ML23046A412
| ML23046A412 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/30/2023 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 87FR76219 | |
| Download: ML23046A412 (4) | |
Text
From:
Cyrus Reed <cyrus.reed@sierraclub.org>
Sent:
Monday, January 30, 2023 11:58 AM To:
ComanchePeakEIS Resource
Subject:
[External_Sender] Comments submitted on Comanche Peak Plant Attachments:
January 30, 2023-Comments-NRC.pdf Cyrus Reed (he-him), PhD Conservation Director Lone Star Chapter, Sierra Club cyrus.reed@sierraclub.org 6406 IH-35, Suite 1806 Austin, Texas 78752 512-888-9411 (office) 512-740-4086 (cell)
@cyrustx (twitter) www.sierraclub.org/texas www.texascleanenergyscorecard.com
Federal Register Notice:
87FR76219 Comment Number:
13 Mail Envelope Properties (CAD31_TafjNNEcLgagbiH5qB-ZCN=u-RQrhWeNq21+eHcX7Somg)
Subject:
[External_Sender] Comments submitted on Comanche Peak Plant Sent Date:
1/30/2023 11:58:28 AM Received Date:
1/30/2023 11:58:53 AM From:
Cyrus Reed Created By:
cyrus.reed@sierraclub.org Recipients:
"ComanchePeakEIS Resource" <ComanchePeakEIS.Resource@nrc.gov>
Tracking Status: None Post Office:
mail.gmail.com Files Size Date & Time MESSAGE 398 1/30/2023 11:58:53 AM January 30, 2023-Comments-NRC.pdf 74440 Options Priority:
Normal Return Notification:
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January 30, 2023 RE: NRC-2022-0183-0003; Vistra Operations Company LLC; Comanche Peak Nuclear Power Plant, Units 1 and 2; License renewal application; opportunity to request a public meeting and request for hearing extension To Whom It May Concern, The Lone Star Chapter of the Sierra Club is the state chapter of the Sierra Club, a 501-C-4 non-profit organization with some 30,000 members in Texas. We also oversee several regional groups, including the Greater Fort Worth Sierra Club which has over 2,000 members in a 12 county area, including Somervell County. The Sierra Club has approximately 1,400 members within a 50 mile radius of Comanche Peak, including members within Bosque, Hill, Somervell, Johnson, Hood, Earth, Palo Pinto, Parker and Tarrant and includes the cities of Fort Worth, Arlington, Weatherford, Granbury, Stephenville, Cleburne, Mineral Wells, Hillsboro, and of course Glen Rose.
On January 17th, I had the honor of participating in an online meeting on behalf of the Sierra Club and I believe several other Sierra Club members were present. However, there were major technical problems and not everyone was able to make their concerns known or questions addressed. In addition, the NRC made the unfortunate decision to cancel in person meetings in the immediate area because of COVID concerns, even though there did not appear to be any issues in the Somervell County area.
Therefore as first item, we would request that the NRC consider extending the time for comments, immediately reschedule an in-person meeting, and consider extending the time to request a formal hearing.
Thus echoing comments submitted by the Fort Worth, we ask you:
- 1) Reschedule an in person meeting in Glen Rose, Somervell County so residents and other concerned citizens can directly interact with NRC staff. There were multiple technical issues with the presentation and many speakers were not able to unmute and Speak.
- 2) We request a 90-day extension for comment period and a 90 day extension for requesting a formal hearing for the 12/1/2022 Federal Register Notice.
While we have several residents who may be interested in formally opposing the new license renewal but as an organization, taking a formal position on a license requires approvals at both the state and national levels. Thus, having time to further consider the license application and consider a formal hearing is important to our organization.
We understand that an Environmental Impact Statement (EIS) will be prepared to assess the impacts to the natural and human environment (Notice of Intent To Conduct Scoping Process and Prepare Environmental Impact Statement; Vistra Operations Company LLC; Comanche Peak Nuclear Power Plant, Units 1 and 2, Federal Register, 12/13/2022). An EIS should take a hard look and properly and effectively analyze and disclose potential significant individual and cumulative environmental impacts proposed by the license renewal and their reasonable alternatives would cause. The EIS should clearly present the information needed for the public to understand the proposed action, its reasonable alternatives, and the potential environmental effects the action and its reasonable alternatives would cause.
We would also ask the NRC to consider alternatives including no renewal, renewal and a renewal of less time. In other words, as the nuclear plant ages, there is more risk that something will go wrong. Considering a shorter time for renewal is important, such as 10 years as opposed to 20.
One other comment is that the electric markets are changing a lot. Thus, at one time electricity from nuclear power in Texas was closer to 15 percent of our energy demand and today within ERCOT it is only about 10 percent. The amount of solar, wind and battery storage is growing significantly and that trend is likely to continue. We hope the economics of our market will be considered in the analysis, because there may not be enough profit in our market to continue to run nuclear plants as zero-fuel cost energy from wind and solar continues to expand. Vistra must have enough revenue to continue to maintain the nuclear power plant safely and we believe that the market may not allow that to happen in 2030 or 2032.
In addition, our climate is changing rapidly and we want to assure that the EIS looks at how climate and weather in Texas may impact the plant. Extended flooding, freezing, heat and drought are all expected to increase as climate extremes become more common. Obviously any of these weather and climate conditions can make the plant more risky. We hope this will be analyzed as part of the EIS analysis.
We appreciate the opportunity to make these comments, Cyrus Reed, PhD Conservation Director, Lone Star Chapter 512-888-9411 Cyrus.reed@sierraclub.rog