IV Action Items: C. Discussion of open items list (maintenance needed)
Afternoon Session – 02/15 – 1:30pm
XII Discussion: review, evaluation, and assessment of matters affected by extended operation under SB 846 including seismic safety, maintenance, and capital project planning
Evening Session – 02/15 – 5:15pm
XVIII Presentation by PG&E
1. update on planning for both decommissioning and extended operations, including plans for license renewal
2. plans for reviewing, approving, and implementing capital projects and changes to maintenance programs needed to support extended operations
3. status of retention programs, attrition, and efforts to retain qualified staff for extended operations
Morning Session – 02/16 – 9:00am
XXV Presentation by PG&E on the state of the plant including key events, outages, highlights, organizational changes, results of refueling outage 2R23, Unit 2 reactor coolant system piping leak and other issues
Afternoon Session – 02/16 – 1:15pm
XXXI Presentation by PG&E on spent fuel management
CALIFORNIA GROUPS TO PG&E: YOU CAN’T CUT CORNERS ON DIABLO CANYON EXTENSION
Following Successful Petition For NRC To Deny Request to Resume Diablo Canyon Renewal Application, Environmental Groups File New Response Asserting PG&E Request for Exemption to Operate Past 40-Year Lifespan Must be Denied.
SAN LUIS OBISPO, CA – FEBRUARY 13, 2023 – On January 24, the U.S. Nuclear Regulatory Commission (NRC) denied a formal request by Pacific Gas & Electric (PG&E) to resume reviewing a 2009 license renewal application to extend the operating life of Diablo Canyon’s twin nuclear reactors, which the company withdrew in 2018. In conjunction, Petitioners San Luis Obispo Mothers for Peace (SLOMFP), Friends of the Earth (FoE), and the Environmental Working Group (EWG) today filed a new petition demanding that the NRC finish its legal obligation to keep Diablo Canyon on schedule to close its twin units in 2024 and 2025 and repudiate PG&E’s recent request for exemption from the “Timely Renewal Rule.”
According to the petitioners, PG&E has no lawful path to continued uninterrupted operation of the Diablo Canyon nuclear reactors after its operating licenses expire in November 2024 (Unit 1) and August 2025 (Unit 2). Granting an exemption from this rule would force the NRC to cram the three-year safety and environmental review process and offer a public hearing into a mere ten months. The catalog of issues the NRC staff must review is so extensive that to cram a complex government review into the short ten-month period between the submission of the license renewal application and the expiration of the Unit 1 license would be difficult if not impossible. Completion of the NRC’s review process, including public hearings, is essential to assure that continued operation of the reactors will be safe for the public and the environment.
Diane Curran, legal counsel for Mothers for Peace, said: “There is absolutely no precedent for the exemption requested by PG&E. The NRC has never allowed a reactor to operate past its license expiration dates without thoroughly assessing the safety and environmental risks. And it must do so in this case too.”
Further, Curran observed that “it would be irrational and irresponsible for the NRC to permit PG&E to operate aging and deteriorating reactors encumbered by aging equipment risks, seismic risks and environmental impacts without a thorough environmental and safety review.”
“NRC’s recent decision to reject PG&E’s request to renew its outdated, withdrawn license renewal application gave us hope that the law is being properly and thoroughly applied to this risky decision,” said Hallie Templeton, Legal Director for Friends of the Earth. “An operating permit extension for any nuclear power plant has major implications for people and the planet. With Diablo Canyon receiving only minimal – if any – safety updates in decades, PG&E’s push to reduce the NRC’s review from several years to several months creates an especially deadly equation. Today’s filing clearly outlines why NRC must proceed with the utmost care and caution, as mandated by a federal law.”
Caroline Leary, an attorney for EWG, said: “PG&E argued to the NRC that its request for an exemption from federal regulations was necessitated by the California Legislature’s vote in favor of extending Diablo’s operation. But nothing in S.B. 846, the law passed by the Legislature, calls upon NRC to relax its safety or environmental regulations for the purpose of extending Diablo Canyon’s operation. In fact, the law relies on the NRC to ensure that if Diablo Canyon continues to operate, it will not put the public or the environment at risk.”
Just as the NRC stood its ground and upheld its own policies by denying PG&E’s request to resurrect its 2009 license renewal application, it should also deny PG&E’s request for an exemption of the timely renewal rule.
The NRC’s January 24 decision  affirmed recent arguments in the earlier petition by San Luis Obispo Mothers for Peace (SLOMFP), Friends of the Earth (FoE), and Environmental Working Group (EWG) that resuming review of PG&E’s withdrawn license renewal application would be unlawful. The organizations demanded successfully that the NRC deny PG&E’s October 31, 2022, request to resume review of the application.
The decision prevents PG&E from circumnavigating NRC regulations that require the company to file a new and up-to-date license renewal application, which would take 3-5 years. PG&E previously admitted that the application was severely outdated and could not be updated or completed until late 2023 – a year before the Unit 1 license term expires. It now appears that PG&E may have to close Diablo Canyon when its licenses expire in the fall 2024 (Unit 1) and spring 2025 (Unit 2) and keep them closed unless and until the NRC approves a new license renewal application.
PG&E reports nuclear reactor welding leak at Diablo Canyon facility
EWG: Critical questions about coolant system damage go unanswered
SAN FRANCISCO – Pacific Gas & Electric found damage to part of a reactor cooling system at the aging Diablo Canyon nuclear plant in California, but it hasn’t yet answered key questions about the extent of the problem.
PG&E is the owner of the state’s last remaining nuclear power plant, and found the fault with the reactor coolant system during a routine inspection in October. PG&E detailed the damage in a report to the Nuclear Regulatory Commission, or NRC, in December.
The power company says the system had a crack in the welding of the wall of Diablo Canyon’s Unit 2 reactor, which was shut down for refueling. PG&E says the presumed cause was fatigue, which was caused by vibrations at the facility indicating a weld defect. The utility says the damage meant the unit fell short of NRC operating requirements.
PG&E says it repaired the leak, and the public and plant workers were never at risk. But the utility’s filing with the commission raises several questions, including:
When was the affected weld last inspected?
When does PG&E believe the crack in the weld formed?
Why had the weld flaw not been identified?
What was the size of the leak when it occurred?
“The communities near Diablo Canyon deserve to know the full details of the incident, how it happened, why it wasn’t discovered earlier and how long it took for PG&E to identify the damage to the reactor coolant system,” said Environmental Working Group President and California resident Ken Cook.
“The main reason for shuttering this aging facility is the potential threat it poses to the public – and PG&E’s overall safety record across its vast service area in the state is among the worst of any power company in the country,” Cook said.
Diablo Canyon’s latest problem highlights ongoing concerns about the stability of the facility and shows why EWG and others are pushing to shut the plant down.
Yet state and federal officials are trying to keep the aging facility operating beyond 2025, when it’s slated to shutter under the terms of a settlement carefully negotiated between PG&E, California and environmentalists.
Last September, at the urging of California Gov. Gavin Newsom, the state legislature approved Senate Bill 846, a law that will keep the plant operating for five more years, until 2030. It will also give PG&E a $1.4 billion loan to cover costs during that extra time.
In November, the Biden administration announced it will give PG&E more than $1 billion in federal funding to keep the plant operating past its scheduled 2025 closure date.
PG&E has also petitioned the NRC to fast-track its October 31 request to extend the license of the twin Diablo Canyon reactors. Four environmental organizations, led by San Luis Obispo-based Mothers for Peace, or SLOMFP, have sent letters to the NRC warning it would violate federal law if it accepts the proposal. The other groups that signed the letters are EWG, Friends of the Earth and Committee to Bridge the Gap.
“PG&E cannot have it both ways,” claimed SLOMFP Board President Jane Swanson. “PG&E stopped preparing the reactors for continued operation in 2016 and voided their license renewal. The company has spent the past six years preparing to mothball the reactors and has saved money by not investing in future operations. It is too late to get a license renewal before the plant must shut down.”
The Environmental Working Group (EWG) is a nonprofit, non-partisan organization that empowers people to live healthier lives in a healthier environment. Through research, advocacy, and unique education tools, EWG drives consumer choice and civic action.
On December 6, 2022, in their second letter to the Commissioners of the U.S. Nuclear Regulatory Commission (NRC) within the space of three weeks, four environmental organizations once again put the NRC on notice that the agency would violate federal law if it accepted Pacific Gas & Electric’s (PG&E’s) October 31 proposal to resurrect and fast-track its review of PG&E’s long-abandoned 2009 license renewal application for the twin Diablo Canyon reactors. San Luis Obispo Mothers for Peace (SLOFMP), Friends of the Earth (FOE), Environmental Working Group (EWG), and Committee to Bridge the Gap (CBG) warned that PG&E’s proposal runs afoul of the NRC’s safety requirements and procedures and would violate the federal National Environmental Policy Act.
The NRC terminated the Diablo Canyon license renewal proceeding in 2018 when PG&E decided to close the reactors in 2024 and 2025. “PG&E cannot have it both ways,” claimed SLOMFP Board President Jane Swanson. “PG&E stopped preparing the reactors for continued operation in 2016 and asked the NRC to terminate the license renewal proceeding. The company has spent the past six years preparing to mothball the reactors and has saved money by not investing in future operations. They can’t reverse course and revive a license renewal application that was declared dead years ago at their own request.”
Last September, the California Legislature passed SB 846 to provide PG&E with economic incentives to request a five-year extension of Diablo Canyon’s license from the NRC. “With years of extended operations on the table for this outdated and potentially deadly nuclear facility, it is crucial that we cut zero corners,” said FOE Legal Director Hallie Templeton. “The California legislature has not provided PG&E carte blanche to seek exemptions and streamline relicensing. If it intends to continue operating Diablo, PG&E should be required to file an entirely new and up-to-date license renewal application, which the NRC must thoroughly analyze by the full letter of the law before reaching a decision.”
The organizations also noted that PG&E had no legal basis for its request to exempt it from important federal regulations requiring an environmental analysis before the NRC can allow the reactors to operate beyond their current license terms.
“The last time the NRC did an environmental review for operation of the Diablo Canyon reactors was 1993,” said Ken Cook, EWG’s President and Co-founder. “Given the potentially extreme impacts and risks of continuing to operate Diablo Canyon, it would be both illegal and sheer folly to proceed with extended operation in the absence of a thorough and up-to-date Environmental Impact Statement.”
Dan Hirsch, spokesperson for CBG, commented, “PG&E’s request to be exempted from regulatory requirements for Diablo Canyon is very dangerous. If the requested exemption were granted, Diablo could keep running, potentially for many years, while the critical issues of whether it is safe to do so are not yet resolved. This creates the potential for an accident and massive radiation release to occur after license expiration and before a renewal decision could be made on those vital safety issues. It is the proverbial nuclear version of shooting first and asking questions later.”
These groups, which submitted their first letter to the NRC on November 17, pledged to continue their efforts to ensure that any license renewal application filed with the NRC by PG&E is reviewed with all the rigor required by federal safety and environmental laws.
The Diablo Canyon Decommissioning Engagement Panel (DCDEP) hosted an informational online webinar on Wednesday, December 14, 2022 to update the community on the status and proposed schedule for the continued operation of the Diablo Canyon Power Plant (DCPP) and implications on decommissioning activities, such as, repurposing, land use, and environmental permitting. The online meeting included presentations by PG&E, the California Energy Commission and the Diablo Canyon Independent Safety Committee. Members of the community submitted questions and concerns prior to the meeting. In preparation for the meeting, PG&E prepared a brief summary of SB 846 and the status of activities relating to the extended operation of DCPP.diablocanyonpanel(dot)org/wp-content/uploads/2022/11/SB-846-PGE-Summary-11_23_22.pdf
View meeting agenda, meeting recording and presentation materials — diablocanyonpanel(dot)org/2022-panel-meetings/#12-14-22-panel-mtg
– – – –
From Mothers for Peace SLO prior to the meeting —
Topics include: review of SB 846 funding and accelerated permitting provisions to allow for extended operations; actions already taken by PG&E; the role of the Diablo Canyon Independent Safety Committee; the role of the Diablo Canyon Independent Peer Review Panel to address seismic issues; and implications of extended operations on the current decommissioning CEQA process.
No public comment will be allowed, but you may submit written comments at any time [to the Panel]. diablocanyonpanel[dot]org/submit-comment/
There is supposedly a list being developed of deferred maintenance projects and the associated estimated costs. Who is participating in the compilation of this list? When will it be available to the public? Who will oversee these projects?
There is much controversy over the seismic safety of Diablo Canyon. What agency(ies) is/are responsible for the independent analysis of seismic dangers? How and when will the public be informed of the findings?
Explain the plans for how the high level radioactive waste will be stored as a result of the proposed extended operation. How will the fuel pools and the Independent Spent Fuel Storage Installation be managed?
SB 846 allows 5 years of extended operation. But the 2018 agreement to shutter the reactors in 2024 and 2025, signed and approved by the CPUC and the NRC, was ignored and reversed. What assurance does the public have that the plant would operate for 5 additional years and no more?
PG&E’s Summary of SB 846 and the status of activities relating to extended operation diablocanyonpanel(dot)org/wp-content/uploads/2022/11/SB-846-PGE-Summary-11_23_22.pdf
There’s a misguided effort being pushed forward by some well-intentioned people who have joined the Nuclear Power Fan Club. These people truly believe that nuclear power will save the planet from climate disaster, and there’s a lot of money to be made.
The newly released Stanford/MIT study recommends exploring the extension of Diablo Canyon’s license to operate in order to combat climate change, but it completely ignores important conditions at Diablo Canyon:
1. Diablo Canyon is situated at the nexus of at least 13 earthquake faults. Two of these, the Hosgri Fault and the Shoreline Fault, are classified by the U.S. Geological Survey (USGS) as “major” and “active.” Keeping Diablo Canyon operating beyond its planned closure is playing Russian roulette.
2. The Unit 1 reactor vessel was manufactured in 1967. The Nuclear Regulatory Commission (NRC) reported it as “embrittled” several years ago. This reactor vessel has not had a mandated ultrasonic examination in more than twenty years. If Unit 1’s reactor had to be shut down in an emergency, there’s a chance that it could shatter like a glass of boiling water suddenly plunged into ice, resulting in unimaginable consequences.
3. Seasoned, highly skilled workers are retiring and moving on, resulting in loss of institutional knowledge about the unique idiosyncrasies of Diablo Canyon. The effect is already being felt, according to information provided to Mothers for Peace by an unnamed employee.
4. Underground pipes were installed at Diablo Canyon in the 1970s. These pipes are subject to high pressure and cannot be inspected. A severe earthquake is all it would take to interrupt the vital cooling water to the plant. Much maintenance at Diablo Canyon has been deferred because closure is imminent. This facility is OLD. These and other components are ready to retire.
5. The spent fuel pools are overcrowded to at least three times their original capacity. A “beyond design” earthquake (think Fukushima) could crack the pools, cause water to leak out, and the spent fuel could spontaneously ignite – the most unimaginable catastrophe possible. This is a “low probability, high risk” scenario, and it’s not considered by the NRC in spent fuel pool safety analysis because “it won’t happen.” We hope not.
6. There is exactly enough space on the dry cask storage pad to accommodate 138 spent fuel casks containing highly radioactive fuel rods that will be stored after closure in 2025. If the lifetime of the nuclear plant were extended, a whole new dry cask facility would have to be permitted and constructed to accommodate the additional toxic waste. With no federal repository for high level nuclear waste, it’s going to be stored on our fragile coastline into the foreseeable future.
7. There is no guarantee of “steady baseload power” from a 40-year-old nuclear power plant. Unit 2’s failed main generator was replaced for nearly $100 million in 2019, but failed again in 2020, working only 30% of that year and narrowly squeaking by during the peak load energy crunches. The complex and costly repairs of aging systems are likely to multiply in the ensuing years.
One must also consider Climate Impacts and Habitat Loss from Diablo Canyon’s Operation:
1. Diablo Canyon circulates 2.5 BILLION gallons of seawater through its piping every 24 hours in a once-through-cooling (OTC) system. Diablo Canyon’s cooling system is responsible for 80% of the loss of marine life on the California Coast. OTC is no longer allowed in California, but the State Lands Commission extended the land leases to 2024 and 2025 to coincide with Diablo Canyon’s operating licenses. With rapid worldwide depletion of fisheries and aquatic biodiversity, it is unacceptable to allow decimation of marine life in order to produce approximately 8% of California’s energy. Would the Lands Commission allow another exemption and sacrifice ocean life for Diablo Canyon’s operation?
2. The seawater intake structure is vulnerable to rising levels of ocean water brought on by global climate change. This is the water that cools the plant. During seawater’s circulation through the facility, it warms by 19°F before being discharged back into the ocean, contributing to ocean warming. Think about it: 2.5 billion gallons every single day for 40 or more years. The math and the impacts are almost incalculable.
3. Nuclear plants emit huge amounts of heat from nuclear reactions into the atmosphere 24/7. Where does the heat go? Global warming.
4. When uranium is mined, milled, enriched, and transported to nuclear plants, there is a spike in CO2 emissions.
5. Uranium mining has decimated some 27,000 square miles of Navajo (Diné) land spread across Utah, New Mexico and Arizona which is home to more than 250,000 people. Many Navajo people have died from kidney failure and cancer, conditions linked to uranium contamination. And new research from the CDC shows uranium in the bodies of babies born now.
6. When a nuclear plant is built, hundreds of millions of tons of concrete are also manufactured. And when the plant is dismantled, this same concrete, plus steel, electrical wiring, plumbing, and radiologically contaminated material must be hauled away. All of it contributes to climate change.
We can do better. People of the Central Coast have put up with living in a nuclear evacuation zone for the past 40 years. Nuclear power is dirty. It’s dangerous. Don’t buy the hype.
Friday, November 10, 2017
Topic: Yucca Mountain – is it viable?
Speakers – Ian Zabarte, Principal Man, Western Bands Shoshone Nation Newe Sogobia, NV Judy Treichal, Executive Director, Nuclear Waste Task Force,
Las Vegas, NV Steve Frishman, Technical Policy Coordinator, Nevada Agency for Nuclear Projects, Las Vegas, NV
Friday, January 19, 2018
Topic: Transportation of Radioactive Wastes
Speaker – Kevin Kamps, Radioactive Waste Watchdog, Beyond Nuclear, Washington,
Topic: Consolidated “Interim” Storage
Speaker – Diane D’Arrigo, Radioactive Waste Project Director, Nuclear Information Resource Service, Washington, DC
On Friday, January 27, Mothers for Peace through Ojai-based attorney Sabrina Venskus, submitted expert testimony to the California Public Utilities Commission showing that Diablo Canyon should be closed in 2019, not 2024. news release
One of Mothers for Peace’s expert witness, nuclear engineer Arnie Gundersen, chief engineer for Fairewinds Associates, Inc, provided testimony demonstrating unsafe and unreliable conditions at the plant. Arnie Gundersen testimony
Another expert witness is David D. Jackson who works with the Department of Earth, Planetary, and Space Sciences at UCLA. In his testimony, Dr. Jackson explains the many types of seismic damage to the plant in case of an earthquake. Among his assertions is that the substantial risk of earthquakes at Diablo Canyon nuclear plant has been underestimated, and that the seismic studies relied upon evaluate only a part of the risk which affects any decision of how long to continue operation of the two Diablo Canyon reactors. David D. Jackson testimony
On Friday January 27, San Luis Obispo Mothers for Peace (SLOMFP) through Ojai-based attorney Sabrina Venskus submitted expert testimony to the California Public Utilities Commission (CPUC) showing that Diablo Canyon should be closed in 2019, not 2024, because it is becoming unsafe and unreliable. SLOMFP’s expert witness is nuclear engineer Arnie Gundersen, chief engineer for Fairewinds Associates, Inc.
“Diablo Canyon was designed in the mid-1960s. Some of its parts are as dated as rabbit ears on a black and white TV. This atomic power reactor is old and tired, and it is not reliable or safe. The faster Diablo Canyon closes, the safer Californians will be,” stated Mr. Gundersen. Replacement costs for these outmoded parts at Diablo Canyon during the next 7 to 8 years are well in excess of a reasonable investment for a plant that is scheduled to shut down in 2024. Mr. Gundersen’s testimony also illuminates the degraded condition of tens of thousands of often neglected switches, plates, springs, shock absorbers, pipes, and other components of this aged atomic power reactor that are in danger of failing well before 2024.
The companies that own nuclear reactors have a tendency to defer needed maintenance and replacement of worn parts when permanent closure is imminent. Called “running to failure,” the operator tends to take a chance that the part won’t fail before the plant closes down. In an old car that is ready for the junkyard the owner won’t replace worn tires with ones that are guaranteed for 50,000 miles. Instead, he will take a chance that the tires won’t blow out before the old car is junked. If there’s a blowout in a tire, it can be hazardous. If there’s a failure of an essential component of a nuclear power plant, the costs of of replacement or of repair of damage can be huge.
Mr. Gundersen’s testimony, attached below, cites numerous parts and components at Diablo Canyon that have been listed in the 2017 Rate Case by Pacific Gas and Electric as in need of replacement. In Mr. Gundersen’s opinion, shutting the doors of the two reactors makes sense in 2019, before parts and components are forced to run to failure.
SLOMFP is commenting as a party to the California Public Utilities Commission’s proceedings on the Joint Proposal reached in June of 2016 between PG&E and several environmental groups and unions. SLOMFP has also submitted expert testimony to the CPUC by David Jackson, Ph.D. regarding seismic damage to the plant in case of an earthquake. SLOMFP has joined with Women’s Energy Matters of Marin County regarding timing and costs of replacing the needed power at Diablo Canyon with renewable energy, using the testimony of energy analyst Robert Freehling. SLOMFP compiled documents regarding the environmental effects of Once-Through Cooling on aquatic life around the facility. By co-sponsoring a portion of the testimony by the Alliance for Nuclear Responsibility’s attorney Al Pak, SLOMFP is objecting to PG&E’s request to recover the costs of its relicensing application filed with the Nuclear Regulatory Commission in 2009, but later withdrawn.
This same event happens at school districts across the United States and probably other countries sponsored by the nuclear industry and related utility companies.
Adapt this sample letter for your area.
From Mothers for Peace
Below is a sample letter to public school administrators that we encourage parents and tax-payers to adapt and send to their local school boards, superintendents and principals.
Dear School Administrator:
The third week of October is annually designated “Nuclear Science Week” by the nuclear industry, and representatives from Diablo Canyon nuclear plant are giving talks and demonstrations in our public schools, touting nuclear energy as “safe,” “clean,” “reliable,” and “of good benefit.”
These representatives from Diablo Canyon do NOT tell the students that radioactive releases are routinely allowed into our air, land and water. They don’t mention that Diablo Canyon, storing over 64 million pounds of highly radioactive nuclear waste, is built at the intersection of at least 13 earthquake faults, two of which have been identified as “active” and “major.” This lethal waste will remain on site at Diablo Canyon far beyond the day the nuclear plant has generated its last watt of energy, and that waste will be the responsibility of these same children who are being given just one side of the nuclear power story – that of Pacific Gas and Electric.
California does not need the electricity supplied by Diablo Canyon. Equivalent energy is already available through renewable energy sources. Nuclear energy has no place in future power generation. California’s clean energy future rests on wind, solar, wave, and geothermal energy. Our children and grandchildren will thank us for investing in it.