CPUC Adjusts San Onofre Settlement

The California Public Utilities Commission (CPUC) yesterday (July 26) made an adjustment to an agreement where ratepayers would pay $3.3 billion, or 70 percent, of the $4.7 billion decommissioning costs of the shuttering of the San Onofre nuclear plant. Subsequent lawsuits and events showed clearly that the closing of the plant was caused by management mistakes. 

Yesterday’s meeting trimmed only $750 million from ratepayer costs.

Duane Arnold Nuclear Plant in Iowa to Close Early

Duane Arnold Energy Center in Palo, Iowa’s sole nuclear power plant, will shut down in late 2020 — five years sooner than the current power purchase agreement between NextEra Energy Resources and Alliant Energy.  That agreement, which requires approval from the Iowa Utilities Board, means the plant is expected to cease commercial operations in 2020.  Alliant’s agreement with NextEra originally was set to run until 2025.

Duane Arnold, which first began producing power in 1975, is located about nine miles northwest of Cedar Rapids and is one of the larger employers in Linn County with 500 highly skilled employees.

Officials for both Alliant and NextEra said the existence of cheaper forms of energy prompted the decision to close Duane Arnold.  

As part of the new agreement, Alliant will make a $110 million buyout payment to NextEra in September 2020. That payment will cover the costs of shortening the power purchase agreement by five years.

Alliant said it had planned to submit an application to the Iowa Utilities Board to receive approval for the buyout.

NextEra owns a 70 percent stake in Duane Arnold, and 70 percent of the electricity produced there — about 430 megawatts — goes to Alliant. Des Moines-based Central Iowa Power Cooperative, or CIPCO, and Humboldt-based Corn Belt Power Cooperative own 20 percent and 10 percent stakes, respectively.

 Duane Arnold

Duane Arnold

Under the new agreements, Alliant will purchase about 340 megawatts of energy from four existing NextEra-owned Iowa wind facilities.

After Duane Arnold shuts down and stops energy production in late 2020, the plant will have to go through a decommissioning process.  That process will include moving fuel rods from the plant’s reactor to a spent fuel pool, where it will cool for four to five years.  Once the rods are cool, they will be moved to dry storage at Duane Arnold.   (The Gazette)

Millstone to Compete In Zero Carbon RFP

 Millstone

Millstone

In its request for proposals for zero carbon energy released Tuesday evening, the Department of Energy and Environmental Protection (DEEP) said it would let energy producers try to convince regulators they're "at risk" of closure before 2022. That could boost Millstone's proposals, as they'll be scored on environmental and grid benefits along with price.

DEEP's decision means as early as 2019, Millstone could potentially gain an advantage over facilities competing in the RFP, which is open to hydropower, solar and wind producers. Just a few weeks ago, DEEP said it wouldn't consider facilities "at risk" until 2023, igniting outcry from lawmakers and warnings from plant owner Dominion Energy that without full consideration of Millstone's benefits in the zero carbon market next year, the plant could face premature closure in a wholesale market dominated by natural gas.

Regulators created the "at risk" designation and let Millstone compete in the zero carbon RFP after state-hired consultants said premature Millstone closure would spark heavy job losses, grid unreliability and spikes in greenhouse gas emissions from replacement power sources. Millstone's two operating units are licensed until 2035 and 2045.

Dominion in May submitted a petition for "at risk" treatment with the Public Utilities Regulatory Authority (PURA), which included a full accounting of Millstone's audited financials. PURA is the agency that regulates the rates and services of utilities and telecommunications companies in the state. 

PURA signaled in July that Millstone could be "at risk" earlier than DEEP believed. PURA urged DEEP to "consider permitting more flexibility in its bidding and evaluation requirements" and to evaluate "on a case-by-case basis ... whether and when a resource is 'at risk.'"  Fuel security and economic impact were also among the factors weighed by regulators evaluating proposals from "at risk" facilities.

By October, PURA must determine whether confidential financial data turned over by Dominion proves Millstone is in financial peril.

DEEP says it will pick winners among zero carbon companies by late 2018 or early 2019. PURA will approve final contracts between energy producers and utilities by spring of 2019.

DEEP said it will hold a bidders' conference on Monday, Aug. 13, in New Britain. Proposals are due to DEEP by Sept. 14.  (The Day, 7/31/2018)

Entergy Agrees to Sell Pilgrim and Palisades

Entergy Agrees to Post-Shutdown Sale of Pilgrim, Palisades Nuclear Power Plants to Holtec International for Decommissioning

 Pilgrim

Pilgrim

Entergy Corp. has agreed to sell the subsidiaries that own the Pilgrim Nuclear Power Station in Plymouth, Massachusetts, and the Palisades Power Plant in Covert, Michigan, after their shutdowns and reactor defuelings, to a Holtec International subsidiary for accelerated decommissioning.  The sales include the transfer of the licenses, spent fuel, and Nuclear Decommissioning Trusts (NDTs), as well as the site of the decommissioned Big Rock Point Nuclear Power Plant near Charlevoix, Michigan, where only the Independent Spent Fuel Storage Installation (ISFSI) remains. The transactions are subject to conditions to closing, including approvals from the U.S. Nuclear Regulatory Commission (NRC) of the license transfers. 

 Palisades

Palisades

Assuming timely regulatory approvals, Holtec expects to initiate prompt decommissioning of Pilgrim in 2020, with the expectation that all major decommissioning work will be completed in approximately eight years.  A timeline for the decommissioning of Palisades will be developed closer to its shutdown.  For both Pilgrim and Palisades, Holtec expects to move all of the spent nuclear fuel out of the spent fuel pools and into dry cask storage within approximately three years of the plants’ respective shutdowns.

Entergy is seeking regulatory approvals to sell its subsidiary that owns the shutdown Vermont Yankee site by the end of this year.

Holtec and Entergy expect to file a license transfer request with the NRC in the fourth quarter of this year for Pilgrim, with transaction closing targeted by the end of 2019. For Palisades, the license transfer request would take place closer to its planned shutdown in the spring of 2022, with transaction closing expected by the end of that year.  (Entergy Press Release)

Arizona Renewables Ballot Initiative Violates Single Subject Rule?

Arizona Constitution.jpg

The Arizona Constitution contains a separate vote requirement provision that applies only to initiated constitutional amendments. This requirement states that multiple amendments must be voted on separately.  Arizona features rules preventing multiple changes to the constitution from being included in one initiated constitutional amendment.

The Renewable Energy for a Healthy Arizona Amendment violates this rule because it addresses two separate items: 1) 50% renewable energy requirement by 2030 and 2) Credit transfer program.   According to the Single Subject Rule, there should be a separate vote requirement for the credit transfer part of the REHAA.  The REHAA initiative has a provision that could 'sever' the Credit Transfer Program from the percentage renewables requirement, but the transfer component is so intricately intertwined with the other part of the initiative that it cannot be severed.  The initiative states:

Section 3. Severability

The People of Arizona declare their intention that the provisions of this Constitutional Amendment is held invalid for any reason, the remaining provisions of this Amendment shall be severed from the void portion and given the fullest possible force and application.

Renewable credits are transferable:

C. Renewable Energy Credits

          3. An owner of a renewable energy credit or distributed renewable energy credit may transfer such credits to another party.

Such a renewables credit transfer authorization basically establishes an alternative for meeting the annual renewable energy resources requirement.  There isn't much guidance in the transfer clause so there could be wide interpretations as to how participants can meet their annual renewable energy requirements.  The bottom line is that the credit provision appears to violate the Single Subject Rule.

In fact, participating utilities are required to use the credit system:

Section D. Annual Renewable Energy Requirement

          1. Each affected utility shall be required to satisfy an annual renewable      energy requirement by obtaining renewable energy credits from eligible renewable energy resources.

In fact, the credit transfer program is in direct competition with other credit trading programs:

D. Annual Renewable Energy Requirement

3.  An affected utility that trades or sells environmental pollution reduction credits or any other environmental attributes associated with KWH produced by an eligible renewable energy resource may not apply renewable energy credits derived from that same KWH to satisfy the requirements in this section.

The initiative clearly recognizes the transfer as being similar to Cap and Trade programs.  The important point is that it is a separate issue item that violates the Single Subject Rule.

This requirement clearly weds the credit trasfer portion of the initiative so closely to the 50% provision that it cannot be separated out via the severability section.  This conflict renders the ballot initiative null and void and the Secretary of State or the Attorney General should remove it from the November ballot.  (Ballotpedia)

Arizona House Bill 2005

Arizona State Capitol Complex House on Right Senate on Left.jpg

House Bill 2005 (HB 2005) was designed to make violations of the Renewable Energy for a Healthy Arizona Amendment a civil penalty, meaning electric utilities that violate the standard would be fined between $100 to $5,000.

On March 21, 2018, the Arizona State Senate passed the bill 16-12.

On March 22, 2018, the Arizona House of Representatives approved the bill 34-24.

Governor Doug Ducey (R) signed the bill on March 23, 2018.

The measure would require electric utilities that sell electricity in Arizona to acquire electricity from a certain percentage of renewable resources each year. The amount would increase each year from 12 percent in 2020 to 50 percent in 2030 and each year thereafter.

The measure would define renewable energy to include solar, wind, biomass, certain hydropower, geothermal, and landfill gas energies.

Clean Energy for a Healthy Arizona reported filing 480,464 signatures on July 5, 2018. At least 225,963 (47.03 percent) of the filed signatures need to be valid for the initiative to make the ballot.  (Ballotpedia)

Note: If the cost of noncompliance is cheaper than the cost of compliance, entities will pay the fines.    

Tom Steyer Gets Signatures For Renewables Ballot Initiative

OPPOSE THIS INITIATIVE.  IT WILL LEAD TO ADDITIONAL AIR POLLUTION

Arizona Constitution.jpg

The Clean Energy for a Healthy Arizona (CEHA) campaign filed 480,464 signatures at the Arizona Capitol to qualify for a ballot initiative [Renewable Energy for a Healthy Arizona Amendment] that seeks to amend the Arizona Constitution to boost the state's renewable energy standard.  CEHA submitted more than double the required signatures to the Arizona Secretary of State's Office to place the measure on this November's ballot.  Arizona law required 226,000 valid signatures for the initiative to qualify for the Nov. 6 ballot.

The initiative would require utility companies to get 50 percent of renewable resources such as wind and solar for electricity by 2030.  The Arizona Corporation Commission, which regulates utility companies, currently requires utility companies to use 15 percent renewable energy by 2025. It is a standard set in 2006.

The clean energy initiative is one of three initiatives bankrolled by California billionaire Tom Steyer through his NextGen Climate Action group. Similar initiatives are being pushed in Nevada and Michigan.

The Arizona Public Service Company and the Arizonans for Affordable Electricity oppose the ballot initiative.  EHJ also opposes the initiative because it will lead to the closure of Palo Verde nuclear power plant.  (Phoenix Business Journal,  7/5/2018)

Palo Verde Nuclear Generating Station Wastewater Cooling System

Palo Verde Nuclear Generating Stations sits 45 miles west of Phoenix.  It is the largest power plant in the country, and the desert facility uses something no other nuclear power plant in the world does: wastewater.  Wastewater from Phoenix’s 91st Avenue wastewater treatment facility and Tolleson’s facility is piped to the nuclear facility underground -- essentially in one giant 36.5-mile pipe -- for use in Palo Verde's cooling towers.

The wastewater moves through the first 28.5 miles of the pipe by gravity alone; it's pumped the remaining 8 miles to Palo Verde. Once on-site at the APS-operated facility, the water is purified again.

Next, the water is channeled into reservoirs at the facility for temporary storage before it is used in the cooling towers near Palo Verde's three reactors. The plant needs 60,000 gallons of treated wastewater per minute.  The plant’s three nuclear reactors each require 20,000 gallons of water per minute.

Palo Verde Facility View From Above.png

Plant managers have to maintain a constant flow of wastewater to the on-site reservoirs to make up for water lost to evaporation.

Seven Southwestern companies own the plant.  Its largest stakeholder is Arizona Public Services (29.1%), but it is also owned by Salt River Project, El Paso Electric, Southern California Edison, Public Service Co. of New Mexico, Southern California Public Power Authority, and L. A. Dept. of Water & Power.

The plant, in commercial operation since 1986, produces power for about 4.1 million people across regions in New Mexico, Texas, California and Arizona.  Each of the turbines within the reactors generates 1,400 megawatts of power.

Palo Verde supplies 80 percent of Arizona's carbon-free electricity.  Only 1.3 percent of the APS energy portfolio came from renewable energy in 2014, while 27.2 percent came from nuclear. Coal leads all sources with 33.5 percent, according to the plant's owner.

If the wastewater supply were to be suddenly cut off, Palo Verde keeps more than a 13-day supply of water in its reservoirs, designed to give facility staff enough time to fix any issue.

According to Nuclear Engineering International: 

Fresh water in the Phoenix, Arizona area comes from the Verde, Salt and Colorado rivers. After it is used by the two million people living in the area, it reaches the 91st Street water treatment plant in Phoenix. This plant, built before Palo Verde but expanded several times since then, actually serves four areas in the metropolitan Phoenix area: Phoenix, Scottsdale, Mesa, Tempe and Glendale, although the city of Phoenix owns more than 50%. Its rated capacity is 204 million gallons/day, but its operational amount is 130-150 million gallons/day. Another treatment plant nearby, capacity 17 million gallons/day, serves the city of Tolleson. Both plants carry out primary and secondary water treatment: primary sludge settling and separation, and degradation of the biological constituents of sewage.

Normally, wastewater treatment plants pump the treated effluent back into a river. At this plant, a 114-in (3m)-diameter pipe diverts up to 90,000 million gallons/day toward Palo Verde; another pipe also takes up to 6 million gallons/day from Tolleson. (Other effluent streams go to irrigation in Buckeye, Arizona, and an artificial wetlands area next door, and the Salt and Gila Rivers). The utility consortium that owns the three-unit Palo Verde Generating Station buys the water from the city; it is authorized to take up to 24 billion gallons/year, or an average of 65 million gallons/day, but uses more like 21-22 billion gallons/year (and up to 2.2 billion gallons/year from Tolleson). It pays based on a unit of an acre-foot, 326,000 gallons/year or 1233.5 m3, in a price that is escalated per year.

Water flows 100 ft downhill inside the buried pipeline for about 28 miles (6 miles at 114 in diameter pipe, 22.5 miles at 96 in diameter pipe) until it reaches the Hassayampa Pumping Station, which pushes it 125 ft uphill the remaining eight miles to the site treatment plant in a 66 in-diameter pipe.

(AZFamily, Tucson.com, 1/1/2016, Nuclear Engineering International, 6/25/2013)

Report on NOx Reductions Via Nuclear Power Plants

The Brattle Group

Nuclear Impact on NOX Emissions in
Designated EPA Ozone Nonattainment Areas

Dean Murphy and Mark Berkman

May 2018

FULL REPORT

The EPA’s recent release of ozone air quality designations augmented its previous designations, filling gaps in the identification of regions that are in nonattainment for EPA’s 2015 ozone NAAQS standards.[1]  The air quality improvements that this shows are necessary highlight the role that existing nuclear power plants play in air quality.  Simply put, nuclear plants avoid air pollutants associated with fossil generation.  The loss of nuclear generation increases emissions as fossil generators operate more to fill the gap.  We identified and quantified this effect in several previous studies that examined the environmental impacts of nuclear plants in Ohio, Illinois, New Jersey and Pennsylvania.  These studies showed that the loss of zero-emission nuclear generation would result in increased fossil generation and thus increased emissions of several pollutants, including NOX, which is both a pollutant in its own right and a precursor for ozone.  Some of the NOX increases would occur within ozone nonattainment areas, just when states must develop plans to decrease pollutant concentrations in those areas.  The loss of nuclear plants would increase the challenge and the cost of bringing nonattainment areas into compliance with air quality standards.

[1]     Additional Air Quality Designations for the 2015 Ozone National Ambient Air Quality Standards (NAAQS), April 30, 2018.  https://www.epa.gov/ozone-designations/additional-designations-2015-ozone-standards

Palo Verde and Environmental Justice

 Palo Verde

Palo Verde

The closure of Palo Verde nuclear power plant would represent an environmental injustice because it will be replaced with mostly fossil fuel-generated electricity, which will increase smog that will increase negative health effects in minority and low-income communities. Environmental Hope and Justice (EHJ) believes the passage of a state initiative to support traditional renewable energy sources would not only lead to the closure of the Palo Verde nuclear power plant, but would also cause a state constitutional crisis. Such a state initiative would directly conflict with the State Implementation Plan (SIP).

The Renewable Energy for a Healthy Arizona Amendment could appear on the ballot in Arizona as an initiated constitutional amendment on November 6, 2018 if proponents can get 225,963 valid signatures by July 5, 2018. The measure would require electric utilities that sell electricity in Arizona to acquire 50 percent of electricity from renewable resources in 2030 and each year thereafter. 

Within the Maricopa nonattainment area, the National Ambient Air Quality Standard has not yet been attained for the 2008 eight-hour ozone standard of 0.075 parts per million (ppm). The 2015 eight-hour ozone standard is 0.070 ppm. The area is classified as a Moderate Area under the Clean Air Act. If the Arizona Renewable Energy Standards Initiative passes, it will trigger a constitutional crisis. It will pit the Arizona Department of Environmental Quality (ADEQ), the Arizona Corporation Commission (ACC), and the Maricopa Association of Governments (MAG) against each other. A state initiative that closes what is a significant ozone control measure (operation of emission-free Palo Verde) would usurp the power of the state agencies in charge of regulating the Clean Air Act at the state level with a measure that runs directly counter to its mission.

MAG has not included the environmental justice consequences of closing Palo Verde due to the passage of the ARESI. Considering the constitutional crisis the passage of ARESI would cause and considering the fact that environmental justice related to Palo Verde closure have not been included in the SIP, the Arizona State Attorney General or the Arizona Secretary of State should remove the initiative from the ballot until these matters have been resolved.

FULL REPORT

Potential Impacts on Phoenix Area Ozone Air Quality from a Proposed Renewable Energy Ballot Initiative - - by NERA Economic Consulting