The Nuclear Regulatory Commission (NRC) is developing an environmental impact statement (EIS) for the proposed license renewal of the Diablo Canyon Nuclear Power Plant and is seeking public comment on issues to be covered by the report. Supporters of MFP are encouraged to consider speaking on any of the topics below – or other matters that concern you.
DIABLO CANYON IS NOT A SOLUTION TO REDUCING ATMOSPHERIC CARBON
Diablo Canyon will prevent California from succeeding in its goal to achieve carbon-free energy of 33% by 2020. Energy analyst 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.
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 is the more flexible renewable sources that have to be shut down.
We urge the NRC to deny the relicensing of Diablo Canyon on the grounds that it is a deterrent, rather than a means, to achieving a reduction in carbon emissions in California.
DIABLO CANYON IS NOT NEEDED TO FILL CALIFORNIA’S ENERGY DEMANDS
The California Independent System Operator oversees energy distribution throughout California by managing the grid. CAISO has expressed concern 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, such as nuclear, who will have to adjust to accommodate it, will not have the flexibility needed to do so.
Nuclear power plants cannot safely turn their power off and on. Every time a reactor is powered down, it causes stress on the parts. In order to have a flexible, resilient energy grid, the power sources must be responsive. Nuclear energy is not flexible. Diablo Canyon will provide about 8.5% of the energy to the grid, whether we need it or not. Therefore, it stymies the growth of rooftop solar and wind, which are very responsive and flexible.
We urge you to deny the relicensing of Diablo Canyon. We do not need the energy in the 21st Century; it leaves a toxic waste behind for hundreds of thousands of years; and we must be forward thinking into a responsive, flexible and resilient energy future.
NUCLEAR IS OUTMODED
“PG&E’s focus on “standalone” energy sources is outmoded and unrealistic. First, PG&E focuses on “baseload” generation by a single source. Second, PG&E is not recognizing the increase, flexibility, and resilience of distributed power generation and is promoting outdated, inflexible “utility-scale” generation. PG&E’s assumptions are outdated because of 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.” They are: “Too big, too inflexible, not even relevant for backup power in the long run.” While UBS ties the shift to the spread of battery technology, other major firms see the shift being driven by the development of technologies including solar, wind, efficiency, and the increasing ability to actively integrate and manage supply and demand.”
The NRC should NOT relicense Diablo Canyon, a dinosaur perched on 13 earthquake faults. California doesn’t need it, and the citizens of San Luis Obispo don’t want it.
SEISMIC DANGERS
Diablo Canyon is built adjacent to 13 known earthquake faults, and it may actually be built directly over the Shoreline Fault. No one – not PG&E, not the US Geological Survey, not the Independent Peer Review Panel – no one actually knows how far east the Shoreline Fault extends. For PG&E to claim that it does is both dangerous and fatuous.
The Shoreline Fault may very well extend directly under this nuclear power plant. When PG&E was studying the fault, their underwater seismic detector was not operating. Their data were extrapolated, not measured.
The mapped length of a fault rupture is not the length of a fault. The mapped length merely tells us what has happened on that fault in the past – not what can happen in the future. Many of the largest and most lethal earthquakes did not occur on known faults – including the 1989 Loma Prieta earthquake (magnitude 7.1); the 1994 magnitude 6.7 Northridge, CA earthquake; and the 2010 magnitude 7.1 Darfield, NZ earthquakes. Perhaps the most astounding example was the 2012 magnitude 8.6 strike-slip earthquake off the coast of northern Sumatra Nevertheless, PG&E disregards this information and unjustifiably relies on scaling relationships to estimate maximum magnitude from fault length.
TERRORISM
Almost 15 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 NRC fails to provide supplementary protection against a realistic 9/11-type attack at Diablo Canyon.
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, NOT covered by a protective dome, is most vulnerable to that kind of attack. One possible protection is a boat barrier. 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 delivered via a small boat.”
Recent security breaches with small unmanned aircraft systems (drones) must not be ignored. Last fall, drones overflew 13 of France’s 19 nuclear power plants in an apparent coordinated fashion. In January, a private drone crashed onto the lawn of the White House. In April, Japanese security forces found a drone on the roof of the Japanese prime minister’s office carrying a small camera and a bottle containing radioactive Cesium-137.
Drones 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 drones become more popular and less expensive, it is likely that nuclear and other sensitive facilities will face an increasing number of potentially-problematic flyovers.
All of these threats – planes, shoulder-mounted missiles, and drones – are possible causes of an uncontrollable release of radiation into the environment around Diablo Canyon. It is your responsibility to close the plant and to deny the 20-year license extension.
PLUTONIUM
Plutonium is the most toxic substance in the world. It is only produced through a nuclear reaction. Its half-life is 24,000 years. Plutonium can be transported in the atmosphere usually when it is attached to particles in the air. It can be deposited on land or water by settling or by rain. Plutonium can stick to particles in soil, sediment, and water.
The US Department of Health says:
| Ingesting 1 microgram of Plutonium through the lungs is guaranteed to cause cancer.“You may develop cancer depending on how much plutonium is in your body and for how long it remains in your body. The types of cancers you would most likely develop are cancers of the lung, bones, and liver. These types of cancers have occurred in workers who were exposed to plutonium in air at much higher levels than is in the air that most people breathe. |
| In laboratory animals, plutonium affected the animal’s ability to resist disease (immune system).” |
| 30,000 pounds of Plutonium are sitting on 13 earthquake faults at Diablo Canyon. It is immoral for the NRC to allow more of it to be produced. There is nowhere to ship it, and there is no safe way to store it.The residents of San Luis Obispo County insist that the NRC deny PG&E’s application to relicense Diablo Canyon. You are responsible. Meet your responsibility. |
FORCE-ON-FORCE DRILLS
Twice in every inspection cycle, Diablo Canyon must participate in a “Force-On-Force” exercise. In this exercise, a mock attack on the facility by outside forces, aided by an insider, must be resisted by the onsite security forces. The reason for the exercise is to prevent a Fukushima-style meltdown caused by terrorists.
Why is testing security performance with force-on-force exercises essential? Because experience has shown that paperwork reviews of security plans cannot fully assess the actual, on-the-ground efficacy of security forces.
Force-on-Force drills must retain an element of surprise and must use independent “mock attackers” not connected with the utility. The NRC has been weakening the drills instead of strengthening them.
Because of industry complaints, the NRC already has reduced the number of Force-On-Force exercises per inspection cycle 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 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.
We in San Luis Obispo insist that the NRC increase the number of Force-On-Force drills to the former number, and we insist that the simulated attackers be from an independent entity. Our safety is at stake here.
DRY CASK STORAGE
The dry casks selected for use at Diablo Canyon are just 5/8 inch thick stainless steel. Lower quality canisters are being used, choosing profits over our safety. NRC documents provide data that indicate thin storage containers can fail 16 years after a crack initiates.
NRC metallurgist Darrell Dunn claims that cracks of the thin stainless steel spent fuel containers may initiate in 16 years. This is of particular concern near coastal environments. These dry storage containers are the primary radiation barrier to the highly radioactive spent fuel.
The NRC claims fuel must be reloaded into new canisters every 100 years, unless there is a permanent repository. However, they have no technical basis to state these canisters will last 100 years, but they do have data that indicates a much sooner potential failure rate.
None of the current U.S. thin steel storage canisters are adequately designed for over 20 year storage and may start failing in as little as 17 to 20 years with through-wall cracks. Vendor claims of longer storage times are not supported by data. There is no aging management designed into these thin canisters. They cannot even be inspected for cracks or repaired.
Numerous factors can trigger stress corrosion cracks in these thin canisters. Salt moist air is one that the NRC has studied more extensively than the others. The nuclear waste containers used in the U.S. were not designed to last for more than 20 to 40 years. However, NRC technical staff stated the stainless steel nuclear waste dry storage canisters used throughout the U.S. may crack within 30 years from stress corrosion cracking in marine environments (like that found at Diablo Canyon). And there is no current technology to inspect or repair these canisters for cracks and no current method to replace these canisters. Other stainless steel products can be inspected and repaired, but that technology cannot currently be used for canisters filled with nuclear fuel waste.
Crack initiation is an unknown variable, since the nuclear industry has not been inspecting installed dry storage canisters and has yet to develop a method to inspect them for cracks. However, a 2014 inspection found sea salt crystals on a Diablo Canyon canister that had only been loaded for two years. Only two Diablo canisters were inspected, ranging from only 2 to 3.5 years in service with heat load of 15 to 20 kW at time of loading. The canister loaded for only two years had sea salts and a low enough temperature range to trigger the corrosive environment needed for stress corrosion cracking initiation — much sooner than the NRC expected.
PROBLEMS WITH LEAKS IN DRY CASKS
I would like to read to you some remarks made by Dr. Kris Singh, CEO of Holtec International, the manufacturer of dry casks at Diablo Canyon:
“…It is not practical to repair a canister if it were damaged… if that canister were to develop a leak, let’s be realistic; you have to find it, that crack, where it might be, and then find the means to repair it. You will have millions of curies of radioactivity coming out of the canister; we think it’s not a path forward…and…A canister that develops a microscopic crack (all it takes is a microscopic crack to get the release), to precisely locate it… And then if you try to repair it (remotely by welding)…the problem with that is you create a rough surface, which becomes a new creation site for corrosion down the road. I don’t advocate repairing the canister.”
Instead, Dr. Singh suggests…”you can easily isolate that canister in a cask that keeps it cool and basically you have provided the next confinement boundary, you’re not relying on the canister. So that is the practical way to deal with it and that’s the way we advocate for our clients.”
However, there are many problems with Dr. Singh’s solution of putting cracked and leaking canisters inside [transport] casks.
▪ There are no NRC approved Holtec specifications that address Dr. Singh’s solution of using the “Russian doll” approach of putting a cracked canister inside a [transport] cask.
▪ NRC requirements for transport casks require the interior canister to be intact for transport. This NRC requirement provides some level of redundancy in case the outer cask fails. Does this mean this leaking canister can never safely be moved? Who will allow this to be transported through their communities? How stable is the fuel inside a cracked canister? And where will the cracked canister go? There is no repository for high level radioactive waste in the US.
▪ What is the seismic rating of a cracked canister (even if it has not yet cracked all the way through)? The NRC has no seismic rating for a cracked canister, but plans to allow up to a 75% crack. There is no existing technology that can currently inspect for corrosion or cracks. The NRC is allowing the nuclear industry 5 years to develop it. It is likely to be inadequate due to the requirement the canisters must be inspected while in the concrete overpacks.
▪ What is the cost for the transport casks that will be needed for storage? Will they be on-site? Where is this addressed? Transport casks are intended to be reusable because of their higher cost. How and where will they be stored and secured on-site?
▪ How will the leaking canisters be handled by the Department of Energy at the receiving end of the transport? The DOE currently requires fuel to be retrievable from the canister.
A better solution is to use casks that are not susceptible to cracks, that can be inspected and repaired and that have early warning monitoring systems that alert usbefore radiation leaks into the environment.
LEAKS FROM DRY CASK CRACKING
The dry storage canisters at Diablo Canyon are just 5/8″ thick stainless steel. In other countries, such as Germany, 14″ to 20″ thick ductile cast iron canisters/casks are used, such as the CASTOR V/19. The U.S. nuclear industry could have chosen the thick CASTOR sealed ductile cast iron casks. Instead, they use lower quality canisters, choosing profits over our safety. NRC documents provide data that indicate thin storage containers can fail 16 years after a crack initiates.
The NRC claims fuel must be reloaded into new canisters every 100 years, unless there is a permanent repository. However, they have no technical basis to state these canisters will last 100 years, but they do have data that indicates a much sooner potential failure rate.
None of the current U.S. thin steel storage canisters are adequately designed for over 20 year storage and may start failing in as little as 17 to 20 years with through-wall cracks. Vendor claims of longer storage times are not supported by data. There is no aging management designed into these thin canisters. They cannot even be inspected for cracks or repaired.
Numerous factors can trigger stress corrosion cracks in these thin canisters. Salt moist air is one that the NRC has studied more extensively than the others. The nuclear waste containers used in the U.S. were not designed to last for more than 20 to 40 years. And there is no current technology to inspect or repair these canisters for cracks and no current method to replace these canisters.
The nuclear industry has not been routinely inspecting installed dry storage canisters and has yet to develop a method to inspect them for cracks. However, a 2014 inspection found sea salt crystals on a Diablo Canyon canister that had only been loaded for two years. Only two Diablo canisters were inspected, ranging from just 2 to 3.5 years in service. The canister loaded for only two years had sea salts and a low enough temperature range to trigger the corrosive environment needed for stress corrosion cracking initiation — much sooner than the NRC expected.
Nuclear waste storage near the coast could fail and release radiation due to the corrosive nature of salt air with metal. Pitting corrosion in a salt fog environment is troubling. If a canister became sufficiently corroded, it would have to be replaced and the fuel assemblies moved. Further, the canister and fuel rods are pressurized, so the canister would leak radiation.
It is both illogical and immoral that the NRC would allow MORE highly radioactive spent fuel to be created every day when they know there is nowhere to store it safely, and there is a likelihood that the canisters will crack, exposing the environment to lethal radiation. You need to shut the plant down now.
ONCE-THROUGH COOLING SACRIFICES MARINE LIFE
PG&E, for many years, provided state water authorities with skewed data on Diablo Canyon. The data showed that the plant’s intake of billions of gallons of water a day did very little harm to surrounding marine life. PG&E’s conclusions were based on the unscientific formula that the amount of sea life drawn into the system at the intake port could be accurately measured by the amount of small fish and other organisms at the outflow of the cooling system.
In the spring of 2000, Diablo Canyon’s operators were discovered to have withheld information from environmental regulators for two decades revealing the true effect of the reactor’s hot water discharges into the coastal waters off Diablo Cove and miles beyond. The concealed data included infrared images indicating more extensive thermal plume impact zones than previously admitted and time-series photographs showing the progressive deterioration of biologically important marine habitat in coastal waters around the reactor. The damage was catastrophic to the indigenous marine life community, including the near obliteration of the already threatened black and red abalone populations. The concealed findings also revealed up to a 90 percent destruction of many varieties of sea life as they passed through Diablo Canyon’s cooling system. These findings had never been reported to state or federal agencies.
State water authorities viewed the escalating damage as sufficiently severe to press for a cease and desist order against the utility’s previously accepted levels of waste heat discharges. A state cease and desist order would have effectively halted, or reduced the thermal discharges, or reduced their temperature, and imposed severe fines on the utility for continued heat pollution that threatened marine habitat and its indigenous species.
However, the order was undermined by the utility. Despite publicly documented evidence, and even evidence of its own, PG&E argued that no mitigation action was needed. Using a threat to outspend environmental regulators in legal actions appealing the cease and desist order, PG&E forced the authorities to back down. Instead, the state regulators have proposed to accept a settlement that ignores the reactor’s ongoing thermal damage and includes a cash pay-off of just $4.5 million for vaguely worded marine species protection measures while simultaneously reducing the scope of monitoring the harmful effects of the Diablo Canyon cooling system.
This regulatory retreat in effect allows the utility to continue its business-as-usual practices while sacrificing an entire indigenous marine life community as the cost of marketing electricity. Again, profit takes priority over life.
THE REACTOR PRESSURE VESSEL IN DIABLO CANYON’S UNIT 1 IS EMBRITTLED.
Diablo Canyon’s Unit 1 is on the NRC’s list of the most embrittled pressurized water reactors in the U.S. http://pbadupws.nrc.gov/docs/ML1310/ML13108A336.pdf
Embrittlement happens over time as the steel in the reactor pressure vessel becomes weakened by intense long-term neutron bombardment from the radioactive fuel inside. As the reactors age, they become increasingly vulnerable to “pressurized thermal shock risks.” Rapid severe cooling plus sudden re-pressurization could shatter the weakened reactor vessel and allow intense radioactivity to escape.
http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/prv.html
http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1806/v2/
There is speculation that an earthquake can be the initiating factor in this shattering.
CLIMATE DISRUPTION AND NUCLEAR ENERGY
The new normal in climate science is that there is no longer any “normal.”
The new normal regarding climate disruption is that, for the planet, today is better than tomorrow.
A study published in Science Magazine shows that global sea levels could rise by at least 20 feet BY 2050, even if governments manage to keep global temperature increases to within the agreed upon “safe” limit of 2 degrees Celsius. The study warns that it is quite possible that 75 feet of sea level rise could well already be unstoppable given current carbon dioxide levels in the atmosphere, and recent studies that show how rapidly Greenland and several Antarctic ice sheets are melting.
Disconcertingly, another new “normal” this month comes in the form of huge plumes of wildfire smoke over the Arctic. As of today, over 12 million acres of forest and tundra in Canada and Alaska have burned in wildfires, and the smoke covering the Arctic sea ice will accelerate melting there. The additional smoke further warms the atmosphere that quickens the melting of the Arctic ice pack.
A recently published study by a team from Anglia Ruskin University’s Global Sustainability Institute has shown that society will likely collapse within 30 years, due to catastrophic food shortages resulting from the ever-worsening impacts of Anthropogenic Climate Disruption. If society collapses, who will care for the nuclear waste? Who will assure the constant circulation of cooling water through the spent fuel pools and reactor vessel?
Another shocking study, one published in The Anthropocene Review, shows how humans are causing catastrophic shifts in planetary ecosystems that have been unprecedented for 500 million years. The study outlines how human actions have led to extinctions of plants and animals, and added that while “species extinctions and other changes are far more advanced” already, global warming as a phenomenon is just beginning.”
If any of these speculations are even remotely true, it is certain that nuclear power facilities built at the ocean’s edge, storing vast quantities of nuclear waste, dependent on efficient circulation of cooling water to prevent catastrophic meltdown, have no place in this world at this time.
It is your responsibility to deny the relicensing of Diablo Canyon. It is the federal government’s responsibility to locate a safe repository for the thousands of tons of toxic nuclear waste. It is our responsibility to demand that you protect us – and future generations – from the damage this technology is spreading throughout the world. Shut it down now.
THE EPA CLEAN POWER PLAN AND NUCLEAR ENERGY
The Environmental Protection Agency does not believe that nuclear power is needed in order to combat climate disruption. According to the just-released Clean Power Plan, the following measures will be taken:
Nuclear reactors under construction are not counted in the emissions targets, but neither are existing nuclear reactors, including the 6% of uneconomical, “at-risk” nuclear reactors. By the same token, relicensed reactors do not count either.
ONLY new reactors that actually operate before 2030 (the five in construction or any others) and power uprates of existing reactors can count toward meeting emissions goals.
That means there is no INCENTIVE under the rule to keep uneconomical reactors operating and no incentive to complete building new reactors. States can achieve compliance with new nuclear (but not with existing nuclear), and they are given no justification for preferring nuclear over renewables. In fact, there are several statements in the rule that indicate just the opposite.
Existing reactors cannot qualify as emissions offsets for fossil fuel generation, at least so far as compliance with the Clean Power Plan is concerned.
States could create a subsidy for new reactors or power uprates for existing reactors, but there is no incentive for them to do so.
If the EPA doesn’t think nuclear power is a viable solution to reducing atmospheric carbon, then why would the NRC?31