Click here to read a Research Paper re. FPSC Annual Review of Docket NO. 080148-EI. The Executive Summary of that document is reproduced below:
Nuclear ventures such as that proposed for Levy County are classified by financial institutions
as inherently too risky for commercial financing. Moreover, escalating capital costs of the nuclear
plants render unsustainable their recovery either from consumers in advance or by including capital
debt service charges in electricity tariffs charged to consumers. Affordable electricity is a
prerequisite to the creation of new jobs in Florida today. The nuclear facility proposed for Levy
County just cannot fulfill that essential requirement.
The State of Florida would be better served by reducing the need for overly large centralized
power generation plants and their associated expensive distance transmission line losses by
employing distributed power generation systems which better survive hazardous weather events, yield
improved energy efficiencies, while avoiding longer term used fuel hazards of all kinds.
Subsequent events have seriously compromised the premises upon which the Determination of Need
was approved by Order Number PSC-08-0518 issued on August 12, 2008.
Addressing Page 24 of the docket number 080148-EI:
First, the electric power price of natural gas actually reduced by 43% over the following two
years from 2008, instead of increasing as testified to the Commission.
The price reductions followed technical advances allowing access to the reserves of natural gas,
previously trapped in shale rock deposits. This event, added a supply source forecast to last for
more than a hundred years, which negates the assertion made on pages 8 and 9 of the said docket,
that an additional base load nuclear energy capacity would be needed to protect consumers from the
high costs of increased natural gas base load generation. It also facilitates chemical rather than
combustive conversion of gas to electricity for vital installations such as hospitals and other
intensive vital uses.
Next, the increased cost of natural gas energy generation (up by 56% in 2018 - Docket Page 6) has
proved to be false prophesy. Moreover, in view of the high unit costs of nuclear power from the
proposed Levy Units 1 and 2 they no longer comprise a critical component of PEF's efforts to
maintain a diverse fuel mix intended to stabilize fuel costs over time and enhance the reliability
of the electrical system.
This would remain the case even if natural gas combustion were used to generate electricity at a
centralized plant. Should, however, the natural gas be converted using fuel cells in a distributed
generation system, not only would carbon dioxide emissions be reduced by a factor of 45%, but
electricity supply would be more reliable and efficient as described in this paper.
In addition, PEF's assumptions and predictions for providing electricity at a reasonable cost
using the proposed Levy Units 1 and 2 are no longer valid. As opposed to the figures quoted on
docket page 10, forecast in- service costs of the Levy Units have risen to an unreasonable $22.5
billion, with overnight costs estimated to double for Unit 1 and be commensurately increased for
Unit 2. With the result that recovery of the capital service costs for the nuclear option in
customer tariffs would be both imprudent and untenable.
By employing the more modern technologies advocated by the Department of Energy in distributed
generation systems, PEF would be enabled to avail themselves of benefits from more effective demand
side management (DSM) and more efficient and renewable energy systems each having lower risk for the
Lastly, although nuclear fuel costs may well be proportionately less than centralized combustion
fossil fuel costs and extend beyond the analysis presented by PEF, the burden of servicing the
increased capital costs of the nuclear option far outweigh any fuel cost savings of benefit to their
Based upon the foregoing it is urgently represented that the matters raised be considered as part
of the 2011, long term feasibility analysis, ordered by PSC-08- 0518-FOF-EI issued on August 12,
From 1992, deregulation of the grid allowed unplanned additions, reduced investment, and reduced some capacity surpluses by increased energy trading. The proposed Smart Grid remedy promises to be very costly with an intelligent monitoring system that keeps track of all electricity flowing in the system and able to influence consumption according to use and available electricity source costs, as a way of reducing greenhouse gas (GHG) emissions.
Demand is forecast to increase by about 2.2% per year, although a widespread introduction of electric vehicles could increase that rate. Stability and quality of supply at an acceptable price remain the prime concern of consumers.
Local rates charged for domestic supplies have increased by about two thirds over the past twelve years to more than $0.13 per kWh(e). Calculations following those of Richard Severance [click RS to view] indicate that costs from the proposed nuclear facility in Levy County would likely exceed $0.36 per kWh, indicating that reliance upon large centralized power generation may have become just too costly and it is taking too long a time to license, build and instal new central generation plants having lower operating levels of GHG emissions and new transmission and distribution infrastructure.
Distributed generation (DG) is a term for a power generating source located close to where the power is employed, as opposed to centralized power generation supplied through the grid which can be located hundreds of miles away from the consumer. The technology of the Direct FuelCell is a perfect fit for a number of emerging markets that require a technology that can provide Ultra-Clean distributed generation over a range of sizes from a kW to several MW. These are discussed in context in a White Paper by Anthony Leo, Vice President of OEM and Application Engineering, FuelCell Energy, Inc..
DG reduces the need for prohibitively expensive larger centralized power systems. Since the DFC does not burn hydrocarbon fuel emission of CO2, NOx, SOx and particulate pollutants are reduced to the lowest of levels.
In Florida as elsewhere, during times of lower demand for centralized electricity generating plants produce less at reduced supply-side efficiency because arrangements to store electricity are generally not employed. Moreover, heat energy cannot be captured for use at the remote location.
Performance data published by the Department of Energy indicate a relatively efficient level of electricity generation is called "Summer Rate Capability" or Summer Peak (SP). Although somewhat simplified, by calculating the difference between the actual annual kWh(e) output achieved and what could be expected from operating at SP for the whole year gives an estimate of under-utilized capacity. At the Crystal River Energy Complex (CREC) during 2008, for example, under-utilized capacity measured 29.56 %, for the four coal fired units. This, together with that of the CREC nuclear plant for 2008, equated to some 800 megawatts of apparent under-utilized capacity. More complex analysis of such features as heat curves and effects of repair and maintenance schedules would doubtless improve the estimates while continuing to affirm the supply-side potential for increasing efficiency.
Considerable increases in supply side efficiencies are achievable by storing excess electricity (and heat) as compressed hydrogen gas for regeneration as electricity when required using utility scale fuel cells. Furthermore, strategic reserves can be provided by siting such (modular) facilities closer to where the electricity is consumed reducing financial and environmental costs and further power losses of transmission lines. National security is enhanced by limiting any massive power outages from a cyber-attack on the grid systems, disrupting the economy, diverting attention from a simultaneous military attack, or simply creating national trauma.
Combining the hydrogen technologies with electricity generation using the lower cost advanced photo voltaic arrays as they become available, while eliminating the expensive stage of conversion to alternating current for transmission prior to electrolysis, would assist Florida to transition from our fossil-fueled to truly carbon-free generation smoothly over time.
Levy County Proposal
On August 12, 2008, with respect to the the two Westinghouse AP1000 nuclear reactors proposed for the Levy County site, the Florida Public Service Commission accepted a petition to the State of Florida for a Determination of Need from the utility company to increase its capacity in 2016 by 2,200 megawatts ( to preserve its 20% "reserve margin" through 2023, assuming Levy 1 online in 2016, and Levy 2 online in 2017). Note that no improvements in supply side efficiencies were considered in assessing the need.
Since 2008, the region has suffered the effects of the economic downturn and the forecast demand from population growth at 1.8 percent each year and an eleven percent increased industrial demand is no longer valid. Moreover, it is no longer feasible to bring any nuclear facility on line by 2016, as predicated in 2008. The need to develop employment opportunities in the shorter term is the high priority.
Furthermore, the site proposed is located in an area of an unconfined aquifer which allows liquid contaminants falling on it to permeate into groundwater which is the source of regional domestic supplies. The principle radionuclide released from the reactors into air is tritium - an EPA registered cancer causing agent, third isotope of hydrogen, with a half life of more than twelve years remaining radioactive for 120 years until degrading into helium. Scientific literature establishes that tritium atoms behave like other hydrogen atoms and persist and accumulate in water molecules of groundwater constituting a pathway for cancer causing emissions into human tissue and vital organs as it is consumed in food and drink having assimilated tritium in groundwater.
In addition, the proposed discharge of tritiated water into the Gulf of Mexico contaminates sea grass meadows near shore and the marine food web nurtured there, harmful both to humans and to protected species the source of attraction for eco-tourism worth tens of millions of dollars to the local economy annually. An added concern is the aggressive penetration and change to the area's fresher water lens proposed to accommodate the deep foundation required for the reactors and containment buildings.
These serious environmental issues are largely ignored in the Draft Environmental Impact Statement, NUREG-1941, and subject of written and verbal submissions to the Nuclear Regulatory Commission, as yet unanswered.
The excessive financial burden of $22.5 billion for the proposed nuclear plant, the serious adverse public health and environmental impacts, and imposing hazards of nuclear process waste upon countless generations yet unborn, the excessive pollution from the mining and processing of uranium as fuel for nuclear reactors is no longer sustainable. Such "fuel train" emissions of climate changing greenhouse gases and flouro-carbons (CFCs) which destroy the ozone layer have to be eliminated. The latter have been declared illegal in many applications since their harming effect was discovered in 1985.
Rather than pursue aging notions of building large centralized electricity generation facilities, with their price tag of tens of billions of dollars, proven new technologies can provide reliable, efficient, ultra-clean solutions to our energy needs at much reduced cost targetedto become less than $0.10 per kWh(e).
A fuel cell is an electrochemical arrangement that converts a source fuel into an electric current without hydrocarbon fuel combustion. It generates electricity through reactions between a fuel and an oxidant in the presence of an electrolyte. The reactants flow into the cell, and the reaction products flow out of it, while the electrolyte remains within it. Fuel cells can operate continuously as long as the reactant and oxidant flows are maintained. Fuel cell power systems are quiet, environmentally clean, highly efficient onsite electrical generators using the electrochemical process - not combustion - to convert fuel into electricity and supply thermal energy for hot water, space heating or other applications. Overall energy service costs are reduced by 20% to 40% over conventional power service.
Some fuel cell designs incorporate the reforming of natural gas to produce hydrogen as the principal fuel source as in the FuelCell Energy (FCE) Molten Carbonate Fuel Cells (MCFC) illustrated here.
Fuel combined with oxygen from the ambient air produces electricity and heat, as well as water. The non-combustion, electrochemical process is a direct form of fuel-to-energy conversion, and is much more efficient than conventional centralized heat engine approaches. Carbon dioxide is reduced, due to the high efficiency of the fuel cell, and the absence of combustion avoids the production of NOx, SOx, and particulate pollutants.
Various kinds of fuel cells have different attributes suited to particular applications. Fuel cells are scalable from a couple of kilowatts to several megawatts and controllable allowing power reduction without loss of efficiency suited to housing , industrial and utility supply applications. A variety of fuel sources can be used including oxygen, hydrogen derived from water, piped natural gas or waste (methane) gas. Combined heat and power systems (CHP) maximize efficient fuel usage by capturing otherwise wasted heat energy. Fuel cells are beginning to take center stage for baseload power in DG applications.
Fuel cells enable reduction of unit costs to consumers, maximizing the utilization of current centralized resources, reducing the burning of fossil fuels and GHG emissions, enabling distributed electricity generation, and embracing the renewable but intermittent wind and solar sources. In addition, jobs would be created in the shorter term and conserve the environment to the benefit of public health and local Floridian economies
Natural gas reforming technology is advancing rapidly from that traditionally used principally in large scale production of ammonia fertilizers, plastics and petroleum products. A gas pipeline delivery infrastructure exists such as is being extended aggressively into this part of Florida
expected to come on stream in the spring of 2011, available for DFC applications.
Using the improved reforming technology together with fuel cells enables natural gas to fuel electricity generation with about sixty percent less GHG emissions. Even more significantly, distributed generation employing modular designs allows electricity generation closer to locations where it is consumed, either to serve energy intensive needs of industry or needs of urban conurbations, reduces the need for large centralized generation facilities with their expensive transmission systems. Moreover, hydrogen technology allows electrical energy to be stored and provide strategically located resources to meet periods of peak demand as Base Load supply.
The United States currently imports about fifteen percent of natural gas consumed. The hydrogen fuel cell application is estimated to increase consumption by less than five percent during a transition period.
Reduce the need for centralized generation by commissioning strategic natural gas fuel cell power wherever possible particularly for combined heat and power (CHP) applications and where ultra clean, efficient, quiet and reliable systems may serve a wide variety of needs. Whatever their source of fuel, fuel cells save energy, save customers' money and reduce emissions.
Capture waste thermal energy and provide hydrogen storage systems to reduce the profound supply-side inefficiencies at centralized facilities. Convert otherwise wasted industrial products into useful energy with fuel cell power. Prepare to wean vehicles from hydrocarbon fuels in the interest of national energy security.
Fuel cell CHP systems are 80% to 90% efficient when both heat and electricity are used. Systems optimized to produce electricity achieve 50% or greater electrical efficiency. Residential fuel cells reduce home energy use by one-third or more. Fuel cell passenger vehicles can yield 60 to 70 miles per gallon equivalent.
Reappraise the need to site 2,200 MW of nuclear generating capacity upon an unconfined aquifer source of the limited supply of potable water vital to longer term community needs.