Your Address

Sat, 05 Jul 2008

California Public Utilities Commission
505 Van Ness
San Francisco, Ca

Dear Commissioner Brown,

Re: DEIR for steam generator replacements at the San Onofre Nuclear Generating Station

California Public Utilities Commission 505 Van Ness San Francisco, Ca

Dear Commissioner Brown,

Re: DEIR for steam generator replacements at the San Onofre Nuclear Generating Station

As California ratepayers, we question the conclusion and the premises of the Draft Environmental Impact Report (DEIR) issued for the Proposed Project to replace the steam generators at the San Onofre Nuclear Generating Station (SONGS). The DEIR fails to review several important environmental impacts that would result from this project.

The SONGS DEIR, blatantly omits an analysis of at least an additional decade of component replacement and maintenance necessitated by the Proposed Project, as well as the production of high-level radioactive waste that will continue to be produced and must be stored on earthquake-active coastal bluffs if the generators are replaced. In addition, the SONGS DEIR relies on a myriad of possibilities and probabilities untried at any other nuclear reactor site.

A plan at San Onofre to either the replace the facility or replace its aging components must begin with weighing the true costs, both economic and environmental. The CPUC DEIR and case-in-chief fail to analyze the full environmental and economic costs of steam generator replacement and therefore is deficient and should be rejected.

California is still reeling from an energy “crisis” and the resultant damage to the state’s budget. To blindly go forward with a project that contains so many “estimates” of costs and will likely result in billions of ratepayer dollars being invested could prove extremely costly and financially short-sighted. It is vital that the CPUC acknowledge that this is an aging technology with an unknown future requiring costly replacements and sited precariously on seismically active coastal zones with a daily production of high-level radioactive waste which must be stored on our coast.

The DEIR for San Onofre is riddled with qualifying words and sentences and relies heavily on the unknown. For example:

1) The proposed project is complicated by numerous challenges unique to the SONGS 2 & 3 site when compared to other nuclear plants…De-tensioning tendons of the type at SONGS 2 & 3 has never been attempted at another operating nuclear plant. Most of the tendons are not designed to be de-tensioned or removed. (B-10)

2) Transportation presents many challenges because of the size of the RSG’s and the relative inaccessibility of SONGS 2 & 3. Steam generator replacement projects have occurred at other nuclear facilities in the U.S., but normally they are accomplished with delivery to a dock area at the power plant site. (B-11)

3) The specific type of transporter [and costs thereof] would be determined in the future (B-14)

4) Safe transport depends on favorable weather conditions, (B-23) What will be the environmental and economic costs of unfavorable conditions?

5)SCE proposes to obtain all appropriate permits [to] meet all applicable compliance conditions. (B-33). Costs and time elements are not addressed.

6) SCE expects the containment to maintain acceptable integrity. (B-33) The failure to meet this expectation could have extreme environmental and economic consequences.

7) SCE has not identified a potential site for an OSG Storage Facility on the SONGS site. (B-15) Does a site exist and if so, what will be the cost to ratepayers to store?

8) SCE has not specified a disposal location, but the likely destination would be Environ-care of Utah . (B-34) Same as above.

9) Details for loading the original steam generators onto rail cars have not been developed, but they would probably involve lifting components from a multi-wheeled land transporter using portable hydraulic jacks and positioning the rail car underneath (B-35). How can the CPUC pass on costs that have yet to be “developed” in Edison’s application?

10) Although the plan for maintaining structural integrity would be developed during the engineering phase…The NRC has yet to review SCE’s proposed plan for restoring the containment, but SCE must eventually prepare an engineering evaluation that describes whether the steam generator replacement would affect operation and safety of the facility. (B-36) This scenario is the most frightening, especially when ratepayers consider they have no insurance in the event of a radioactive release.

This partial list of omissions, uncertainties and plans not-yet-developed, should have sent red-flags flying at the CPUC. Yet the DEIR recommends that this frighteningly deficient report be adopted and that the project be found reasonable and environmentally sound.

The DEIR does recognize that the "No Project Alternative would benefit the environment" and that “emissions from relatively steady operation of a bank of portable engines that would be used while creating the containment opening could cause significant impacts.” (B-22) “Emissions” is extremely narrowly defined in the SONGS DEIR and ignores the emission of radioactive waste that will remain on California’s coast in perpetuity.

The CPUC must determine if planning for alternative energy sources can save ratepayers billions of dollars in investments in steam generators and other failing components at California's nuclear plants. This determination is not sufficiently analyzed in the economic nor the environmental phase of this proceeding. Should ratepayer dollars be used to create electric generation that will benefit our state with new jobs, new property taxes, clean energy and a phase out of the production of high-level radioactive waste? This is a question and answer not found in the DEIR nor anywhere else in this proceeding. The opportunity to move toward renewable generation inherent in the alternatives to the Proposed Project must be seriously considered.

The DEIR’s finding that a license renewal at SONGS and Diablo Canyon is not foreseeable is disingenuous. To date, the NRC has granted over 31 nuclear license renewals. Of these, only 5 have not already replaced steam generators. PG&E and SCE acknowledge that they are performing feasibility studies for license renewals. A license renewal could not occur but for the proposed RSG projects.

License renewal is a reasonably foreseeable outcome of the project. In fact, it is more likely than the numerous yet-to-be-determined phases of the project itself. A costly decision to replace steam generators at California’s nuclear facilities could result in our state being boxed into an energy source that not only requires additional expensive replacements and retrofits, but leaves tons of high-level radioactive waste on our precious coast.

The DEIR finds that replacement power projections would be too remote and speculative to predict exactly how replacement power would be provided, given the wide range of possibilities. The Governor and the state have invested time and resources to create a renewable energy policy. The outcome of the RSG Proposed Projects will run counter to that plan.

The DEIR’s statement that “these [alternative] technologies do, however, cause environmental impacts, and they also have technical feasibility limitations” are accompanied by no analysis. The CPUC cannot issue a blanket dismissal of alternative and renewable energy as expensive or technologically unfeasible, especially when such important issues of the RSG Project such as maintaining integrity of the containment vessels remain an unknown.

Geology: The new steam generators will extend the useful life of California’s Nuclear Plants by at least 8 and 12 years respectively, i.e. at least until the end of the current licensing periods in 2021, 2022 and 2025. This extension of the operations of the facility beyond the “natural” decommissioning point in 2013 creates an additional period of seismic risk. It would therefore be reasonable to expect the DEIR to include an analysis of seismic risks associated with operation of the entire nuclear facilities for this extended period. As it is, the DEIR focuses narrowly on seismic risks associated only with the steam generator replacement project, i.e. to the OSG storage site, etc.

A key risk associated with the steam generator replacement project is the fact that the proposed OSG storage site is located at the base of a large landslide mass and on eroding coastal bluffs. The landslide could be re-activated and damage the OSG storage facility. The OSG’s are low-level radioactive, and the integrity of the storage area is thus critical to prevent contamination of the surroundings.

As a mitigation measure, the DEIS prudently suggests conducting a geotechnical study of the proposed site to assess the landslide/slope stability risk in more detail and determine if the site needs to be moved, or if the site can be engineered appropriately. However, based on the geologic map, it looks like both the “preferred” and alternative OSG storage sites are in close proximity to the landslide mass and are therefore at risk. Thus, depending on the results of the geotechnical study, the CPUC may need to push PG&E and SCE to identify other potential sites.

It is the obligation of our state representatives and oversight agencies to reduce economic and environmental risks, especially in the area of energy. To that end we ask the CPUC to reject the DEIR and further review the ALL environmental impacts of steam generator replacement at the San Onofre Nuclear Station. Furthermore, we request that ALL costs of the additional 10 years of operation be included.

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Sincerely,

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cc: Governor Arnold Schwarzenegger
cc: Commissioner President Peevey