NRC-2013-0192, Comment (28) of Fereshtek Bunk on Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2; Draft Supplemental Environmental Impact Statement
| ML25008A059 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/16/2024 |
| From: | Bunk F Mothers For Nuclear |
| To: | Office of Administration |
| References | |
| NRC-2013-0192, 89FR87433 00028 | |
| Download: ML25008A059 (1) | |
Text
PUBLIC SUBMISSION As of: 1/8/25, 7:38 AM Received: December 16, 2024 Status: Pending_Post Tracking No. m4r-sjx8-3fj2 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-0037 Comment on FR Doc # 2024-25444 Submitter Information Name: Fereshteh Bunk Address:
Los Osos, CA, 93402 General Comment My comment is attached as a PDF. Thank you Attachments My NRC Comment 1/8/25, 7:38 AM blob:https://www.fdms.gov/ccdd2b39-1fca-4bff-afb6-da219b2a9339 blob:https://www.fdms.gov/ccdd2b39-1fca-4bff-afb6-da219b2a9339 1/1 SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Kim Conway, Antoinette Walker-Smith, Mary Neely Comment (28)
Publication Date:
11/1/2024 Citation: 89 FR 87433
Hello NRC, I appreciate the opportunity to provide feedback on this draft report. My name is Fereshteh Bunk. I am a resident of Los Osos in San Luis Obispo County here in California, right by Diablo Canyon Power Plant. I am also a recent graduate from California Polytechnic State University, San Luis Obispo with a Bachelor's degree in Physics and a minor in Indigenous Studies of Natural Resources and the Environment. I currently work for Mothers for Nuclear. This comment reflects my personal opinions. Although this comment does align with the perspective of Mothers for Nuclear, I am not commenting on the nonprofits behalf.
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 a citizen concerned about climate change, I was very pleased to see the inclusion of greenhouse gas emissions analysis in Section 3.15.31 highlighting the importance of clean energy in addressing climate change.
However, there are 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.
Since 2020, California has struggled with reliability, 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% of our states electricity. In 2022, the state legislature passed SB846, the bill that requested the continuation of DCNPP because of grid reliability concerns and insufficient capacity. In 2023 the California Energy Commission report confirmed concerns and warned of energy shortfalls, recommending Diablo stay online until 2030. If the plant is decommissioned, since natural gas is Californias marginal utility, dependence on natural gas and emissions would increase, as seen after San Onofre's closure.
2.
Purchased Power Alternative: The EIS understates the 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% 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.
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, Fereshteh Bunk Operations Associate for Mothers for Nuclear BA in Physics & Minor in Indigenous Studies of Natural Resources & the Environment