Should Los Alamos continue on to the next phase of the Carbon Free Power Project (CFPP) - a nuclear electric generation facility proposed to be constructed at Idaho National Laboratory that uses small modular reactor (SMR) technology?

August 9, 2020

Dear Board of Public Utilities and the County Council:

The purpose of this letter is to ask for the DPU and County Council to APPROVE the continued funding of the Small Modular Reactor Project in connection with the Carbon Free Power Project.

Los Alamos County showed foresight in the 1980's when they purchased the El Vado and Abiquiu hydro-electric projects for $80 million. Both Abiquiu and El Vado Lakes are at extremely low levels (I was at both on Saturday August 8, 2020). The predictions are that they won’t be filling anytime soon, and both dams are really showing their age. Abiquiu has a leak so it can’t be filled to capacity, and what is up where the El Vado dam is settling and the road/steel plates are bowed down? All infrastructure has a lifetime, how long were these dams designed for?

As discussed many times, even if Los Alamos county never receives one DIRECT electron from the project (800 miles away) we will still be contributing to Base Load Carbon Free Electricity to Planet Earth and the United States, and we can swap our low cost Base Load Electricity for other, closer Base Load Electricity. We will DIRECTLY be preventing a lot of carbon emissions the same as we did with El Vado and Abiquiu, preparing the way for Robust, Reliable, Base Load Nuclear Electricity. The project could pave the way for the possibility of a modular reactor (or a few) here in Los Alamos in the future.

If we were really positive and forward thinking we could arrange the much touted pumped storage scheme and use those reservoirs for the cooling lakes as well as pumped storage and fishing! (Triple Use: 2 X Power + Recreation = WIN!)

I have only lived in Los Alamos County for 27 years so I cannot name the DPU or County Council members that had the foresight to purchase the El Vado and Abiquiu hydro stations, but they were smart and forward thinking! They were Giants, and we stand on their shoulders!

Thank you for your support on this. Be a Giant!

Sincerely,

Michael A. Dempsey
300 Connie Ave.
White Rock, NM 87547

A couple of Notes:

In todays world, if you don’t have reliable electricity, you have NOTHING. No monetary transactions except cash, and that is a maybe because without scanners, beep beep, and the internet there is no inventory control. I bet everyone on the Council and DPU board can make change and estimate tax in their head. Think about the kids running the registers today. Very few monetary transactions will be possible. Gasoline at the stations can’t be pumped, natural gas to your water heater can’t be CONTROLLED from the producing basins to your house, water can’t be pumped from the wells by the river to 1000 feet higher to your sink.

If you don’t have electricity, you don’t have any monetary transactions, water, lights, heat, inventory control, pricing information, transportation, communications and on and on and on. Without Reliable-Robust Base Load Electricity we will have nothing. Wind, solar, and batteries are a mostly dead end.

A steel arc furnace (wind turbine towers, concrete rebar, bearings etc.) cannot be run on a wind/solar/battery system, so to make the actual components of wind turbines and pure silicon for solar panels reliable base load electricity is needed. Right now and for the foreseeable future this only includes Natural Gas, Coal, Hydro and Nuclear.

Wind turbines produce electricity about 25% of the time. Not all sites are suitable for wind turbines. (little or intermittent wind and Eagle Chopping).

Solar is by night/day definition and conditions OFF for 50% of the time but the actual capacity is about 25% also. The most cost effective photovoltaic cells are about 25% efficient when new and drop off over time. 0.25 x .025 x100 (for percent) = 6.25% actual efficiency. (even if there is never a cloud: 0.25 x 0.5 x 100 for percent) = 12.5% efficient.

Any battery system can only run at less than 50% efficiency. If it gets hot (inverter/transformer) or makes noise (transformer/charger) you are losing energy. Scientists have been looking for over 100 years to improve battery performance. Chemistry has its limits. Battery charging/discharging is still only 50% efficient at best. Do you feel your phone getting hot?

Please see below and the executive summery page 7.

http://www.nmprc.state.nm.us/utilities/docs/2011-12-21_Final_Report_NMPRC.pdf

February 2011 was NOT memorable to people living in Los Alamos County. That was the time during a extreme weather event (the same thing happened in 1966 and 1979) when most of the state dropped to -17F and remained <20F for a week. Los Alamos county DID NOT run out of natural gas because of the 3 foot diameter trunk pipeline and the bought-ahead contracts which supply the Lab, County and the Labs natural gas fired power plant. For almost a week it was cloudy (no solar) and foggy with freezing fog (no wind). The natural gas supply went off (Texas had bought ahead contract also) and so did all the pilot lights from Taos to Carlsbad. Many Natural Gas powered generating stations went off line due to high demand and short supply as well as inoperable stations due to extreme conditions. People in the Espanola Valley were moved into shelters, because they had no heat and sometimes no electricity (rolling Black Outs) and the National Guard was called out to relight pilot lights all over the state.

Please support the reactor component.
Thank you,
Dianne Coane

I am in favor of continuing with the next phase of the carbon free power project. Nuclear energy is the highest-density energy available at this time, environmentally sound as it requires minimal land use, does not generate air pollution, does not depend on the sun shining or the wind blowing and is free of carbon emissions.
"Go for it."

Dear Utilities Board:

The carbon free power project, also known as the small modular nuclear reactor project, is the kind of long-term effort that is necessary to secure the energy future of the county. There are four advantages to this project:

1. This is a power source that will provide power when it is needed. Wind and solar power arrive without control.

2. Using power from widely varied sources increase the ability to absorb unpredictable changes in the future.

3. The DOE has agreed to support a large portion of the development costs.

4. We can eventually make this a local power source and can eliminate the vulnerability of long distance transmission. We can increasingly be in possession our own power supply.

The first two items are about short-term and long-term stability. Without the DOE commitment this project could not continue. The consortium met their responsibilities to us by obtaining that commitment and we should respond by continuing our support. Joining this project was a wise decision by previous councils and we should demonstrate continuity and stability.

8/9/20

This comment supports the position that it is not only irresponsible to continue the County’s involvement with the UAMPS Carbon Free Power project, but that continuing involvement will detract from work in support of reaching the County’s carbon neutral goal before 2040.

It is time for the Board of Public Utilities and the Los Alamos County Council to vote to exit participation in UAMPS’s Carbon Free Power Project. Staff have diligently worked to determine if continued participation makes sense. It has become increasingly clear that it does not. If the County continues to participate, a million dollars, in addition to County staff time, will have been wasted before the next off-ramp opportunity. (“Cost-to-date for the County, DOE and Los Alamos National Laboratory is $258,673. He further reported that the County’s share for the 11.186 megawatts would be $1,046,849 for the next phase.” As reported in the LA Daily Post 8/3/20.)

From the UAMPS presentation to Los Alamos County on the Carbon Free Power Project by Mason Baker, UAMPS General Counsel, at:
https://www.losalamosnm.us/UserFiles/Servers/Server_6435726/File/Government/Departments/Public%20Utilities/DPU%20Files/CFPP/DPU_BR170112%20Final%20UAMPS-%20CFPP%20presentation.pdf
The map on slide 5 shows the locations of UAMPS members.
36 are in Utah.
3 are in California.
3 are in Idaho.
2 are in New Mexico.
1 is in Nevada.
1 is in Oregon.
Of those 46, 36 are currently participants in the Carbon Free Power Project. (The current County FAQs put the number of participants at 37.)

At the Los Alamos County website’s FAQs it is stated that the expected life of the small modular reactor is 60 to 80 years. Assuming that occurred, costs do not end there. Slide 15 assumes the small modular reactor finally operates and will then someday be decommissioned. It states that the decommissioning period begins at the end of the operating period and continues until the CFPP is fully decommissioned and all decommissioning costs and liabilities have been paid and discharged. It is conceivable that electric bills of Los Alamos County ratepayers could be affected for a century if the County does not get out.

Los Alamos County has an 11 MW capacity interest in the 720 MW capacity of the plant. That 1.5% interest makes the County a small, if not insignificant, player.

Figures for Los Alamos County currently available on the County’s website show that in 1985 the County’s electrical power resources were:
36 MW San Juan 4
10 MW Laramie River
8 MW El Vado
18 MW Abiquiu
1 MW Western Area Power Administration
1 MW Photovoltaic array at East Jemez Road landfill
County transmission arrangements
County purchased power contracts
https://www.losalamosnm.us/government/departments/utilities/energy_resources

Whether those are still good numbers, total available of 74 MW, is good enough. 74 MW is only slightly more than 2% of the wind generating capacity in New Mexico that is already installed plus what is under construction. (74 / [1953 + 1447])

According to the U.S, Energy Information Administration, New Mexico at the end of 2019 had 1,950 MW of wind generating capacity.
https://www.eia.gov/state/?sid=NM
An undated webpage shows that installed wind generating capacity in New Mexico is 1,953 MW, with 1,447 MW under construction. The electric grid mix shows wind generation providing over 19%.
https://windexchange.energy.gov/states/nm

The percentage of Texas’ electrical power generation provided by wind has increased dramatically:
In 2003, it provided 0.8%.
In 2010, it was 8%.
In 2019, 22%.
https://www.cnn.com/2019/07/25/us/texas-wind-energy-trnd/index.html

In August 2019, Texas’ wind generation capacity was 24,200 MW.
https://www.eia.gov/todayinenergy/detail.php?id=40252

Note that 74 MW is 0.3 % of Texas’ wind generation capacity.

It seems clear that carbon neutral electrical power for Los Alamos County does not have to wait until 2040. And to meet that goal, there does not need to be any dependence on a currently not-built, unknown-cost, and unlicensed small modular reactor of unknown lifetime and having unknown decommissioning costs. Now is the time for Los Alamos County to exit UAMP’s CFPP.

I suggest that County staff who have been spending time and energy on UAMPS activities redirect their efforts to activities associated with The Wind Coalition. “The Wind Coalition is the industry trade association created to promote the development of the wind energy resource as a clean, reliable, affordable, and infinite source of power. The Wind Coalition is the wind energy industry’s voice within the Electric Reliability Council of Texas (ERCOT) and Southwest Power Pool (SPP) systems, which include Texas, Kansas, Oklahoma, Nebraska, Arkansas, Missouri, New Mexico, and Louisiana. The organization works to expand transmission capacity, increase wind power use within the region, and facilitate wind power export.”
https://windexchange.energy.gov/states/tx

As Bob Dylan might say, the answer for a carbon-neutral Los Alamos County lies not in as-yet non-existent small modular reactor, but rather in the proven, existing and rapidly-increasing amount of wind-generated electrical power available in the Southwest. In other words, the answer is blowin’ in the wind, and it is becoming louder with each passing year. Why not make the goal 2030 instead of 2040?

I fully support bring a SMR to Los Alamos County. The more carbon free technologies we can utilize, the better. And I've always found it quite odd that this town didn't have a nuclear reactor.

In short, No, we need to exit this project now.

We absolutely need to transition to carbon-free power as soon as possible. Unfortunately, the CFPP appears to be a slow, uncertain, and expensive way to get there. Low subscription, high price, novel technology, changing social/political/regulatory/energy landscapes, and uncertain completion date all put the success of this project in serious doubt. Tying our progress towards carbon neutrality to this project, when it's timeline keeps slipping further and further into the future, may mean that we pass up opportunities that arise sooner, cheaper and more feasibly.

I think our time, money and attention are better spent on pursuing 1) energy conservation and 2) existing, or near-term, renewable options. The Utilities Department and BPU just convened a Conservation Committee to suggest ways for LAC to reduce power use. We should put serious effort into following up on their ideas and other approaches to conserving energy (the cheapest and lowest-carbon approach).

The DPU should also put more effort into finding opportunities to expand our renewable energy sources, which are springing up at an accelerating pace, and can help us transition away from our remaining coal-fired generation contract at LRS. Although Staff have stated that "renewables plus storage are not yet feasible", they are being adopted widely by cities, states, islands and countries. A couple of weeks ago, the NM PRC approved 100% renewable energy+battery storage as the path forward for replacing coal-fired generation from the San Juan Generating Station. 650 MW of solar and 300 MW of battery storage are planned in several projects. And just this year, LAC approved a contract with Uniper Global Commodities to supply us with 15 MW of renewable, firm energy from NM solar and wind farms, for a mere $36.67/MWh. This sort of pricing seems likely to be the future of energy, so why are we considering signing up to pay $55/MWh for 40 years?

Please do not succumb to the "sunk cost fallacy", and throw good money after bad. We have already invested in this project, but the only rational reason on which to base your decision now is future consequences. The CFPP is a risk we do not have to take, and one that will likely keep us from attaining our carbon neutral goal as quickly as possible.

Thank you for working towards a carbon-free future for Los Alamos!
Sue Barns, Los Alamos

Full disclosure: I am not a resident of Los Alamos County (LAC). I am a resident of Idaho Falls, Idaho and an Idaho Falls Power (UAMPS SMR project Participant) ratepayer.

Some readers may ask, "Why is this Hamman guy sticking his nose in our business?" Well, a close reading of the CFPP contract reveals that we (CFPP Participants) are in this project together - decisions made by the Idaho Falls City Council could impact LAC ratepayers, likewise decisions made by LAC could impact Idaho Falls ratepayers.

Let me provide two examples from the City of Idaho Falls 2018 Power Sales Contract:

(1) "Step-up obligation, non-defaulting Participants can be required to take a portion of a defaulting Participant’s Entitlement Share, subject to a maximum increase in the Entitlement Share over the term of the PSCs of 25%.”

(2) "Certain decisions of the PMC are required to be made by a Super-Majority Vote (75% by number and Entitlement Share)."

https://tinyurl.com/yb5t7yok (cf. pdf pages 80, 81)

Noteworthy is that of the 36 municipalities participating in the SMR project, 27 municipalities are located in Utah. A prudent investor (i.e., municipality) would pay close attention to Utah dialogue. For example:

"Utah Taxpayers Association calls on cities to bail out of nuclear power project."
https://tinyurl.com/y2q5jktb (August 4, 2020)

Murray (Utah) City Council Meeting (August 4, 2020):
Link to discussion with Professor Ramana and Utah Taxpayers Association (UTA)
(Ramana: video time 0:05:46 and UTA video time 0:47:54)
https://tinyurl.com/y6srujv3

"It is commendable that UAMPS wants to build a project ..."
https://lnkd.in/gYzqgfq (July 7, 2020)

“Will the Idaho 1995 Settlement Agreement, limiting the storage of nuclear waste in the state, impact the project?”
https://tinyurl.com/y4ogxt8v (July 27, 2020)
https://tinyurl.com/y33l83aw (Settlement Agreement)

Finally,

"Yet it is incumbent on those in high places to make wise decisions, and it is reasonable and important that the public be correctly informed."
- H.G. Rickover, Father of the Nuclear Navy

https://tinyurl.com/yclrnnup (1970)
.

Norman Schroeder
I support the continuation to the next phase of this project.

I attended the Aug. 3 town hall and was very disappointed with what I learned. Here are the factors that lead me to oppose carrying the project forward:
- No answer to the question of nuclear waste handling and disposal (I'll revise this if new information becomes available)
- Reactor design still being revised
- LA County would be paying RD&T costs
- Not a single nuclear-fueled test of existing design
- Engineering company has zero installation experience
- Cost estimates require 100% subscription; current level is 30% and no specific additional subscribers are known
- Nuclear power has a long history of cost overruns

This project appears to be highly speculative and I consider it unwise to proceed to the next phase.