ML24326A043
| ML24326A043 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/21/2024 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 89FR87433 | |
| Download: ML24326A043 (8) | |
Text
From:
Jill ZamEk <jzamek@gmail.com>
Sent:
Thursday, November 21, 2024 1:48 AM To:
DiabloCanyonEnvironmental.Resource
Subject:
[External_Sender] NUREG-1437, Supplement 62, draft, Docket ID NRC-2023-0192 Diablo Canyon Attachments:
Draft SEIS by Jill ZamEk.pdf November 2024 Comments submitted by Jill ZamEk, Arroyo Grande NUREG-1437, Supplement 62, draft, Docket ID NRC-2023-0192 Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 62, Regarding License Renewal of Diablo Canyon Nuclear Power Plant, Units 1 and 2 Section 2.1.7 pertains to Operations and Maintenance. Nowhere in this 424-page report does it mention the embrittlement of the Unit 1 reactor pressure vessel. It hasnt been tested for over 20 years due to NRC waivers, yet the NRC recommends approval of a 20-year license renewal. I object to that conclusion without evidence that Unit 1 is safe to operate.
Section 2.4.3.3 discusses a no-action alternative. Its conclusion states: A combination of energy sources discussed in Section 2.3.2.2 such as wind, solar, and battery backup, along with purchased power and demand-side management, could complement each other and reduce intermittent electricity generation issues. I support the no-action alternative. I suggest that our ratepayer and taxpayer money be invested in renewable energy with battery backup.
Section 3.4.5 focuses on the seismic issue. California State Senate Bill 846 was passed in September 2022 to extend the operation of Diablo Canyon and included a covenant for PG&E to perform an updated seismic analysis. PG&E published the results of that analysis on March 6, 2024 (PG&E 2024-TN10192). The results were not discussed in the ER because they had not been publicly released when the ER was submitted to the NRC. The NRC staff independently reviewed pertinent portions of the updated analysis report to determine whether new and significant information was provided therein that might change the ERs description of the affected geologic environment at and adjacent to the Diablo Canyon site. New information was developed on slip rates for the Hosgri fault and certain other faults The new slip rate data notwithstanding, the NRC staff concludes that none of these tectonic structures will have impacts on the geologic environment at or adjacent to the Diablo Canyon site that are different from impacts occurring during the current license term since no new faults were reported based on the updated analysis.
For such a vital safety element, this process sounds slipshod to me. I would like the NRC to consider Dr. Peter Birds evidence showing that the earthquake faults that run directly under the plant are vertical thrust faults, meaning they could cause much more ground motion than formerly thought possible. PG&E significantly underestimates the likelihood of a severe earthquake at Diablo Canyon.
Section 3.5.1.3.2 deals with the National Pollutant Discharge Elimination System Diablo Canyon utilizes the Once-Through Cooling system which violates the Clean Water Act. But again and again, PG&E has been granted waiver after waiver and has been allowed to continue damaging the marine environment.
in 2021, there was a settlement between PG&E and the CCRWQCB associated with historical and ongoing thermal discharge impacts from Diablo Canyon cooling water discharge.
The settlement, associated with Case No. 21CV-0111, was reached in May 2021 in the California Superior Court, County of San Luis Obispo. PG&E made a one-time payment to the Bay Foundation of Morro Bay to benefit water quality and the environment on Californias Central Coast. The Consent Judgement did not specifically conclude if PG&E violated its NPDES permit.
And The current NPDES permit was issued on May 11, 1990 by the CCRWQCB, and had a listed expiration of July 1, 1995. However, the permit has been under administrative extension and is listed as currently active on the SWRCB database (SWRCB 2024-TN10087). According to PG&E, the NPDES permit is anticipated to be re-issued in late 2026 (PG&E 2023-TN9822).
PG&E confirmed that during its discussions with the CCRWQCB, the Board did not indicate that any changes to Diablo Canyons NPDES permit would be required (PG&E 2024-TN10032).
Again: slipshod. The permit has been under administrative extension since 1995.
Impingement Mortality and Entrainment of Aquatic Organisms is discussed in section 3.7.5.1. PG&E intends to comply with the OTC Policy by ceasing the use of Diablo Canyons once-through cooling water intake system by a specified compliance date. On September 2, 2022, California Governor Gavin Newsom signed California Senate Bill 846 (State of California 2022-TN10038) into law. Effective September 2, 2022, Senate Bill 846 established a new OTC Policy compliance date for Diablo Canyon. Senate Bill 846 added Section 13193.5 to the Water Code, which specifies, in part: Notwithstanding any provision to the contrary in the State Water Resources Control Boards Water Quality Control Plan on the Use of Coastal and Estuarine Waters for Power Plant Cooling, as referenced in Section 2922 of Title 23 of the California Code of Regulations, the final compliance dates for Diablo Canyon Units 1 and 2 shall be 15 October 31, 2030. Furthermore, the SWRCB has determined under the OTC Policy that BTA [Best Technology Available] for Diablo Canyon is to cease the use of Diablo Canyons once-through cooling water intake system by October 31, 2030. Until that time, the OTC Policy allows PG&E to pay an annual mitigation fee based on the volume of Pacific Ocean water that Diablo Canyon withdraws.
Yet, the NRC endorses a 20-year license extension, not 5 years. Will PG&E really be required to change their cooling system? No more waivers and extensions?
The NRC mission statement is as follows: The NRC licenses and regulates the Nation's civilian use of radioactive materials to provide reasonable assurance of adequate protection of public health and safety and to promote the common defense and security and to protect the environment.
Yet section 3.10 focuses on socioeconomics - regional employment, income, housing, and tax revenues. The inclusion of socioeconomic factors confuses me, for it is not included in the NRCs mission statement, nor does it pertain to the assurance of adequate protection of public health and safety. Quite the contrary - economic and social factors should not influence the decision in a license renewal process.
Section 3.10 explains the 2016 Joint Proposal Agreement which was to permanently cease operations in 2024 and 2025. As part of this agreement, PG&E agreed to a Community Impact Mitigation Plan with local jurisdictions to ease the impacts of the impending closure of Diablo Canyon (PG&E 2023-TN9822). The Community Impact Mitigation Plan included an Essential
Services Mitigation Fund totaling $75 million paid to the county in annual installments through 2025 in the amount of $9,375,000 (PG&E 2024-TN10032). The second part is an Economic Development Fund one-time payment of $10 million paid to the county intended to fund regional economic development and job creation (PG&E 2023-TN9822). Due to the Joint Proposal Agreement and legislation in California Senate Bill 1090, the unitary tax paid by PG&E for Diablo Canyon was set on a linear path to zero by August 2025 (the planned permanent cessation of Unit 2). As of the publication of this draft SEIS, legislation regarding a new tax structure for Diablo Canyon has not been introduced.
That money has been spent. Does this mean that the ratepayers will be on the hook AGAIN for easing the economic losses when the plant finally closes?
Unavoidable Environmental Impacts is the topic of section 3.17.1. During nuclear power plant operations, workers and members of the public would face unavoidable exposure to low levels of radiation as well as hazardous and toxic chemicals. And The generation of spent nuclear fuel and waste material, including low-level radioactive waste, hazardous waste, and nonhazardous waste, would be unavoidable.
Thats why I assert that we should take no action, close Diablo Canyon on schedule, and invest in clean, renewable energy with battery backup. We dont need old, dirty, dangerous, and costly Diablo.
Federal Register Notice:
89FR87433 Comment Number:
32 Mail Envelope Properties (CAH91G3pcwgB+OYTn55DmnQz7vQMGtr5v2H8MZgF+FV_1DWk4Qw)
Subject:
[External_Sender] NUREG-1437, Supplement 62, draft, Docket ID NRC-2023-0192 Diablo Canyon Sent Date:
11/21/2024 1:47:50 AM Received Date:
11/21/2024 1:48:19 AM From:
Jill ZamEk Created By:
jzamek@gmail.com Recipients:
"DiabloCanyonEnvironmental.Resource" <DiabloCanyonEnvironmental.Resource@nrc.gov>
Tracking Status: None Post Office:
mail.gmail.com Files Size Date & Time MESSAGE 8213 11/21/2024 1:48:19 AM Draft SEIS by Jill ZamEk.pdf 39723 Options Priority:
Normal Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
November 2024 Comments submitted by Jill ZamEk, Arroyo Grande NUREG-1437, Supplement 62, draft, Docket ID NRC-2023-0192 Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 62, Regarding License Renewal of Diablo Canyon Nuclear Power Plant, Units 1 and 2 Section 2.1.7 pertains to Operations and Maintenance. Nowhere in this 424-page report does it mention the embrittlement of the Unit 1 reactor pressure vessel. It hasnt been tested for over 20 years due to NRC waivers, yet the NRC recommends approval of a 20-year license renewal. I object to that conclusion without evidence that Unit 1 is safe to operate.
Section 2.4.3.3 discusses a no-action alternative. Its conclusion states: A combination of energy sources discussed in Section 2.3.2.2 such as wind, solar, and battery backup, along with purchased power and demand-side management, could complement each other and reduce intermittent electricity generation issues. I support the no-action alternative. I suggest that our ratepayer and taxpayer money be invested in renewable energy with battery backup.
Section 3.4.5 focuses on the seismic issue. California State Senate Bill 846 was passed in September 2022 to extend the operation of Diablo Canyon and included a covenant for PG&E to perform an updated seismic analysis. PG&E published the results of that analysis on March 6, 2024 (PG&E 2024-TN10192). The results were not discussed in the ER because they had not been publicly released when the ER was submitted to the NRC. The NRC staff independently reviewed pertinent portions of the updated analysis report to determine whether new and significant information was provided therein that might change the ERs description of the affected geologic environment at and adjacent to the Diablo Canyon site. New information was developed on slip rates for the Hosgri fault and certain other faults The new slip rate data notwithstanding, the NRC staff concludes that none of these tectonic structures will have impacts on the geologic environment at or
adjacent to the Diablo Canyon site that are different from impacts occurring during the current license term since no new faults were reported based on the updated analysis.
For such a vital safety element, this process sounds slipshod to me. I would like the NRC to consider Dr. Peter Birds evidence showing that the earthquake faults that run directly under the plant are vertical thrust faults, meaning they could cause much more ground motion than formerly thought possible. PG&E significantly underestimates the likelihood of a severe earthquake at Diablo Canyon.
Section 3.5.1.3.2 deals with the National Pollutant Discharge Elimination System Diablo Canyon utilizes the Once-Through Cooling system which violates the Clean Water Act. But again and again, PG&E has been granted waiver after waiver and has been allowed to continue damaging the marine environment.
in 2021, there was a settlement between PG&E and the CCRWQCB associated with historical and ongoing thermal discharge impacts from Diablo Canyon cooling water discharge. The settlement, associated with Case No. 21CV-0111, was reached in May 2021 in the California Superior Court, County of San Luis Obispo. PG&E made a one-time payment to the Bay Foundation of Morro Bay to benefit water quality and the environment on Californias Central Coast. The Consent Judgement did not specifically conclude if PG&E violated its NPDES permit.
And The current NPDES permit was issued on May 11, 1990 by the CCRWQCB, and had a listed expiration of July 1, 1995. However, the permit has been under administrative extension and is listed as currently active on the SWRCB database (SWRCB 2024-TN10087).
According to PG&E, the NPDES permit is anticipated to be re-issued in late 2026 (PG&E 2023-TN9822). PG&E confirmed that during its discussions with the CCRWQCB, the Board did not indicate that any changes to Diablo Canyons NPDES permit would be required (PG&E 2024-TN10032).
Again: slipshod. The permit has been under administrative extension since 1995.
Impingement Mortality and Entrainment of Aquatic Organisms is discussed in section 3.7.5.1. PG&E intends to comply with the OTC Policy by ceasing the use of Diablo Canyons once-through cooling water intake system by a specified compliance date. On September 2, 2022, California Governor Gavin Newsom signed California Senate Bill 846 (State of California 2022-TN10038) into law. Effective September 2, 2022, Senate Bill 846 established a new OTC Policy compliance date for Diablo Canyon. Senate Bill 846 added Section 13193.5 to the Water Code, which specifies, in part: Notwithstanding any provision to the contrary in the State Water Resources Control Boards Water Quality Control Plan on the Use of Coastal and Estuarine Waters for Power Plant Cooling, as referenced in Section 2922 of Title 23 of the California Code of Regulations, the final compliance dates for Diablo Canyon Units 1 and 2 shall be 15 October 31, 2030. Furthermore, the SWRCB has determined under the OTC Policy that BTA [Best Technology Available] for Diablo Canyon is to cease the use of Diablo Canyons once-through cooling water intake system by October 31, 2030. Until that time, the OTC Policy allows PG&E to pay an annual mitigation fee based on the volume of Pacific Ocean water that Diablo Canyon withdraws.
Yet, the NRC endorses a 20-year license extension, not 5 years. Will PG&E really be required to change their cooling system? No more waivers and extensions?
The NRC mission statement is as follows: The NRC licenses and regulates the Nation's civilian use of radioactive materials to provide reasonable assurance of adequate protection of public health and safety and to promote the common defense and security and to protect the environment.
Yet section 3.10 focuses on socioeconomics - regional employment, income, housing, and tax revenues. The inclusion of socioeconomic factors confuses me, for it is not included in the NRCs mission statement, nor does it pertain to the assurance of adequate protection of public health and safety. Quite the contrary - economic and social
factors should not influence the decision in a license renewal process.
Section 3.10 explains the 2016 Joint Proposal Agreement which was to permanently cease operations in 2024 and 2025. As part of this agreement, PG&E agreed to a Community Impact Mitigation Plan with local jurisdictions to ease the impacts of the impending closure of Diablo Canyon (PG&E 2023-TN9822). The Community Impact Mitigation Plan included an Essential Services Mitigation Fund totaling $75 million paid to the county in annual installments through 2025 in the amount of
$9,375,000 (PG&E 2024-TN10032). The second part is an Economic Development Fund one-time payment of $10 million paid to the county intended to fund regional economic development and job creation (PG&E 2023-TN9822). Due to the Joint Proposal Agreement and legislation in California Senate Bill 1090, the unitary tax paid by PG&E for Diablo Canyon was set on a linear path to zero by August 2025 (the planned permanent cessation of Unit 2). As of the publication of this draft SEIS, legislation regarding a new tax structure for Diablo Canyon has not been introduced.
That money has been spent. Does this mean that the ratepayers will be on the hook AGAIN for easing the economic losses when the plant finally closes?
Unavoidable Environmental Impacts is the topic of section 3.17.1.
During nuclear power plant operations, workers and members of the public would face unavoidable exposure to low levels of radiation as well as hazardous and toxic chemicals. And The generation of spent nuclear fuel and waste material, including low-level radioactive waste, hazardous waste, and nonhazardous waste, would be unavoidable.
Thats why I assert that we should take no action, close Diablo Canyon on schedule, and invest in clean, renewable energy with battery backup.
We dont need old, dirty, dangerous, and costly Diablo.