ML24346A027

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Printed Documents Provided to NRC Staff During Nov 20, 2024 Public Meeting
ML24346A027
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 11/20/2024
From: Kimberly Conway
NRC/NMSS/DREFS/EPMB1
To:
References
Download: ML24346A027 (1)


Text

CAPITOL OFflCE 1021 0 STREET SUITE 8720 SACRAMENTO. CA 95814 TEL 19161 651-4017 FAX *9!6J 651*4917 MONTERav DIST~IC'T OFFICE 99 PACIFIC STREET SlJITE 575 f" MONTEREY. CA 9.'3940 TEL <8311 657-6315 FAX <8311 657*6'320 SAN LUIS OBISPO DISTRICT OFFICE 1026 PALM STRECT SUITE 201 SAN LUIS OBISPO. CA 93401 TEL 18051 549-3784 FAX 1805, 549*3779 SANTA CRUZ DISTRICT OFFICE 701 OCEAN STREET. SUITE 318A SANTA CRUZ. CA 95060 TEL 1831 l 4?5*0401 FAX 18311 425-512<1 SANTA CLARA COUNTY SATELLITE Of"FICE TEL *408! 847-6101 Qlalifnrnia ~tate ~enate SENATOR JOHN LAIRD SEVENTEENl'H SENATE DISTRICT March 13, 2024 San Luis Obispo County Board of Supervisors Katcho Achadjian Government Center 1055 Monterey Street Suite D430 San Luis Obispo, CA 93408

Subject:

Diablo Canyon Power Plant

Dear Supervisors:

COMMITTEES BUDGET SUBCOMMITTE

  1. 1 1EDUCATION1 CHAIR JOINT COMMITTEE ON RULES VICE CHAIR BUDGET 8c FISCAL REVIEW

.JUDICIARY LABOR. PUBLIC EMPLOYME.NT Be RETIREMENT NATURAL RESOURCES 8c Wl>.TER RULES JOINT LEGISLATIVE AUDIT COMMITTEE I am writing of your proposed resolution on the extension of the life of the Diablo Canyon Power Plant, owned and operated by Pacific Gas & Electric (PG&E). As the local state legislator who was involved in the negotiations for Senate Bill 846 in 2022, which approved extending the life of the plant from 2025 to 2030, I thought it important to call attention to the provisions of that bill and how progress on its implementation should inform your proposed action.

Senate Bill 846 was the result of extensive conversations with relevant stakeholders, the subject of an online townhall meeting with hundreds of attendees, and the consideration of all the relevant issues at hand.

Specifically, the major provisions of SB 846 include the following:

Required that San Luis Obispo County communities that received $85 million in mitigation funding and PG&E employees who benefitted by a $350 million retention and retraining program based on the former closing date of 2025 (as authorized under SB 1090-2018) do not have to return those funds, in light of the limited, five-year extension; 0 Required seismic and other safety review processes so that the continued safety of workers and surrounding residents would be considered in the extension of an aging facility; Required that the financing process around the state loan for the extension process have very limited exposure to utility ratepayers and state taxpayers; 1 of 3 Required a regular California Coastal Commission approval of the extension, with the time for that process limited; Provided a process and funding for the protection of and public access to the Diablo Canyon Lands, which surround the plant; 0 Limited the extension to 2030 to allow for the use of transmission for the energy generated by offshore wind at the Morro Bay Wind Energy Area; Provided for the purchase of fuel in a timely manner to meet the extended plant life; and Set forth provisions about maintenance of facilities; planning for economic reuse of the Parcel P section of the plant; raised the once-through-cooling fee with an eye to certain expenses; and provided one billion dollars over three years for additional renewable electricity development in California.

I list these items, because many of them have are in different stages of process, and have not been completed. For example, 0 The safety analysis will not be completed until the embrittlement of Unit 1 can be tested, which will not be done until 2025, with the results available no earlier that 2026; While the loan has been approved at the federal level, it does not reach the level expected to cover all costs of plant extension, and the risk to the taxpayers and ratepayers must still be protected, especially at a time when PG&E rates are going through the roof across California; PG&E's application to the California Coastal Commission for a Consistency Certification (under the Coastal Zone Management Act) has not been completed, and the conditions of the consistency determination, and of a coastal development permit, have not been developed nor implemented; The federal government has issued three leases for offshore wind in the Morro Bay Wind Energy Area since SB 846 was enacted, and the process of involving different stakeholders and attempting to resolve differences has only just begun;

\\

The once-through-cooling fee issues have not _been resolved; and The process for reviewing options for the Diablo Canyon Lands is underway but is at the early stages.

In short, many of the issues that might be involved in an additional fifteen-year extension have not even been resolved yet for the five-year extension set forth in SB 846. Therefore, it is clear that any discussion of an extension beyond what was enacted with SB 846 is very premature.

There are other issues that are also worthy of examination. If Diablo Canyon Power Plant were to continue twenty years from the current time, it would not likely justify transition pay for the workers, as SB 1090 and SB 846 intended, and implications of this would have to be explored.

2 of3 For all these reasons, as well as the fact that a stakeholder and public participation process similar to what occurred prior to the enactment of SB 846 has not been completed, I would recommend that the Board set aside a resolution for a further extension at this time. That could be properly considered if the additional five years progressed according to the terms of SB 846, and the safety and other issues were properly and completely addressed, including coordination with offshore wind and other renewable energy development efforts, and, importantly, the financial risk to already stressed ratepayers.

The State Legislature and Governor have only authorized the five-year extension ofDiablo Canyon Power Plant beyond 2025, and as a state legislator from this region, I would certainly not support any legislation for a further extension until the extension we have already approved is fully permitted, and all the attending issues outlined above are fully considered and addressed.

Very Truly Yours, JOHN LAIRD State Senator, 17th District cc:

Chris Patterson, VP, State & Local Government Relations Rep. Salud Carbajal Rep. Jimmy Panetta Sen. Monique Limon Asm. Dawn Addis Rebecca Campbell, SLO County Chief Administrative Officer 3 of3

Good evening my name is Belinda Popovich, Vice President of Marketing for the Santa Maria Valley Railroad.

The Santa Maria Valley Railroad is a short line railroad located in the Santa Maria Valley and we interchange with the Union Pacific Railroad in Guadalupe. The Santa Maria Valley Railroad has had various relationships with PG&E, from transporting their freight that strengthen our community's grid to working together on utility easements along the railroad right of way.

As a clean & green transportation system, the Santa Maria Valley Railroad wants to do our part to help with the safe transportation of the dismantling of the Diab lo Power Plant when the appropriate time arises.

As California mandates to electrify all modes of transportation systems and our local City &

County governments seek to encourage the reliance on renewable energy such as the City of San Luis Obispo wanting gas appliances in new construction to be switched to all electrical appliances. This will require the state to increase the production of electricity but at this point the demand for renewable electricity cannot keep pace with the demands needed by our counties &

state to reach these goals.

It has been our personal experience with the PG&E Diablo Team and Right of Way Construction Teams, that they are an exemplary company with excellent safety culture. We have seen for ourselves in working with these teams that safety is of the upmost importance, with this we can confidently support their teams and the continuation of the safe operation of the Diablo Plant.

Decommissioning of the power plant would mean that we are able to provide transportation options for the plant but the need for clean and safe electrical production for our community is by far more important and that is why we wholeheartedly support the extension for the operation of the diablo canyon nuclear power plant.

Califorina's Most Promising Geological Formation for Spent Fuel "The California Option" mboldt Bay Siskiyou E)

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Contact:

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https://adamswebsearch2.nrc.gov/webSearch2/maln.jsp?AccessionNumber=ML24281A106 From:

Sent:

To:

Cc:

Subject:

Attachments:

Perry Buckberg govern ment@cgnp.org Wednesday, October 2, 2024 11:16 PM Perry Buckberg Info; Peter Bird; Tanya Black

[External_Sender] RE: Pacific Gas & Electric Company; Diablo Canyon Power Plant, Unit Nos. 1 and 2; 10 CFR 2.206 Petition dated March 4, 2024 CGNP to Perry Buckberg 10 02 24.pdf Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 telephone: 301-415-1383 email : Perrv.Buckberq@nrc.gov RE: Pacific Gas & Electric Company; Diablo Canyon Power Plant, Unit Nos. 1 and 2; 10 CFR 2.206 Petition dated March 4, 2024 October 2, 2024 Hello, Mr. Buckberg: Please see the attached letter from CGNP regarding the matter shown in the subject line.

This letter is being CC:ed to the Diablo Canyon Independent Safety Committee, The California Seismic Safety Commission, and Dr. Peter Bird at UCLA. We look forward to your feedback.

Sincerely,

/sf 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 https:/ /greennuke.substack.com Substack

Hearing Identifier:

Email Number:

NRR_DRMA 2615 Mail Envelope Properties (0fe324c1f75baffc7d3c7589f9095382)

Subject:

[External_Sender] RE Pacific Gas & Electric Company; Diablo Canyon Power Plant, Unit Nos. 1 and 2; 10 CFR 2.206 Petition dated March 4, 2024 Sent Date:

10/2/2024 11: 16: 12 PM Received Date:

10/2/2024 11: 17:28 PM From:

government@cgnp.org Created By:

Recipients:

"Info" <info@dcisc.org>

Tracking Status: None government@cgnp.org "Peter Bird" <pbird@epss.ucla.edu>

Tracking Status: None

'Tanya Black" <tanya.black@caloes.ca.gov>

Tracking Status: None "Perry Buckberg" <Perry.Buckberg@nrc.gov>

Tracking Status: None Post Office:

cgnp.org Files Size MESSAGE 993 CGNP to Perry Buckberg 10 02 24.pdf Options Priority:

Return Notification:

Reply Requested:

Sensitivity:

Expiration Date:

Normal No No Normal Date & Time 10/2/2024 11:17:28 PM 2748028

~~~

green nucle*ar p&wer WWW.CGNP~

Perry Buckberg Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 telephone: 301-415-1383 email: Perry.Buckberq@nrc.gov RE: Pacific Gas & Electric Company; Diablo Canyon Power Plant, Unit Nos. 1 and 2; 10 CFR 2.206 Petition dated March 4, 2024 October 2, 2024 Hello, Mr. Buckberg:

Independent nonprofit intervenor in the public interest Californians for Green Nuclear Power is concerned that Peter Bird, Ph.D.'s claims regarding the importance of active thrust faulting at Diablo Canyon Power Plant (DCPP) site are exaggerations based on making false analogies to the Noto Peninsula in Japan.

I observed and heard Dr. Bird's presentation regarding Agenda Item XXIX while attending in-person the June 21, 2024 Diablo Canyon Independent Safety Committee meeting which Dr. Bird attended remotely.

As one of CGNP's representatives, I have commented during earlier NRC proceedings regarding DCPP's seismic robustness.

This is the version of my comments that appeared in the NRC report released to the public regarding the 28 April 2015 meeting between the NRC, their consultants, and the owner of Diablo Canyon Power Plant.

The staff received a comment from Dr. Gene Nelson (Physical Sciences professor at Cuesta College and Government Liaison for Californians for Green Nuclear Power) via email during the meeting. The NRC staff inadvertently missed the opportunity to acknowledge Dr. Nelson's comment during the meeting.

According to Dr. Nelson, Diablo Canyon has favorable site conditions, which attenuate or dissipate earthquake energy over relatively short distances. Due to these favorable conditions, the primary earthquake forces seen by the plant would be dominated by nearby earthquake sources and energy transmitted to the plant would be dominated by

CGNP to NRC Office of Nuclear Reactor Regulation October 2, 2024 Page 2 of 4 the small section of the earthquake rupture closest to the plant. Dr. Nelson stated that when considering the information presented at the meeting of overall plant ruggedness and the seismic hazard insights discussed above, Diablo Canyon will continue to operate safely - with generous safety margins - during anticipated earthquakes.

During his June 21, 2024 DCISC presentation, Dr. Bird asserted there were significant similarities between the tectonic setting at the Noto Peninsula in Japan and the present conditions at the DCPP site. I hold that is not the case.

1. The largest recent earthquake near the DCPP site was the Magnitude 6.6 San Simeon Earthquake on December 22, 2003. The epicenter was about 20 miles NNW of DCPP. The rupture propagated to the southeast for 12 miles. The shaking was sufficient to damage buildings in Paso Robles, California and kill two. Total damage was $250-300 million. DCPP's operations were unaffected by this earthquake. The plant operated at full power before, during, and after this earthquake. Essentially all of the active earthquake faults in the immediate vicinity of DCPP are strike-slip.
2. The Magnitude 7.5 January 1, 2024 earthquake on the Noto Peninsula caused at least 401 fatalities. Damage was about $17.6 billion. The Noto Peninsula is a complex tectonic setting which could be in the process of becoming a subduction zone. The Japan Meteorological Agency supplied the following earthquake swarm map of the Noto Peninsula. The earthquakes began in December, 2020.

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CGNP to NRC Office of Nuclear Reactor Regulation October 2, 2024 Page 3 of 4 A May 5, 2023 Magnitude 6.5 earthquake preceded the January 1, 2024 earthquake. Thrust faulting and folding is apparent in the Noto Peninsula. The uplift at Kaiso Fishing Port in Wajima was 4 m (13 ft) exposing parts of the seafloor that were submerged before this earthquake.

3. One of the markers for active thrust faulting in California is the presence of commercially exploitable petroleum reserves. The nearest production fields to DCPP are in Carpenter Canyon, about 10 miles to the southeast of DCPP. There are also production fields in San Ardo, over 30 miles to the north of DCPP. There are also offshore production fields more than 30 miles to the south of OCPP.
4. I agree with Dr. Bird that there has been thrust faulting in the Irish Hills area. However, this thrust faulting likely antedates by millions of years the Holocene epoch, which began about 11,700 years ago. Active faulting during the Holocene epoch is a significant NRC regulatory concern.

Here's a photograph I took in December, 2022 of some compressionally-folded sedimentary limestone deposits at about the 600 foot elevation on a hill to the south of Avila Beach, California. This is a road cut. The width is about 2-3 meters.

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CGNP to NRC Office of Nuclear Reactor Regulation October 2, 2024 Page 4 of 4 A bit further to the west on this road, the sedimentary deposits are completely vertical instead of horizontal. The edge of the road is at the bottom of the image which is 2-3 meters wide.

I'm confident the NRC is aware of this information, but I wished to insure this is the case.

Sincerely, 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 https://greennuke.substack.com Substack CC:

Via email to The Diablo Canyon Independent Safety Committee California Seismic Safety Commission Peter Bird, Ph.D.

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