2015 - 07 - 31 MFP Comments on Scoping for EIS

These Comments on Environmental Issues for Diablo Canyon Nuclear Plant License Renewal are submitted San Luis Obispo Mothers for Peace. The Comments offer sufficient information to justify inclusion of the issues raised in the scoping of the Environmental Impact Statement (EIS) to be developed by the NRC.


The consideration of energy alternatives is a category 2 issue, and new information shows that there is a range of renewable alternatives that negates any need for license renewal for the Diablo Canyon plant.

Mark Cooper is Senior Fellow for Economic Analysis at the Institute for Energy and the Environment at Vermont Law School. He is an expert in the field of economic and policy analysis with a focus on energy, technology, and communications issues.

Mark Cooper’s Declaration in Support of SLOMFP’s Motion to File New Contentions Regarding Adequacy of Environmental Report for Diablo Canyon License Renewal Application is

available at http://pbadupws.nrc.gov/docs/ML1509/ML15096A614.pdf

In this report, Mark Cooper points out that

“PG&E’s focus on “standalone” energy sources reflects two irrational and unsupported biases: first, towards reliance on “baseload” generation by a single source, and second towards “utility-scale” generation. But these biases have been outdated by the ongoing transformation of the electric utility sector. As one prominent financial firm that specializes in analysis of the electricity sector, UBS, put it, “Large-scale power generation . . . will be the dinosaur of the future energy system.” 1 They are: “Too big, too inflexible, not even relevant for backup power in the long run.” 2  While UBS ties the shift to the spread of battery technology other major firms see the shift being driven by the development of other technologies including solar,3 wind,4 efficiency,5 as well as the increasing ability to actively integrate and manage supply and demand. 6”

1  UBS, 2014, Global Utilities, Autos & Chemicals Will solar, batteries and electric cars re-shape the

electricity system?, August 20, p. 1. UBS “is considered the world's largest manager of private wealthassets,” http://en.wikipedia.org/wiki/UBS

2  Id

3 Bernstein Energy and Power Blast: If solar wins, Who Loses?, Bernstein Research, April 2. Lazard,

2013, Levelized Cost of Energy Analysis – Version 8.0, June.

4  Eggers, Dan, et al., 2014, A Thought... The Transformational Impact of Renewables, Credit Suisse,

December 20; CITI Research, 2012, Shale & Renewables: A Symbiotic Relationship, September 12.

5 Eggers, Dan, 2013, A Thought... Energy Efficiency: The Reality of Slower Power Demand Growth, Credit Suisse, February 11; McKinsey and Company, 2010, Energy Efficiency: A Compelling Global Resource

6  UBS, 2014, Global Utilities, Autos & Chemicals Will solar, batteries and electric cars re-shape the electricity system?, August 20; Frankel, David , Kenneth Ostrowski, and Dickon Pinner, 2014, “The disruptive potential of solar power: As costs fall, the importance of solar power to senior executives is rising,” McKinsey Quarterly, April.

In another paper, Mark Cooper makes the case that, “Nuclear reactors old and new are far from a necessary part of a low-carbon solution. Nuclear power, with its war against the transformation of the electricity system, is part of the problem, not the solution.”


California has a goal, set by the California Energy Commission and Governor Brown, to increase the proportion of renewable, carbon-free energy to 33% by 2020. See http://www.energy.ca.gov/renewables/index.html

Diablo Canyon’s electrical output will be an obstacle to reaching that goal, because nuclear is not a flexible source of energy. It is unsafe to ramp down the level of output of a nuclear plant, so when there is an overabundance of energy available to the Western Grid, it will be the more flexible renewable sources that have to be shut down.

See article by David Howarth and Bill Monsen, with MRW & Associates, LLC in Oakland, California  titled Renewables Face Daytime Curtailments in California


Paragraph 5:

“The California Independent System Operator (CAISO) is concerned that there may be times when there is so much variable wind, solar and other renewable energy being scheduled onto its system that the other generators who will have to adjust to accommodate it will not have the flexibility needed to do so.“

Paragraph 8:

“Some generators, such as nuclear, small hydroelectric and most geothermal and combined heat and power plants, need to run and have little ability to shut down because they have limited flexibility.“


PG&E’s Severe Accident Mitigation Alternatives Analysis for Diablo Canyon fails to resolve important questions about the potential for earthquakes very near the plant, and for potentially very large earthquakes. Clearly these are category 2 issues, being unique to the Diablo Canyon plant.

PG&E’s seismic hazards analysis fails to account for reasonably foreseeable earthquakes located nearer to the DCPP than PG&E has assumed. For instance, the seismic stations used to locate earthquakes on the Shoreline Fault are all onshore, east of the fault, so that the fault’s east-west location is highly uncertain. Thus the fault could be closer to or further from DCPP than assumed in DC03.

PG&E’s understatement of magnitude stems from its reliance on “scaling relations”, which are equations relating magnitude to rupture length or rupture area. But scaling of earthquake magnitudes from fault geometry has been demonstrated to be unsupportable, because the mapped fault length is no limit to the ultimate rupture length. Many earthquakes have ruptures exceeding the length of the faults on which they started. Even PG&E implicitly acknowledges this: examples listed in the SSC Report at page 6-6 include the 2002 Denali, AK (magnitude 7.9), the 1992 Landers, CA (magnitude 7.3), and the 1999 Hector Mine,CA (magnitude 7.1). Other major earthquakes occur on previously unknown faults, even in areas with extensive prior geological study: the 1989 Loma Prieta earthquake (magnitude 7.1; Spudich,1996); the 1994 Northridge, CA (magnitude 6.7); and the 2010 Darfield, NZ (magnitude 7.1) earthquakes. Perhaps the most astounding example was the 2012 magnitude 8.6 strike-slip earthquake off the coast of northern Sumatra (Ishii et al., 2013). Nevertheless, PG&E disregards this information and unjustifiably relies on the scaling relationships to estimate maximum magnitude from fault length.


Emergency planning for the communities surrounding the Diablo Canyon nuclear plant should be classified as category 2, as the roads, geography, and earthquake potential of the Central Coast is unique.


Emergency response plans for a nuclear disaster are generally modeled after studies of responses to natural disasters, but research makes it clear that people tend to respond differently in technological disasters.


Studies indicate that panic often does not occur in a natural disaster.  Panic in an emergency situation is most likely to occur when there is a perception

  • that the danger is increasing rapidly; (Radiation is unseen, it seems mysterious, it can cause major health problems later and there is no way of knowing how fast the plume will arrive or how long it will remain.)
  • that the escape routes are closing off. (In this area the escape routes are very limited and people know that they could easily be closed off by accidents or the rush of traffic. This is an area of small town with a highway system built for an area of small towns, but it is also a major tourist area that can easily draw 150,000 people for an event. It would be impossible to evacuate all of the tourists and homeless people from the area, and homeless people and tourists in the many camp grounds would have no way to shelter.)


Protective Action Zones are central to the Diablo Canyon Emergency Response Plan, and it is assumed that people will follow the instructions given for their zones – but this might not be the case in a real nuclear emergency.  In contrast to the reluctance by some people to evacuate during natural disasters, people sometimes overreact in technological disasters.  This is particularly true when radiation is involved because it seems mysterious and it cannot be seen or felt.  Research in the 1980s indicated that evacuations by zones was not likely to work. (Cutter, 1984; Zeigler et al., 1981)

In March of 2013 the Government Accountability Office (GAO) issued a requested report to congress that was publically released April 10, 2013, claiming that the NRC needs to better understand the effect of shadow evacuations.  The NRC disagreed with that recommendation, but GAO responded:

“To better inform radiological emergency preparedness efforts, GAO recommends that NRC obtain information on public awareness and likely public response outside the 10- mile zone, and incorporate insights into guidance, as appropriate. NRC generally disagreed with GAO's finding, stating that its research shows public response outside the zone would generally have no significant impact on evacuations. GAO continues to believe that its recommendation could improve radiological emergency preparedness efforts and is consistent with NRC guidance.”


According to an article in The Professional Geographer: “The 10-mile emergency planning zone is a politically arbitrary distance. It has no bases in meteorology, radiation releases mechanisms and human behavior. In fact studies of human behavior following the Three Mile Island accident in 1979, where a limited evacuation advisory was issued by Pennsylvania Governor Thornberg, provides evidence that people will be spontaneously leaving their homes well beyond the current 10-mile planning zones.”

("Evacuation Behavior In Response To Nuclear Power Plant Accidents," by Donald Zeigler and James Johnson, Jr. in the May,1984 issue of The Professional Geographer)

After the Three Mile Island accident, pregnant women and preschool children in the area around the plant were advised to evacuate (about 2,500 people).  An estimated 144,000 people (39% of the population) actually left (Zeigler, Brunn, & Johnson, 1981).


“Research conducted in the vicinity of the now closed Shoreham nuclear power station on Long Island, NY questioned bus drivers and volunteer fireman. "What do you think you would do first if an accident requiring a full scale evacuation of the population within 10 miles of the nuclear reactor were to occur?"

“The results found that 68% of 291 fire fighters, 73% of the 246 bus drivers indicated that family obligations would take precedence over emergency duties.

Additionally, during the TMI accident role conflict was documented among many emergency workers including the exodus of physicians, nurses, and technicians required to staff both the short term and long term medical facilities.”



San Luis Obispo County Fire Chief Robert Lewin pointed out site specific challenges in the event of a fire emergency beyond that which can be managed by the small PG&E fire-fighting crew.

See http://www.hstoday.us/focused-topics/emergency-managementdisaster-preparedness/single-article-page/in-the-shadow-of-fukushima-facing-the-fires-of-a-meltdown/242a4119dabc5511e28a97a206016ef6.html


Security issues should be considered category 2, because the geogrophy surrounding the Diablo Canyon plant is unique.


On August 15, 2013, The Nuclear Proliferation Prevention Project (NPPP) at The University of Texas at Austin's LBJ School of Public Affairs released a report titled “Protecting U.S. Nuclear Facilities from Terrorist Attack: Re-assessing the Current ‘Design Basis Threat’ Approach.

Commenting on the NPPP report, one of the authors, Prof. Kuperman said:  “More than 10 years have come and gone since the events of September 2001, and America’s civilian nuclear facilities remain unprotected against a terrorist attack of that scale.  Instead, our civilian reactors prepare only against a much smaller-scale attack, known as the “design basis threat,” while the government fails to provide supplementary protection against a realistic 9/11-type attack.”


Diablo Canyon is vulnerable to water-borne attacks.  A Small boat may be able to evade the coast guard long enough to get close enough to the plant to launch a missile.  The waste storage area that is not covered by a protective dome is most vulnerable to that kind of attack.

One possible protection is a boat barrier. Wave Dispersion Technologies, Inc. – a manufacturer and marketer of floating security barriers and floating wave attenuators , pointed out that: “Boat barriers provide a visible physical deterrent for inadvertent recreational boat traffic from entering the security zone.  Boat barriers also establish a physical layer of security to deter, deny and delay terrorists utilizing water-borne improvised explosive devices (WBIED) delivered via a small boat.” http://www.whisprwave.com/category/nuclear-security/

There are no such water barriers at the Diablo Canyon plant. While boats and ships are supposed to stay more than a mile away from the plant, that does not always happen. Fishing craft have been sighted within Diablo Cove by members of Mothers for Peace while touring the plant site with the Diablo Canyon Independent Safety Committee. (Jane Swanson, janeslo@icloud.com)

During that incident the Coast Guard appeared from around a breakwater shortly after the PG&E guide explained that the yellow craft appearing to be within a hundred yards of the intake structure was a PG&E craft. The Coast Guard ship used a megaphone to tell the craft that it was in waters not allowed, and ordered the fishing vessel to turn out to sea. The Coast Guard then escorted that vessel out beyond the mile mark.


May 28, 2015

“Recent security breaches with small unmanned aircraft systems (“sUAS”) have garnered much attention. Last fall, UAS overflew 13 of France’s 19 nuclear power plants in an apparent coordinated fashion. In January, a private UAS crashed onto the lawn of the White House. In April, Japanese security forces found a UAS on the roof of the Japanese prime minister’s office carrying a small camera and a bottle containing radioactive Cesium-137.

Nuclear facility operators now operate sUAS under Federal Aviation Administration (“FAA”) exemptions for beneficial purposes, including electrical facility inspections, but others may operate UAS for destructive and subversive purposes. sUAS could be used to monitor a facility’s security activities, divert security forces’ attention from a second threat to physical security, or carry and release destructive conventional, chemical, biological, or radiological payloads. As sUAS become more popular and less expensive, it is likely that nuclear and other sensitive facilities will face an increasing number of potentially-problematic flyovers.” (http://www.uaslawblog.com/2015/05/28/uas-and-nuclear-power-plant-security/#more-102)


Force on force drills should be considered category 2, because each plant has unique vulnerabilities related to plant design and geography.

Force on Force drills should retain an element of surprise and they should use independent “mock attackers” not connected with the utility.  The NRC has been weakening the drills instead of strengthening them.

“In response to industry complaints, the NRC already has reduced the number of FOF exercises per inspection from three to two and is proposing to reduce it to only one by 2017. In exchange, the NRC will give more credit to licensee-run security drills and will observe one such drill in each inspection cycle. This is a slippery slope toward the industry’s ultimate goal: to take control of the process and eliminate the potentially embarrassing FOF exercises altogether. Even worse, the NRC commissioners have directed the staff to review the entire FOF program with an apparent eye toward weakening it even further.”( http://allthingsnuclear.org/the-nrcs-security-inspections-at-nuclear-power-plants-are-again-under-attack/)