ML25008A061
| ML25008A061 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/16/2024 |
| From: | Mansfield-Wells J - No Known Affiliation |
| To: | Office of Administration |
| References | |
| NRC-2023-0192, 89FR87433 00029 | |
| Download: ML25008A061 (1) | |
Text
PUBLIC SUBMISSION As of: 1/8/25, 7:44 AM Received: December 16, 2024 Status: Pending_Post Tracking No. m4r-swxp-2bc3 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-0038 Comment on FR Doc # 2024-25444 Submitter Information Name: Julie Mansfield-Wells Address:
Los Osos, CA, 93402 Email:ja.gibson@att.net General Comment Environmental Impact - Diablo Canyons Once Through Cooling (OTC) System For the past 40 years, the antiquated cooling system at Pacific Gas & Electric Companys Diablo Canyon nuclear power plant has killed billions of fish, endangered marine mammals and sea turtles, and degraded the ocean environment near a marine sanctuary on the Central Coast of California.
According to PG&E, the plants intake structure is 240 feet long, 100 feet wide, and 18 feet high and extends down some 30 feet below sea level. The intake structure is located at the shoreline in Intake Cove, a cove fragment constructed for the purpose of protecting the intake from the large seas in the Diablo Canyon area. Its four 13,000-horsepower electric motors pump 1.7 million gallons of seawater per minute, or up to 2.5 billion gallons per day.
Every day, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, seven days per week, 365 days per year, Diablo Canyon circulates 2.5 BILLION gallons of seawater through its OTC system. The plants cooling system discharges water back into the cove 20 degrees (F) hotter, devoid of any life. Each year of operation, the plant sucks in more than a billion fish in early life stages while killing vast amounts of plankton, the foundation of life in our oceans.
In 2010, the State Water Board ordered all coastal power plants to phase out OTC systems, but PG&E obtained a temporary exemption and planned to fully decommission the plant by the end of 2025. Then, due to the passage of Senate Bill 846 in 2022 (which proposes operating the plant for an additional five years), the State Water Board extended the date for Diablos compliance with the OTC rules to October 31, 2030, and the State Lands Commission extended the land leases to 2030 to coincide with this date.
1/8/25, 7:45 AM blob:https://www.fdms.gov/0b32f9df-456b-4211-acbb-9e1fd4d5584c blob:https://www.fdms.gov/0b32f9df-456b-4211-acbb-9e1fd4d5584c 1/2 SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Kim Conway, Antoinette Walker-Smith, Mary Neely Comment (29)
Publication Date:
11/1/2024 Citation: 89 FR 87433
If Diablo Canyons operating licenses are extended an additional 20 years, PG&E will be required to build cooling towers or other alternative cooling systems by 2030 to comply with Californias OTC regulations.
A 2013 report by PG&E contractor, Bechtel Power Corp., projected that a closed-cycle cooling system would cost $6 to $12 BILLION. These costs have no doubt increased since 2013, and most certainly would be charged to Californias ratepayers and taxpayers. A State Water Board subcommittee reviewed the Bechtel report, and found no basis for further exemptions of Diablo Canyon from the OTC Policy.
According to the Bechtel report, construction of alternate cooling systems could take as long as 14 years and be subject to California Environmental Quality Act review, as well as other lengthy permitting processes. The Diablo Canyon Independent Safety Committee (DCISC) maintains that the extensive retrofitting necessary for any proposed closed-cooling systems would require PG&E to file a license amendment request with the NRC. PG&E has argued previously that the cost to phase out OTC at Diablo Canyon is too high.
With rapid worldwide depletion of fisheries and aquatic biodiversity, it is unacceptable to allow this decimation of marine life to continue in order to produce approximately 9 percent of Californias energy.
If the impact is so minimal as the SEIS states, why did the State Water Board create a law to phase out these destructive OTC systems?
Additionally, the seawater intake structure is vulnerable to rising levels of ocean water brought on by global climate change. The water that cools the plant is warmed by 20 degrees (F) before being discharged back into the ocean, contributing further to ocean warming. Think about it: 2.5 billion gallons every single day for 20 more years. The math and the impacts are almost incalculable. This aging plant must be decommissioned now; no license extension should be allowed. For additional details on Diablos adverse marine impacts, see:
https://www.sanluisobispo.com/news/local/environment/article258804173.html Attachments Cooling Towers at DCNPP - Artist's Rendering 1/8/25, 7:45 AM blob:https://www.fdms.gov/0b32f9df-456b-4211-acbb-9e1fd4d5584c blob:https://www.fdms.gov/0b32f9df-456b-4211-acbb-9e1fd4d5584c 2/2
1/8/25, 7:48 AM 90e964bf-08e6-4f9a-bfdd-5b70fbb79bdf (504x326) blob:https://www.fdms.gov/90e964bf-08e6-4f9a-bfdd-5b70fbb79bdf 1/1