Public comment presented during the August 24, 2022 Engagement Panel Meeting:

MR.UMPTER:··Good evening.·Thank you, Chuck. I believe you can all hear me.· I'm Louis Umpter.· I live in San Francisco.· And I emigrated into the U.S. from France which is 70 percent nuclear for its energy production.
· · · I wanted to talk about a little bit risk versus exposition.· And this one is for you, Mariam, and the people at the gym.· So it's very important -- a lot of people are scared about nuclear.· And I think it's very important to explain the difference between the risk and exposition.
· · · Nuclear is very risky.· If you like, you know, our near (unintelligible) like, you're going to get radiated and die pretty quickly.· But the thing is we are not very exposed to that.· All right?· I trust people like Bob and the NRC to keep us safe from those dangers.
· · · However, I am much more exposed to, like, car traffic when I am biking.· All right?· And that's in the end more risky for me.· All right?· So explain the difference in risk and exposition is super important. You're never exposed to radioactive materials.· That doesn't happen.· But the safety that we just saw it allowing we can learn from historical data.
· · · I want to talk about the work of the GRC, which is the European Union body for science research which is Europe commission.· And the report from last year section 3.5 report of severe accidents.· Nuclear is on par with hydro.· So if you guys want to close nuclear plants because they are risky, you should also consider closing all hydro and damns that we have, because they are the same risk in the end.· Right?
· · · Also about safety and risk, I want to talk about the story of, like, Japan and Ukraine.· Japan and Ukraine are the two countries with the biggest nuclear accidents, yet they are ones most committed to nuclear today.· Japan just announced today that they were going to restart, like, almost 20 reactors next summer.· And they are going to build new ones.
· · · Ukraine is heavily invested in nuclear.· They are, like, one of the biggest plants in Europe today.· And it's safe even with the war.· I'm still not scared by that.· There's better fights to pick for climate change. The fight against nuclear is just, like, nonsense. Fight against, like -- fight for your transparency. Fight for better transparency with the police and so on. There's better fights.· Thank you for your time.

Public comment presented during the August 24, 2022 Engagement Panel Meeting:

MS. SAMEK:· ·I'm Jill Samek.· I'm a member of the Board of the San Luis Obispo Mothers for Peace and a downwind resident of Arroyo Grande.
· · · I am adamantly opposed to extended operation of Diablo Canyon beyond 2025 for any length of time.· It should have closed by natural consequences in 2019 when it became economically unviable.
· · · I'm opposed to any further negotiations, subsidies, continued and increased safety risks and environmental waivers.· There is a deal to close Diablo by 2025, for good reasons.· And we must not violate it. · · · It was well thought out.· And it has benefitted all parties; PG&E, cities, schools and workers.· Any attempt to renege on it shows lack of integrity and foresight.· We must not continue to burden rate payers and taxpayers with the tremendous cost of resurrecting this old dirty and dangerous plant.· We must not go back to 1960s technology.· We must not continue to generate even more toxic waste to be stored above multiple active earthquake faults.· We must not expose the region to further risks.
· · · Remember Three Mile Island.· Remember Chernobyl. And remember Fukushima.· People did die as a consequence of those accidents.· We must close Diablo as planned. We must spend our time and money on implementing 21st century energy clean resources, efficiency and conservation.· Thank you.

Public comment presented during the August 24, 2022 Engagement Panel Meeting:

· · MR. WASSERMAN:· ·Hi.· My name is Harvey Wasserman. I'm a resident of Los Angeles.· And I have children and grandchildren here.
· · · That -- the Diablo Canyon reactors are not insured for the good reason.· I want to see somebody who is advocating continued operation of Diablo Canyon step forward and tell me how you will compensate me and my family for the loss of our health and our livelihoods when and -- if and when -- and I think it's more when than if -- the San Andreas or one of the many other earthquake faults takes those reactors to the ground.
· · · Diablo Canyon One is embrittled.· We asked Gavin Newsom years ago to inspect it.· In 2019 we presented him with a petition signed by 2500 people.· And he has
refused to inspect that reactor.· And here we are after -- there were two years of very important, very credible negotiations that went on to come to the conclusion that those reactors should shut.· And now he's pushing forward in less than two months to force a decision.
· · · The 1.4 billion should go to renewables.· And there is no one advocating for the continued operation of these reactors that can come forward and tell me how they are going to be insured.· After all of these years the nuclear power industry has been unable to get private insurance.· And now you can't tell me, as a Los Angeles resident, what will happen to my children and grandchildren when those reactors blow up.· So thank you very much.

Public comment presented during the August 24, 2022 Engagement Panel Meeting:

· · · MR. PICKERING:· ·Hello.· My name is Ryan Pickering from Berkeley, California.· The purpose of my comment is to highlight a viable plan to extend operations at the plant while achieving broad community support and restorative justice.
· · · Diablo Canyon is located on the Pecho Coast, the ancestral homelands of yak tityu tityu yak tilhini tribe known locally as YTT.· On July 27th, Mona Tucker, the tribal chair of YTT sent a letter to the Governor's
office.· The letter expresses unanimous support from YTT tribal council to demand the return the Diablo lands. This land was stolen from YTT without consent, agreement or compensation.· The tribal resolution lays out a pathway towards restoring the land to the tribe for conservation.
· · · The tribe has spoken publicly that they are willing to lease these lands to PG&E for continued operation of the plant.· The tribe was not consulted in the 2018 joint proposal to close the plant, making it invalid.
· · · In June 2021 the tribe registered to acquire Diablo lands through the CPUC's new tribal land transfer police. I call on this panel to support extended operations of and partnership with YTT tribe. This ensures prosperity for California while --

Public comment presented during the August 24, 2022 Engagement Panel Meeting:

· Thank you panel.· I appreciate the opportunity to speak to you.· You represent us locally.· And I've had
that privilege at a prior time in my life representing my community up in the state legislature.· So I want to speak to you as an entity that represents us locally. And I appreciate you giving opportunity for those who live here to speak.
· · · We heard a lot about probabilistic risk assessment, which all sounds great.· Dr. Bruce Gibson talked about the difference between a fender bender and what you pay to fix a fender bender versus a more calamitous outcome that may be quite rare but the outcome of which would be absolutely devastating.· And the challenge of trying to weigh those two.
· · · We've seen many instances where advanced technologies have been believed to be safe.· We remember the space shuttle was described as safe and could have 1000 launches without a failure.· We found out very quickly that such is not the case in a complex system. We've been told that transmission lines are safe.· And the people in Paradise found out very personally just how safe they were or were not.· And same was true with the people in San Bruno.
· · · So I come to you not talking about probabilistic risk assessment.· Although I have a doctorate in geological sciences, a masters and a bachelors in geophysics from Berkeley.· I served on the California
Seismic Safety Commission and authored some of the legislation you've heard about.
· · · I come to you as a constituent, talking about the real world impacts of uncertainty.· Why do I talk about uncertainty?· Because what we're talking about here is how sure are we that we are safe or not safe?
· · · There are a lot of elements that go into that, but there is a very important area of seismology which is still under intensive investigation around which we don't have much certainty, but which we would need to know with great precision to say that the plant is safe. And that is the behavior of strong motion seismology and proximity through very large earthquakes that are literally hundreds of meters from a complex facility.
· · · Now, you heard Dr. Gibson talk about the time distance relationships, the distance magnitude relationships, and the probabilistic methodologies that are used to come up with the approximate levels of shaking.· All of that's well and good, unless you are extremely close to an active fault.
· · · Now we don't have a lot of data about earthquakes like that because -- in fact, you are very lucky to have that type of instrumentation right next to a fault when it fails.
· · · There is a fairly well-known example in Parkfield,
California, about 20 years ago where a magnitude 6 earthquake occurred.· That's where I did much of my doctoral studies.· So I am very familiar with the San Andreas Fault.· And what was fascinating with the dozens of swung motion instruments surrounding Parkfield is that when they looked at the shaking, instead of coming up with a single simple number that accurately defined how a magnitude 6 earthquake would produce shaking, they found shaking as low as a tenth of a G at 15 seconds and as high as over 2.5 G.
· · · The magnitude and range of the uncertainty and the actual measurements so far eclipse any estimate that would have otherwise have been made, you have to conclude estimates of shaking in the near field are poorly constrained.· And it's doubly so in the site response.

Closing Diablo Canyon would greatly increase the likelihood of power shortages and blackouts. At a recent California Energy Commission hearing, CAISO clarified that even if future procurement of renewable generation and storage goes perfectly, the state will still have a power generation shortfall of 1800 MW in 2025 (the year Diablo Canyon is scheduled to close). The single act of keeping the plant open will eliminate that shortfall.

Some Democrats are proposing that we close Diablo Canyon and direct funds to building even more renewables instead. That shows a misunderstanding of the problem. If California could have secured enough renewable generation and storage, to replace Diablo Canyon while maintaining grid reliability, they would have chosen that path. The problem is not insufficient funding. It’s that, despite their best efforts, they cannot procure and install the needed generation fast enough.

Even with the short-term costs of actions required to extend operation, keeping Diablo Canyon running will save money, not cost money, over time. Analyses show that continued operation would significantly reduce overall power system costs (by up to ~$20 billion). For that reason, PG&E will be able to replay the loan (of up to $1.4 billion). Furthermore, in the likely event that the PG&E will secure funding from the federal, DoE Civil Nuclear Credit program to cover such costs, the required loan amount will be significantly reduced.
Closure of Diablo Canyon would significantly delay the reduction of gas-fueled power generation in the state, resulting in more CO2 emissions and air pollution, much of which occurs in disadvantaged communities.

Even if the plant’s output could be fully replaced by renewable generation and storage, that renewable generation could have been used to replace gas (fossil) generation instead. About half of California’s in state power generation still comes of gas, and the gas fraction hasn’t fallen much in the last 20 years. Much of the reason is that California has been using increased renewables to replace other non-emitting sources (nuclear and hydro) instead of fossil generation.

This does boil down to a question of (non-emitting) nuclear vs. gas. Why is the focus on closing the carbon-free Diablo Canyon plant (first), instead of reducing gas generation? It shows a lack of concern about climate and people who are suffering from the impacts of gas plant pollution.

The Diablo Canyon plant, by itself, generates as much or more carbon-free power as all the state’s wind turbines, or all the state’s rooftop solar. Imagine if someone proposed tearing down all the state’s wind turbines, or removing all the rooftop solar panels in the state, and said that it’s “OK” because they would build enough new renewable generation to replace them, resulting in no increase in emissions. How would you react to such a proposal? That’s basically what we’re doing if we close Diablo Canyon.

I am a Ph.D. Candidate and a woman of color. I perform nuclear fusion research as a user at the DIII-D National Fusion Facility in San Diego as part of my Ph.D. work.

I want to address Senator Laird’s concerns about waste storage. I spent 22 years living in Illinois, just 15 minutes away from the now-decommissioned Zion nuclear site. I recently hosted a tour of that facility for local leadership last month, where I learned that it only took 2 years to construct from scratch and prepare the independent spent fuel storage installation that stores the Zion spent fuel. Meanwhile, spent fuel at Diablo Canyon must spend 5 years in the spent fuel pool to cool down. So unforeseen waste from extending the plant’s life past 2025 would only need to be added to interim storage as early as 2030. This would give Diablo Canyon 8 years to complete an estimated 2-year project to extend its storage capacity.

When SONGS was decommissioned less than 10 years ago, its generation was entirely replaced with natural gas. There has been much discussion regarding the safety of Diablo Canyon, which the NRC has reviewed. Yet, there is a concerning lack of interest in the public health and environmental hazards posed by the natural gas plants that would initially replace Diablo Canyon.

According to the CEC's data, 59% of all electricity consumed in California is already carbon-free. We’re actually ahead of schedule to achieve a 100% clean electric grid by 2045. Diablo Canyon alone produces 18% of that good carbon-free electricity.

If Diablo Canyon was prematurely decommissioned and renewables could ramp up production to make up for the plant closure, then we would simply be back where we are today, having made no climate progress. Without Diablo Canyon, the best-case scenario would be to tread water on climate goals just to make up for lost ground. But if California keeps Diablo Canyon open, that massive continued renewables growth would diminish fossil fuels usage and close coal and natural gas plants instead and actually make progress.

If we are serious about environmental and safety concerns during a climate crisis. If we are serious about public health during these times of drought, flex alerts, and blackouts. Then we will do everything we can to protect all of California’s clean energy assets. As a scientist and a nuclear fusion engineer, I am urging California lawmakers to save Diablo Canyon.

Diablo Canyon's lifespan should NOT be extended.

August 24, 2022

Regarding DCNPP and the proposal to extend the life of the reactors, first of all, we need to admit that everything is guesswork. Will there be a catastrophic accident? Nobody knows. But meanwhile, Fukushima proved that as long as there are "beyond design basis" accidents, there are NO experts. Beyond design basis accidents are unevaluated, unexpected, unnatural, and hopefully unlikely -- but they might happen tomorrow, and no one will be able to stop it.

And in fact, so-called "solutions" for beyond design basis accidents are actually just mitigation of the catastrophic effects. How quickly can people be informed of the danger? How far from the plant must they be evacuated? When (if ever) can people go back to their homes? All of these (and many more potential actions) are mitigations after a catastrophic beyond design basis accident. They do not prevent that accident.

Shutdown does.

Also, to make the right decisions for future generations, we would need to know what to do with the nuclear waste it generates. While we might get some electricity today, future generations will have to manage the waste without getting any benefit, but with great risk and cost all their lives.

The less we leave them, and the cooler it is, the better for them.

Regarding the money Joe Biden has offered the nuclear industry, it is blood money. It is a bribe. Don't accept it. If some other state decides to take that bribe, they'll be the sucker.

Regarding the embrittlement of Unit 1, while it might be true that the steel pressure vessel is "ductile" when it is very hot, the question is: Can it be cooled properly? Nobody knows. But we do know that at Fukushima, they decided to pour ocean water on the reactor. Cold, salty, and millions of gallons were needed. Can Unit 1 survive that?

Regarding earthquakes, for some reason the "worst case scenario" is being considered in isolation. It is just a guess. It does not consider what happens if, say, the San Andreas fault causes the Hosgri fault to also snap. The reactor might be only slightly damaged from the first quake -- but will be hanging by a thread when the second quake happens, from another fault line, in a different direction.

Lastly, there is no reason to consider Diablo Canyon to be a good "baseload" system. Unscheduled shutdowns in older plants are far more common than in the middle of their lifespan. Diablo Canyon has already entered that phase.

Shut it down and keep it shut. Don't tempt fate.

Ace Hoffman
Carlsbad, California

Some panel members have injected their own opinions about technology options. For instance Bruce Severance asserted that when DCNPP closes, the grid will be balanced by hydrogen peaker plants. Hydrogen peaker plants have never been demonstrated anywhere in the world, and have unresolved technological barriers to implementation. Barriers that may prove intractable. Examples of that potential intractability include hydrogen embrittlement, greater leakage, and the lower caloric density and storage densities of hydrogen relative to natural gas. No one currently knows if those four points are show-stoppers, only that hydrogen is not a plug-in replacement for gas. This example and other statements suggest the panel may not be equipped to make informed comments about the necessity of this power plant for California's electrical system. We have an Independent System Operator with staff that specializes in the attributes of grid components. How about relying on them to determine the right generation mix?

Thank you for accepting comments.
The Governor’s DCPP Extension Legislation draft was developed through consultation with CAISO, and with CAISO as a co-sponsor. It aims to specifically address the problem of system reliability. This is an area where CAISO is the relevant expert.
By contrast the assembly’s counterproposal does not rely on the findings of system experts, but rather favors technologies promoted by activists, lobbyists, and anti-nuclear groups.
It is understandable that many Decommissioning Panel members are deeply invested in pressing forward with decommissioning; and have vested interests. However, neither the panel, nor the State Assembly, have relevant expertise in grid reliability, or what technologies contribute to reliability. That is CAISO’s area.
Therefor a responsible approach would be to rely on the organization with knowledge to determine what is necessary for system reliability. And that recommendation is to extend DCNPP operations into the next NRC license period. I urge this panel to adjust to the decision that provides the system reliability that California residents require.
Thank you.

Thank you for your time and commitment to thoughtfully considering this topic.

I would like to share a comment in support of the extension of Diablo Canyon Power Plant. Keeping Diablo Canyon online isn’t getting in the way of building more renewables and storage, but taking it offline will mean a disastrous hit to California's economy and cost of living, quality of life (blackouts), and carbon emissions.

If Gov. Newsom could solve California’s projected electricity shortages with renewables, he certainly would. But there is no viable path for California to replace the 24/7 available electricity Diablo Canyon, which accounts for 9% of the state’s electricity generation, with other carbon-free energy sources by 2025.

In addition, we’ll need even more carbon-free electricity to meet state emissions targets and the electric vehicle mandate. Diablo Canyon is a meaningful contributor to this, and we should be only adding to our carbon-free energy generation options, not taking them away.

California has been a pioneer in the climate change movement, and keeping Diablo online will allow it to remain an example to others on how to build out a strong mix of carbon-free energy sources.

To Whom It May Concern:

Too much effort has been spent on plans for decommissioning to simply turn around and decide that the plant has more years in it. There are numerous reasons that the plant should be decommissioned: Safety of the aging plant components and spent fuel storage, to name a few.

Sincerely,
Susan Biesek

I am opposed to the extension and urge your committee to stay the course on your decommissioning work. The facility is an aged-out, poorly maintained nuclear plant. To operate beyond 2025 would require exorbitantly expensive repairs as well as the added costs of ever-mounting radioactive waste. And decommissioning will be vastly more expensive the longer it is postponed. The costs and risks increase each day Diablo is allowed to remain operating. As everybody should know by now, nuclear power is not safe, it's not clean, and it's not cheap. Instead of wasting even more money and time on Diablo, real clean technology--solar, storage, wind--needs to ramp up immediately. Please continue your committee's vitally important work to help complete decommissioning on schedule.

Mary Jones
Santa Barbara

I live in Oceano, 5 miles downwind from Diablo Canyon, and am opposed to any extension of its operating permit--for ALL of the reasons that have been documented in all previous hearings, including the one tonight.

Sincerely,

Charles Varni

Dear Diablo Canyon Decommissioning Engagement Panel,
It is critical that Diablo Canyon be shut down as scheduled by 2025. The agreement to shut the plan must be honored for all the stakeholders who participated in making the agreement. Much thought, work and energy went into the agreement, and the arguments put forth for violating it, though perhaps well-meaning, are fallacious.
There are many reasons and issues that make the shut-down critical, any one of which is sufficient for rejecting the proposed extension. Among them are the following:
1. Multiple earthquake faults nearby make the plant dangerously vulnerable to damage and disastrous radiation leaks.
2. Deferred maintenance, including lack of inspection of critical welds in the reactors, creates an extremely dangerous situation for this embrittled and aged plant.
3. The closure agreement must not and need not be violated in light of the ability of the state to provide sufficient energy via existing resources, conservation of energy, and development and bringing online of alternative energy sources.
4. The once-through cooling system is unlawful.
5. It will cost PG&E, and thus the ratepayers, billions to continue operations. Any financial expenditures should instead be applied to development and distribution of clean, renewal energy systems.
6. The issue of radioactive waste storage is critical. There is not capacity for storage of high level radioactive waste beyond 2025.

While I reside in the SF Bay Area, not near the plant, I'm concerned for the safety and economic health of all California. California's economy will be ruined, and the lives of millions living downwind from the plant, including the populations of Santa Barbara and Los Angeles, will suffer devastating consequences if Diablo Canyon were to have an accident. Radiation travels in the air, water and soil, and thus all parts of the state as well as the Western United States will be harmed.
Please do not agree to extending the operation of Diablo Canyon.
Thank you.
Cynthia Papermaster, Berkeley, California

Another voice on the history of NRC decisions of acceptable risk concerning seismic safety from the Union of Concerned scientists:

Of the many concerns facing the potential extension of Diablo Canyon, the most glaring is the issue of the spent fuel storage. Currently there is no destination for the excess waste created past the 2025 deadline. Where will the extra waste go? Who will protect the local communities from the hazards of this waste while we figure out a storage solution? If construction is made, what local ecosystems and environments would have to be demolished to make room? What is the justification for perpetuating this toxic energy generation when it carries so many risks?
To elucidate on a few other concerns, what is the plan to mitigate against the already-diagnosed seismic risks, one of the contributing factors towards the decision to decommission initially. Why are we acting as though these risks have diminished because of Newsom's sudden concern we won't have enough energy to make it through warming summers, despite the rapid development of solar and other renewables that is on track to replace Diablo as planed?
The hypocrisy and inconsistencies are abundant and the lack of transparency regarding Newsom's sudden about-face on Diablo and PG&E insinuates there is more to the effort to keep Diablo online than fear of a future blackout.

I am strongly opposed to the continuation of operations at Diablo Canyon beyond the currently agreed closure. This is a high risk operation situated on fault lines, at risk of earthquake and tsunami surrounded by a growing population of 500,000 people not to mention wildlife and birds of land and ocean. An accident here would be devastating to the local economy as well as the welfare of San Luis Obispo county inhabitants.
It would be much more efficacious to take the money that the Governor is offering to expand battery storage and to encourage wind and solar power in alignment with the recent federal IRA act.

Stanford Physicist Amery Lovins presents compelling data arguing that the extension of Diablo Canyon beyond 2025 is counterproductive from both an environmental and ratepayer perspective......

Please find attached the opening statement by State Senator John Laird (SD 17, including all of San Luis Obispo County) at the Governor/CEC/CAISO workshop on August 12, 2022, regarding the proposed extension of the Diablo Canyon Power Plant.

re: Continued operation of Diablo Canyon

see attached report: Pathway to a Clean and Reliable Grid for California -- without Diablo Canyon: Analysis and Recommendations

Hello,

Diablo Canyon Nuclear Power Plant must be shut down as scheduled by 2025. There are myriad unresolved and disconcerting issues: seismic vulnerability, violation of the closure agreement, unlawful cooling system, storage of even more high-level radioactive waste, and the prohibitive cost of this attempt to resurrect the Plant. In addition, in a worst case scenario, there would be no escape of injuries and likely death of Plant employees and residents in much of San Luis Obispo County.

We are near-lifetime residents of San Luis Obispo who urge the scheduled closure of the Diablo Canyon Plant as scheduled by 2025.

Sincerely,
Warren and Carol Sinsheimer
San Luis Obispo

Attached letter contains questions regarding potential license extension versus decommissioning of Diablo Canyon Nuclear Power Plant.

Letter submitted to PG&E by legal counsel on behalf of the San Luis Obispo Mothers for Peace.

Dear Ms. Poppe and Mr. Simon,

Attached please find a letter on behalf of San Luis Obispo Mothers for Peace, urging you to abide by the terms of your well-considered 2016 decision to retire the Diablo Canyon nuclear reactors and alerting you to some of the legal consequences of abandoning that decision.

Sincerely,

Diane Curran
Counsel to San Luis Obispo Mothers for Peace

Public comment presented during the May 25, 2022 Engagement Panel Meeting:

· · ·MR. MARRE:· Great.· I want to build on what Marty Brown alluded to in terms of monitoring of radioactive waste (inaudible) good old-fashion Geiger counter.· You have some vents, some intake events which are just, you know, fine.· But then you have some outflow events.
· · ·What is your radioactivity of the air coming out of there in those outflow events?· That's the question.