ML24046A079

Comment (2) of Anonymous on Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2

ML24046A079
Person / Time
Site:	Diablo Canyon
Issue date:	02/14/2024
From:	Wurtz C Fission Transition
To:	Office of Administration
References
NRC-2023-0192, 89FR4631 00002
Download: ML24046A079 (1)

Text

2/15/24, 9:25 AM blob:https://www.fdms.gov/ddeea9d1-5f47-40f8-bfbe-7f9898811c95

SUNSI Review CompleteAs of: 2/15/24, 9:23 AM Template=ADM-013 E-RIDS=ADM-03 Received: February 14, 2024 PUBLIC SUBMISSIONADD: Kim Conway, Status: Pending_Post Antoinette Walker-Smith, Tracking No. lsm-ims4-iplh Mary Neely Comments Due: February 23, 2024 Comment (2) Submission Type: Web Publication Date:1/24/2024 Docket: NRC-2023-0192 Citation: 89 FR 4631 Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2

Comment On: NRC-2023-0192-0003 Notice of Intent To Conduct Scoping Process and Prepare Environmental Impact Statement; Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2

Document: NRC-2023-0192-DRAFT-0002 Comment on FR Doc # 2024-01355

Submitter Information

Email: cwurtz@fissiontransition.org Organization: Fission Transition

General Comment

As part of the EIS for Diablo Canyon's license renewal, the National Environmental Policy Act (NEPA) requires consideration of a No-Action Alternative". With this alternative, the EIS would consider what adverse environmental impacts could be expected if Diablo Canyon is not re-licensed.

The Commission's Draft Regulatory Guide (DG-4015) provides guidance on how this requirement should be interpreted:

"Decommissioning is not a consequence of the No-Action Alternative, because it would occur at some point in time at the end of the plant's operating life, whenever the applicant decides that the plant is no longer viable and terminates plant operations...the impacts of concern for the No-Action Alternative include the impacts of terminating plant operations rather than from decommissioning. The analysis should consider direct, indirect, and cumulative impacts."

Since applicant PG&E won approval in 2018 to terminate operations, there have been several analyses of possible environmental impacts. The conclusions vary, but here we cite what we believe to be the most credible source: a 2023 study prepared by Stanford University and Massachusetts Institute of Technology, titled "An Assessment of the Diablo Canyon Nuclear Plant for Zero-Carbon Electricity, Desalination, and Hydrogen Production":

http://scientificintegrityinstitute.org/MITDiabloPPT031622.pdf

Among other findings, the study concluded that closing Diablo Canyon would:

• Increase CO2 emissions by 7 million tonnes annually through 2035, equivalent to ~1.5 million extra internal combustion cars on California roads. Added emissions would be the result of replacing Diablo Canyon's baseload power with electricity from plants powered by natural gas, oil, coal, or a combination

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• Require an additional 90,000 acres of land to be used for ener gy production from renewable resources, an area roughly the size of the San Francisco Peninsula.

• Require an additional 9 terawatthours of clean electricity each year, to augment California's shrinking supply of fresh water with desalinated water from the Pacific.

Limiting access to the lands surrounding the plant has not only helped to maintain security, but to protect local wildlife. Moreover, these lands were the ancestral home of the YTT Chumash tribe for ~10,000 years before Spanish missionaries appropriated the land in the 18th century. Numerous artifacts and burial grounds remain, but are threatened by plans for commercial development should Diablo Canyon close.

For these and other reasons, Fission Transition ur ges the NRC to re-license Diablo Canyon Power Plant for a additional period of 20 years. Despite California's plans to replace it with solar and wind power,

there is every indication a plant shutdown would dramatically increase California s CO2 emissions, at a time when preserving lar ge sources of carbon-free ener gy is critically important.

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