Cheatham County Generation Site EIS Scoping Report
Appendix C Summary of Scoping Comments
Tennessee Valley Authority
Comment 12: Include continued coordination with TDEC regarding the hydrologic determination (HD) concurrence request submitted on April 11, 2023. The inability of TVA to submit a full and complete concurrence request to TDEC, even after TDEC requested additional requireddocuments, has made me question the ability of TVA representatives to conduct a proper analysis of surface waters or to meet any other regulatory requirements that will be in place for the proposed Cheatham County site. Comment 13: Include a plan for perpetual upkeep of the proposed pollinator habitat as well as time increments for review of the plan and assessment of the pollinator habitat’s performance (such as the need to replace plants or plant different species). Consider partnering with the local Cheatham County Beekeepers group to place hives on the proposed site. Comment 14: In addition to the proposed pollinator habitat, create bat habitat enhancement based on the results of the site’s bat surveys. The site’s long history of having hardwood woodlands bordered by open fields make it a fantastic hunting and roosting habitat. Examples of habitat enhancement may include utilizing BrandenBark™ to create artificial natural bark roosts for the endangered Indiana Bat and the endangered Northern Long-eared Bat or creating man-made tunnels to support the endangered Gray Bat.
Cheatham County Generation Site [#60]_004
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Comment 5: Weigh the impacts and life cycle costs of building a fossil fuel plant which may only be operable for 20-25 years before being retired to meet carbon and GHG reduction requirements. Is the impact on the proposed Cheatham County site and its surrounding natural and human environment worth it with such a short life cycle? Provide data in the EIS to show that TVA has included this in its calculations and considerations. Also include all impacts of natural gas/methane use from cradle to grave, including fracking and pressurized pipeline transfer.
Comment 6: Answer the question: Will the proposed Cheatham County CT site help or hinder TVA to meet current national goals of net-zero emissions before 2050?
Comment 7: Consider the life cycle costs, including material sources (heavy metals, etc.) and waste disposal restrictions, of the lithium-ion batteries proposed for the BESS in the EIS. Include all impacts of the lithium-ion batteries from cradle to grave. Comment 8: Include management practices that exceed industry standards in regard to the storage of fuel oil, such as utilizing tertiary containment (a double-wall tank plus an earthen berm) and constant liquid sensing equipment in the interstitial space (instead of the monthly inspection of the interstitial space required by 40 CFR 112). Additionally, include seismic activity protections in the construction of the storage tank due to the region’s proximity to seismic activity zones. Comment 9: Include stormwater, wastewater and process water management practices that exceed industry standards with the goal of releasing no stormwater from the proposed Cheatham County site with any objectionable color, clarity or content parameters. Any stormwater sediment ponds required for construction should remain for post-construction water retention and treatment. Based on the fuel oil storage that is proposed, all water should pass through an oil-water separator or similar device before being released. All water should also be treated to reduce suspended solids and turbidity before being released, preferably by a water treatment unit but alternatively through flocculant use. Comment 10: Include air quality management practices that exceed industry standards and permit requirements. Enact an agreement with the local constituency that if air quality standards or permit requirements are not met (such as with Case No. APC22-0175, Case No. APC19-0121 and Case No. APC17-0060, among others), a detailed plan for remediation and installation of additional controls will be required in addition to what is required by the Tennessee Department of Environment and Conservation (TDEC) Division of Air Pollution Control. TVA should be required to answer to the locality it is impacting in addition to TDEC. Comment 11: Include any and all possible best management practices and control equipment to reduce or suppress the amount of noise generated by the proposed Cheatham County site. Acoustic enclosures, exhaust silencers, attenuators for combustion and enclosure intake, and intake filtration can be compounded with other available equipment to reduce the noise impact on surrounding landowners. Natural and non-CT measures should also be utilized, such as tall vegetation and sound barrier walls. Noise impacts on human neighbors, bat species and their roosting and hunting activities, and other local wildlife should be considered. Comment 4: The EIS should address and discuss additional alternatives beyond the ‘No Action’ and the ‘Action Alternative’ presented during the TVA’s open house meeting on June 21, 2023. The additional alternatives should be fully evaluated for their current and long-term viability through an unbiased lens. The details of the evaluations should be presented as part of the EIS. Possible additional alternatives that could be explored include: • Locating the CT site in closer proximity to the area where additional energy generation is actually needed: West Nashville. During the June 21 meeting, multiple TVA representative noted that the proposed Cheatham County site was the only land that was available with proximity to West Nashville. However, even today, multiple plots of land in West Nashville are available for purchase including a 313-acre plot near Highway 100 and Highway 96. • Hydroelectric generation utilizing Cheatham Dam. • Locating the CT or a more productive generation plant on the site of the soon-to-be retired Cumberland Site. A TVA representative stated that there would not be enough room once the currently proposed combined turbine plant is built, but no details or proof of this were provided. The Cumberland unit (Unit 2) that the Cheatham County site is meant to partially replace won’t be retired until 2028, at which point the site of Unit 1 could be demolished and replaced with another combined turbine plant. According to TVA representatives on June 21, the time to build the CT plant would be two years, allowing for 3 years to demolish Unit 1 and replace with a CT or a combustion plant. This alternative already has transmission lines and other infrastructure available, thus reducing the impact and cost to build. • Construction of a small modular reactor. This would help move TVA towards its supposed carbon reduction goals and is already being researched for other location(s). • Equipping homes and businesses with their own dedicated solar systems with battery storage. A former TVA employee presented to the Cheatham County Commissioners that a minimum of 200 acres are needed for the smallest of grid solar systems. Installing individual systems for homeowners would fill energy generation gaps and prevent rolling blackouts. Regardless of the Alternative Action(s) considered, do the work and prove that TVA has actually explored other options and show the population that the decision to proceed with the Preferred Alternative wasn’t made before the EIS process even started. This is especially important given the recent accusations and lawsuits against TVA for potentially making its decision for the Cumberland conversion site before the EIS was conducted and not properly considering other energy options in the EIS.
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