ML22203A046
| ML22203A046 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/21/2022 |
| From: | Californians for Green Nuclear Power |
| To: | Office of Administration |
| References | |
| 87FR37533 00003, NRC-2022-0132 | |
| Download: ML22203A046 (3) | |
Text
7/22/22, 9:08 AM blob:https://www.fdms.gov/6712d7b0-91e7-4273-8990-16e3c1e6dc4d SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 As of: 7/22/22 9:08 AM Received: July 21, 2022 PUBLIC SUBMISSION ADD: Felica Keith, Samson Lee, Jennifer Harrity-Dixon. Mary Status: Pending_Post Tracking No. l5v-pxfc-4wjb Neely Comment (3)
Comments Due: October 19, 2022 Publication Date: Submission Type: Web 6/23/2022 Citation: 87 FR 37533 Docket: NRC-2022-0132 Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2; Post-Shutdown Decommissioning Activities Report Comment On: NRC-2022-0132-0001 Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2; Post-Shutdown Decommissioning Activities Report Document: NRC-2022-0132-DRAFT-0003 Comment on FR Doc # 2022-13406 Submitter Information Email: government@CGNP.org Organization: Californians for Green Nuclear Power, Inc.
General Comment Please see CGNP's attached two-page Comments which form the basis for our spoken comments at the July 21, 2022 NRC Diablo Canyon Power Plant meeting regarding planned decommissioning. . CGNP will upload the supporting exhibits in a subsequent Comment.
Attachments CGNP's Comments to the NRC Objecting to DCPP Decommissioning Plans 07 21 22-1 blob:https://www.fdms.gov/6712d7b0-91e7-4273-8990-16e3c1e6dc4d 1/1
https://www.regulations.gov/commenton/NRC-2022-0132-0001 RE: Docket ID NRC-2022-0132 July 21, 2022 CGNP's Comments to the NRC Objecting to the DCPP Decommissioning Plans There have been a set of changed circumstances in California that call into question the January 11, 2018 CPUC Decision to voluntarily close Diablo Canyon Power Plant (DCPP) in 2025. In the view of the independent nonprofit Californians for Green Nuclear Power, Inc. (CGNP) and several other organizations, those changed circumstances should be sufficient to cause a halt in the State of California plan to voluntarily cease DCPP operations in 2025. This will conserve ratepayer resources. Instead, appropriate resources should be organized at the local, state, and federal level to promptly renew DCPP's NRC operating license and continue DCPP's operations to 2045 at a minimum.
DCPP's owner, Pacific Gas and Electric (PG&E) has been a good DCPP steward. PG&E executed well-planned steam generator replacements in 2008 and 2009, earning awards from POWER Magazine.
PG&E has also been an industry pioneer in replacement of DCPP's original analog controls with modern, redundant digital process controls. In conjunction with the NRC, the plants Independent Safety Committee (DCISC.org) has provided excellent oversight of PG&Es plant operation. DCPP operates independently of California's aging and fragile natural gas transmission system which provides 95% of the natural gas used to power about 3/5 of California's dispatchable generation. DCPP has an exemplary environmental and safety record with all NRC performance indicators being in "green" status. DCPP was designed to last a century. DCPP's staff are well-trained. As a result, when an off-site special protection circuit gave an erroneous failure indication on December 1, 2018, Unit 2 experienced an unplanned full-load trip, which is a rigorous test of operator and plant system performance. After careful inspection, this unit was restored back to full power operation in about five days. Per a May 8, 2020 NRC letter (ML20093B934,) DCPP passed its post-Fukushima review of beyond design basis seismic and flooding readiness with no additional actions required.
DCPP license renewal will result in prevention of environmental damage from the planned replacement of its nominal 18 terawatt-hours per year of DCPP's essentially emission-free, dispatchable generation mostly with dispatchable emission-laden Wyoming coal-fired and natural-gas-fired generation. When the costs of Wyoming-based generation and transmission to California load centers are summed, the post-2025 result is more expensive power for California ratepayers.
DCPP has short, triply redundant connections with wide rights of way, per previous NRC filings, to the main 500 kV AC "backbone" to the California bulk power system. In contrast, the post-2025 State of California plan depends on an expensive (almost $ 20 billion) new transmission network that traverses tinder-dry, poorly-managed forests in Idaho, Oregon, California, Arizona, and Nevada - endangering California grid reliability. See "Wildfires Raise Concerns for Western Tx Lines" by Hudson Sangree, August 2, 2021, RTO Insider. https://www.rtoinsider.com/articles/28328-wildfires-raise-concerns-for-western-tx-lines This problem was illustrated by the effects of the Bootleg Fire on Path 66, (also known as the Pacific AC Intertie ) which has a capacity of about 5,000 MW, during the evening of Friday, July 9, 2021. With climate change, the trend to 2045 will likely be a far greater danger to California grid reliability with the State of California plan. These issues were discussed during a panel presentation at the national meeting of the American Nuclear Society (ANS) in Anaheim, California on June 15, 2022.
CGNP's comments at this meeting are included in the attached slides with speaker notes.
CGNP's attached April 5, 2022 OpEd in California Weekly summarizes the environmental, ratepayer, and reliability harms of the State of California plan. For the benefit of the Nuclear Regulatory Commission, excerpts from the cited California Public Utilities Commission (CPUC) filings that substantiate CGNP's concerns are also attached. DCPP's power is required to serve vital California 24/7 water pumping loads.
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CGNP's concerns have apparently been heard at the state and federal level, with published comments from California governor Newsom and members of the Biden administration now supporting continued DCPP operations beyond 2025. At the local level, since 2018, CGNP operated a booth at the City of San Luis Obispo Farmer's Market. We have noted strong public support for the continued safe operation of DCPP beyond 2025 at our booth. We have gathered approximately 1,000 signatures of support. Since 2016, CGNP made frequent public comments in support of continued DCPP operations at the San Luis Obispo County Board of Supervisors meetings. A majority of the Board support CGNP's perspective.
CGNP has also been strong advocates for continued safe DCPP operation beyond 2025 before the Diablo Canyon Safety Committee (DCISC) and before the Nuclear Regulatory Commission, among other regulatory and oversight bodies. CGNP anticipates being granted Party status soon in a new CPUC Proceeding, the new DCPP Nuclear Decommissioning Triennial Cost Proceeding (NDTCP.) As a result, CGNP will have Party status in a dozen relevant CPUC Proceedings. We have filed comments in several relevant FERC Proceedings, including filing a Complaint in EL21-13-000. Our carefully-drafted well-footnoted written testimony totals several thousand pages.
CGNP's summary is that conditions have been significantly changed since January 11, 2018. We request a halt to the decommissioning planning process. We request that all bodies work instead on restarting DCPP's NRC Licensing Renewal Application, which began in 2009 and was sidelined by State of California actions in 2016. The result will be significant environmental benefits, a reduction in ratepayer costs, and enhanced California public safety stemming from increased California grid reliability.
File List:
Exhibit 1. CGNP's American Nuclear Society slides and speaker notes showing DCPP's important California grid reliability role Exhibit 2. CGNP's April 5, 2022 Capitol Weekly OpEd summarizing the harms of the State of California plan associated with DCPP's unnecessary planned 2025 shut down.
Exhibit 3. Excerpts from the CPUC's June 24, 2021 Procurement Order in R.2005003 that establish the important reliability role of 5,000 MW of "unspecified imports" and the special confidential treatment for the suppliers of unspecified imports.
Exhibit 4. Three-page CPUC July 1, 2021 summary of their June 24, 2021 R.2005003 Procurement Order showing the supply stacks by year. The important role of unspecified imports and "shortfall" is shown.
Exhibit 5. Excerpts from the CPUC's February 10, 2022 R.2005003 Preferred System Portfolio showing the arbitrary and unsupportable modeling assumption that the criteria emissions from unspecified imports from 5,000 MW of out-of-state are artificially set to zero.
Exhibit 6. November, 2021 Stanford and MIT study showing the benefits of continued safe operation of DCPP for power reliability, desalinated water supply, and emission-free source of hydrogen for fuel and industrial purposes.
Exhibit 7. Schedule 1 from CAISO showing CDWR's Participating Load Agreement dated August 21, 2021.
These vital California pumping loads total 2,858 MW, which exceeds DCPP's 2,256 MW.
Exhibit 8. July 19, 2022 E&E Wire article, "Calif.s last nuclear plant faces closure" by Anne Mulkern.
While this article focuses on arguments of plant opponents, it also includes the admission that California grid reliability is poor at least until 2030. Per CGNP's above criticism of the State of California plan, if DCPP is shut down, California grid reliability will suffer for decades, not just five years.
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