ML24351A253
| ML24351A253 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/16/2024 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 89FR87433 | |
| Download: ML24351A253 (4) | |
Text
From:
Jim Hopf <jamesehopf@gmail.com>
Sent:
Monday, December 16, 2024 10:18 PM To:
DiabloCanyonEnvironmental.Resource
Subject:
[External_Sender] James E. Hopf Comments on NRC Diablo Canyon EIS Attachments:
James Hopf Testimony on NRC Diablo Canyon EIS.pdf
- NRC, The attached PDF file presents my witten testimony on the NRC's Draft Supplemental Environmental Impact Statement for Diablo Canyon Nuclear Power Plant License Renewal - Docket ID NRC-2023-0192.
James E. Hopf 1430 Tennis Lane Tracy, CA 95376 (408) 710-6666 jamesehopf@gmail.com
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89FR87433 Comment Number:
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James Hopf Testimony on NRC Diablo Canyon EIS I fully concur with NRCs conclusions presented in Table 2-1 and Sections 4.1 and 4.2 of the draft Environmental Impact Statement. The conclusions are consistent with the consensus among formal scienti"c bodies, that nuclear powers environmental impacts are similar to those of renewable sources, and are much smaller than those of gas generation (as shown below).
If Diablo Canyon closes, its power will be replaced by renewable generation, gas generation, or both.
Thus, the environmental impacts of keeping Diablo Canyon open will be similar to or lower than those associated with closing the plant.
That said, I do have some recommendations to improve the EIS.
First of all, presenting the no action case currently de"ned in the EIS as an alternative is confusing to the reader. It is not an actual alternative, because it does not evaluate the impacts of the power generation that would replace Diablo Canyons power. I understand that NRC is trying to stay within a generic EIS format, which requires presentation of a no action case. I also appreciate that NRC clari"es things in Sections 2.3.1 and 4.2, which acknowledge that Diablos power would have to be replaced with something. But given the confusion caused, I would recommend removing the currently de"ned no action case as an evaluated alternative. Instead, NRC should classify the Purchased Power Alternative currently de"ned in Section 2.3.2.1 as the no action alternative, as it is the most likely result of closing Diablo Canyon.
Secondly, the greenhouse gas evaluation discussed in Section 3.15.3, and the CO2 emissions estimates in Table 3-34, should be revised to more accurately estimate the CO2 emissions associated with actual alternatives to continued Diablo operation, i.e., the CO2 emissions from potential replacement power sources. The currently de"ned no action case should not be presented, as discussed above, and the CO2 emissions associated with the Renewable Combination Alternative are not negligible.
The Renewable Combination Alternative will involve signi"cant CO2 emissions, beyond the tiny emissions associated from operation of existing renewable sources. To replace Diablos power with renewables, renewable generation will have to be increased, i.e., built. Thus, the renewable alternative should include CO2 emissions associated with construction.
As shown in the Our World in Data chart above, analyses show that the overall CO2 emissions of renewable sources are slightly higher than those of new nuclear. The (going forward) CO2 emissions associated with operating an existing nuclear plant would be much lower, i.e., far lower than the emissions associated with building and operating renewable generation. (It should be noted that the CO2 emissions for both nuclear and renewable generation are very small, even if construction is included.)
Also, the analysis does not include the gas generation that will replace some or most of Diablos power while the replacement renewable generation is being built. Renewable generation that would be used to replace Diablos power will not instantly appear after the plant closes. It will take a signi"cant amount of time to build.
The fact that gas generation will not be allowed after 2045 is not relevant to this license extension evaluation, which covers the 20-year period between 2025 and 2045.
Thus, the Renewable Combination Alternative case should assume a mixture of gas and renewable generation, over the course of the 20-year extended operation period. If it did so, the emissions would be well over a million tons per year. The emissions associated with continued operation of Diablo Canyon would be orders of magnitude smaller.
Finally, I recommend that the greenhouse gas emissions estimated for each alternative should be included in Table 2-1. Given the level of concern about climate change, that evaluation should be given a high pro"le.
James E. Hopf 1430 Tennis Lane Tracy, CA 95376 (408) 710-6666 jamesehopf@gmail.com