Presentation at 9/14/2018 Facility Repurposing Workshop. Please see workshop video.

19 MR. HOUGHTON: Thank you, Chuck. My name is
20 Dave Houghton, and I live in San Luis Obispo.
21 Interesting meeting. I didn't expect to see a
22 lot of PASION at a meeting like this, but I think we're
23 getting some and that's good.
24 So I was at the last meeting where Bob Budnitza
25 held forth with what's happening actually with
0076
1 decommissioning and the process and so forth and the
2 technical side of it. And at that meeting, I recall that
3 there was a possibility that the DCISC would continue into
4 decommissioning, and that that may have been a proposal
5 before the PUC, so that's one question I have. Does that
6 having legs? Is that likely to go anywhere? And is that
7 committee likely to continue? Because it seemed like
8 everybody agreed that would be a nice idea.
9 So I am going to roll on with my questions --
10 MR. ANDERS: Our normal process is to not
11 respond during your comments but possibly after.
12 MR. HOUGHTON: Okay. So should I keep asking
13 questions?
14 MR. ANDERS: Yes.
15 MR. HOUGHTON: And then you'll rack them up.
16 Okay.
17 And my next comments and questions are about
18 Alex's proposal.
19 And Alex, I certainly understand the
20 philosophical underpinnings of what you're getting at
21 there, and my question is more about the practical side of
22 it. So are you concerned truly about influence that might
23 be exerted by PG&E or are you concerned more about the
24 perception of the structure of this? And are there
25 specific actions that you think that might or might not be
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1 taken by this committee -- and again, remembering that's
2 only advisory, not even advisory, but engagement -- that
3 you could point to that you think might be harmful, that
4 either would or wouldn't be taken?
5 And then my last question was about the cost of
6 this committee has been mentioned a couple of times. And
7 I probably could look this up somewhere. I did try to
8 look up the new website, and all I got was something that
9 told me that my phone was being infected; so whoever
10 that's connected to right now probably need to --
11 So the cost, what is approximately the cost of
12 this and the budget of this committee? I understand it's
13 shouldered by PG&E and currently by shareholders rather
14 than ratepayer funding. It's my understanding it's not in
15 the rate base. And are there per diems for this committee
16 in addition to covering traveling expenses? So those are
17 my questions. Thank you.

17 MS. SWANSON: Yes, Jane Swanson. I am speaking
18 just as an individual, not on behalf of an organization
19 tonight. And this is very brief and very general, but
20 this discussion has been excellent tonight. And everybody
21 has valid points to be made. But the question is how do
22 you bring it together? And I have no wisdom on that, but
23 I just wanted to point out some reflections on the word
24 expert. Some of the -- a fair amount of the discussion
25 was about the availability of experts and the value of
0080
1 experts. And yeah, experts are very valuable, but I want
2 to point out my own personal thoughts that being an expert
3 does not make one right or wise. If you think about what
4 experts do, in my personal vision, what experts -- there
5 is a risk -- I'm not saying all experts do this, but there
6 is a risk for an expert to get a little bit of tunnel
7 vision and not see beyond it.
8 So I was just thinking -- so talking about
9 technical experts that know a lot about nuclear physics,
10 what have they done for the world so far? Well, they
11 brought us atmospheric testing of weapons which has
12 polluted our earth totally. They brought us the bombing
13 of Hiroshima and Nagasaki, and some people justify that.
14 I won't argue about that. I'll just say experts did that,
15 and some of those experts had second thoughts about it
16 also. And so I don't mean my comments to be geared only
17 toward nuclear experts, but it's true of anything. City
18 planners, experts in medicine, whatever, it's easy to get
19 into the tunnel of your expertise and not see the broader
20 vision. That's why I come to these meetings because I am
21 not an expert in anything. But like some people on this
22 panel, I've been around for 75 years, so I know a little
23 bit about life and the bigger picture. Thank you.
24 MR. ANDERS: Thank you very much.

As a result of this meeting, I know more about the Diablo Canyon decommissioning process.

Presentation at Spent Fuel Workshops. See Workshop Video.

Presentation at Spent Fuel Workshops. See Workshop Video.

Presentation at Spent Fuel Workshops. See Workshop Video.

http://cal-span.org/unipage/?site=slo-span&owner=DCDEP&date=2019-02-23

http://cal-span.org/unipage/?site=slo-span&owner=DCDEP&date=2019-02-23

http://cal-span.org/unipage/?site=slo-span&owner=DCDEP&date=2019-02-23

Presentation at Spent Fuel Workshops. See Workshop Video.

Presentation at Spent Fuel Workshops. See Workshop Video.

Presentation at Spent Fuel Workshops. See Workshop Video.

(This comment is offered after watching the March 13th meeting, and also the recent 2 day workshop on spent fuel). COMMENT: I don't think I don't think there has been enough of an effort by the March 13th presenters (Dr. Budnitz and PGE) to explain to the public that the fuel currently being used in the reactors, will be hotter when it comes out of the reactors not simply because it just came out of the reactor. It will be hotter because the current generation of fuel used in nuclear reactors is what is called high-burnup fuel, which by its nature, is intentionally hotter than previous generations of fuel used in the reactors. So it seems to me that what is being missed here, is that a big part of the spent fuel problem , is that PGE plans to operate the plant another 5 to 6 years, utilizing this much hotter, high burnup, fuel. It is the continued use of this high burnup fuel the next 5-6 years, that is a very big contributing factor, to PGE's decision and perceived need to halt offloading fuel from the pools now.

8 MS. SWANSON: Yes. I'm Jane Swanson,
9 spokesperson for San Luis Obispo Mothers For Peace and I
10 1,000 percent endorse every word that Carol just said,
11 very much worth thinking of and it ties into the one
12 topic I want to bring up.
13 At the two days of workshops in February, there
14 were extensive presentations comparing different types
15 of casks and canisters for storing that spent fuel. The
16 information was well-presented and it was valuable. I
17 learned a lot, but the conclusion I drew was that
18 there's no such thing as the perfect canister or the
19 perfect cask. There are issues with all of them related
20 to monitoring, inspections, leaks, corrosion, blah,
21 blah, or how thick the walls of a canister should be.
22 The ones currently used at Diablo are less than a half
23 inch thick; whereas, in Germany and Japan, they are nine
24 inches or more. Lots to think about and debate there.
25 So I'm asking this panel, and especially
0101
1 Pacific Gas and Electric Company, to seriously ponder
2 the concept of hardened on-site storage. At that point,
3 you're quibbling over which kind of canister or cask.
4 You do the best you can, but you don't count on them for
5 your total package of protection.
6 Given that spent fuel is a million times more
7 radioactive when it comes out of the reactor than when
8 it goes into the reactor, it's crucial that this spent
9 fuel be protected from a possible terrorist attack.
10 It's something we cannot rule out in this day and age.
11 Hardened on-site storage requires that the
12 spent fuel be surrounded by earthen berms or concrete or
13 gravel or something to make them less visible to
14 possible attackers and also sheltered from such an
15 attack.
16 Given that there is not presently any long-term
17 underground storage for radioactive waste, given that if
18 eventually a repository even the size of a Yucca
19 Mountain one should open, it will only be able to take a
20 fraction of the radioactive waste that's already stored
21 at various reactors.
22 Given that the proposal for consolidated
23 interim storage is currently merely an idea and it is
24 definitely contrary to federal law because federal law
25 says no fair doing interim storage unless you have a
0102
1 permanent repository already in place, which we don't,
2 we have to assume that the waste will be stored at
3 Diablo Canyon for decades or hundreds of years or more,
4 we don't know, and given that length of storage, it only
5 makes sense to seriously consider hardened on-site
6 storage.
7 It would be most -- much preferable to the
8 current reality with the casks grouped together all
9 nice, neat rows and totally visible from the ground, the
10 ocean or the air. Yes, hardened on-site storage would
11 be an additional expense, but given the possible
12 consequences of a terrorist attack, it seems a very
13 worthwhile investment. Thank you.

1. When and where will security of Diablo spent fuel be discussed by the Panel?
2. What are the specifics of the San Onofre off-loading: time, strategy of hor and cold rods, what kind of casks are they using and can they be transported?
3. Why is $ an issue since the cost of off-loading is passed on the the consumer?

Who will pay for the emergency planning and response necessary while the fuel is in the pool, and when it is sent to dry cask?

During the Decommissioning Engagement Panel’s recent workshop on spent nuclear fuel (“SNF”), Kara Woodruff requested a response from the Alliance for Nuclear Responsibility (“A4NR”) to PG&E’s asserted conflict between reducing pre-shutdown inventories of SNF in the Diablo Canyon fuel pools vs. achieving the earliest possible post-shutdown elimination of wet storage of SNF. A4NR believes both objectives are compatible and the expected consequence of the direction from state regulators PG&E has ignored for more than a decade. Beginning with its AB 1632 Report in 2008, the California Energy Commission has urged PG&E to return each of the two fuel pools to its original design capacity of 270 fuel assemblies. In 2014, the California Public Utilities Commission conditioned financial approval of PG&E’s expansion of the ISFSI pads on PG&E filing with its 2017 general rate case “a satisfactory plan to comply with California Energy Commission recommendations regarding the transfer of spent fuel to dry cask storage in its Assembly Bill 1632 Report." Rather than file such a plan, PG&E agreed in settlement of its 2017 general rate case and in its Joint Proposal to Retire Diablo Canyon to coordinate and collaborate in good faith with the Energy Commission to file an SNF plan as part of its 2018 NDCTP filing. The CPUC directed that this collaborative effort evaluate both pre-shutdown and post-shutdown expedited transfers of SNF to dry casks. At the Engagement Panel’s February 22, 2019 workshop, the Energy Commission’s Executive Director made clear that this collaboration never took place. Determining an optimal dry cask loading schedule is a computationally intensive task, which is why the engagement of the Energy Commission as an objective and transparent forum is indispensable. A4NR has long embraced the guidance offered in 2008 by the NRC Chairman, Gregory Jaczko: “The most clear-cut example of an area where additional safety margins can be gained involves additional efforts to move spent nuclear fuel from pools to dry cask storage.” The Diablo Canyon Independent Safety Committee reached a similar conclusion in 2013, observing also that dry cask loading costs will likely be absorbed by the Federal government. PG&E’s cask vendor began (successfully) licensing a 3-year cask in 2011, announcing an NRC License Amendment Request to accommodate plants that have loaded canisters with predominantly low decay heat fuel assemblies over the years, and have thus substantially depleted the number of cold fuel assemblies remaining in their pool inventory. This LAR has also been prompted by the cataclysmic events at Fukushima Daiichi which indicates that a more rapid movement of used fuel in wet storage to dry storage may be the preferred approach. This high heat-load cask would appear directly applicable to the constraints PG&E often cites for extended wet storage. It is implausible that its existence has been unknown to PG&E, given the requirement of California’s Nuclear Decommissioning Act of 1985 that each triennial update to PG&E’s decommissioning cost estimate reflect changes in technology and regulation. Yet PG&E currently relies on a 7-year wet cooling assumption, and was faulted by the CPUC for the unreasonableness of its 10-year assumption in the 2015 NDCTP and its 12-year assumption in the 2012 NDCTP. A4NR is uncertain what significance to attach to statements about the availability of a 2-year cask for Diablo Canyon made by two of the vendors at the Engagement Panel workshop. But in early 2018, the NRC staff recommended approval of a 2-year wet storage period to accommodate the accelerated transfer of high burn-up fuel assemblies from Vermont Yankee’s final core offload. Why has PG&E been so slow to adapt? It is widely believed that the company’s culture allowed insular decision-making and cognitive bias to inhibit best practices in gas pipeline inspection, vegetation management, and distribution line reclosers and insulation. The sad state of PG&E’s SNF policy conforms to this pattern. 

Please update the PG&E Engagement Panel website regularly. In February when a public meeting date was canceled it was not updated on the website in a timely way, so I went to a non-meeting. I am looking at the online information on the Feb. 22, 23 workshops on waste storage, which states the meetings are 8 am to 5 pm. But a member of the DCDEP tells me the Friday workshop goes until 7 pm and the Saturday probably will end more like 4 pm.  I also think it would be appropriate for the public to have access to the agendas for these workshops. Who will be presenting on what topics? Can we be informed of the approximate times of various presentations?

How about a solar powered de-sal plant. There is a small scale system on site now. Solar technology should expand to the point where it would be feasible to operate using solar power as main source. Run the fresh water product along the access road into Avila and tap in there.

See attached letter of support for making land and facilities available to yak tityu tityu yak tilhini - Northern Chumash Tribe.

To Whom It May Concern

As Diablo Canyon starts the decommissioning process, I would hope that this endeavor be put under a PLA ‘project labor agreement ‘. This will insure that the safest and most highly trained local workforce is utilized to its highest potential. It is my sincere belief that PGE owes this to the community to put into place the only mechanism that will insure all of the above

Sincerely

Martin A. Rodriguez
Business Agent Ironworkers local 433
President
Tri- Counties Building and Construction Trades Councils
AFLCIO

I would like to comment about the potential use lands freed up by the closing of the plant. I personally would like to see lands set aside for recreation and conservation. Construction of trails so the public can enjoy this beautiful part of our coast should be a top priority.
Thanks for listening.

Brian Koch, MD

Please respect the will of the local voters and consider the benefits to the entire state and region and PRESERVE THE ALL THE DIABLO LANDS FOR MAXIMUM PUBLIC ACCESS IN PERPETUITY.

I completely support the recommendations regarding the future of the Diablo Canyon Lands.