ML20328A300
| ML20328A300 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/23/2020 |
| From: | Nelson G Californians for Green Nuclear Power |
| To: | Samson Lee Division of Operating Reactor Licensing |
| Lee, Samson | |
| Shared Package | |
| ML20328A296 | List: |
| References | |
| EPID L-2020-LRM-0101 | |
| Download: ML20328A300 (2) | |
Text
From:
government@cgnp.org To:
Lee, Samson
Subject:
[External_Sender] Comment RE: DCDEP Public Meeting - November 24, 2020 Date:
Monday, November 23, 2020 3:22:16 PM Attachments:
Battle Brewing About Californias Rolefilename2= size=301806 EL21-13 Docket Opened - Federal Register 11 03 20.pdf NERC Reliability Standards Overview.pdf Samson Lee Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission samson.lee@NRC.gov (301) 415-3168 November 23, 2020
Subject:
CGNP's Comments RE DCDEP Public Meeting
Dear Mr. Lee:
Californians for Green Nuclear Power, Inc. (CGNP) continues to object to "putting the cart before the horse" in planning to voluntarily shut down Diablo Canyon Power Plant (DCPP) in 2025. On October 26, 2020 CGNP filed a Complaint with the Federal Energy Regulatory Commission (FERC) opposing this voluntary plan. FERC opened Docket EL21-13-000 the next day. There are currently 56 entries in the FERC EL21-13 docket.
DCPP supports California electric grid reliability, supplying almost 10%
of California's in-state generation, safely, reliably, cost-effectively, and without producing any greenhouse gas emissions. DCPP operates independently of California's aging and vulnerable bulk natural gas transmission and storage system. During inevitable California natural gas delivery constraint events, DCPP helps to assure reliability of California's natural gas system by decreasing demand for natural gas.
95% of California's natural gas system is supplied by imports from out of state. About 60% of California's dispatchable in-state generation is supplied by burning natural gas. As the NERC region under ReliabilityFirst Corporation illustrates, nuclear power is the solid foundation for electric generation resource adequacy. ReliabilityFirst has almost 40% of the U.S. nuclear generation fleet. On the other hand, within WECC's vast geographic area there are only six power reactors.
One third of WECC's reliable generation would disappear in 2025 under this voluntary plan.
The voluntary plan to shut down DCPP appears to be driven by business interests that will profit from a closure of DCPP, not by scientific, engineering, and economic principles. In summary, the voluntary plan to close DCPP does not serve the public interest, which is the foundational principle for any regulatory action involving public utilities.
Attached find the Federal Register notice which opened FERC Docket EL21-13, a November 19, 2020 Power Magazine article summarizing the issues being considered in FERC Docket EL21-13, and a CGNP analysis of NERC's 117 Reliability Standards that calls into question NERC's alleged focus on generation reliability in NERC regions other than the ReliabilityFirst region.
Sincerely,
/s/ Gene Nelson, Ph.D. CGNP Legal Assistant Californians for Green Nuclear Power, Inc. (CGNP) 1375 East Grand Ave Ste 103 #523 Arroyo Grande, CA 93420-2421 (805) 363 - 4697 cell Government@CGNP.org email http://CGNP.org website