ML25008A058
| ML25008A058 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/16/2025 |
| From: | Poggemann C - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 89FR87433 00027, NRC-2023-0192 | |
| Download: ML25008A058 (1) | |
Text
PUBLIC SUBMISSION As of: 1/8/25, 7:34 AM Received: December 16, 2024 Status: Pending_Post Tracking No. m4r-saoq-28xe Comments Due: December 16, 2024 Submission Type: Web Docket: NRC-2023-0192 Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2 Comment On: NRC-2023-0192-0013 Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2; Draft Supplemental Environmental Impact Statement Document: NRC-2023-0192-DRAFT-0036 Comment on FR Doc # 2024-25444 Submitter Information Name: Connor Poggemann Address:
Morro Bay, CA, 93442-3160 General Comment
Dear NRC,
I appreciate the opportunity to provide feedback on this draft report. I am Connor Poggemann, a Cal Poly physics graduate and resident of Morro Bay in SLO County.
Thank you for conducting a thorough analysis of the environmental impact of the Diablo Canyon Nuclear Power Plant (DCNPP) and its alternatives. I agree with your recommendation that the environmental impacts of Diablo Canyon Nuclear Power Plant are minimal and should not prohibit a license renewal. It was reassuring to see in Section 3.14 that there is no new, significant information about its environmental effects. As I am concerned about climate change, I was very pleased to see the inclusion of greenhouse gas emissions analysis in Section 3.15.31 highlights the importance of clean energy in addressing climate change.
However, please find below my feedback on specific areas of the report that I believe could benefit from further consideration and refinement.
- 1. No-Action Alternative: The analysis attempts to detail the negative impacts of not issuing the permit to DCNPP, but fails to address their implications for decarbonization efforts and grid reliability California has struggled with reliability since 2020, when the state had its first rolling blackouts since 2001, leaving nearly 2 million citizens without power for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. It is assumed that California can replace DCNPP, a plant that provides 10 per cent of our states electricity and ignores state policies passed to prevent the closure. In 2022, the state legislator passed SB846, the bill that reversed and requested the continuation of the plant due to grid reliability concerns and insufficient capacity. Furthermore, in 2023 the California Energy Commission report confirmed concerns and warned of energy shortfalls, 1/8/25, 7:35 AM blob:https://www.fdms.gov/7e1987f6-345d-47e9-a8b4-c41b7e9dbcb5 blob:https://www.fdms.gov/7e1987f6-345d-47e9-a8b4-c41b7e9dbcb5 1/2 SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Kim Conway, Antoinette Walker-Smith, Mary Neely Comment (27)
Publication Date:
11/1/2024 Citation: 89 FR 87433
recommending Diablo stay online until 2030. If the plant is decommissioned, because natural gas is our marginal utility, our dependence on natural gas and emissions would increase as seen after San Onofre's closure.
- 2. Purchased Power Alternative: The EIS understates the socio-economic, GHG emissions, and environmental justice impacts of increasing energy output from existing generating facilities while also overestimating the states ability to procure capacity.
Because the state has struggled with reliability during times of high demand, expensive procurements and extensions of fossil fuels have burdened citizens. Californias electricity prices, already among the nation's highest, continue to rise, with many residents struggling to pay their bills. Although the report correctly states that emissions from purchased power will initially increase GHG emissions it assumes that because the state has mandates to stop burning fossil fuels after 2045 this means it will happen.
However, the state had originally planned to close Diablo in 2016 claiming that enough replacement power would be ready but in 2022 that wasnt the case and SB846 legislation was passed to extend Diablo.
The loss of DCNPP was calculated in the MIT-Stanford report which found that delaying DCNPPs retirement could reduce carbon emissions by over 10%, save billions in energy costs, and improve grid reliability.
Delaying the retirement of Diablo Canyon to 2035 would reduce California power sector carbon emissions by more than 10 per cent from 2017 levels and reduce reliance on gas, save $2.6 Billion in power system costs, and bolster system reliability to mitigate brownouts; if operated to 2045 and beyond, Diablo Canyon could save up to $21 Billion in power system costs and spare 90,000 acres of land from use for energy production, while meeting coastal protection requirements.
- 3. Renewables Combination Alternative: The framing of this alternative assumes sufficient capacity and underestimates the land and resource demands of renewable energy.
Nuclear energy, especially existing sites like DCNPP, has a significantly lower environmental footprint than solar, wind, or hydro when considering emissions and land use.
- 4. Table 3-34, the EIS incorrectly assumes that after 2045 the emissions are negligible. This fails to acknowledge the states inability to procure energy capacity and assumes the lost power from nuclear and gas will be replaced with clean energy sources.
In conclusion, I appreciate the thorough analysis and agree with your ultimate determination. However, I believe the report could benefit from a more detailed discussion of the potential negative outcomes of the alternatives to DCNPPs clean energy supply. I kindly ask that you consider this research when refining the final report. Thank you for the time and effort your team has dedicated to reviewing my comments.
Sincerely, Connor Poggemann Cal Poly Astrophysics Researcher 1/8/25, 7:35 AM blob:https://www.fdms.gov/7e1987f6-345d-47e9-a8b4-c41b7e9dbcb5 blob:https://www.fdms.gov/7e1987f6-345d-47e9-a8b4-c41b7e9dbcb5 2/2