ML15275A228

Comment (30) of Unknown Individual Opposing Diablo Canyon Units 1 and 2

ML15275A228
Person / Time
Site:	Diablo Canyon
Issue date:	09/30/2015
From:	- No Known Affiliation
To:	Division of Administrative Services
References
80FR37664 00030, NRC-2009-0552
Download: ML15275A228 (3)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001

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DIABLO CANYON IS NOT A SOLUTION TO REDUCING ATMOSPHERIC CARBON Diablo Canyon will prevent California from succeeding in its goal to achieve carbon-free energy of 33% by 2020. Energy analyst Mark Cooper makes the case that, "Nuclear reactors old and new are far from a necessary part ofra low-carbon solution. Nuclear power, with its war against the transformation of the electricity system, is part of the problem, not the solution."

DIABLO CANYON IS NOT NEEDED TO FILL CALIFORNIA'S ENERGY DEMANDS The California Independent System Operator oversees energy distribution throughout California by managing the grid. CAISO has expressed concern that there may be times when there is so much variable wind, solar and other renewable energy being scheduled onto its system that the other generators, such as nuclear, who will have to adjust to accommodate it, will not have the flexibility needed to do so.

NUCLEAR IS OUTMODED "PG&E's focus on "standalone" energy sources is outmoded and unrealistic. First, PG&E focuses on "baseload" generation by a single source. Second, PG&E is not recognizing the increase, flexibility, and resilience of distributed power generation and is promoting outdated, inflexible "utility-scale" generation. PG&E's assumptions are outdated because of the ongoing transformation of the electric utility sector. As one prominent financial firm that specializes in analysis of the electricity sector, UBS, put it, "Large-scale power generation.., will be the dinosaur of the future energy system." They are:

"Too big, too inflexible, not even relevant for backup power in the long run." While UBS ties the shift to the spread of battery technology, other major firms see the shift being driven by the development of technologies including solar, wind, efficiency, and the increasing ability to actively integrate and manage supply and demand."

SEISMIC DANGERS Diablo Canyon is built adjacent to 13 known earthquake faults, and it may actually be built directly over the Shoreline Fault. No one - not PG&E, not the US Geological Survey, not the Independent Peer Review Panel - no one actually knows how far east the Shoreline Fault extends. For PG&E to claim that it does is both dangerous and fatuous.

TERRORISM Almost 15 years have come and gone since the events of September 2001, and America's civilian nuclear facilities remuain unprotected against a terrorist attack of that scale. Instead, our civilian reactors prepare only against a much smaller-scale attack, known as the "design basis threat,"

while the NRC fails to provide supplementary protection against a realistic 9/11-type attack at Diablo Canyon.

PLUTONIUM Plutonium is the most toxic substance in the world. It is only produced through a nuclear reaction. Its half-life is 24,000 years. Plutonium can be transported in the atmosphere usually when it is attached to particles in the air. It can be deposited on land or water by settling or by rain. Plutonium can stick to particles in soil, sediment, and water.

FORCE-ON-FORCE DRILLS Because of industry complaints, the NRC already has reduced the number of Force-On-Force exercises per inspection cycle from three to two, and is proposing to reduce it to only one by 2017.

In exchange, the NRC will give more credit to licensee-run security drills and will observe one drill in each inspection cycle. This is a slippery slope toward the industry's ultimate goal: to take control of the process and eliminate the potentially embarrassing FOF exercises altogether. Even worse, the i:,

with an apparent eye toward weakening it even further.

DRY CASK STORAGE The dry casks selected for use at Diablo Canyon are just 5/8 inch thick stainless steel. Lower quality canisters are being used, choosing profits over our safety. NRC documents provide data that indicate thin storage containers can fail 16 years after a crack initiates.

LEAKY CASKETS ONCE-THtROUGHt COOLING SACRIFICES MARINE LIFE PG&E, for many years, provided state water authorities with skewed data on Diablo Canyon. The data showed that the plant's intake of billions of gallons of water a day did very little harm to surrounding marine life. PG&E's conclusions were based on the unscientific formula that the amount of sea life drawn into the system at the intake port could be accurately measured by the amount of small fish and other organisms at the outflow of the cooling system.

EMBRITTLED.

Diablo Canyon's Unit 1 is on the NRC's list of the most embrittled pressurized water reactors in the U.S.

Embrittlement happens over time as the steel in the reactor pressure vessel becomes weakened by intense long-term neutron bombardment from the radioactive fuel inside.

As the reactors age, they become increasingly vulnerable to "pressurized thermal shock risks." Rapid severe cooling plus sudden re-pressurization could shatter the weakened reactor vessel and allow intense radioactivity to escape.h