ML24043A140
| ML24043A140 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/12/2024 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 89FR4631 | |
| Download: ML24043A140 (7) | |
Text
From:
government@cgnp.org Sent:
Monday, February 12, 2024 1:36 PM To:
Brian Harris NRR; Kim Conway
Subject:
[External_Sender] Re: CGNP Notes - DCPP Public Meeting at the Embassy Suites, SLO 02 08 24 Attachments:
CGNP to NRC - Public Meeting 02 08 24.pdf
Dear Brian and Kimberly:
Per your request, here are CGNP's notes regarding our Comments at the DCPP Public Meeting on February 8, 2024. Please disseminate this to your NRC colleagues and include it in the record of the meeting. CGNP will post this to our website as well.
Gene On 2024-02-08 19:56, government@cgnp.org wrote:
Dear Brian:
Thank you. Same here. Gene On 2024-02-08 16:53, Brian Harris NRR wrote:
I will inform the coordinators that you wish to make a comment on the record tonight.
I look forward to seeing you at the public meeting tonight.
- Thanks, Brian From: government@cgnp.org <government@cgnp.org>
Sent: Wednesday, February 7, 2024 12:55 AM To: Brian Harris NRR <Brian.Harris2@nrc.gov>
Subject:
[External_Sender] RE: DCPP Public Meeting at the Embassy Suites, SLO 02 08 24
Dear Brian:
I have a small favor to request as a result of the audio problems during the February 1, 2024 teleconference regarding Diablo Canyon Power Plant (DCPP.) It was very distracting to hear my voice through my phone about 1 second after I spoke.
I made a complaint about this problem via the meeting feedback form with a request for a NRC staff outreach to me. Nothing happened.
I plan to attend the NRC meeting after I finish booth duty at the SLO Downtown Farmer's Market From 5:00 PM until 8:30 PM on Thursday. Californians for Green Nuclear Power (CGNP) has a booth there. I will tear down the booth as quickly as possible and head to the Embassy Suites, about two miles away.
Could you please reserve a time slot for me just prior to 9:00 PM? I request between 3 to 5 minutes to make my comments on the record.
Please confirm receipt of my email.
Thank you.
/s/ Gene Nelson, Ph.D. CGNP Senior Legal Researcher and President 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 https://CGNP.org website
Federal Register Notice:
89FR4631 Comment Number:
15 Mail Envelope Properties (64106ffee318ad0bf7de51a0693dba0f)
Subject:
[External_Sender] Re: CGNP Notes - DCPP Public Meeting at the Embassy Suites, SLO 02 08 24 Sent Date:
2/12/2024 1:35:30 PM Received Date:
2/12/2024 1:35:53 PM From:
government@cgnp.org Created By:
government@cgnp.org Recipients:
"Brian Harris NRR" <Brian.Harris2@nrc.gov>
Tracking Status: None "Kim Conway" <Kimberly.Conway@nrc.gov>
Tracking Status: None Post Office:
cgnp.org Files Size Date & Time MESSAGE 2094 2/12/2024 1:35:53 PM CGNP to NRC - Public Meeting 02 08 24.pdf 375650 Options Priority:
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To: Brian Harris, brian.harris2@nrc.gov, (301) 415-2277 and Kim Conway, kimberly.conway@nrc.gov, (301) 415-1335 RE: Environmental Scoping Public Meeting for the Diablo Canyon License Renewal Application, Embassy Suites, San Luis Obispo, California - February 8, 2024
Dear Brian,
Kim, and the NRC colleagues that attended the environmental scoping public meeting:
First, thank you for postponing the adjournment of the public meeting so that I was able to discuss the points I raised regarding the need to keep Diablo Canyon Power Plant (DCPP) running. In this memo, I will summarize the points I made at the public meeting. Californians for Green Nuclear Power, Inc. is an independent nonprofit focused on the environmental and ratepayer benefits of extended operations for Pacific Gas & Electric's (PG&E's) DCPP. Between 2016 and 2022, CGNP was at loggerheads with PG&E, since the utility was acquiescing to State of California pressure to wastefully close DCPP in 2025.
- 1. Federal perspectives now supporting extended DCPP operations.
A. Here's some quotes from an article regarding the biennial joint NRC - FERC meeting on January 25, 2024. 1 Even though a lot of politicians in California wanted to close [Diablo Canyon], they faced the reality that they could not close it and keep their lights on, FERCs Christie said. Nuclear is a critical tool for reliability and decarbonization. FERC Commissioner Mark Christie touted the benefits of nuclear power. Number one, its carbon free and thats great. Number two, it runs all the time, he said. So basically, any future where you want to have reliable power and reduce carbon emissions its got to include nuclear.
Christie commented on Pacific Gas & Electrics 2,250-MW Diablo Canyon power plant in California, which had been slated for retirement but is in the process of having its life extended.
Even though a lot of politicians in California wanted to close it, they faced the reality that they could not close it and keep their lights on, Christie said. So one lesson there was ultimately reality wins.
B. The above statements were significant improvements in FERC's perspective regarding the importance of zero-emissions DCPP to California grid reliability. In 2021, CGNP initiated a FERC Compliant EL21-13-000 challenging the proposed 2025 DCPP retirement on reliability and environmental grounds. Regrettably, FERC rejected CGNP's Complaint on March 16, 2021.
- 2. Grounds under NEPA for adopting the "No Project Alternative" supporting DCPP relicensing to 2045 A. DCPP is a large baseload generator serving California's grid which requires about 100 terawatt-hours (TWh) of imports - the greatest amount of any state. DCPP's typical power production is about 18 TWh / year, the largest California in-state generator.
1 "25 SMR license applications expected by 2029, plus six other takeaways from FERC, NRC joint meeting," by Ethan Howland, January 26, 2024, Utility Dive.
https://www.utilitydive.com/news/ferc-nerc-joint-meeting-smr-nuclear-black-start/705708/
Meeting video at https://www.youtube.com/watch?v=OCr9ODxjZmY DCPP at about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 9 minutes
Summary of CGNP's Comments at the 02/08/24 NRC DCPP Environmental Scoping Meeting Page 2 of 4 2
DCPP typically generates the equivalent of five Hoover Dams of emission-free electricity annually. DCPP's typical annual capacity factor is in excess of 90%. Independent of the quantity deployed, nondispatchable California solar and nondispatchable California wind can never replace dispatchable DCPP. Solar and wind destabilize the grid with their random and predictable output diminutions. On the other hand, DCPP stabilizes the grid with substantial grid inertia. Each of the twin DCPP steam turbines and rotor assemblies weighing in excess of 500 tons contributes considerable grid inertia. DCPP is reliably connected to the state's 500 kV AC backbone by three separate sets of 500 kV AC transmission lines, each less than about 100 miles in length.
B. If dispatchable DCPP were wastefully closed in 2025, it would need to be replaced with increased dispatchable in-state natural gas-fired generation and increased dispatchable out-of-state coal-fired generation. Emissions would increase by millions of metric tons of CO2 annually. Furthermore criteria pollutants such as SO2, NOx, and Mercury would increase. The adverse environmental consequences of this replacement are discussed in the attached CGNP OpEd published in Capitol Weekly on April 5, 2022. The environmental harms of Berkshire Hathaway Energy (BHE) subsidiary PacifiCorp are highlighted in the OpEd.
C. The environmental harms of coal-fired imports for the California power grid are already occurring. Statistics published at the Western Energy Imbalance Market (WEIM) website show that over $ 1.2 billion in mostly coal-fired imports have already been utilized mostly in California since the establishment of WEIM in November, 2014 2. WEIM was established jointly by PacifiCorp and the California Independent System Operator (CAISO.)
While there is important 2006 California environmental legislation, SB 1368 (Perata) that prohibits long-term power supply contracts if the out-of-state generator emits at a higher level than a modern combined-cycle natural gas-fired power plant, it only applies to long-term power supply contracts in excess of five years.
WEIM's daily electricity spot market is exempt from SB 1368's emissions performance standards.
- 3. Financial Challenges for CGNP in 2024 and Beyond CGNP is an intervenor before the California Public Utilities Commission (CPUC.) Normally, intervenors are eligible for intervenor compensation if their testimony supports the final CPUC Decision. CGNP was the only intervenor of 55 that supported DCPP extended operations during the entire Proceeding - consistent with the CPUC's final Decision. While CGNP submitted an intervenor compensation request for over $153,000, our request was completely denied about a month ago. (On the other hand, DCPP opponents were awarded about
$2 million in intervenor compensation in this Proceeding.) We would not be surprised to learn that PacifiCorp's expenditure of over $2.5 million in directly lobbying the CPUC during the past years was influential. PacifiCorp continues to support CAISO grid regionalization which would likely imperil California environmental legislation such as SB 1368 if CAISO were to become a multistate balancing authority, following the reasoning of the 2016 Supreme Court decision Hughes v. Talen Energy Marketing. Unless CGNP obtains additional financial support, we will likely have diminished effectiveness in 2024 and beyond.
Gene Nelson, Ph.D. CGNP President and Senior Legal Researcher, Arroyo Grande, CA (805) 363 - 4697 cell government@CGNP.org email.
2 https://www.westerneim.com/Pages/About/QuarterlyBenefits.aspx (Sum of sales of BHE subsidiaries PacifiCorp and NV Energy)
Summary of CGNP's Comments at the 02/08/24 NRC DCPP Environmental Scoping Meeting Page 3 of 4 3
Closing Diablo Canyon spurs fears over replacement power BY GENE NELSON POSTED 04.05.2022 GENE'S EMAIL: GOVERNMENT@CGNP.ORG (805) 363 - 4697 GENE'S CELL HTTPS://TINYURL.COM/DCPP-VERSUS-COAL HTTPS://CAPITOLWEEKLY.NET/CLOSING-DIABLO-CANYON-SPURS-FEARS-OVER-REPLACEMENT-POWER/
Californias power is expensive and polluting - but doesnt have to be.
The state of California plans to replace Diablo Canyon Power Plant (DCPP) mostly with Wyoming coal-fired generation. The source of the replacement power will remain hidden until 2025, when Californians cant stop the state.
As a nonprofit intervenor before the California Public Utilities Commission (CPUC) since 2016, Californians for Green Nuclear Power (CGNP) has uncovered four obscure clues in CPUC filings that confirm the states plan. CGNPs thousands of pages of filings provide the details.
While Diablo Canyon is compact, its annual production is the equivalent of five Hoover Dams.
The first clue is the engineering requirement that since Diablo Canyon Nuclear Power Plant is a reliable 24/7 generator, any incremental replacement generation must have similar reliability. Otherwise, rolling blackouts occur.
Engineers use the term dispatchable (under human control) to describe Diablo Canyons power. Dispatchable generators that supply power like Diablo Canyon are powered by natural gas or coal. The ongoing drought means building new dams is impractical. While Diablo Canyon is compact, its annual production is the equivalent of five Hoover Dams.
Californians demand that Californias coal plants be shut down and they object to new plants powered by natural gas.
Widely-promoted solar and wind arent dispatchable. The sun doesnt always shine and the wind doesnt always blow with sufficient force. Natural gas fills in for solar and winds substantial intermittencies. Batteries are extremely expensive and could optimally be reserved for vehicles to improve air quality, instead of displacing natural gas in power plants.
Summary of CGNP's Comments at the 02/08/24 NRC DCPP Environmental Scoping Meeting Page 4 of 4 4
Those constraints imply that Californias replacement generation must be located mostly out of state. There are many generators that could produce additional power to replace Diablo Canyon located in or near the nations biggest coal deposits in Wyoming.
Unspecified imports sounds nicer than coal. Unfortunately, this term mostly applies to out-of-state coal power.
The second clue is the requirement that a new transmission network needs to be built to send the power about 1,000 miles from Wyoming to California.
Such a large network, first announced in 2007, is the Energy Gateway. The networks mastermind, Warren Buffett, stated in his 2021 letter to shareholders the network would cost
$18 billion by 2030. Oregon and Washington state have already announced upcoming bans against out-of-state coal power. Thus, by California utility law, most of this transmission cost will be borne by Californians.
Third clue: A California legal euphemism unspecified imports, which sounds nicer than coal, was created in 2009. Unfortunately, this term mostly applies to out-of-state coal power.
The term appears twice on page 16 in the CPUCs June 24, 2021 procurement decision in R2005003. Between 4,000 and 5,000 megawatts (MW) of generation capacity is stipulated.
In order to convert this to more familiar kilowatt-hours (kWh) on your power bill, the capacity factor, or percentage ON time is used. California nuclear power has a capacity factor of 90% and there are 8,766 hours0.00887 days <br />0.213 hours <br />0.00127 weeks <br />2.91463e-4 months <br /> in a year. The product of 5,000 MW times 8,766 hours0.00887 days <br />0.213 hours <br />0.00127 weeks <br />2.91463e-4 months <br /> times 90% is 40 billion kWh.
The fourth clue is the increased air pollution from burning coal.
How can Californias leaders evade this problem? The answer requires models they can manipulate. On page 104 of the CPUCs R2005003 Preferred System Portfolio adopted on Feb. 10, 2022 is the sentence, Criteria pollutants were counted from generation within California only, and not from unspecified imports. This means toxic air pollution from out-of-state coal power is artificially zeroed.
The increased demand for U.S. natural gas to supply Europe after Russias invasion of Ukraine means increased gas costs for utilities, resulting in pressure to burn more coal. Since nuclear plants like Diablo Canyon dont emit air pollution, they should remain online instead.
With the increased transmission costs, in 2025 Californians could have the worst of both worlds with significantly higher toxic pollution released into the environment while paying more for this emission-laden power from Wyoming.
Beginning to reverse Californias harmful energy policies means continuing operation of safe, reliable and cost-effective zero-emission Diablo Canyon well beyond 2025.
Editors Note: Gene Nelson has a Ph.D. in radiation biophysics and served as a science and engineering professor at 3 colleges and a university. He helped found CGNP in 2013, and has been CGNPs Legal Assistant since 2016.