ML24054A851

Comment (46) E-mail Regarding Diablo Canyon Lr EIS Scoping

ML24054A851
Person / Time
Site:	Diablo Canyon
Issue date:	02/23/2024
From:	Public Commenter Public Commenter
To:	NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
89FR4631
Download: ML24054A851 (7)

Text

From:

Bruce Campbell <madroneweb@aol.com>

Sent:

Friday, February 23, 2024 7:59 PM To:

DiabloCanyonEnvironmental.Resource

Subject:

[External_Sender] Re: Docket ID NRC-2023-0192 Scoping Comments for DC-specific Supplemental to the GEIS (part one)

February 23, 2024 To whom it may concern at the Nuclear Regulatory Commission and beyond:

These are my scoping comments (part one) on the DCNPP-related Supplemental to an earlier GEIS in regards to operating license extensions for commercial nuclear reactors in the USA.

The state in the USA which has the largest population, the largest economy, and the largest farming sector in the nation is the State of California.

When so much is at stake considering the location of the DCNPP on the Central Coast of California, it is extremely SENSIBLE that a THOROUGH and UP-to-DATE SEISMIC EVALUATION be conducted as an integral part of the DCNPP-specific Supplemental to the earlier Generic EIS.

I believe it is likely (though I could not attend recent hearings accepting vocal input) that commenters to this point have very likely shown concern about, and WANT THOROUGH ANALYSIS REGARDING NEWLY-DISOVERED EARTHQUAKE FAULTS in the VICINITY of the DCNPP.

It is sensible that such an analysis include evaluating possible impacts to Diablo Canyon safety systems from the TWO VERTICAL THRUST FAULTS discovered beneath the Diablo nuclear facility itself.

The discovery of the VERTICAL THRUST FAULTS at the Diablo Canyon facility itself is a reminder that any thorough seismic analysis would include projections of the likelihood of certain levels of both HORIZONTAL and of VERTICAL GROUND ACCELERATION.

Please consider the following Significant Issues, and thus include the following analyses in the DCNPP-specific Supplemental to GEIS:

Potential impacts from HIGH MEASUREMENTS of VERTICAL GROUND ACCELERATION during Quakes; Evaluate seismic science of recent years involving: A.) the realization that there have been major quakes (rather than more of a creeping which can result in more moderate size quakes most of the time) along the central segment of the San Andreas Fault in the time between about 2000 years ago and a few million years ago, and some researchers now believe that the San Andreas Fault is capable of delivering a STATEWIDE EARTHQUAKE to California; and B.) the largest earthquakes in central / southern California in recent years were in the Ridgecrest / Trona area which is quite close to the major Garlock Fault. Though fairly recent

seismic activity was centered on other nearby faults, but the series of quakes in northeastern Kern County may have caused the first movement on the Garlock Fault for hundreds of years due to an increase in stress in the area from the shifting of seismic stresses due to that series of quakes in recent years. There certainly must be more concerted research on the faults in the Ridgecrest / Searles Valley region, and how that is impacting seismic stress on the Garlock Fault and even on the San Andreas Fault. By the way, that series of sizable earthquakes which occurred in the general Kern / Inyo County line vicinity struck on July 4th and 5th, 2019. The three main temblors were of 6.4, 5.4, and 7.1 magnitudes. There have been thousands of aftershocks since that time including a 5.5 quake in the Searles Valley area including in early June 2020.

An Newsweek article in July 2020 was entitled Center of Californias San Andreas Fault could cause even Bigger Earthquakes, says Study. One excerpt from this article reads: The research challenged earlier assumptions that the central section of the San Andreas Fault did not create severe earthquakes, compared to other parts of the fault. The authors suggested instead that earthquakes of large magnitude have happened there in the past and could happen again. The Newsweek article is based on an article published in the Geology journal. As far as qualifications of a researcher focused on this study, please note that Ross Stein is an earthquake scientist emeritus of the USGS and an adjunct professor of geophysics at Stanford University. He told the Times that the numerical data indicates about a tripling of the likelihood of a large quake on the San Andreas Fault.

The USGS notes that the Ridgecrest quakes released energy along at least two shallow strike-slip faults about 100 miles northeast of the San Andreas Fault.

It should be noted that the San Andreas is right in between the DCNPP (to the west) and the desert area where the sizable central California quakes have been occurring during the last 5 years or so -- which is to the east of the San Andreas Fault.

Lastly in regards to possible repercussions from the Ridgecrest/Trona region quakes and building seismic pressure on certain faults likely including the San Andreas Fault, please evaluate the regional seismic picture in central California in relation to how the greater seismic setting (including the bend in the San Andreas Fault) as well as the seismic shifts brought about by the series of quakes near Ridgecrest may be related to the Garlock Fault and even related to the 2000-km oceanic east-west fracture zone which meets the North American continent in western Santa Barbara County.

These are my main three take-aways from the Diablo Canyon seismic hearings conducted by the NRCs Atomic Safety and Licensing Appeals Board back in October of 1980 which I attended with my safe energy group (which camped out on the lawn of the Vets Memorial Building in San Luis Obispo). My first clear conclusion was that there was certainly sufficient info presented at those ASLAB seismic hearings (conducted 43 and a half years ago) which could lead a sensible person to conclude that the Diablo Canyon nuclear reactors were precariously situated and

likely could not withstand GROUND ACCELERATION READINGS which the few-mile-from-DCNPP Hosgri Fault could deliver impacting infrastructure including safety systems at the Diablo Canyon facility.

My second take-away (which became clearer after the decision was made) was to inform you that the glorious Chairman of the 3-man ASLAB, Mr. Salzman, conveniently was appointed to a federal judgeship by President Reagan shortly before the ASLAB unanimously ruled that the Diablo Canyon nuclear reactors were seismically safe back in 1981.

My third take-away was just to share with you what prompted the NRCs ASLAB to conduct hearings at that time in regards to the seismic setting of the DCNPP. The reason that Diablo Canyon seismic hearings were held back in 1980 was due to the surprising seismic focusing effect directing released seismic energy that was noted in the Imperial Valley October 15th, 1979, quake. There were also SURPRISINGLY HIGH GROUND ACCELERATION readings noted during that quake, particularly in regards to VERTICAL GROUND ACCELERATION.

There was an important article I believe in the Santa Maria Times which was entitled, NUDGING the GARLOCK FAULT (and the SAN ANDREAS FAULT) CLOSER to FAILURE of 7-6-19 which should be checked out for helpful background info.

Certainly any forthcoming Diablo Canyon-specific Supplemental to the GEIS must include a CURRENT DETAILED ASSESSMENT in regards to the condition of the Diablo Canyon facility. This must include not just its PRESSURE VESSELS, but we also need an update in regards to the 3000 problems at the Diablo facility which had been reported via sworn testimony by 105 workers (facilitated by the Government Accountability Project) in the time preceding final approval for PG&E to fire up / reach criticality at its Unit 1 Reactor. This was after 2 and a half years of repairs following the major delay at Diablo Canyon brought about by an engineer blowing the whistle about switched blueprints for seismic reinforcements in Diablo Canyons auxiliary cooling systems. Such a report happened to get major publicity since it was came to light during the time when the Diablo Canyon Blockade / Encampment was taking place. PG&E brought more experienced nuclear power facility construction firm Bechtel in to at least look like they were fixing enough things such as the auxiliary cooling systems so that PG&E could get another rubber-stamp this time to fire up Unit 1 to a low-power test level. So, despite 3000 outstanding problems sworn to by workers at Diablo Canyon, the NRC allowed Diablo Canyon reactors to go critical despite not resolving that huge backlog of problems sworn to by workers of the DCNPP.

In regards to issues deserving analysis in the Diablo-specific Supplemental to the GEIS, among such issues should be the impact of activities relating to license extension and further operation of the nuclear reactors at the DCNPP such as: 1. Impacts from an additional 20 years of elevated thermal discharges violating the federal Clean Water Act (but PG&E got a waiver) into Diablo Cove. You could also study the likely impacts of extending DCNPPs operating license for their reactors for an additional 5 years beyond when their current operating licenses expire, as well

as the likely impacts from operating for ten years beyond the dates of current license expirations. Sorry for the different time frames, but it is your own documents that offer varying numbers of years in which operation would continue beyond when the current operating licenses expire. (California legislation SB 846 says 5 years numerous times, I believe Newsom had mentioned ten years at some point, yet PG&Es submitted License Renewal Application applies for a 20-year renewal of the operating license!)

The waste discharge from operating the reactors at Diablo Canyon includes significant levels of heavy metals as well as a certain amount of inadvertent radioactivity which is dumped into Diablo Cove / Pacific Ocean. There must be an evaluation regarding how much impact nuclear generation at Diablo Canyon is having and will have in the future if there is a 20-year (or other time frame) extension of operating licenses in which to boil water using the splitting of radionuclides to turn steam generators to produce electricity. Analyses regarding the impact of extended DC operations on marine organisms must certainly involve evaluating the impact of an additional 20 years (or perhaps 5 or 10 years) of impingement and entrainment of marine species at water intake areas for the Diablo Canyon nuclear facility located at Diablo Cove.

In regards to radioactive waste, I see these two issues desperately crying for thorough analysis:

1. The first is in regards to the storage area for thin canisters stuffed with spent fuel rod assemblies. I understand that that radwaste storage area is already near its planned capacity at Diablo Canyon, but since it goes hand-in-hand with extracting corporate welfare from government agencies, obviously PG&E will claim, and NRC will agree, that they can place another 20 years of very hot radioactive waste in that radwaste storage area even if that claim is not supported by reputable studies.

2. The second is related to the first, but deserves to be its own separate key point as well.

It is the BAIT-and-SWITCH involved with the NRC and nuclear industry promises to the public that thick casks would be used to store their highly radioactive waste, but instead PG&E bought the NRC-offered thin Holtec canisters in which to place spent fuel rod assemblies. Fairly recently I understand they may have chosen the Areva-model thin canister for their more freshly generated spent fuel waste. That company didnt even make such containers (seeing that Europe uses a lot thicker containers in which to store their spent fuel rod waste) until fairly recently, but since they did not want to pass up the opportunity to sell radwaste containers to U.S. utilities (even if they consider thin canisters as quite inferior for radwaste containment when compared with thick casks which Areva manufactures at least for some utilities in Europe), they chose to start manufacturing such thin canisters to satisfy some demand by American utilities (seeing that thick cask options apparently have never been offered to utilities in the USA).

I believe that the DCNPP-specific Supplemental to the GEIS must clearly PRINT the ACTUAL TEXT (rather than a mere legal code # or even link) of various pieces of LEGISLATION which relate to whether DCNPP is eligible to receive a major hand-out by the federal govt. in order to extend the operating license for DCs nuclear reactors for another 20 years (or whatever the time

frame is). I noticed back when I read the legalese of the Bi-Partisan Infrastructure bill that PG&E appeared to be ineligible seeing that they did not abide by the criteria despite it being mentioned in a Federal Register notice.

I notice that government agencies and elected officials are bowing to the whims of some of the worst players in the nuclear industry by changing their wording, or giving an interpretation that what is written in fairly clear English there can actually be changed in order to reap gifts upon the felonious PG&E as well as upon the disreputable Holtec corporation to actually operate their first nuclear reactor - and on a Great Lake which is quite shameful! Holtec has such a pathetic record regarding thin canisters, regarding merging with a Canadian company convicted of bribery, and in regards to their joke of a decommissioning cleanup plan for the Indian Point, NY, nuclear reactors in which they do not plan to address groundwater contamination deeper than four feet beneath the surface at that now-retired power plant on the Hudson River - while the groundwater of the area is connected to the Hudson River.

Also, the NRC appears eager to abide by wishes of PG&E even if safety at the DCNPP might be compromised. One disturbing aspect of the Civil Nuclear Credits program is that the federal govt. will award credits to help with operating license extensions for nuclear reactors - AS LONG AS SUCH NUCLEAR REACTORS CONTINUE OPERATIONS OVER THE FOUR-YEAR AWARD PERIOD. THIS COULD BE A MAJOR THREAT TO PUBLIC HEALTH SINCE NUCLEAR UTILITIES ARE ALREADY PRONE TO ERR ON THE SIDE OF PROFIT, AND IF THEY HAVE TO KEEP THOSE NUCLEAR REACTORS / STEAM GENERATORS CHURNING EVEN IF THERE ARE SERIOUS OR EVEN IMMINENT SAFETY CONCERS AT THE NUCLEAR REACTOR SITE, THAT IS A GREATLY INCREASED AND UNACCEPTABLE RISK TO PUBLIC AND ENVIRONMENTAL HEALTH!

Another example of the NRC happily bowing to whims of PG&E is in regards to a 1-17-24 letter in which PG&E requested that the NRC avoid scheduling any [license renewal application]

review activities during the upcoming Unit 2 refueling outage. It appears that when a formal Docket # is assigned to some environmental impact paperwork (such as that of the DCNPP license application in this case) that such an assignment initiates related safety and environmental reviews. Yet the following paragraph in the 1-26-24 letter by Brian K. Harris to Paula Gerfen of PG&E says the schedule for the review accommodates PG&Es January 17, request. This requires the NRC staff to delay outage which impacts the overall schedule. The environmental review schedule is not impacted by PG&Es request. So the docketing kicked off the safety and environmental review activities, yet the NRC agreed to abide by PG&Es preferences in the 1-17-24 letter and DELAY SCHEDULING CRITICAL SAFETY REVIEW ACTIVITIES, SUCH AS EARLY AUDITS, UNTIL AFTER THE UNIT 2 REFUELING OUTAGE WHICH IMPACTS THE OVERALL SCHEDULING. Was this agreed to due to the increase in the number of workers at a nuclear power facility during reactor refueling, or was it agreed to in order make sure that safety reviews which might take place before a refueled reactor is fired back up do not lead to a conclusion to close the nuclear reactors at the DCNPP. The public health of complex species (including homo sapiens) in the California Floristic Province is threatened when critical safety review activities are delayed to please an investor-owned utility.

Ive been trying to figure out why there is such an obsession in regards to avoiding the scheduling of license renewal application safety review activities during the Unit 2 refueling outage. It appears that safety is being sacrificed to the whims of the schedule forwarded by a disreputable investor-owned utility. What are PG&Es concerns which prompted the request in their letter to the NRC License Renewal Branch to delay safety reviews at DCNPP until after the re-loading of fuel in Unit 2 is completed? Are there concerns that safety reviews at DCNPP which might occur sooner rather than later would not be ideal for the utility, and thus they want a delay in safety reviews at Diablo Canyon? Is there a fear on the part of PG&E that if safety reviews are conducted sooner rather than later that something which may be discovered might prevent the completion of fuel-reloading -- or prompt calls by safety advocates and concerned citizens insisting that Unit 2 not be re-started after its refueling outage? Or is there another key reason why PG&E insists on delays in regards to safety reviews? Then that same paragraph continues and discusses how various enviro review activities can be streamlined, and how old EISs might count toward supposedly adequate analysis of safety systems at the DCNPP and whether they can withstand the vertical and horizontal ground acceleration which might be delivered by faults in the area of the DCNPP. So, lets see if I am clear on this - delay safety reviews at least during Unit 2 refueling outage, but then try to accelerate review of various aspects of the facility including using analyses from 15 years ago, or inspections from around 18 years ago. Please do a thorough job and do not avoid or delay any safety reviews to please any investor-owned utility. Also, please publish in future enviro impact documents the reason why PG&E is hoping to avoid safety reviews at the DCNPP at least when Unit 2 goes offline for refueling.

Lastly, besides the Bait-and-Switch that I mentioned in regards to being promised thick casks in which to place spent fuel rod assemblies (after they have cooled for awhile in spent fuel pools),

I want to point out another sad bait and switch pertaining to how long the term would be for operating license extensions at the DCNPP. Documentation relating to the California Legislatures forgivable loan to bail out PG&E passed in the first hour of September 1, 2022, said that the extension would be for 5 years and claim it was in order to meet Californias clean energy goals. Yet Governor Newsom discussed a ten-year extension. Well, surprise, I noticed that what is sought by PG&E - as noted on pages 4631-4632 of the Federal Register notice of January 24, 2024, is that they seek to extend the operating licenses for Units 1 and 2 to November 2, 2044, and August 26, 2045. Thus, not surprisingly, the CA Legislature was certainly under the impression that DCNPP (and nuclear reactors generally) was carbon-free and that the Diablo facility was the sole choice available to guarantee a reliable grid. Well hey, evaluate whether Murphys Law might occur at the DCNPP. If the big investment and energy provider goes down, then the CA grid and population might really be at risk and would have to gather various decentralized sources to make up for the scheduled or unscheduled shutdown of nuclear reactors at the DCNPP including in the Central Valley during some heat waves.

Sincerely yours, Bruce Campbell Los Angeles, CA 90034

Federal Register Notice:

89FR4631 Comment Number:

46 Mail Envelope Properties (04bd01da66bc$ada72c70$08f58550$)

Subject:

[External_Sender] Re: Docket ID NRC-2023-0192 Scoping Comments for DC-specific Supplemental to the GEIS (part one)

Sent Date:

2/23/2024 7:59:09 PM Received Date:

2/23/2024 7:59:42 PM From:

Bruce Campbell Created By:

madroneweb@aol.com Recipients:

"DiabloCanyonEnvironmental.Resource" <DiabloCanyonEnvironmental.Resource@nrc.gov>

Tracking Status: None Post Office:

aol.com Files Size Date & Time MESSAGE 19467 2/23/2024 7:59:42 PM Options Priority:

Normal Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date: