Represented by Ojai-based attorney Sabrina Venskus, San Luis Obispo Mothers for Peace (SLOMFP), longtime intervenor in matters concerned with safety and the environment at the Diablo Canyon nuclear power plant (DCPP), has filed a Response to the Joint Proposal to close DCPP. While SLOMFP appreciates PG&E’s Joint Proposal to shutter the Plant, the organization questions PG&E’s assumption that the Plant should continue in operation through the end of the licensing period of 2024-2025, and not retire sooner. The validity of PG&E’s timing assumptions should be assessed in the Dedicated Proceeding, and the Commission should direct PG&E to consider accelerated shut-down scenarios.
SLOMFP’s filing asks the CPUC to consider the economic repercussions if there were an earthquake at the plant, located in fault-ridden terrain along the Central California coastline. The earthquake data that has been submitted by PG&E is highly contested by a number of seismologists, and SLOMFP asserts that each day of plant operation presents safety and economic risks to the State.
The NRC has ordered retrofits and replacement of parts at Diablo Canyon to meet the post-Fukushima upgrades that were ordered in response to the triple meltdowns at the Fukushima Dai-Ichi nuclear plant in 2011. SLOMFP has concern that PG&E is in a problematic position. If all of the upgrades and retrofits are met, the cost will be passed on to the ratepayers. On the other hand, if PG&E applies for exemptions to these retrofits and upgrades because of the imminent closure of the plant, public health and safety may be compromised. Thus, shuttering DCPP much sooner than the end of its licensing period may be the most cost effective approach to the Proposal to retire the Plant.
Diablo Canyon’s Unit 2 steam generator is in need of major repairs involving the Stator, and the estimated cost of replacement is between $84 Million and $151 Million. PG&E has decided not to replace the stator because of Unit 2’s planned closure in 2025. However, as stated by PG&E, the stator may have to be replaced because of its severely worn condition. If the stator breaks down before 2025, the replacement cost will be enormous, and has the potential for causing health hazards to workers at the plant.
In its own description of the problem, PG&E stated in 2015, “The Unit 2 main generator, which converts mechanical power from the main turbines into electrical energy, is critical for the safe, reliable operation of DCPP Unit 2. The Unit 2 main generator stator1 is reaching the end of its service life. The expected life of the stator, based on industry experience, is approximately 30 years. As of 2015, Unit 2 has been in operation for 30 years.”
San Luis Obispo Mothers for Peace asserts that the expense of this potential stator repair makes a strong argument for the rapid closure of the plant
The reactor pressure vessel of Unit 1 has been deemed by the NRC to be among the five most embrittled reactors in the United States. Thus an extraordinarily dangerous threat to California would be posed if a cold shutdown caused the vessel to crack. PG&E applied for and was granted an exemption to the mandated 10-year inspection of the vessel, and now the inspection has been delayed until 2025. SLOMFP is extremely concerned that the financial burden resulting from a failure of the Unit 1 reactor pressure vessel by brittle fracture would be more than PG&E’s ratepayers could withstand. The NRC was imprudent in granting a 10-year delay in this critical inspection, but the risks from such a delay could be readily mitigated by retiring the plant much sooner than 2025, The Commission has a responsibility to consider such an approach.
SLOMFP understands that PG&E wishes to evade the provisions of the State Water Resources Control Board’s (SWRCB) Once-Through-Cooling (OTC) policy while the DCPP remains in service. The substantial harm to marine life caused by DCPP’s 2.5 billion gallons of ocean water heated 18 to 20 degrees Fahrenheit and pumped back into Diablo Cove should not be tolerated for nine additional years. It may be more prudent, on balance, to close DCPP sooner than 2024 to avoid these environmental impacts should PG&E wish to continue pressuring the SWRCB not to impose its Federal Clean Water Act-mandated OTC policy on Diablo Canyon.
Given the rapid rise in the availability of solar, wind and geothermal energy and the rapid innovation in energy storage capacity, the nine-year timeline for closure of the plant is much too long. SLOMFP submits that the transition to renewables can and must be made much sooner.
SLOMFP supports PG&E’s proposed program to retain experienced workers in the last years of operation and to soften the financial blows of decreased property taxes on the County of San Luis Obispo, but using the decommissioning fund, paid for by ratepayers, may not be a reasonable and prudent, nor legal, plan. The Commission should consider the appropriateness of requiring the utility’s shareholders to shoulder the cost of these programs. The Decommissioning Funds have been designated by the NRC to safely disassemble the plant.
The issue of whether PG&E’s incurred costs of $53 Million related to the license renewal process was reasonable and prudent is one that should be addressed in the proceeding. SLOMFP believes that it is inappropriate for PG&E to recover its full costs of license renewal efforts from ratepayers since SLOMFP believes it was neither reasonable nor prudent for PG&E to seek license renewal given the unique circumstances surrounding the DCPP.
The CPUC will hold a prehearing conference sometime in October. San Luis Obispo Mothers for Peace attorney Sabrina Venskus will appear there to represent the interests of the community of San Luis Obispo and the residents of the State of California who support the work of SLOMFP.
For more information, go to mothersforpeace.org.