Tag Archives: nuclear power

Should CCAs accept a slice of Diablo Canyon power?

The northern California community choice aggregators (CCAs) are considering a offer from PG&E to allocate to each CCA a proportionate share of parts of its portfolio, including the Diablo Canyon nuclear generation station. Many CCA boards are hearing from anti-nuclear activists to deny this offer, both for moral reasons and the belief that such a rejection will somehow pressure PG&E financially. The first set of concern is beyond my professional expertise, but their reasoning on the economic and regulatory issues is incorrect.

  • CCAs buy a substantial portion of their generation (the majority for many of them) from the California Independent System Operator (CAISO) energy markets. PG&E schedules Diablo Canyon into those CAISO markets and under the current CAISO tariffs, nuclear generation is a “must take” resource that the CAISO can’t turn back. So the entire output of Diablo Canyon is scheduled into the CAISO market (without any bidding process), PG&E is paid the market clearing price (MCP) for that Diablo power, and the CCAs buy that mix of nuclear power at the MCP. There is no discretion for either the CAISO or the CCAs in taking excess power from Diablo. There is no “lifeline” for Diablo that the CCAs have any control over under current legal and regulatory parameters.
  • CCAs already pay for a proportionate share of Diablo Canyon equal to the CCAs share of overall load. That payment is broken into two parts (and maybe a third): 1) the purchase of energy from the CAISO at the MCP and 2) the stranded capital and operating costs above the MCP in the PCIA. (CCAs also may be paying for a share of the resource adequacy, but I haven’t thought through that one.) Thus, if the CCAs receive credit for the energy that they are already paying for, the energy portion essentially comes as “free”. In addition, because CCAs currently pay for the remaining share of Diablo costs, but get no energy credit for that in the PCIA calculation, then that credit is in the PCIA is also “free”. In addition, the CCAs gain credit for Diablo’s GHG-free generation (as recognized in the Air Resources Board GHG allowance program) as LSE’s for no extra cost, or for “free.” The bottom line is when the CCAs gain credit for products that they are already paying for, receipt of those products is for “free.”
  • Accepting this deal will not solve ALL of the CCAs problems, but that’s a false goal. That was never the intent. It does however give the CCAs a respite to get through the period until Diablo retires. One needs to recognize that this provides some of the needed relief.
  • Finally, there’s never any certainty over any large deal. Uncertainty should not freeze decision making. The uncertainty about the PCIA going forward is equally large and perhaps offsetting. The risks should be identified, discussed, considered and addressed to the extent possible. But that’s different than simply nixing the deal without addressing the other large risk. Naively believing that Diablo can be closed in short order (especially with the COVID crisis) is not a true risk management strategy.

From these points, we can come to these conclusions:

  1. Whether the CCAs accept or reject the nuclear offer has NO impact on PG&E’s revenue stream. The decisions that the CCAs face are entirely about whether the CCAs can lower their costs and gain some additional GHG reduction credits that they are already paying for (in other words, reduce their subsidies of bundled customers.) Nothing that the CCAs decide will affect the closure date of Diablo. If the CCAs reject the allocations, it will simply be business as usual to the full closures in 2025. Any other interpretation doesn’t reflect the current regulatory environment at the CPUC which are unlikely to change (and even that is unknown) until enough commissioners’ five-year terms roll over.
  2. The system can only be changed by legislative and regulatory action. That means that the CCAs must make the most prudent financial decisions within the current context rather than making a purely symbolic gesture that is financially adverse and will do nothing to change the BAU practice. A wise decision would consider what is the true impact of the action on
  3. Finally, early closure of Diablo will NOT remove the invested capital cost from PG&E’s ratebase, which is what drives the PCIA. After the plant is closed, activists will ALSO have to show that the INVESTMENT in the plant was imprudent and should not have been allowed. Given the long history on decisions and settlements in Diablo investment costs and the inclusion of recovery of Diablo costs in both AB1890 and AB1X at the beginning and end of the energy crisis, that is an impossible task. Only a constitutional amendment through the initiative process could possibly lead to such an action, and even that would have to survive a court challenge that probably would push past 2024.

I want to finish with what I think is a very important point that has been overlooked by the activists: The effort to close Diablo Canyon has won. Activists might not like the timeline of that victory, but it is a victory nevertheless that looked unachievable prior to 2016. It’s worthwhile considering whether the added effort for what will be for a variety of reasons little gain is an important question to answer.

Note that Diablo Canyon is already scheduled for closure in 2024 and 2025. A proceeding to either reopen A.16-08-006 or to open a new rulemaking or application would probably take close to a year, so the proceeding probably wouldn’t open until almost 2021. The actual proceeding would take up to a year, so now we’re to 2022 before an actual decision. PG&E would have to take up to a year to plan the closure at that point, which then takes us to 2023. So at best the plant closes a year earlier than currently scheduled. In addition, PG&E still receives the full payments for its investments and there’s likely no capital additions avoided by the early closure, so the cost savings would be minimal.

We’ve already paid for Diablo Canyon

As I wrote last week, PG&E is proposing that a share of Diablo Canyon nuclear plant output be allocated to community choice aggregators (CCAs) as part of the resolution of issues related to the Integrated Resource Plan (IRP), Resource Adequacy (RA) and Power Charge Indifference Adjustment (PCIA) rulemakings. While the allocation makes sense for CCAs, it does not solve the problem that PG&E ratepayers are paying for Diablo Canyon twice.

In reviewing the second proposed settlement on PG&E costs in 1994, we took a detailed look at PG&E’s costs and revenues at Diablo. Our analysis revealed a shocking finding.

Diablo Canyon was infamous for increasing in cost by more than ten-fold from the initial investment to coming on line. PG&E and ratepayer groups fought over whether to allow $2.3 billion dollars.  The compromise in 1988 was to essentially shift the risk of cost recovery from ratepayers to PG&E through a power purchase agreement modeled on the Interim Standard Offer Number 4 contract offered to qualifying facilities (but suspended as oversubscribed in 1985).

However, the contract terms were so favorable and rich to PG&E, that Diablo costs negatively impacted overall retail rates. These costs were a key contributing factor that caused industrial customers to push for deregulation and restructuring. As an interim solution in 1995 in anticipation of forthcoming restructuring, PG&E and ratepayer groups arrived at a new settlement that moved Diablo Canyon back into PG&E’s regulated ratebase, earning the utilities allowed return on capital. PG&E was allowed to keep 100% of profit collected between 1988 and 1995. The subsequent 1996 settlement made some adjustments but arrived at essentially the same result. (See Decision 97-05-088.)

While PG&E had borne the risks for seven years, that was during the plant startup and its earliest years of operation.  As we’ve seen with San Onofre NGS and other nuclear plants, operational reliability is most at risk late in the life of the plant. PG&E’s originally took on the risk of recovering its entire investment over the entire life of the plant.  The 1995 settlement transferred the risk for recovering costs over the remaining life of the plant back to ratepayers. In addition, PG&E was allowed to roll into rate base the disputed $2.3 billion. This shifted cost recovery back to the standard rate of depreciation over the 40 year life of the NRC license. In other words, PG&E had done an end-run on the original 1988 settlement AND got to keep the excess profits.

The fact that PG&E accelerated its investment recovery over the first seven years and then shifted recovery risk to ratepayers implies that PG&E should be allowed to recover only the amount that it would have earned at a regulated return under the original 1988 settlement. This is equal to the discounted net present value of the net income earned by Diablo Canyon, over both the periods of the 1988 (PPA) and 1995 settlements.

In 1996, we calculated what PG&E should be allowed to recover in the settlement given this premise.  We assumed that PG&E would be allowed to recover the disputed $2.3 billion because it had taken on that risk in 1988, but the net income stream should be discounted at the historic allowed rate of return over the seven year period.  Based on these assumptions, PG&E had recovered its entire $7.7 billion investment by October 1997, just prior to the opening of the restructured market in March 1998.  In other words, PG&E shareholders were already made whole by 1998 as the cost recovery for Diablo was shifted back to ratepayers.  Instead the settlement agreement has caused ratepayers to pay twice for Diablo Canyon.

PG&E has made annual capital additions to continue operation at Diablo Canyon since then and a regulated return is allowed under the regulatory compact.  Nevertheless, the correct method for analyzing the potential loss to PG&E shareholders from closing Diablo is to first subtract $5.1 billion from the plant in service, reducing the current ratebase to capital additions incurred since 1998. This would reduces the sunk costs that are to be recovered in rates from $31 to $3 per megawatt-hour.

Note that PG&E shareholders and bondholders have earned a weighted return of approximately 10% annually on this $5.1 billion since 1998. The compounded present value of that excess return was $18.1 billion by 2014 earned by PG&E.

Calculating the risk reduction benefits of closing Germany’s nuclear plants

Max Aufhammer at the Energy Institute at Haas posted a discussion of this recent paper reviewing the benefits and costs of the closure of much of the German nuclear fleet after the Fukushima accident in 2011.

Quickly reading the paper, I don’t see how the risk of a nuclear accident is computed, but it looks like the value per MWH was taken from a different paper. So I did a quick back of the envelope calculation for the benefit of the avoided consequences of an accident. This paper estimates a risk of an accident once every 3,704 reactor-operating years (which is very close to a calculation I made a few years ago). (There are other estimates showing significant risk as well.) For 10 German reactors, this translates to 0.27% per year.

However, this is not a one-off risk, but rather a cumulative risk over time, as noted in the referenced study. This is akin to the seismic risk on the Hayward Fault that threatens the Delta levees, and is estimated at 62% over the next 30 years. For the the German plants, this cumulative probability over 30 years is 8.4%. Using the Fukushima damages noted in the paper, this represents $25 to $63 billion. Assuming an average annual output of 7,884 GWH, the benefit from risk reduction ranges from $11 to $27 per MWH.

The paper appears to make a further error in using only the short-run nuclear fuel costs of $10 per MWH as representing the avoided costs created by closing the plants. Additional avoided costs include avoided capital additions that accrue with refueling and plant labor and O&M costs. For Diablo Canyon, I calculated in PG&E’s 2019 ERRA proceeding that these costs were close to an additional $20 per MWH. I don’t know the values for the German plants, but clearly they should be significant.

CCAs don’t undermine their mission by taking a share of Diablo Canyon

Northern California community choice aggregators (CCAs) are considering whether to accept an offer from PG&E to allocate a proportionate share of its “large carbon-free” generation as a credit against the power charge indifference adjustment (PCIA) exit fee.  The allocation would include a share of Diablo Canyon power. The allocation for 2019 and 2020; an extension of this allocation is being discussed on the PCIA rulemaking.

The proposal faces opposition from anti-nuclear and local community activists who point to the policy adopted by many CCAs not to accept any nuclear power in their portfolios. However, this opposition is misguided for several reasons, some of which are discussed in this East Bay Community Energy staff report.

  • The CCAs already receive and pay for nuclear generation as part of the mix of “unspecified” power that the CCAs buy through the California Independent System Operator (CAISO). The entire cost of Diablo Canyon is included in the Total Portfolio Cost used to calculate the PCIA. The CCAs receive a “market value” credit against this generation, but the excess cost of recovering the investment in Diablo Canyon (for which PG&E is receiving double payment based on calculations I made in 1996) is recovered through the PCIA. The CCAs can either continue to pay for Diablo through the PCIA without receiving any direct benefits, or they can at least gain some benefits and potentially lower their overall costs. (CCAs need to be looking at their TOTAL generation costs, not just their individual portfolio, when resource planning.)
  • Diablo Canyon is already scheduled to close Unit 1 in 2024 and Unit 2 in 2025 after a contentious proceeding. This allocation is unlikely to change this decision as PG&E has said that the relicensed plant would cost in excess of $100 per megawatt-hour, well in excess of its going market value. I have written extensively here about how costly nuclear power has been and has yet to show that it can reduce those costs. Unless the situation changes significantly, Diablo Canyon will close then.
  • Given that Diablo is already scheduled for closure, the California Public Utilities Commission (CPUC) is unlikely to revisit this decision. But even so, a decision to either reopen A.16-08-006 or to open a new rulemaking or application would probably take close to a year, so the proceeding probably would not open until almost 2021. The actual proceeding would take up to a year, so now we are to 2022 before an actual decision. PG&E would have to take up to a year to plan the closure at that point, which then takes us to 2023. So at best the plant closes a year earlier than currently scheduled. In addition, PG&E still receives the full payments for its investments and there is likely no capital additions avoided by the early closure, so the cost savings would be minimal.

Nuclear vs. storage: which is in our future?

Two articles with contrasting views of the future showed up in Utility Dive this week. The first was an opinion piece by an MIT professor referencing a study he coauthored comparing the costs of an electricity network where renewables supply more than 40% of generation compared to using advanced nuclear power. However, the report’s analysis relied on two key assumptions:

  1. Current battery storage costs are about $300/kW-hr and will remain static into the future.
  2. Current nuclear technology costs about $76 per MWh and advanced nuclear technology can achieve costs of $50 per MWh.

The second article immediately refuted the first assumption in the MIT study. A report from BloombergNEF found that average battery storage prices fell to $156/kW-hr in 2019, and projected further decreases to $100/kW-hr by 2024.

The reason that this price drop is so important is that, as the MIT study pointed out, renewables will be producing excess power at certain times and underproducing during other peak periods. MIT assumes that system operators will have to curtail renewable generation during low load periods and run gas plants to fill in at the peaks. (MIT pointed to California curtailing about 190 GWh in April. However, that added only 0.1% to the CAISO’s total generation cost.) But if storage is so cheap, along with inexpensive solar and wind, additional renewable capacity can be built to store power for the early evening peaks. This could enable us to free ourselves from having to plan for system peak periods and focus largely on energy production.

MIT’s second assumption is not validated by recent experience. As I posted earlier, the about to be completed Vogtle nuclear plant will cost ratepayers in Georgia and South Carolina about $100 per MWh–more than 30% more than the assumption used by MIT. PG&E withdrew its relicensing request for Diablo Canyon because the utility projected the cost to be $100 to $120 per MWh. Another recent study found nuclear costs worldwide exceeded $100/MWh and it takes an average of a decade finish a plant.

Another group at MIT issued a report earlier intended to revive interest in using nuclear power. I’m not sure of why MIT is so focused on this issue and continuing to rely on data and projections that are clearly outdated or wrong, but it does have one of the leading departments in nuclear science and engineering. It’s sad to see that such a prestigious institution is allowing its economic self interest to cloud its vision of the future.

What do you see in the future of relying on renewables? Is it economically feasible to build excess renewable capacity that can supply enough storage to run the system the rest of the day? How would the costs of this system compare to nuclear power at actual current costs? Will advanced nuclear power drop costs by 50%? Let us know your thoughts and add any useful references.

The two problems to be addressed head on by nuclear power advocates

6e0c32214e80ee9f4fbabf2e4ffe6fcd

Nuclear power advocates bring up the technology as a supposedly necessary part of a zero-GHG portfolio to address climate change. They insist that the “next generation” technology will be a winner if it is allowed to be developed.

Nevertheless, nuclear has two significant problems beyond whatever is in the next generation technology:

  1. Construction cost overruns are the single biggest liability that has been killing the technology. While most large engineering projects have contingencies for 25-30% overruns, almost all nuclear plants have overruns that are multiples of the original cost estimates. This has been driving the most experienced engineering/construction firms into bankruptcies. Until that problem is resolved, all energy providers should be very leery of making commitments to a technology that takes at least 7 years to build.
  2. We still haven’t addressed waste disposal and storage over the course of decades, much less millennia. No other energy technology presents such a degree of catastrophic failure from a single source. Again, this liability needs to be addressed head on and not ignored or dismissed if the technology is to be pursued.

MIT tries to resurrect nuclear power

6e0c32214e80ee9f4fbabf2e4ffe6fcd

I received a notice of a new MIT study entitled “The Future of Nuclear Energy in a Carbon-Constrained World” which looks at the technological, regulatory and economic changes required to make nuclear power viable again. A summary states

The findings are that new policy models and cost-cutting technologies would help nuclear play vital role in climate solutions. Progress in reducing carbon emissions requires a broad range of actions to effectively leverage nuclear energy.

However, nothing in the summary reveals the paradigm-shattering innovation that will be required to make nuclear power competitive with a diverse fleet of renewables plus storage that would achieve the same goals. The cost of a solar plant plus storage with today’s technology still costs less than a current technology nuclear plant. That alternative fleet would also provide better reliability by diversifying the generation sources through smaller plants and avoid any radiation contamination risk.

The nuclear industry must clearly demonstrate that it can get past the many hurdles that led to the recent cancellation of two projects in the southeast U.S. Reviving nuclear power will require more than fantasies about what might be.

Silverstein: If I’d written the DOE grid study recommendations | Repost from Utility Dive

Alison Silverstein, who drafted the technical portions of the DOE grid study, says its summary and recommendations missed key points on grid reliability and resilience.

Source: Silverstein: If I’d written the DOE grid study recommendations | Utility Dive

Vogtle nuke cost could top $25 billion| From Utility Dive

The Vogtle nuclear power plant cost is projected to balloon to more than $12,000 per megawatt. In a study we did for the California Energy Commission in 2009, even at $4,000 per megawatt, nuclear power was uneconomic. This explains why nuclear power is not taken seriously as a solution to reducing greenhouse gas emissions.

Source: Vogtle nuke cost could top $25B as decision time looms | Utility Dive