2018 - 12 - 09 MFP Comments on Diablo Canyon Decommissioning Engagement Panel Draft Report

San Luis Obispo Mothers for Peace submitted the following comments on Public Review Draft of the Strategic Vision of the Diablo Canyon as written by the Decommissioning Engagement Panel (DCDEP), dated November 2018. The DCDEP consists of eleven volunteer citizens and all of their workshops and meetings are open to the public. For more information about the schedule and work of the DCDEP go to https://www.pge.com/en_US/safety/how-the-system-works/diablo-canyon-power-plant/diablo-canyon-power-plant/engagement-panel.page

A. Decommissioning Process

a. San Luis Obispo Mothers for Peace (SLOMFP) strongly supports the recommendations of the

Decommissioning Panel to begin decommissioning immediately upon shutdown of the plant.

b. SLOMFP concurs with the goal that the health and safety of the community is paramount

during this process. It agrees with the recommendations to:

i. the CPUC that the spent fuel stored on-site be monitored at all times using real-time

radiation monitoring

ii. the CPUC that the implementation of technologically advanced storage methods be

implemented as identified and found feasible

iii. PG&E that both ship and truck transport of dismantled facilities be investigated and the

data communicated to the DCDEP and CPUC

iv. PG&E that the transport of demolished facilities through surrounding communities be

avoided during times of peak traffic.

c. SLOMFP supports the continuation of the DCDEP – or like entity – throughout the

decommissioning process.

d. SLOMFP opposes the alternative vision for the panel.

i. It appears that the current panel has been working well, and that the panelists are

putting in a tremendous amount of time. They must educate themselves and

collaborate with others.

ii. SLOMFP believes that assigning elected officials to this task would be less effective

because these working people are too busy with their paid jobs! If there are problems

with certain individuals, perhaps there can be a process of replacement. There is also

the possibility of a combination of panelists – from public office as well as private

citizens.

B. Decommissioning Funding

a. SLOMFP strongly supports the DCDEP statement: “Although funding the costs for

decommissioning should be guided by the principle of avoiding imposition of undue burdens on

ratepayers, the safety of the community, both now and in the future, should never be

discounted.” Again, SLOMFP highlights SAFETY FIRST.

b. The DCDEP also states that the existing trust fund should be protected and preserved. SLOMFP

understands that PG&E intends to use decommissioning funds for the bonus pay to retain

employees. Although important, SLOMFP strongly agrees that the money put aside for

decommissioning should be shielded.

C. Diablo Canyon Lands

a. SLOMFP strongly supports the vision statements in this document. It would be wonderful if

those beautiful lands could be preserved in perpetuity for the enjoyment and recreation of all.

SLOMFP would like them to be managed to ensure sustainability. These lands must NOT be

exploited for private gain.

b. SLOMFP agrees with the proposal to seek the lifting of the CPUC order prohibiting PG&E from

taking action regarding the lands. This would be for the purpose of enabling conservation

discussions to proceed before decommissioning.

D. Facility Repurposing

a. SLOMFP strongly supports the recommendations of the DCDEP; highlighting that the

repurposing of facilities should be consistent with SAFETY AND SECURITY of the site. SLOMFP is

particularly concerned with radiological contamination from operations and from fuel storage.

b. SLOMFP is particularly encouraging of the idea of repurposing the facilities for renewable

energy production.

Other Comments

a. SLOMFP urges that Diablo Canyon be shut down before 2024-2025. The electricity generated is

not needed, and safety may be compromised as we get closer to the end of current licenses

due to employee loss and the cost incentives to delay needed maintenance and repair.

c. SLOMFP strongly opposes the transport of radioactive waste by truck, train or barge until and

unless a permanent repository is designated by the Department of Energy. It would be

unconscionable to subject communities along our roads, railroads and coastlines to the risks of

high level radioactive wastes more than once. This is what would happen if “interim storage”

sites are used before a suitable permanent repository is prepared.

b. SLOMFP encourages the continuation of emergency planning and services until all the fuel is

out of the pools and removed from the property.