Join the campaign to halt Diablo
relicensing prior to seismic studies
The Sierra Club is a co-intervenor in the ratepayer case at the California
Public Utilities Commission on the funding of PG&E's application for
renewal of its license to operate the Diablo Canyon Nuclear Power Plant.
A broad public campaign to prevail upon the Nuclear Regulatory Commission
and the PUC to halt the rush to relicensing prior to completion of advanced
seismic studies was launched at an April 16, 2011, rally sponsored by
the Mothers for Peace in Avila Beach.
LUIS OBISPO REJECTS NRC's FAULTY “WASTE CONFIDENCE”
least 230 people attended an important meeting of the Nuclear Regulatory
Commission (NRC) on the evening of November 20. They came to voice their
opinions on the NRC's Draft Generic Environmental Impact Statement (GEIS)
and proposed Waste Confidence Rule. The GEIS is an assessment
of the environmental impacts associated with the continued storage of
spent nuclear fuel after the closure of nuclear plants. The Waste Confidence
Rule states that the NRC has confidence that, even though it has failed
to figure out what to do with radioactive waste for the 60 years of commercial
reactors, it will solve the problem “in time,” thereby allowing the creation
of more radioactive waste.
from the vast majority of the approximately 100 verbal comments delivered,
this absurd assumption was the motivating force for most of the downwind
residents in attendance. Some came from as far as Santa Barbara and Los
Angeles. They had to brave rain, a lack of sufficient parking, and a lack
of sufficient chairs. The walls were lined with those left standing as
the meeting began.
NRC is traveling to twelve cities throughout the nation to hear public
comment on its proposed regulations, which the Federal Court of Appeals
ordered the agency to revise because the NRC had no technical basis
for asserting that current on-site storage practices in fuel pools and
dry casks would be safe for the indefinite future. The court ruling also
forced the NRC to stop licensing or relicensing any nuclear facilities
until its errors were corrected. The NRC has set a schedule to adopt its
new Waste Confidence rule within two years so that it can resume the issuing
of licenses, even though its own staff declared it would take at least
seven years to do an adequate job.
vast majority of speakers shared the opinion that Diablo Canyon nuclear
plant is no place to store radioactive nuclear waste for the undetermined
future, in large part because of the 13 earthquake faults that surround
the two reactors.
including San Luis Obispo County Supervisor Adam Hill, urged the NRC to
order PG&E to transfer the radioactive wastes into dry casks storage
on an accelerated schedule, rather than leaving the rods in densely packed
spent fuel pools. Some pointed out that the pools are vulnerable to accident
or terrorist attack because they are not protected by thick concrete in
the way the reactors are.
speakers urged the NRC to shut down Diablo Canyon and all nuclear plants
because there is nowhere to put the waste, creating an intolerable burden
on future generations, all for the sake of boiling water for our needs
was brought up many times as a warning and an illustration of the dangers
posed by nuclear technology. It was pointed out that the entire
Pacific Ocean, and indeed the west coast of the United States, is seriously
threatened by the radiation from the crippled plant. Several also pointed
out that right up until the minute before the earthquake and tsunami hit
Fukushima, the plant operators were fully confident that their plants
Swanson, a spokesperson for San Luis Obispo Mothers for Peace, pointed
out that in determining the risks of a spent fuel pool accident, the NRC
relied on an outdated 1994 study of plants east of
the Rocky Mountains. And now, in an unsupported leap of faith, it claims
that the risks and consequences of an accident are the same for west coast
plants, despite their very different geology.
the other issues raised by the public were that California does not need
the electricity from Diablo; that a combination of conservation and increased
use of truly sustainable sources of energy can fill our needs. Several
pointed out that nuclear power is not the answer to climate change because
it produces carbon emissions in the mining and enrichment of uranium and
in plant construction.
speakers pointed out that NRC rules are useless because they are not enforced,
a prime example being allowing Diablo to operate despite the fact that
new information about nearby earthquake faults show that the plant could
not withstand the predicted ground motion from some of the nearest faults.
bottom line of most of the speakers was that the NRC should be in the
business of protecting public safety, not the profits of the industry
it is supposed to regulate. The new proposed GEIS and Rule were strongly
Read the blockbuster AP investigation of the nuclear industry:
Tritium Leaks Found at 48 US Nuke Sites
Rules Loosened for Aging Nuclear Reactors
Nuclear Evacuation Plans Haven't Kept Up with Population
Long Can Nuclear Reactors Last? US Industry Extend Spans
Don't Relicense Diablo!
"Existing plant designs are not what you want to build
today; [they are]
similar to driving an automobile without airbags."
- Per Peterson, professor of nuclear engineering, University
of California Berkeley, speaking at Diablo Canyon Independent Safety Committee
Meeting, San Luis Obispo, January 31, 2007
The Geology of Diablo Canyon
Santa Maria, CA, February
Hello, Sierra Clubbers -
PG&E must conduct a "seismic
accounting" of the chaotic network of faults that has created a shattered
zone of bedrock on and around their Diablo facility. I have authored a
tour of the area around the Diablo facility. It is an easy tour
that can be completed in a day. I invite you through this publication
to join me and see for yourself. The photographs speak louder than PG
&E's reluctance to open the door to reality. Also included are photos
of cut and polished pieces of bedrock that illuminate the crushing effects
of our local geology.
Common sense should guide this
issue, not monetary expediency nor political manipulation. Please take
the time to see for yourself.
In 2010, we joined the
Alliance for Nuclear Responsibility, CALPIRG, and the Environment California
Research Center in protesting
the application of PG&E to charge ratepayers for the costs of renewal
of Diablo Canyon's operating license without making it conditional on
completion of state-mandated seismic studies.
for Nuclear Responsibility
are co-intervenors with the San Luis Obispo Mothers for Peace on PG&E's
application to the Nuclear Regulatory Commission to indefinetly store
highly radioactive nuclear fuel rods on the Central Coast. We appealed
PG&E's permit to the California Coastal Commission in June 2004.
We are Parties in the Central Coast Regional Water Quality Control
Board's hearings on PG&E's permit to continue to use ocean water
for once-through cooling.
In April 2004, the Santa Lucia Chapter and Mothers for Peace successfully
petitioned the California Public Utilities Commission to reconstitute
the Diablo Canyon Independent Safety Committee in order to add public
outreach to its responsibilities.
We need people to read, analyze, attend meetings, and write letters.
proposed to the
Nuclear Regulatory Commission the
construction of on site storage at
Diablo Canyon Nuclear Power Plant
By Pete Wagner
PG&E has proposed to the Nuclear Regulatory Commission the
construction of a huge concrete pad called an Independent Spent
Fuel Storage Installation (ISFSI) for outdoor storage of encapsulated
"spent" nuclear fuel rods at the Diablo power plant. The
radioactivity of these rods takes about 8000 years >to die down
to the level of natural uranium ore. At present, the fuel rod >assemblies
are stored in two water baths. These will be filled to capacity
by 2006. The proposal is to continue to store assemblies in the
baths for the first five years after being taken out of service,
during which they lose much of their initial activity, and then
encapsulate and transfer them, while still highly radioactive, to
the outdoor pad. Eventually they are supposed to be moved to Yucca
The period of storage could extend long beyond 2025 when the plant
is slated for decommissioning. An operating extension for another
25 years is not unlikely to be requested, which presumably would
require enlargement of the ISFSI. Further, if Yucca Mountain should
lack space to accept the fuel rods or not be built, Diablo would
become an essentially permanent storage site.
The Chapter determined that, beyond public health and safety considerations,
protection of the environment from a potentially devastating episode
at Diablo is a significant Sierra Club issue. We joined Mothers
for Peace and several other citizen organizations as formal intervenors
in the NRC hearings and have adopted the formal position stated
in the following paragraphs:
1. What are the provisions for safeguarding the liquid storage pools
from overhead attack? Any shortcomings must be rectified immediately.
At present the liquid storage pools appear to have virtually no
protection from an overhead terrorist attack, nor has the FAA answered
our inquiry about regulations or advisories covering overflights.
The public should be told what measures, if any, are in place. Any
shortcomings must be remedied independently of the decision on outdoor
storage, because the liquid storage pools will remain in use whether
or not the application is approved.
2. After bankruptcy, will PG&E finance the mitigation measures
already adopted to compensate for the adverse effects of the cooling
water discharge on marine life, as well as new mitigation and safety
measures that might be required for the proposed project? No decisions
on PG&E's applications to the NRC and to SLO County can reasonably
be made until the financial terms of PG&E's bankruptcy application
have been settled.
Until PG&E's financial obligations under bankruptcy have been
established by the courts, there is no way of knowing whether the
utility will pay either for mitigation measures stipulated in previous
negotiations or for added mitigation and safety measures that the
new project may require. Though it has been widely believed that
PG&E has agreed to measures intended to compensate for adverse
cooling water impact at Diablo, these measures have never been enacted
and are still under negotiation with the Regional Water Quality
Control Board. Could this sad story be repeated when mitigation
and safety measures associated with the new project are negotiated?
3. What are the regulatory and jurisdictional implications of the
bankruptcy settlement? These should be specified clearly before
any action is taken on the two PG&E applications.
PG&E has asked for the abolition of state (and presumably lower
governmental level) jurisdiction over Diablo. Authority would be
vested at the federal level. The major impact would probably fall
on utility rates, but also, state and county-level jurisdiction
over environmental matters might be removed. This could conceivably
include bypassing the CEC, the CPUC, CalEPA, the ISO, the Coastal
Commission, and SLO County. The amount of authority over environmental
matters that remains with the State and County must be delineated
in the bankruptcy settlement and must be satisfactory.
4. How can the mandate and composition of the Diablo Canyon Independent
Safety Committee be restructured to include greater public involvement
and more effective dissemination of information to the public? Improvements
DCISC is a unique instrument created by the State to independently
oversee the plant. Its three members are appointed by the Governor,
the Attorney General, and the CEC. The DCISC purview appears to
be limited to an ongoing critical evaluation of plant operations,
which it does very well as indicated by a long published list of
recommendations successfully implemented over the years. Its responsibilities
do not explicitly include outreach. Its efforts at public contact
consist of placing of its reports in the Cal Poly library, holding
three open meetings yearly (which it announces widely in the press
ahead of time), and responding to inquiries from individuals on
a case by case basis. These methods for reaching the public are
passive rather than active; we could find no other mechanism for
The need for public contact has been exacerbated by the events of
September 11, 2001. Many people are worried. Several steps to reach
the public could easily be taken by the DCISC. These include moving
its small office to SLO County (it is now 100 miles away in Monterey),
providing speakers for meetings held by community organizations,
holding more frequent meetings on its own initiative at which public
comment would be encouraged, distributing copies of its annual report
to regional public libraries, and perhaps publishing a newsletter
Above all, due to a clear conflict of interest, PG&E should
be removed from the process of nominating DCISC candidates. At least
one DCISC member should specialize in community health and the environment.
Candidates for this position would also have to be technically competent
in nuclear science and engineering. They could go through the existing
nomination procedure (after removal of PG&E from the process)
and could be selected by CalEPA or another appropriate state agency
instead of one of the three offices that now appoint members.
DCISC members have told us informally that any restructuring actions
go beyond their authority; however they strongly opposed the addition
of afourth member representing environmental and public health interests
when it was proposed to the proper authority some time ago. If no
steps are taken by DCISC internally to increase public access and
communication, we should consider advocating desired changes at
appropriate offices in Sacramento or even proposing legislation.
If the original proposal for a fourth member should be resurrected,
it could lead to the possibility of tied votes. We would prefer
to see an odd number of members, three or even five, as long as
the interests of the public are represented.
5. Has a risk analysis been performed that treats terrorist attacks,
earthquakes, accidents, and other incidents that could breach plant
security and have catastrophic consequences? If so, the results
should be made available to the public. If not, such an analysis
should be undertaken by a highly qualified panel whose members have
no connection with the nuclear industry or the governmental regulatory
Any existing analyses that are applicable to Diablo should be provided
by the applicant. If none exists, a new analysis should be performed
by an independent panel at the level of expertise and credibility
of the National Academy of Sciences. It would cover all plausible
scenarios that could adversely affect public health, safety, and
the environment. We recognize that the probability of occurrence
of an episodic disaster can be estimated only qualitatively, but
the repercussions of various disaster scenarios can be quantified
and phrased in a manner understandable to the lay public.
The public should be represented both on the panel itself and in
the selection of panel members. Costs of operation should be borne
by PG as part of its application.
A new development occurred at a very recent hearing, at which an
NRC lawyer actually objected to the inclusion of terrorist actions
at Diablo as a topic in the review of PG&E's license application!
His basis was that a comprehensive NRC analysis of plant security
is already planned for every nuclear power plant in the country;
however no indication of the contents or scheduling of the NRC study
was given. It is not clear, for example, that it would be completed
before the license decision was made. Until the scope and timing
of the putative study are revealed it is impossible to tell whether
it will satisfy the criteria of independence and completeness as
well as timeliness. The Nuclear Security Act of 2001 does not call
explicitly for such an analysis but does require a security plan
for every nuclear site. This legislation, SB 1746, is now in committee.
6. Has the applicant made a comparative evaluation of the disadvantages
and advantages of other means for handling the high level waste?
Such an analysis is essential.
All credible waste handling alternatives must be evaluated for comparison
to the proposed method. This is a national need of which Diablo
is just one example. For example, reprocessing which could greatly
reduce the amount of residual nuclear waste is no longer banned.
How much of a reduction could be realized by reprocessing, and at
what risk level? What are the tradeoffs associated with further
reracking, which would significantly reduce the need for outdoor
storage but might be too dangerous? These and other plausible waste
treatment alternatives should be analyzed if they have not been.
The results should be clearly spelled out in lay language and publicized.
7. Will all feasible alternative methods for electricity production
and demand reduction be fully evaluated and compared point by point
to the applicant's proposal?
Expanding the waste fuel storage capacity at Diablo, irrespective
of how it is done, is not the only possible option; the Alternatives
analysis should include a detailed comparison of nuclear electricity
production at Diablo versus other, more benign ways of either providing
its 2000 MW baseload capacity or reducing baseload demand by the
same amount. A tradeoff analysis should be made with the most likely
alternative, a natural gas fired turbine plant that generates the
same baseload power but carries its own environmental penalties
of waste heat, atmospheric pollutants, and greenhouse gas. Wind
generation appears plausible in California -- even at the same site
-- and should be fully evaluated. There are more exotic but plausible
schemes, such as a combination of solar powered hydrogen generation
with small, distributed hydrogen burning generators. These merit
comparison to continued nuclear generation.
Another important area is demand reduction. Rate payers were remarkably
effective at lowering electricity use during the recent California
power shortage. Electricity savings through further conservation
should be fully evaluated and the potential savings in generation
be quantitatively estimated. Price elasticity at consumer and industrial
levels should be examined, as well as demand reduction through efficiency
improvements in industry, home appliances, and insulation, and incentives
designed to reward efficiency and penalize excessive consumption.
Since nuclear plants are not used for peaking, the emphasis should
be in lowering baseline generation as opposed to peaking capacity.
A useful starting point is the recent CEC 2002-2012 Electricity
8. If no method of high level waste handling is determined to involve
socially acceptable risks, should a moratorium not be called on
electricity production at Diablo until a satisfactory solution is
found? Operations at Diablo should not continue after the existing
liquid storage space is used up in 2006 unless a safe storage option
is found by that time.
Diablo produced about 6.7% of California's total electricity generation
in 2000. At the present level of operation, the amount of radioactive
waste created will continue to grow in direct proportion to the
length of time the plant operates, and the radioactivity of its
used fuel will persist at a level above that of natural uranium
ore for about 10,000 years. Safely handling this waste is an open-ended
engineering problem. Until the analysis called for above is complete,
it will not be clear whether any existing method is capable of storing
spent fuel for such a long time with a level of risk that society
finds acceptable. If this turns out to be the case, the only options
are to accept the "unacceptable" risk, to call a moratorium
until a satisfactory solution can be found, to do without the electricity,
to generate it in some other way, or to ship the waste to Yucca
Mountain; however Yucca Mountain may not ever be completed, the
transportation risk may be unacceptable, or it may never have space
for Diablo's waste fuel.
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