission recommended that PG&E conduct a number of additional seismic hazard and plant vulnerability analyses. The California Public Utilities Commission (CPUC) also directed PG&E in 2009 to report on the major findings and conclusions from these studies as part of its license renewal feasibility studies for Diablo Canyon.

These important studies include:

" Updated seismic/tsunami hazard studies, including using three-dimensional geophysical seismic reflection mapping and other advanced techniques to explore fault zones near Diablo Canyon;

" Assessments of the long-term seismic vulnerability and reliability of the plant, focusing on switchyards and other non safety-related components;

An evaluation of additional pre-planning or mitigation steps that the utility could take to minimize plant outage times following a major seismic event, such as the earthquake that struck the Kashiwazaki-Kariwa plant in 2007; and

" An evaluation of the adequacy of access roads to Diablo Canyon and surrounding roadways for allowing emergency personnel to reach the plants and local communities and plant workers to evacuate.

1.

PG&E's completion of these seismic studies is particularly important in light of the nearly 3-year outage of the Kashiwazaki-Kariwa nuclear power plant following the 2007 earthquake in Japanmand the recently discovered.Shoreline Fault near:DiabloCanyon.--

The Energy Commission and the CPUC have also identified a number of other studies that are needed in order to determine the economic, environmental, and reliability implications of relicensing Diablo Canyon. These studies would answer the following questions:

1. What would be the local economic impacts of continuing to operate the nuclear plant, and how would these impacts compare with potential alternate uses of the Diablo Canyon site?

2. What would be the low-level nuclear waste disposal costs for waste generated through a 20-year plant license extension, including the low-level waste disposal costs for any major capital projects that might be required during this period? In addition, what are PG&E's plans and estimated costs for the storage and disposal of low-level waste and spent fuel from the plant's operation and decommissioning?

3. What alternate power generation options could be used in place of power from Diablo Canyon? What would be the reliability, economic, and environmental impacts of these options compared to the impacts of Diablo Canyon?

4. What mitigation plans may be needed to ensure the integrity of the Diablo Canyon reactor pressure vessel over a 20-year license extension in light of any updates to the estimated seismic hazard at the site?

5. What are the options and costs for complying with California's once-through cooling policy?

The seismic studies and these additional studies are all needed to assess the cost and benefit to the state of continuing to operate Diablo Canyon for an additional 20 years. In addition, some of these same studies are also relevant to the NRC's evaluation of the environmental and safety implications of continuing to operate the plant. For example, an updated seismic hazard assessment is needed to assess the vulnerability of aging plant components to an earthquake. This is especially important for those reactor components, such as the reactor pressure vessel, that have been embrittled by neutron bombardment. In addition, the environmental assessment should consider possible changes to Diablo Canyon's cooling system resulting from the State's emerging once-through cooling regulations, required by provisions of the U.S. Clean Water Act, and updated assessments of site evacuation plans.

We, therefore, request that the NRC evaluate the safety and environmental implications of all of the AB 1632 recommended studies and issues identified by the CPUC and the Energy Commission and require that these seismic studies and the other state-mandated studies be reviewed as part of the Diablo Canyon's license renewal review proceeding before the Atomic Safety and Licensing Board.

2

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Text

Dear Commissioners,

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