•Scheduled to be decommissioned in 2024/2025 (two 40 year old reactors)
•PG&E is applying to add 20 more years of operation, until 2045. (will be 60 years old)
•Radioactive nuclear waste is increasing and being stored onsite until 2105, but with no alternative storage site, forever?
Introduction
Our thoughts and prayers go out to the people of Japan and the victims of this tremendous ongoing tragedy as we write. This nuclear accident is the second tragedy affecting marine habitat with implications for our local rich, diverse and dense marine habitat and life forms with national and international significance we have witnessed during the last few months. The first tragedy was the oil gusher in the Gulf of Mexico, a grim demonstration of what is possible off our shores.
The nuclear disaster in Japan also demonstrates what the release of radioactive materials into our land and offshore waters would entail. Nuclear power advocates are flooding the media and internet with dubious messages designed to placate growing public and scientific concern.
PG&E's Diablo Canyon Nuclear Power Plant (DCNPP) is mankind's attempt to assume that engineering can eliminate any possibility of a seismically induced accident. However, improbable is not impossible, as earthquakes are unpredictable. "Now, as Japan struggles to contain four out-of-control reactors, all of us—whatever our views of nuclear energy—must focus not on assurances that it can't happen here, but rather on ensuring it never does," Joel R. Reynolds, senior attorney and director of the Southern California program of the Natural Resources Defense Council.
From the beginning, (designed in the 1960's and built from the seventies through the early 1980's), local residents and concerned scientists have opposed and questioned DCNPP for four main reasons:
1. Risk benefit analysis and economic costs to the public, the state and the national economy
2. Storage of deadly radioactive spent fuel onsite
3. California's unpredictable seismic faults could cause dangerous earthquakes
4. Once through cooling is problematic to operational shut-downs, destroys at least 1.7 billion fish larvae each year, and is vulnerable to tsunamis
Risk Benefit Analysis and Economic Costs to the Public and to the State and the National Economy
What would happen if a massive earthquake hit a California nuclear power plant? Estimates are that California represents 13% of the US GDP, 12% of the population, and ranks eighth in global economies. Therefore, loosing California's productivity due to a nuclear accident would be catastrophic to both California and the entire United States of America.
Nuclear power plants are built within an economic philosophical framework called risk benefit analysis. Do the benefits of an economic endeavor outweigh the real and potential risks? The bottom line is that for San Luis Obispo (SLO) County residents, we are the at risk. For PG&E, profits are the benefits. The tragic problem with PG&E's bottom line is that it's fractured with known and hidden faults upon which the other risks of nuclear power sit.
The real experts for risk benefit analysis can be found in the insurance business sector of the economy. Our political and economic system has designed within it a variety of checks and balances to avoid undue risk and maintain a balance of power. After careful study, the insurance companies, when approached to insure nuclear power plants, refused. For them, the risks were too overwhelming. How did the nuclear industry do an end run around this check? They got the government to insure them (the Price-Anderson Act of 1957). The Encyclopedia of Earth states, "opponents argue that the Act represents a massive taxpayer subsidy of the nuclear industry that substantially reduces the cost of doing business. Some opponents claim that without the cap on liability damages, the industry could not survive."
Had PG&E proved during the licensing and hearings process a willingness for transparency, being openly forthcoming, honest, and non-bullying, many a PG&E critic would not be looking askance at the avalanche of safety and not-to-worry hubris filling local and national newsprint and air waves as the Japanese tragedy unfolds.
Some could give PG&E credit for naming the plant after the devil, Diablo Nuclear Power Plant, as unintended truth in advertising. Some believe the devil comes in many disguises, bearing gifts to the gullible. In this county, the gifts have come in the form of a huge property tax windfall for government and for a large number of groups, associations and non-profit organizations, as generous donations and grants. This has bought many open—and unfortunately—hidden friends and a loud painful silence.
Let us examine some of the risks PG&E is willing to take, since they have no real liability.
1) A radioactive release large enough to radiate a 12-mile radius would close down the major north-south coastal transportation corridor for the entire state and cause considerable damage to our county population and ocean life.
2) A radioactive release large enough to radiate a 50-mile radius would threaten National Security by making Vandenberg Air Force Base useless. That also means no West Coast space launch site.
3) Radiation would contaminate vast areas of major agriculture production including perhaps California Central Valley agriculture lands. This would also perhaps shut down the other main north-south transportation corridor.
4) Then there is the huge population who survived the earthquake damage at risk and faced with death, slow death and injury from radiation.
This potential destruction is as if PG&E has been playing a card game while being pals with the card dealer (NRC) and the gambling house (Nuclear Industry). However, PG&E has not been playing with their money, but with the money belonging to all others at the table (ratepayers). PG&E was given an operating permit to get away with a bet on our lives and livelihood and on the economy of the county, state and, nation and national security (Vandenburg Air Force Base, aka Space Port West Coast). All these risks have been for PG&E's profits.
What About the Payments the California Ratepayers Continue to Pay?
Extending DCNPP's operating license would likely open ratepayers up to footing even more than the $5.5 billion bill for the plant thus far, commented Steven Weissman, a former administrative law judge at the California Public Utilities Commission (CPUC) and current law professor at the University of California, Berkeley, as reported in the Scientific American magazine.
Furthermore, as reported in the same article, California's only power to influence the federal relicensing process lies in its ability to protect customers from high electricity rates. PG&E's request to pass on about $85 million of seismic studies and other relicensing costs to the ratepayers could provide an outlet for the California Public Utilities Commission to withdraw the plant's certificate of public convenience and necessity.
Storage of Deadly Radioactive Spent Fuel Onsite
Concern: Safety of Indefinite Storage of Nuclear Waste Onsite
The DCNPP, owned and operated by PG&E, consists of two reactor units, and each unit has its own spent fuel storage pool. The Diablo Canyon Independent Spent Fuel Storage Installation (ISFSI) provides additional spent fuel storage capacity when the storage capacity of the spent fuel pools is reached. The Nuclear Regulatory Commission (NRC) has stated that nuclear power plants may store spent fuel onsite for 60 years after cessation of operations.
DCNPP plans to put the spent fuel from the pools into dry storage casks. However, with a 20-year extension to PG&E's operating license, the pools will then be used to store the next 20-year supply of spent nuclear fuel. The U.S. has no permanent storage solution for the waste, which takes about 250,000 years to lose it's harmful radiation potency. Therefore, San Luis Obispo County now has a radioactive storage site at DCNPP, one that was never planned, permitted, nor agreed to by the community or the state of California.
Janet Zimmerman's article, "Japan Crisis Renews U.S. Nuclear Fuel Storage Debate," in the Press-Enterprise is an analysis of the problems with the U.S. storage of radioactive nuclear spent fuel.
Zimmerman states, "At U.S. nuclear plants, spent fuel rods are cycled out of reactors every 18 months or so and placed in deep pools of circulating water to cool. The process takes seven years or more. As the pools reach capacity, the rods are moved to dry-cask storage on site, since there is no national repository." Nuclear power plants have to rack and stack their used nuclear fuel and build another facility to maintain and guard. Therefore, U.S. communities with nuclear power plants now have to also endure radioactive nuclear waste storage sites.
Zimmerman further reports that in a 2008 speech to the nuclear trade industry, Nuclear Regulatory Commission head Gregory Jaczko said it is safer to store spent fuel in the dry containers than in the wet pools. He recommended requiring plants to transfer spent fuel to dry casks rather than letting it accumulate in the pools.
A large radiation release from a wet pool fire could result in thousands of cancer deaths and hundreds of billions of dollars in decontamination costs and economic damage, according to a 2004 study published in the journal Science and Global Security. (Storing Radioactive Fuel)
Newsweek reported a study that showed," an attack on a dry cask storage area would result in a much smaller release of radioactivity and much less severe damage." In one important respect, the threat in the U.S. might be even greater than what befell Japan. The U.S. has failed to establish a permanent nuclear-waste depository, the NRC allows plant operators to move from "open rack" configurations—which cool the rods most effectively—to a "dense pack" design that eventually fills pools "almost wall to wall," argues Robert Alvarez of the Institute for Policy Studies, a former Department of Energy official.
Diablo is Faulted - Quake Risk
Concern: New Seismic Shoreline Fault Added to Other Faults
In 2008, a new seismic fault line, the Shoreline Fault, was found less that a half-mile from the plant.
The Diablo Canyon Nuclear Power Plant would not be permitted, due to this and the other multiple seismic threats, if it were planned to be constructed today on the location it currently sits.
California State Senator, Sam Blakeslee (R), a former Exxon research scientist from San Luis Obispo with a Ph.D. in earthquake studies, authored a bill in 2006 Assembly Bill 1632 (Blakeslee, Statutes of 2006, Chapter 722), requiring the state to assess the vulnerability of the state's nuclear plants to a major disruption either from an earthquake or plant aging. The California Energy Commission, in turn, produced a report in 2008 directing both utilities to update their seismic studies using more advanced techniques than had ben available before. Neither has yet done so.
USGS states, "The chance of having one or more magnitude 6.7 or larger earthquakes in the California area over the next 30 years is greater than 99%." The chance for a magnitude 7.5 or greater earthquake is set at 46%. (USGS)
The seismic risk map shows the danger of earthquakes for the state.
See: Economic Populist.org - Post Nuclear Japan-pre-Disaster United States
California's two nuclear power plants are located on or near major fault lines. The Diablo Canyon facility is of particular concern. Designed to withstand a 7.5 magnitude earthquake, there are reasons to be less than confident in this estimate. The plant operator, PG&E, completely misinterpreted blueprints in the initial construction of "certain crucial pipe supports in the reactors containment room." The misinterpretation involved constructing the pipe supports in a "mirror image" of the intended design.
Diablo Canyon is just 2.5 miles from the Hosgri Fault, a major portion of the San Andreas Fault. Construction proceeded despite the discovery of this massive fault early on. In fact, Carl Neiburger, staff writer for SLO Telegram-Tribune wrote the article, "14-year cover-up - PG&E declined to pursue fault" in the November 5, 1981 newspaper. Neiburger's article begins, "Pacific Gas and Electric Co. found evidence of an earthquake fault within 500 feet of the Diablo Canyon nuclear power plant in 1967 but chose not to pursue it to avoid 'additional speculation and possibly delay the project.' "
According to the Southern California Data Center, the last major rupture of the Hosgri Fault Zone occurred November 4, 1927. The probable magnitude was 6.5-7.5, and the fault was primarily reverse and thrust, with some right-lateral slip.
Recently, PG&E executives diminished the importance of the Shoreline Fault less than a mile offshore from the nuclear plant. This fault was discovered in 2008.
Ralph Bishop authored a book that gives an easy photo-documented geological tour of the area around the Diablo facility. 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. Mr. Bishop observes, "Although the epicenters of many earthquakes take place on or near main trending faults, the terranes crushed between them are always impacted by the vertical thrust fault that separate them and often creates a higher degree of jeopardy and damage. "Undiscovered" or "blind" thrust faults that riddle the bedrock can also rupture independent of main trending faults at any given time."
Once through cooling at DCNPP is problematic to operational shut-downs and destroys about 1.7 billion fish larvae each year, as reported by San Luis Obispo's Mothers for Peace, in the November, 2010 issue of the Journal.
Maintaining the proper functioning of nuclear cooling systems is vital to safety. However, David R. Baker reported there was an 18-month uncorrected emergency reactor cooling system failure at Diablo: "Union of Concerned Scientists . . . report criticizes both plant operators and the Nuclear Regulatory Commission for allowing some known safety issues to fester" in the March 18, 2011 San Francisco Chronicle.
While DCNPP sits on a high cliff, the once-through cooling intake is at sea level. Therefore, when the ocean water retreats before the tsunami waves come onshore, the cove would have no ocean water to intake. Also, debris and marine life could become stuck and cut off the intake of water. Jellyfish have already caused a manual shutdown at DCNPP, as well as at other nuclear power plants for becoming impinged in the intake of the OTC. "Impingement" is the capture of larger organisms such as fish and shrimp on screens protecting the small bore tubes of the heat exchangers from blockage.
Also, the height of the cliff supposedly makes DCNPP out of reach from a tsunami. But there are numerous stream-eroded channels along the cliff that are possible weak points to a world-class tsunami, as for example, with the October 2010 Indonesian 7.5 quake-generated tsunami.
OTC is covered in our article on CORE AREAS 5 & 6 in the November 2010 issue of the Journal. (Scroll down to threats for a detailed description.)
We are concerned that 1.7 billion fish larvae and uncountable microscopic life forms are killed in the OTC of Diablo Canyon plant each year. Despite the State of California outlawing OTC for new power plants, DCNPP is allowed to continue using OTC until 2025. However, since OTC is used to cool the pools as well, the loss of marine life will possibly continue after the decommission of the plant to maintain the cooling pools.
Conclusion
In our opinion, because of the high risks of nuclear accidents, PG&E needs to formally withdraw their license renewal application for DCNPP until PG&E adheres to Assembly Bill 1632 (Blakeslee, Statutes of 2006, Chapter 722), and ALL seismic lessons learned from Japan are resolved.
Rushing to achieve more years of operation rather than focusing on safety issues is irresponsible.
Many ask, what can I do? We are going to write a letter to Governor Jerry Brown and to the California Public Utilities Commission (CPUC) stating our concerns.
If you would also like to take this action, here is the information:
TAKE ACTION–SEND A LETTER: to Governor Brown and CPUC opposing Relicensing of California's aging nuclear plants.
Please "copy" the following letter, add or modify with any of your own personal comments, and then open the website for email to Governor Jerry Brown. At his web site, choose "Energy Issues/Concerns" from the drop down menu, add your personal information, and then paste the contents of the letter.
You can then send email the Public Advisor at the California Public Utilities Commission. We would appreciate if you would also send a cc: to Rochelle@a4nr.org. In the "Subject" box type: A. 10-01-022 OPPOSE Settlement Agreement
RE: RELICENSING OF CALIFORNIA'S NUCLEAR PLANTS
CPUC Application. 10-01-022 (Diablo Canyon)
Dear Governor Brown and CPUC Commissioners:
In light of the tragic events unfolding in Japan due to the earthquake, tsunami and nuclear meltdowns, we are gravely concerned about the seismic threats at California's nuclear power plants. As the Japanese have sadly learned, despite assurances from their regulators, the seismic risks were greatly underestimated. After the discovery of a new fault only 1800 feet from Diablo Canyon, which has yet to be independently studied, analyzed, and peer reviewed, there is no reason to delay fully implementing the studies authorized under AB 1632 for both operating reactor sites.
We ask that you instruct the CPUC to rescind the Certificate of Public Convenience and Necessity for both PG&E's Diablo Canyon and SCE's San Onofre nuclear power plants, and allow them to operate conditionally only under the agreement by the utilities to immediately begin to fully comply with completion of the state-directed AB 1632 studies. These studies must be completed and independently peer reviewed by 2015, and any ability of the utilities to operate the facilities after that date will be contingent upon the results of the studies and analysis.
We cannot wait for a disaster like the one befalling Japan to strike before we act.
Yours truly,
Please place this message in the official record of the proceeding and forward to all CPUC Commissioners.
