DCL-14-103, License Renewal Application Appendix E Applicant'S Environmental Report - Operating License Renewal Stage Amendment 1. Part 4 of 4

License Renewal Application Appendix E Applicant'S Environmental Report - Operating License Renewal Stage Amendment 1. Part 4 of 4

ML14364A270
Person / Time
Site:	Diablo Canyon
Issue date:	12/22/2014
From:	Pacific Gas & Electric Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML14364A259	List: DCL-14-103, License Renewal Application Appendix E Applicant'S Environmental Report - Operating License Renewal Stage Amendment 1. Part 4 of 4 ML14364A261 ML14364A262 ML14364A264 ML14364A265 ML14364A266 ML14364A269
References
DCL-14-103, FOIA/PA-2016-0438
Download: ML14364A270 (71)

Text

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I 4.2 ENTRAINMENT OF FISH AND SHELLFISH IN EARLY LIFE STAGES NRC "Ifthe applicant's plant utilizes once-through cooling or cooling pond heat dissipation systems, the applicant shall provide a copy of current Clean Water Act 316(b) determinations... or equivalent State permits and supporting documentation. If the applicant cannot provide these documents, it shall assess the impact of the proposed action on fish and shellfish resources resulting from ... entrainment."

10 CFR 51.53(c)(3)(ii)(B)

"...The impacts of entrainment are small at many plants but may be moderate or even large at a few plants with once-through and cooling-pond cooling systems. Further, ongoing efforts in the vicinity of these plants to restore fish populations may increase the numbers of fish susceptible to intake effects during the license renewal period, such that entrainment studies conducted in support of the original license may no longer be valid...." 10 CFR 51, Subpart A, Appendix B, Table B-I, Issue 25 The NRC made impacts on fish and shellfish resources resulting from entrainment a Category 2 issue, because it could not assign a single significance level (small, moderate, or large) to the issue. The impacts of entrainment are small at many facilities, but may be moderate or large at others. Also, ongoing restoration efforts may increase the number of fish susceptible to intake effects during the period of extended operation (Reference 18). Accordingly, the NRC must determine the type of cooling system (whether one-through or cooling pond) and the status of any Clean Water Act Section 316(b) determination or equivalent state documentation.

DCPP has a once-through heat dissipation system that withdraws from and discharges to the Pacific Ocean. The general design and operational parameters of the cooling system are provided in Section 3.1.2.

The NRC has indicated in the GElS for license renewal (Reference 18) that issuance of a National Pollutant Discharge Elimination System (NPDES) Permit implies certification by the State. Consistent with the GELS, PG&E provides the current, enforceable, DCPP NPDES Permit No, CA0003751, Order 90-09 (Reference 1), as evidence of Water Quality Certification under Clean Water Act (CWA) Section 401 (CCRWQCB, 1990)

(see Attachment B). The permit issued to PG&E specifically states that the location, design, construction and capacity of cooling water intake structures at DCPP reflect the Best Technology Available (BTA) for minimizing adverse environmental impact under 316(b). The permit was due to expire in 1995, and has since been in administrative extension. PG&E is a-tively we.,ngcontinuing to work with the State Water Resources Diablo Canyon Power Plant Page 4.2-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I Control Board (SWRCB) and Central Coast Regional Water Quality Control Board (CCRWQCB) to renew the permit. The current permit does not include any requirements for ongoing entrainment monitoring during power plant intake operations.

The significance of entrainment losses for early life stages of marine organisms as well as cooling system discharge thermal impacts have been the subject of discussions between PG&E and the regulatory agency directly responsible for authorization and enforcement of plant specific NPDES requirements. The issues have resulted in extensive communications and consultations between PG&E and the CCRWQCB.

Other state agencies have also been involved in permit related consultations, including the Caliofeora Stato VA*ater e.ourc.Control, Boa*rd (SWRCB) and the California State Department of Fish and Game-Wildlife (CDFW&G). The nature of these communications and consultations are provided in the references for this Section and Section 4.4, Heat Shock.

A summary of entrainment specific issues is provided in this section and the accompanying technical data report (Reference 10). Issues related to thermal discharge are discussed in Section 4.4. PG&E anticipates that final resolution of all outstanding issues for both entrainment and thermal discharge impacts will occur during the current operating license period, and PG&E will be issued a renewed NPDES permits prior to the period of extended operation.

The primary issue regarding entrainment is whether or not the absolute loss of larval organisms or eggs due to power plant cooling system operations constitutes an adverse environmental impact regardless of whether or not those losses result in degradation of the overall health of the aquatic ecosystem. The regulatory community, including the SWRCB and CCRWQCB, has-prometedhavesupported the viewpoint that absolute losses are an adverse impact regardless of the presence or absence of detectable population level effects in the environment, and therefore entrainment reduction or mitigation measures may be warranted under any circumstances. This has been a general issue throughout the electric power generation industry, as well as an issue of relevance regarding continued use of once-through cooling (OTC) systems at existing nuclear power plants that have applied for license renewal. Generically, operators of facilities with OTC systems support the interpretation that observable population or ecological level effects are the appropriate indicator of whether or not entrainment losses result in adverse environmental impacts. This-While this issue continues to be discussed among the generation industry, regulators,and ,omponentsof the regulator;

.. MMU.ityvarious stakeholders, the United States EnvironmentalProtectionAgency (USEPA) and the SWRCB have now adoptedregulationsandpolicies that provide a compliance framework discussedbelow. Final resolution of issues rolated to the Significance of entrainment imnpacts for DCPP are pending, and current issues regarding continued use of OTC have the potential to remain open for an extended period of tim Regarding the impacts of entrainment of phytoplankton and zooplankton, because of the large numbers and short regeneration times of plankton, and generally ubiquitous dispersion of these organisms in both nearshore and offshore marine habitat, localized Diablo Canyon Power Plant Page 4.2-2 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I entrainment impacts are considered to be of little ecological consequence. Further, any potential effects from entrainment losses at a specific location would also not be expected to contribute to detectable cumulative impacts in a nearshore region because the regeneration times of remaining non-entrained plankton are so rapid.

PG&E anticipates continued operation of the existing OTC system at DCPP during the period of extended operation. This is consistent with determinations regarding use of the installed cooling system within the Final Environmental Statement (FES) for the initial operating license period. As such, the Environmental Report and the conclusions of individual assessments related to Aquatic Ecology are predicated on the continued exclusive use of OTC. Issues specific to NPDES Permitting of the cooling system are expected to be resolved through the jurisdictional regulator,' authority and associated pfOGesses-fOF-implementation and enRf*orem.et of Federal Clean Water Act FequweFreFe*of the SWRCB's OTC policy for DCPP.

4.2.1 STATUS OF WASTE DISCHARGE REQUIREMENTS PERMIT Commercial plant operations began in May 1985 with cooling system wastewater discharges authorized under NPDES Permit No. CA0003751 Permit Order 82-54 as amended April 1983. In August 1985, the CCRWQCB issued modified NPDES Permit Order No.85-101. DCPP then applied for renewal of the permit, as required, prior to expiration of Order No.85-101.

NPDES Permit No. CA0003751 Order 90-09, for DCPP Units 1 and 2, was adopted by the CCRWQCB on May 11, 1990 with an expiration date of July 1, 1995. In accordance with Federal and State regulations (and Order 90-09 Section D. Provisions, Subsection 9), an application was submitted by PG&E for a new permit 180-days prior to the expiration of Order 90-09 on November 7, 1994, and all applicable application fees paid.

PG&E was notified on June 26, 1995 by the CCRWQCB that a timely and complete application for re-issuance of Permit No. CA0003751 was received, and pursuant to 40 Code of Federal Regulations (CFR) Part 122.6, the existing permit order would remain valid, enforceable, and fully effective until January 1, 1997 (Reference 2). Renewal of the permit was deferred pending preparation of a comprehensive final report assessing adequacy of the existing discharge thermal limits. Recommendations were being considered by the CCRWQCB to modify the permit monitoring and reporting program, and a multi-agency workgroup was established to advise on the development of the comprehensive thermal effects assessment. These various efforts significantly impacted advancement of the permit renewal process On August 29, 1996, PG&E was informed in a letter from the CCRWQCB that under the authority of California State Code of Regulations (CCR) Title 23, Section 2235.4, the existing NPDES Permit Order (90-09) would remain valid until a new permit was issued provided the facility complied with all requirements of the permit (Reference 3).

Renewal of the permit continued to be deferred pending further development of the comprehensive thermal impacts assessment, as well as initiation and completion of a Diablo Canyon Power Plant Page 4.2-3 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I 316(b) demonstration study developed and implemented under the direction of a technical work group coordinated by CCRWQCB staff. The thermal assessment and 316(b) demonstration study were subsequently completed, and reports submitted to the CCRWQCB.

PG&E submitted an amended application for renewal of waste water discharge requirements under Permit No. CA0003751 to the CCRWQCB on January 24, 2001. A hearing was conducted on July 23, 2003 to consider adoption of a renewed permit for DCPP Units 1 and 2. The draft updated permit was not adopted, and additional evaluations and analysis, primarily concerning alternative potential mitigation strategies to compensate for entrainment losses, were requested by the CCRWQCB. The agency subsequently directed a team of independent consultants to consider and develop mitigation strategies for entrainment. The consultant's draft report was presented to the CCRWQCB in a public hearing that took place in September of 2005. The draft report concluded that construction of a large scale artificial reef in the ocean could provide an acceptable mitigation strategy to provide in-kind compensation for larval organisms and egg loss due to operation of the power plant cooling system. Construction and management of such a structure in the ocean however would likely result in project costs far in excess of the monetized losses caused by plant entrainment.

No further CCRWQCB-initiated activities related to renewal of the DCPP NPDES permit have occurred subsequent to the 2005 hearing. Regulatory focus shifted to the USEPA's development of regulations implementing Clean Water Act Section 316(b) and the SWRCB's development of a OTC Policy to implement Section 316(b) in Califomia..urren.t* d.eferral o-f action has primnarilY been due to developmentn subsequent litigation surrounding the US EPA Phase 11Rule for regulation of impingement and entrainment (I*&l) at existing pWer pla*tS using ITC. Varid method*slý4 of facility cormplialnce provided in the initial 2C1004 PhDase IIHRule were legall challenged. The Federal Second Circuit Court subsequently remanded substantial components of the rule back to US ElPA in the 2007 "RI eIkeeper I' decisin, as well as determined- that-costs,of compliance options versus benefits gained were notn appropriite Gnside*ration when -eveloping cmOpliance strategies Or assessing rule applicabIlity. The cost benefit portIIon o*f RivoIer I 11 was then subsequently appealed to the US Supremt e Curt. 1The' USSuprem Cort ruled on Api*! 1, 2009 that cost versus benefit evaluations can be Used as a component. Of Federal E=PA Rule mnaking, specifically as it relates, to the dev:elopment of M&E Fegulatiens. Development and of a modified PhaIe 11Rule by the EPA is pending.

in addition to the outstanding issues involving a final Phase 11Rule, the California SIA.RCB developed a draft State Policy in 2008 to standardize implementation of M&E regulations by the various Regional WPater Quality Conrol1 Boards, including the, CCRWVQCB- that over-sees the DCGPP NPDE=S Permnit. The draft state policy includes stringent requirements to implement significant M&E reduct~ios at existing power plants along the California Coast. The draft policy effective'ly directs facilities to implemnent 1&

reductions commnensurate With closed cycle cooling (retrofit to coGolig towers) regardles~s Of cost Or technical feasibility, Or cease operations. However, the draft policy Diablo Canyon Power Plant Page 4.2-4 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 rui nrt lully ac*ount ior all rFlWlVanT Uc~Issennveing ecrGntomlt, Teaslonity OT1 e lunlnrg permits Or licenses to implement facility moedifcation or replacement, other adyersee env~ieromental impacats that wou-ld- resul-t.fromn policY imlmnatoo the overall effects of the policy on the State's electric generation resources. Fu~theF developmen of the policy is anlticipated to inc'ude input from an inter agency process, that wall facdlitate*onsideration re" and- of th osesues the in*it';aI dr*,aft did not adequately development of revised-Feea1Pae1 Roule. The 6CCR\.QGB has, therefoe rad, ,*+ess Additionaly

• .r a ta*It"e 6pG,, P1GYWil;;l;,mle;edig h Permit pending further arations at both the Federal and State leve.'l regarding l&E regulations for existing OTCG facilities.

Pending full resolution of outstanding regulatoIy issues involving nE, and subsequeRt final approval Of a revised permit, the existing NPDES Permit No. 0A00037-51 Ordter 90 09 remains current and enfrc-eable for DCPP Units 1 and 2.

USEPA issued final Section 316(b) regulationsin August 2014. These regulations include separateassessments for entrainmentand impingement: a site-specific assessment for entrainment,allowing for the use of cost benefit considerations,and list of compliance options for impingement. However, there is exemption for facilities with very low levels of impingement. The cost benefit assessment was allowed after the Supreme Court's 2009 ruling in the Riverkeeper case. It should be noted that these regulationshave been challenged, so further changes may occur.

In 2010, the State Board adopted a Once Through Cooling (OTC) Water Policy to standardizeimplementation of I&E regulationsby the various Regional Water Quality ControlBoards, including the CCRWQCB that oversees the DCPPNPDES Permit. The State Policy includes stringentrequirements to implement significant I&E reductions at existing fossil-fueled power plants along the California coast, effectively requiring reductions of at least 85 percent of flow or commensurate with closed-cycle cooling.

However, the Policy acknowledges the unique contribution of the state's two nuclear plants (DCPPand Southern Califomia Edison's San Onofre Nuclear GeneratingStation) to meeting California'sGreenhouse Gas reduction goals and creates a separate process for establishing OTC compliance at the two nuclearfacilities. The final Section 316(b) regulationsin August 2014 specify that the Califomia OTC policy is at least as stringent as the federal regulations,so it will govern Section 316(b) compliance in Califomia.

The state's OTC Policy creates a nuclearreview committee to oversee the development of an altemative technology assessment reportby an independent third party consultant for each nuclearplant. Additionally, the Policy includes a variance provision which requiresthe State Board to modify the Policy to establish alternative compliance requirementsfor the nuclearplants if either the cost of installingalternative technologies (e.g., cooling towers) is wholly out of proportion to the costs consideredby the State Board in adopting the Policy, or if the installationwould be wholly unreasonable consideringfactors such as engineering,permitting, and space constraints,as well Diablo Canyon Power Plant Page 4.2-5 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 safety concerns and adverse environmentalimpacts. Mitigation is requiredfor any remaining impacts after implementation of the alternative requirements, with funding provided to the CaliforniaCoastalConservancy.

4.2.2 ONCE-THROUGH COOLING (OTC) SYSTEM Section 3.1.2 provides a general description of the DCPP OTC system. During full power operations, the plant circulates approximately 2.45 billion gallons (equivalent to 9.275 million cubic meters) of raw seawater per day through the main steam condensers. Intake is from the Pacific Ocean at ambient temperature, and discharge is returned to the Ocean approximately 20'F on average above ambient.

The 3/8-inch mesh traveling debris screens located at the intake structure do not filter out or impinge microscopic phytoplankton and zooplankton, or the eggs and larval of the vast majority of marine fish and shellfish present in the source water body susceptible to entrainment in the cooling water flow. Microscopic and small organisms carried in the flow pass unobstructed through the mesh. These entrained organisms are then subjected to pumping forces, exposure to macro-fouling cropping within the system (primarily filter feeding barnacles and mussels that populate the seawater conduit surfaces), rapid thermal change passing through the main steam condensers, and significant turbulence during discharge back to the Pacific Ocean.

No specific technological or operational methods are employed to reduce entrainment of fish and shellfish larvae or eggs. Losses for entrained fish and shellfish are administratively set by agreement between PG&E and the CCRWQCB at 100 percent when considering entrainment impacts caused by cooling system operations. Actual losses for hard bodied more-durable organisms are likely much lower than 100 percent.

Soft bodied organisms such as fish larvae, however, may in fact experience relatively low survival rates when transiting the system.

The abundance and diversity of organisms present at any given time in the intake water column, oceanographic and operational conditions, and the state of system conduit macro fouling will affect actual entrainment losses during plant operations at any given time. Regardless, for all regulatory and assessment purposes, entrainment losses caused by DCPP are considered 100 percent of all organisms withdrawn form the Pacific Ocean with the intake flow under all conditions.

Diablo Canyon Power Plant Page 4.2-6 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 4.2.3 EVALUATION OF PLANT INTAKE ENTRAINMENT AND IMPACTS The aquatic ecosystem in the vicinity of DCPP has been extensively studied and monitored both prior to operation of the plant, and throughout commercial operations.

DCPP has been the subject of an extensive marine ecological impacts assessment.

These studies have included extensive pre-operational evaluation and modeling, and post-operational monitoring, of the impacts from thermal discharge to the Pacific Ocean receiving waters at Diablo Cove. During operations, extensive monitoring has also been conducted on ambient control areas North and South of the facility. The detailed monitoring has provided direct assessments of the abundance of multiple species of organisms over the operational life of the facility, which provides evidence regarding population level impacts from cooling system entrainment. The details of thermal discharge assessment studies are included in Section 4.4.

In addition to thermal impacts assessments, an extensive three-year long evaluation of plant entrainment and source water body fish and shellfish larval diversity and abundance was conducted from 1996-1999 and submitted to the CCRWQCB in March 2000. Development and implementation of the study was directedby a technical work group of independent scientists establishedby the CCRWQCB. The details of design, implementation, study area, and the conclusions of this study are provided in the 316(b) Demonstration Study Report (Reference 15). Descriptions of the fish and shellfish resources in the vicinity of DCPP susceptible to entrainment, including assessment of adult equivalent losses are also provided in the study report.

As recommended by USEPA, the 2000 study did not evaluate entrainmentof phytoplankton and zooplankton. This is because the large numbers of short regenerationtimes of these forms of plankton and the generallyubiquitous dispersion of these organismsin both nearshoreand offshore marine habitat. Given these circumstances,localized entrainmentimpacts are consideredto be of little ecological consequence. Thus, the focus of the study was on the evaluation of fish and shellfish larvae.

The summary conclusion from the e"densi*'.e entrainment and Source water body assessmeRt2000 316(b) DemonstrationStudy is that DCPP 4akesrentrains on average approximately 11 percent of the larval population susceptible to entrainment-(Nete.

dependi pees.on specific factos*, lar"al losses are generally greater than Or leso e

than 11 percent for iRdivedual species affected). Considering the volume of water circulated through DCPP, this results in significant absolute numbers of fish and shellfish larvae lost when the 100 percent administrative mortality estimate is appliedassumed. Annual entrainment of larval fish is estimated to range between 1.48 and 1.77 billion, dependent on flow.

Though the absolute numbers are large, it is noteworthy that the natural survival rate for eggs and larvae to juvenile stages is generally <1 percent, and survivorship to adult stage for most species is far less than 1 percent. In terms of natural survivability, the loss of 11 percent of the available larval population on average is not significant in light Diablo Canyon Power Plant Page 4.2-7 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 of the fact that 99 percent or more of larvae normally suffer mortality from natural factors before reaching juvenile stages of development.

Biological compensation can . be .. sidered moreis an important to-factor in the development and maintenance of a healthy aquatic ecological system thaR'-that can compensate for the changes in the absolute la~vai-numbers of larvae produced each year. As long as habitat is present that supports successful recruitment and development of organisms from larvae stages to juvenile stages and beyond, available larvae can successfully develop to sustain stable reproductive adult populations. This is especially true for fishes such as the rockfishes, sculpinds, and cabezon that inhabitthe nearshore rocky aquatic habitat in the area that provides for .helter and foraging for rckfish, sculpins, and cabazonvicinity of DCPP. These fish species are the most prevalent in the vicinity, and therefore are also these-the most susceptible to entrainment in early life stages.

Therefore, the loss of 11 percent of the larval population on average due to DCPP operations is ultimately compensated for by the remaining 9 percent

.. on ave..ge ,rvae that remain available for recruitment to the habitat present in the vicinity and region of DCPP. The health and viability of habitat immediately surrounding the power plant is shown in the data available from the extensive long-term ecological studies conducted in the vicinity.

During the current period of operation, available data from both DCPP-specific ecological studies, as well as independent studies of regional marine fisheries, provide evidence that local populations of fish susceptible to entrainment in larval stages have remained relatively stable. In general, adult populations of individual species have shown varying declines or increases in abundance over time that can be attributable to numerous natural variation alonephysical and biologicalfactors that vary in intensity from year to year. The conclusion from the extensive data from past and ongoing monitoring has shown that overall population decreases have not occurred, and the local marine ecosystem remains healthy.

DCPP is situated on an isolated stretch of pristine coastline with no other substantial human related influences that could negatively impact the health of the marine environment, with exception of limited commercial or recreational fishing. DCPP has provided a unique setting for the assessment of OTC impacts. The design capacity and actual operation of the facility define DCPP as the largest (by volume of water circulated) OTC system on the Pacific Coast. In addition to relative seclusion, a marine protected area (MPA) exists to the immediate north of the facility, and a 1-mile security exclusion zone aroundthe plant site and extending offshore has further reduced fishing in the immediate plant vicinity since 2001. The DCPP setting has provided a relatively isolated crucible for assessing population level impacts of the large scale OTC operation.

If DCPP operations were resulting in detrimental impacts to fish and shellfish populations in the vicinity, these impacts should be observable, even apparent, after Diablo Canyon Power Plant Page 4.2-8 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 ever-2Oalmost 30 years of commercial operations, most of which has been at high capacity factors - essentially maximizing potential ecological impacts. However, population-level impacts have not been detected. An independent study of fisheries catch data has shown that the number of rockfish caught per fisher hour in the vicinity (catch per unit effort) has remained stable, even increasing substantially in several recent seasons, despite the fact that the larvae of rockfish are among the species most susceptible to entrainment by DCPP (Reference 28). This and other similar facts provide direct evidence that entrainment losses are not resulting in population level effects in the area. In summary, "The combination of length-frequency analyses, ETM

[Empirical TransportModel] estimates, and other corroborating data support the conclusion that the local subpopulations of most nearshore taxa are not experiencing long-term declines in abundance due to entrainment" (Reference 15).

4.2.4 CONSIDERATION OF CUMULATIVE ECOLOGICAL IMPACTS FROM OTC OPERATIONS Cumulative ecological impacts due to potential for additive (synergistic) impacts caused by entrainment, impingement, and thermal discharge by DCPP have been considered.

Cooling system thermal discharge impacts, as described in Section 4.4, are isolated to a relatively small geographic location (Diablo Cove) influenced directly by the thermal plume. Extensive thermal monitoring programs implemented throughout the history of the facility have shown that discharge impacts are localized, and do not result in substantial local habitat disruption that would be necessary to cause population level impacts in the greater marine environment - either in the immediate DCPP vicinity or in the region. Degraded ecosystems and subsequent loss of species productivity and abundance can often be attributable to extensive losses of habitat available for larval recruitment and subsequent juvenile stage to adult development for multiple species.

The limited/localized influence of the thermal discharge on the expansive rocky intertidal and rocky subtidal habitat running along the coast surrounding DCPP does not support any conclusion that thermal impacts cause population levels effects, or any detrimental effects outside of the limited area directly influenced by the plume.

Impingement impacts from DCPP operations are discussed in Section 4.3. Fish and shellfish biomass trapped on debris screens due to cooling system flow and subsequently lost is very small both in absolute numbers, as well as when considered in respect to the large volumes of water withdrawn by the plant intake. Population level impacts cannot be caused by DCPP impingement, because impingement losses themselves are insignificant.

Entrainment impacts may be less localized and have the potential to influence biological populations throughout the source water area. Due to the limited extent of DCPP's thermal impact, and the design features that result in a small level of impingement, cumulative impacts on populations in the vicinity are expected to primarily reflect impacts that result from entrainment. Entrainment impacts have not been shown to result in detectible population level effects in the vicinity of DCPP or in the region. Also, many of the fishes that are impinged, such as sharks, rays, and surfperches do not Diablo Canyon Power Plant Page 4.2-9 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I produce planktonic larvae that would be subject to entrainment. Therefore, a conclusion can be drawn that cumulative impacts from entrainment, impingement, and thermal discharge are likewise not significant 4.2.5 TECHNOLOGY OR MITIGATION MEASURES TO REDUCE ENTRAINMENT LOSSES There have been no specific measures implemented during the initial operating license period to reduce the potential adverse impacts of entrainment. As previously discussed, no population level or ecological system level adverse impacts have been identified.

The CRV^QGB h ly deterni*ed that the loss of .a..alorganisms alon" may constitute an advore imat howeveF, this same Agency also determincd that "Regar-ding entrainment of.larp~ae in the cooling water system, the propertienal loss of larvae;issignificant. However, the coests of DC-1PPmoedification oroeational changes are wA.holly dsp*Op.,tionatc to the benefit to be gained." (Referene 4)The State OTC Policy establishesa December 2024 deadline for DCPPto be in compliance and further establishes a process to determine compliance requirements. The policy requiresthe SWRCB to review the results of the Bechtel Alternatives Analysis and determine whetherthe costs of alternativetechnologies are "wholly out of proportion"to the costs consideredby the Board in adoptingthe policy or if installationof alternative technologies are "wholly unreasonable"based on a number of factors including engineering,permitting, space and safety constraints,as well as adverse environmental impacts. Any difference in impacts to marine life resultingfrom alternative,less stingent requirementsmust be fully mitigated.

Consideration of technology or mitigation measures that have the potential to reduce or offset entrainment losses from DCPP OTC system operations are detailed in the supporting references for this report section (References 10, 19, and 27).

As noted above, in accordancewith the State's OTC policy, Bechtel was selected to prepare an alternative technologies reportfor the DCPP. The report developed a cost assessment and schedule for each of the technically feasible options, including fine mesh screens, offshore wedgewire screens,and closed-cycle cooling. A final report was submitted to the SWRCB in September 2014 (Reference 27). The SWRCB is expected to make a compliance determinationby the second quarterof 2015.

No available technologies, other than retrofitting DCPP to closed-cycle cooling, have been identified that could appreciably reduce entrainment losses from cooling system operations. However, retrofitting DCPP to a closed-cycle cooling system is only a conceptual possibility, and would require implementation of a project at an unprecedented scale compared to any other similar undertaking previously conducted in the power generation industry. Additionally, evaluation of retrofitting DCPP has determined that likely insurmountable site-specific permitting, licensing, technical, and economic factors make such a project essentially infeasible. There are no technology or mitigation measures available in which the costs of implementation would not be very significant in relation to potential benefits that could be gained (References 19 and 27).

Diablo Canyon Power Plant Page 4.2-10 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 It Or unknown if implementaon of any mitigatiRn *t*ategy, of required, durig the period of et*ended operation would redu ce ongoin DP. entra.inment. Any effo.t to increase the abund"ane of larFac in the urce wate b (,uch as the GGRWQCB Gonsulta proeposal to establish an artificial reef OR the '.icinity Of DOP P1) could cause an increase in the abundance of larwal populations susceptible to entrainment (Reference 4)-.

InrGeases inabundance inthe source water body could result in related inrae nthe ahaui n*umkfar ,%4inui dru Ot ih ne-"ngn system w~ithin ai given voluime ofwater-. *Vm i LJ^*..* ,* .. . i .. 1 M-.--- i. 4. i 4 .4.--.

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losses as those now exeined, ultimatel not changing the relative larval 'tae and/or impact of the power plant due to entrainment. As population level impacr*

attributable to entrainment are curently not witnessed, similarly none would be anticipated a9 any speiaGl mlnifgation strategy was u*plementea in tme viclilnity.

4.

2.6 CONCLUSION

- IMPACTS ON FISH AND SHELLFISH RESOURCES RESULTING FROM ENTRAINMENT DURING THE PERIOD OF EXTENDED OPERATION PG&E anticipates that current uncertainty regarding final regulator; policies regarding reduction OFr mitigation r iements for absolute entr.a;iment lasse"r resulting from power plant cooling sytmoeations,wall be resoled through ongoing legislative and administrative, . procees, and ultimately the SWRCB will complete its evaluation of the Bechtel study and make a compliance determinationin 2015 and that the CCRWQCB will then renew the NPDES permit, incorporatingcompliance findings and any required mitigation. PG&E believes that the existing OTC system will continue to be considered best technology available for DCPP due to site specific considerations.

It is unknown currently what type of mitigation would ever be required for cooling system entrainment during a period of extended operation. In a case in which mitigation would be necessary to offset absolute entrainment losses, the specifics of the mitigation option would be developed and implemented under the guidance of the SWRQB and CCRWQCB as part of the NPDES permitting process.

Based on evidence from the extensive ecological studies conducted during the initial operating license period, entrainment losses of marine organism larvae and/or eggs do not result in observable population level impacts, and subsequently observable detrimental impacts to the overall ecological system susceptible to influence by cooling system withdrawal. Therefore, entrainment impacts to marine fish and shellfish resources from operation of DCPP's OTC system during the period of extended operation are projected to be SMALL. Species-specific evaluations of impacts to threatenedor endangeredspecies due to entrainment are discussedin further detail in Section 4.10.

Diablo Canyon Power Plant Page 4.2-11 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I 4.3 IMPINGEMENT OF FISH AND SHELLFISH NRC "If the applicant's plant utilizes once-through cooling or cooling pond heat dissipation systems, the applicant shall provide a copy of current Clean Water Act 316(b) determinations.. .or equivalent State permits and supporting documentation. If the applicant cannot provide these documents, it shall assess the impact of the proposed action on fish and shellfish resources resulting from... impingement...."

10 CFR 51.53(c)(3)(ii)(B)

"...The impacts of impingement are small at many plants but may be moderate or even large at a few plants with once-through and cooling-pond cooling systems...." 10 CFR 51, Subpart A, Appendix B, Table B-i, Issue 26 The NRC made impacts on fish and shellfish resources resulting from impingement a Category 2 issue, because it could not assign a single significance level to the issue.

Impingement impacts are small at many facilities, but might be moderate or large at other plants (Reference 18). Information that needs to be ascertained includes (1) type of cooling system (whether once through or cooling pond) and (2) a current Clean Water Act 316(b) determination or equivalent state documentation.

DCPP has a once-through heat dissipation system that withdraws from and discharges to the Pacific Ocean. The general design and operational parameters of the cooling system are provided in Section 3.1.2.

As discussed in Section 4.2, the Central Coast Regional Water Quality Control Board (CCRWQCB) issued an NPDES Permit (CA0003751) (see Attachment B) to PG&E in 1990. The permit was-due-teoexpired in 1995, and has since been in administrative extension. PG&E is aotivelycontinuing to working with the SWRCB and the CCRWQCB to renew this permit. The current permit does not include any requirements for ongoing impingement monitoring during plant intake operations.

PG&E completed an impingement assessment of the OTC system in 1986. The year long study concluded that impingement of all marine organisms was very low, and further studies have not been warranted. The study found that impingement losses during full flow intake operations (4 main circulatingwaterpumps and 2 auxiliary water pumps in operation) amount to approximately 2.5 pounds of fish and shellfish biomass daily for a maximum of between 900-1200 pounds of biomass on an annual basis. This is in comparison to intake system performance of other west coast power generation facilities using OTC in which impingement can exceed DCPP'sannual biomass total in a single day, even with lower net intake withdrawal volumes at full power. The low Diablo Canyon Power Plant Page 4.3-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I impingement rates of the DCPPintake system are attributableto initial design and installationintended to reduce loss of fish due to impingement, as well as placement of the shoreline intake within an engineeredprotective cove. A study for the SWRCB showed that DCPPhas the lowest impingement rate of any power plant in California using coastal waters for cooling (Reference 29).

In 2003, Tthe CCRWQCB staff found dete-mMiRed-that "regarding impingement of adult fish in the intake structure, the number of fish lost per year is so minor (a few hundred fish per year) that intake structure modifications or operational changes are not necessary. These losses are already minimized pursuant to Clean Water Act Section 316(b)" (Reference 4). Additionally, as part of the 2000 316(b) DemonstrationStudy, the CCRWQCB's Technical Work Group reviewed the 1986 impingement study results, as well as additionaldata, and agreed that the low levels of impingement did not warrantfurther study (Reference 13).

aRnd 2 auxilia; water pmpe in operation) armount to apprOXimately 2.5 pounds of fish and Shellfish biomass al o maximum of betmAeen 000 1200 pounds of biomass on an annual basis. Thisis in comnparison to intake system pcrformance of other west coastpoer ge erato facilities using OTCG in which an eXcccd DCPP1's Gmigmn full peweFe. The low iminemn raters oef thee DCPP in atake system are aftributable to initialI dfersnn aind instaIation intendedt- to rediie 10enn~f firh d, -P to Vl I1*

innmntp arfI Ianana ,;.k ; n an n nG a~ *ka e.karn G r~a ;.-.*nL,~. ~. an ann inn d Drotec.tive cave. Refer to the Impingement of Fish and Shellfish Technical Data Report for more information regarding intake structure design, and the results of impingement assessments conducted (Reference 9).

PG&E concludes that impingement impacts to fish and shellfish resources from operation of the OTC system during the period of extended operation, based on the determination of impacts during the initial operating license period, are projected to be SMALL. Species-specific evaluations of impacts to threatenedor endangeredspecies due to impingement are discussedin further detail in Section 4.10.

Diablo Canyon Power Plant Page 4.3-2 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 4.4 HEAT SHOCK NRC "If the applicant's plant utilizes once-through cooling or cooling pond heat dissipation systems, the applicant shall provide a copy of current Clean Water Act...316(a) variance in accordance with 40 CFR 125, or equivalent State permits and supporting documentation. If the applicant cannot provide these documents, it shall assess the impact of the proposed action on fish and shellfish resources resulting from heat shock..." 10 CFR 51.53(c)(3)(ii)(B)

"...Because of continuing concerns about heat shock and the possible need to modify thermal discharges in response to changing environmental conditions, the impacts may be of moderate or large significance at some plants ....." 10 CFR 51, Subpart A, Table B-i, Issue 27 The NRC made impacts on fish and shellfish resources resulting from heat shock a Category 2 issue because of continuing concerns about thermal discharge effects and the possible need to modify thermal discharges in the future in response to changing environmental conditions (Reference 18). Information to be ascertained includes (1) Type of cooling system (whether once-through or cooling pond), and (2) Evidence of a CWA Section 316(a) variance or equivalent State documentation.

DCPP has a once-through heat dissipation system that withdraws from and discharges to the Pacific Ocean. The general design and operational parameters of the cooling system are provided in Section 3.1.2.

As discussed in Section 4.2, the Central Coast Regional Water Quality Control Board (CCRWQCB) issued an NPDES Permit (CA0003751) (see Attachment B) to PG&E in 1990. The permit was-due-to-expired in 1995 and has since been in administrative extension. PG&E is aGtWely-continuing to working with the SRWQCB and the CCRWQCB to renew this permit. The permit includes an effluent limit that requiresthe dischargetemperaturebe no more than 22°F above the ambient receiving waterand also includes numerous narrativereceiving waterlimits including requirementsthat the dischargenot cause objectionable aquaticgrowth or degradationof indigenous biota, degradationof marine communities, including vertebrate, invertebrate,and plant species and temperature of receiving waterto adversely affect beneficial uses.

In accordance with permit requirements, PG&E monitors discharge characteristics (including heat shock) and reports the results to the CCRWQCB. Refer to the Heat Shock Technical Data Report for more information regarding the history of studies completed for thermal discharge (Reference 7).

Diablo Canyon Power Plant Page 4.4-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 The physical characteristics and biological effects of the DCPP thermal discharge have been extensively studied beginning in the mid-1 960s when the area was first considered as a power plant site. During plant operations in the initial license period, actual effects of the thermal discharge were found to be only slightly greater in spatial extent than predicted, but are largely confined to the shoreline and shallow areas of Diablo Cove.

The most recent completed detailed analysis of the effects of the thermal discharge using data through 2002 (Reference 16) showed that the nature and spatial extent of the effects had not increased since the previous assessment detailing changes through 1995 (Reference 14). In general, pre-operational assessments have been confirmed by actual plant operations, and thermal discharge impacts are not significantly changing over time as a result of continued plant operations.

Currently, DCPP is updating the cooling system thermal discharge impacts assessment using data gathered through 2008-2013 from the ongoing Receiving Water Monitoring Program (RWMP). The final reporft from the effort expands the.econd operational period (p~erio ) data soet usred in the last comprohensiv.e analysis (Reference16 from 1995 2002 to 1995 2008. It is scheduled for completion during 4-61-2nd Quarter 20-102015, and preliminary conclusions from the in-progress project are not substantially different from those in the earlier comprehensive reports.

Continued monitoring of the marine environment influenced by the DCPP discharge is anticipated to further support previous conclusions regarding thermal impacts. Once-through cooling system thermal effects are not significantly changing or increasing, and protection of the beneficial uses of the receiving water will continue in the period of extended operation.

PG&E concludes that heat shock impacts to fish and shellfish resources from operation of the OTC system during the period of extended operation, relative to the determinations of thermal discharge impacts during the initial operating license period, are projected to be SMALL. Species-specific evaluationsof impacts to threatenedor endangeredspecies due to heat shock are discussed in further detail in Section 4.10.

Diablo Canyon Power Plant Page 4.4-2 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 4.5 GROUNDWATER USE CONFLICTS (PLANTS USING >100 GPM OF GROUNDWATER)

NRC "If the applicant's plant...pumps more than 100 gallons (total onsite) of ground water per minute, an assessment of the impact of the proposed action on groundwater use must be provided." 10 CFR 51.53(c)(3)(ii)(C)

"...Plants that use more than 100 gpm may cause ground-water use conflicts with nearby ground-water users...." 10 CFR 51, Subpart A, Table B-1, Issue 33 The NRC made this groundwater use conflict a Category 2 issue because at a withdrawal rate of more than 100 gpm, a cone of depression could extend offsite. This could deplete the groundwater supply available to offsite users, creating an impact that could warrant mitigation. Information needed to address this issue includes the DCPP groundwater withdrawal rate (whether greater than 100 gpm), offsite drawdown, and impact on neighboring wells.

Based on information presented in Section 3.1.2, DCPP average1 groundwater use is less than 100 gpm. Groundwater reserves at the site are limited by the nature of the plant location, and lack of hydraulic connection with groundwater resources on properties outside of plant controlled lands.

DCPP has a groundwater well (Deep Well #2) available as a backup freshwater resource. The deep well has a maximum capacity of 170 gpm, and a tested reliable production rate of 150-155 gpm that can be maintained even during drought conditions without depleting the trapped aquifer. However, the well is not intended to operate continuously, and is only in-service as needed. Average production from the well on an annual basis is projected to be 6igniftantly-less than 100 gpm during the period of extended operation. The estimate for total well use is approximately 12 weeks (or approximately 350-2000 hours) on average per year at the 150 gpm production rate.

Deep Well #2 will normally only be used in the event the Seawater Reverse Osmosis (SWRO) Unit freshwater production is insufficient to maintain plant makeup or firewater reserves. This is anticipated to occur only during a non-routine period of unusually high freshwater consumption by Unit 1 and/or Unit 2 (such as an extended dual unit forced outage with Units maintained in hot standby), or during periodic planned or unplanned clearance of the SWRO. SWRO supply is generally only insufficient when the system is unavailable for an extended period of time due to scheduled equipment maintenance,

'Regulatory Guide 4.2 Supplement I Section 4.5 states that this section is applicable to plants that use more than an annualaverage of 100 gpm. Thus, DCPP's evaluation is based on the annual average use of groundwater.

Diablo Canyon Power Plant Page 4.5-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 an unplanned equipment failure, or a system trip from a transient event such as electrical power loss or excessive pump backpressures. Continuous use of the well at maximum rated capacity is therefore not anticipated during the period of extended operation. The system will remain a back-up freshwater resource, and will be used primarilyfor SWRO backup, as well as conditioningof SWRO product waterer*y When in operation, the well draws from an isolated source specific to DCPP. The topography of the location precludes any connection between the well source water and offsite water resources. There are no neighboring wells (outside of the DCPP industrial site and adjacent controlled property) that can be impacted or made unavailable due to operation of the onsite well. Therefore, no cone of depression can be created from groundwater use on the plant site that could extend offsite regardless of pump withdrawal rate or an extended period of withdrawal. Further assessment of the issue of groundwater use conflicts (required for plants using more than 100 gpm groundwater) is not necessary and the impacts of this issue are SMALL.

Diablo Canyon Power Plant Page 4.5-2 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I 4.10 THREATENED OR ENDANGERED SPECIES NRC "Additionally, the applicant shall assess the impact of the proposed action on threatened and endangered species in accordance with the Endangered Species Act." 10 CFR 51.53(c)(3)(ii)(E)

"Generally, plant refurbishment and continued operation are not expected to adversely affect threatened or endangered species. However, consultation with appropriate agencies would be needed at the time of license renewal to determine whether threatened or endangered species are present and whether they would be adversely affected."

10 CFR 51, Subpart A, Appendix B, Table B-i, Issue 49 The NRC made impacts to threatened and endangered species a Category 2 issue because the status of many species is being reviewed continuously, and site-specific assessment is required to determine whether any identified species could be affected by refurbishment activities or continued plant operations through the renewal period. In addition, compliance with the Endangered Species Act requires consultation with the appropriate federal agency (Reference 18, Sections 3.9 and 4.1).

Section 2.2 describes the aquatic communities near the plant site, presents special status (State and Federal)aquaticspecies that have the potentialto occur in the vicinity of DCPP,and discusses population trends in recreationally and commercially important populations. Section 2.4 describes important terrestrial habitats at DCPP and presents special status (State and Federal)terrestrialspecies that have the potential to occuron the Diablo Canyon lands. Section 2.5 discusses State- and Federally-listed threatened or endangered species that occur or may occur at-on the DCPP site (ParcelP), or along associated transmission corridors andpotential impacts to these species.

PG&E is currently unaware of any adverse issues that involve State and Federally listed threatened or endangered specie assoc.iatod with the operation andlor mnaintenance of DCPP, in*luding the existing transmission lines, towers, and access roads. PG&E corresponded with appropriate agencies (USFWS, CSLC, BLM, NMFS, and GDF=GCDFW) requesting information on the role each agency would expect to play in the license renewal process and the scope of information that may be required to fulfill those responsibilities. Agency consultation correspondence is provided in Attachment C.

As discussed in Section 3.2, PG&E has no plans to conduct refurbishment activities at DCPP during the license renewal term. Therefore, there would be no refurbishment-Diablo Canyon Power Plant Page 4.10-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 related impacts to special-status species and no further analysis of refurbishment-related impacts is warranted.

Furthermore,plant operations will continue to be conducted in accordance with the EnvironmentalProtection Plan (Reference 30) which ensures that the plant is operated in an environmentally acceptablemanner, as establishedby the FES and otherNRC environmental impact assessments. FurthermrFe, bBecause PG&E has no plans to alter current operations, PG&E concludes that license renewal related impacts to State and Federally-listed threatened or endangered species from license renewal discussed below and to special status species listed in Tables 2.2-3 and 2.4-1 would be SMALL and do not warrant mitigation beyond current management programsand existing regulatorycontrols.

Threatenedor endangeredspecies are discussed in detail in Section 2.5. The species-specificimpact conclusions are summarized below:

TerrestrialSpecies

• Californiatiger salamanderand California red-leggedfrog are the only terrestrial threatenedor endangeredspecies with the potentialto occur on the DCPPsite (ParcelP). There is only marginalhabitatfor these species on the DCPPsite and despite long-term monitoring and othersite specific surveys, none have ever been recordedon the plant site or even on the surroundingDiablo Canyon lands.

In addition, there are no refurbishment or construction activities associatedwith DCPPlicense renewal. Thus, there is no anticipatedimpact to these species due to DCPPcontinued operation and PG&E concludes that impacts to threatenedor endangeredterrestrialspecies would be SMALL.

Aquatic Species

• Cooling system thermal dischargeimpacts, as describedin Section 4.4, are isolated to a relatively small geographiclocation (Diablo Cove) influenced directly by the thermal plume. Extensive thermal monitoringprogramsimplemented throughoutthe history of the facility have shown that dischargeimpacts are localized, and do not result in substantiallocal habitatdisruption that would result in population level impacts in the greatermarine environment - eitherin the immediate DCPPvicinity or in the region. The limited/ocalized influence of the thermal discharge on the expansive rocky intertidaland rocky subtidalhabitat running along the coast surroundingDCPPdoes not provide any evidence that thermal impacts cause population levels effects, or any detrimentaleffects outside of the limited area directly influenced by the plume. Thus, PG&E concludes that heat shock impacts to fish and shellfish resourcesfrom operation of the OTC system during the periodof extended operation would be SMALL.

• Discussion of potentialimpacts to threatenedand endangeredspecies due to impingement and entrainment are discussed specific to each species below.

• Because the NRC is responsible for licensing nuclearpower plants to operate, it is their responsibilityunder Section 7 (a) (2) of the ESA to requestconsultation Diablo Canyon Power Plant Page 4.10-2 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I on the take of listed species during the operation of DCPP. The NMFS issued a biological opinion on the effects of continued operation of DCPPon federally listed aquaticspecies subsequent to formal consultation with the NRC entered into on July 20, 2005 (Reference 24). The biologicalopinion evaluated direct and indirect effects of DCPPoperationsover a study area including DCPPfacilities, the intake and discharge structures,and the region where the dischargeof warm and chlorinatedwater extends. The biologicalopinion concluded that operation of DCPPis not likely to jeopardize federally listed green sea turtles, leatherback sea turtles, loggerheadsea turtles, and olive ridley sea turtles (Reference 24). In addition, blue whale, sperm whale, fin whale, humpback whale, sei whale, Guadalupe fur seal, white abalone, green sturgeon, and steelheadmay be found in the study area for limited amounts of time, but in the NMFS opinion, are not likely to be adversely affected by DCPPoperation. Species specific conclusions of the 2006 biologicalopinion areprovided below. While killer whale and north pacific right whale were not identifiedas a threatenedor endangered species that may be present in the study area at the time the biological opinion was published, the effects to killer whale and north Pacific right whale would be the same as those whale species discussedin the biologicalopinion and thus, PG&E concludes killer whale and north Pacific right whale not likely to be adversely affected by DCPPoperation. Therefore, PG&E concludes impacts to these species due to DCPPcontinued operation would be SMALL.

SCCC Steelhead DPS

• The FederalRegisterrule package identifies streams that provide habitatsuitable for this species. Within the vicinity of DCPP,only Coon Creek, located north on the boundary with Montana de Oro State Park, is described (Reference 25).

Currentfreshwaterhabitaton the Diablo Canyon lands is not anticipatedto decline with continuedoperations as current operationhas no effect on this designated criticalhabitat. In contrast,beginningin 2002, PG&E partneredwith the City of San Luis Obispo, the NMFS, and the CDFW in a successful steelhead habitat restorationproject on Coon Creek (Reference 26). Given that steelhead are an anadramousspecies (spawn in fresh water), there is no anticipated entrainmentof steelhead larvae because the presence of larval steelheadin the intake cove is not likely. In addition, the likelihood of adult steelhead impingement is low due to the low uniform intake approach velocity (which allows fish to swim away from the intake structure), and lack of any steelheadidentified in the vicinity of the intake cove in past DCPPmonitoring efforts. Therefore, incidental take is unlikely and PG&E concludes that impacts to the Federally-listed SCCC steelhead DPS from continued operations would not likely adversely affect the species, and thus, impacts will be SMALL.

TidewaterGoby

• No streams traversingthe Diablo Canyon lands have designatedcriticalhabitat for the tidewatergoby (78 FR § 8745). No suitable habitatis available in Diablo Creek, as the creek has no estuary and ascends steeply over rocky substrate Diablo Canyon Power Plant Page 4.10-3 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 from the mouth upstream, precludingthe occurrence of gobies. Coon Creek presents very limited and marginalhabitatfor the tidewatergoby at the very mouth of the stream; however, no adult gobies are currently or historicallyknown to inhabitthis stream. Entrainment of tidewatergoby larvae is unlikely due to the lack of historicalpresence orpotential habitat(coastallagoon or estuary) in the vicinity of the intake cove. In addition, the likelihood of adult tidewatergoby impingement is low due to the lack of habitat. Tidewatergobies are uniquely adaptedto coastal lagoons and the uppermost brackish zone of largerestuaries, rarely occurringin marine habitats. Therefore, it is highly unlikely that tidewater goby would be in the vicinity of the intake cove. This is supported by the fact that there are no records of adult tidewatergoby presence in the vicinity of the inake cove throughout the history of DCPPoperationduring extensive marine monitoring. Therefore, incidental take is unlikely, and PG&E concludes that impacts to the tidewatergoby from continued operations would not likely adversely affect the species, and thus, impacts will be SMALL.

Green Sturgeon

• No criticalhabitatfor the green sturgeon is designatedin the vicinity of the DCPP (74 FR § 52300). Given that green sturgeon are an anadramousspecies (spawn in fresh water), there is no anticipatedentrainmentof green sturgeon larvae. In addition, green sturgeon spawning grounds are very distant from DCPP (several hundred miles away), with the nearest confirmed location in the Sacramento River. Therefore, the presence of larval green sturgeon in the vicinity of the intake cove is highly unlikely. Although the marine habitataround DCPPis within the range of adult green sturgeon, the likelihood of adult green sturgeon impingement is low due to the low uniform intake approach velocity (which would allow fish to swim away from the screens), and the lack of any green sturgeon identified in the vicinity of the intake cove throughout the history of DCPP operationduring extensive marine monitoring. Therefore, incidental take is unlikely, and PG&E concludes that impacts to the green sturgeon from continued operations would not likely adversely affect the species, and thus, impacts will be SMALL.

Coho Salmon

• No criticalhabitatfor the coho salmon is designatedin the vicinity of the DCPP (64 FR § 24049). Given that coho salmon are an anadramousspecies (spawn in fresh water), there is no anticipatedentrainmentof coho salmon larvae because presence of larval coho salmon in the intake cove is not likely. Although the marine habitataround DCPPis within the range of adult coho salmon, the likelihood of adult coho salmon impingement is low due to the low uniform intake approach velocity (which would allow fish to swim away from the screens), and the lack of any coho salmon identifiedin the vicinity of the intake cove throughout the history of DCPPoperationduring extensive marine monitoring. Therefore, incidentaltake is unlikely, and PG&E concludes that impacts to the coho salmon Diablo Canyon Power Plant Page 4.10-4 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I from continued operations would not likely adversely affect the species, and thus, impacts will be SMALL.

Southern Sea Otter Sea otterpopulationsfrom Point Buchon to near Point San Luis (including geographicarea off the coast of DCPP)have been monitored since 1973. This extensive monitoringeffort has identified no impact to southern sea otter populations from DCPPoperation. Therefore, incidentaltake is unlikely, and PG&E concludes that impacts to the southern sea otter from continued operationswould not likely adversely affect the species, and thus, impacts will be SMALL.

Guadalupe Fur Seal

• Marine mammal populations off the coast of DCPPhave been monitored throughoutplant operation. This monitoring effort has identified no impact to Guadalupefur seal populationsfrom DCPPoperation. Therefore, incidental take is unlikely, and PG&E concludes that impacts to the Guadalupe fur seal from continued operationswould not likely adversely affect the species, and thus, impacts will be SMALL.

Green Sea Turtle

• During the period of 1977 (priorto reactorstart-up and plant commercial operation)through 2014, there were 14 occurrencesof a green sea turtle found strandedin the forebay of the DCPPintake structure. NMFS issued a Biological Opinion and Incidental Take Statement, in accordancewith Section 7 of the ESA (16 U.S.C 1531 et seq.), on September 18, 2006 for the possession and disposition of impinged or strandedsea turtles within the DCPPintake structure (Reference 24). The biologicalopinion on the effects of DCPPoperation on federally listed species issued by NMFS in September 2006 concluded operation of DCPPis not likely to jeopardize green sea turtles. Sea turtles would not likely be directly harmed by elevated water temperatures. While it is possible that temperatureincreasesfrom thermal discharge could affect the turtle's normal distributionor foragingpatterns (as sea turtles have been known to aggregatein warm watereffluent elsewhere), based on stranding and sighting data, there have been no known cases of sea turtles aggregatingnearthe DCPPdischarge area. In addition, the warm water effluent does not extend to the intake cove and, therefore, would not likely modify turtle behaviornear the intake structure (Reference 24). While PG&E is covered underthe Biological Opinion and Incidental Take Statement for the possession and dispositionof impinged or stranded sea turtles at DCPP,strandingof green sea turtles within the intake structure at DCPPhas never resultedin a green sea turtle mortality or injury, and there has never been an instance of sea turtle impingement againstthe bar racks at DCPPdue to the low uniform intake approach velocity. Thus, PG&E concludes that impacts to the green sea turtle from continuedoperationswould not likely adversely affect the species, and therefore, impacts will be SMALL.

Diablo Canyon Power Plant Page 4.10-5 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 Leatherback Sea Turtle

• While designated criticalhabitatfor the leatherbackturtle includes geographic area off the coast of the DCPP,in the almost 30 years since DCPPstarted operating,PG&E has never observed leatherbacksea turtles in the vicinity of DCPP. However, in the event that a leatherbacksea turtle were encounteredin the vicinity of DCPP,PG&E is covered under the Biological Opinion and Incidental Take Statement for the possession and dispositionof impinged or strandedsea turtles at DCPP. NMFS issued a Biological Opinion and Incidental Take Statement, in accordance with Section 7 of the ESA (16 U.S.C 1531 et seq.), on September 18, 2006 for the possession and disposition of impinged or strandedsea turtles within the DCPPintake structure (Reference 24). The biologicalopinion on the effects of DCPPoperationon federally listed species issued by NMFS in September 2006 concluded operation of DCPPis not likely to jeopardizeleatherbacksea turtles. Sea turtles would not likely be directly harmed by elevated water temperatures. While it is possible that temperature increasesfrom thermal discharge could affect the turtle's normal districutionor foraging patterns (as sea turtles have been known to aggregatein warm water effluent elsewhere), based on strandingand sighting data, there have been no known cases of sea turtles aggregatingnear the DCPPdischargearea. In addition, the warm water effluent does not extend to the intake cove and, therefore, would not likely modify turtle behaviornear the intake structure (Reference 24). Based on past strandingevents with green sea turtles, which have not resulted in an injury or mortality, there would be no anticipatedinjury or mortality from strandingof a leatherback. Additionally, there would be no anticipatedimpingement of a leatherbacksea turtle due to the low uniform intake approach velocity and the lack of any sea turtle impingement againstthe intake structure barracks throughout the history of DCPPoperation. Thus, PG&E concludes that impacts to the leatherbacksea turtle from continued operations would not likely adversely affect the species, and therefore, impacts will be SMALL. In addition, the limited range of the thermal plume from DCPPthermal discharge in relation to the widespread species' range, lends to the conclusion that impacts to the species' criticalhabitatfrom DCPPthermal dischargewould be SMALL.

Pacific Olive Ridley Sea Turtle

• NMFS issued a Biological Opinion and Incidental Take Statement, in accordance with Section 7 of the ESA (16 U.S.C 1531 et seq.), on September 18, 2006 for the possession and disposition of impinged or strandedsea turtles within the DCPPintake structure (Reference 24). The biological opinion on the effects of DCPPoperation on federally listed species issued by NMFS in September 2006 concluded operation of DCPPis not likely to jeopardize olive ridley sea turtles.

Sea turtles would not likely be directly harmed by elevated water temperatures.

While it is possible that temperature increasesfrom thermal dischargecould affect the turtle's normal distributionor foraging patterns (as sea turtles have been known to aggregate in warm water effluent elsewhere), based on stranding Diablo Canyon Power Plant Page 4.10-6 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I and sighting data, there have been no known cases of sea turtles aggregating near the DCPPdischarge area. In addition, the warm watereffluent does not extend to the intake cove and, therefore, would not likely modify turtle behavior nearthe intake structure (Reference 24). While PG&E is covered under the Biological Opinion and Incidental Take Statement for the possession and disposition of impinged or stranded sea turtles at DCPP,in the almost 30 years since DCPPstartedoperating,PG&E has never observed olive ridley sea turtles in the vicinity of DCPP. However, in the event that an olive ridley sea turtle were encountered in the vicinity of DCPP, based on past strandingevents with green sea turtles, which have not resulted in an injury or mortality, there would be no anticipatedinjury or mortality from strandingof an olive ridley sea turtle.

Additionally, there would be no anticipatedimpingement of an olive ridley sea turtle due to the low uniform intake approachvelocity and the lack of any sea turtle impingement againstthe intake structure bar racks throughout the history of DCPPoperation. Thus, PG&E concludes that impacts to the olive ridley sea turtle from continued operationswould not likely adversely affect the species, and therefore, impacts will be SMALL.

LoggerheadSea Turtle

• NMFS issued a Biological Opinion and Incidental Take Statement, in accordance with Section 7 of the ESA (16 U.S.C 1531 et seq.), on September 18, 2006 for the possession and disposition of impinged or strandedsea turtles within the DCPPintake structure (Reference 24). The biologicalopinion on the effects of DCPPoperation on federally listed species issued by NMFS in September 2006 concluded operationof DCPPis not likely to jeopardize loggerheadsea turtles.

Sea turtles would not likely be directly harmed by elevated water temperatures.

While it is possible that temperatureincreasesfrom thermal discharge could affect the turtle's normal districutionor foraging patterns (assea turtles have been known to aggregatein warm water effluent elsewhere), based on stranding and sighting data, there have been no known cases of sea turtles aggregating nearthe DCPPdischarge area. In addition, the warm water effluent does not extend to the intake cove and, therefore, would not likely modify turtle behavior near the intake structure (Reference 24). While PG&E is covered under the Biological Opinion and Incidental Take Statement for the possession and disposition of impinged or strandedsea turtles at DCPP,in the almost 30 years since DCPPstartedoperating,PG&E has never observed loggerheadsea turtles in the vicinity of DCPP. However, in the event that a loggerheadsea turtle were encounteredin the vicinity of DCPP,based on past stranding events with green sea turtles, which have not resulted in an injury or mortality, there would be no anticipatedinjury or mortalityfrom strandingof a loggerheadsea turtle.

Additionally, there would be no anticipatedimpingement of aloggerheadsea turtle due to the low uniform intake approach velocity and the lack of any sea turtle impingement against the intake structure barracks throughout the history of DCPPoperation. Thus, PG&E concludes that impacts to the loggerheadsea turtle from continuedoperations would not likely adversely affect the species, and therefore, impacts will be SMALL.

Diablo Canyon Power Plant Page 4.10-7 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I Black Abalone

" Entrainmentof fish and shellfish larvae is discussedin detail in Section 4.2.

While there is potential for entrainmentof black abalone larvae at DCPP, there are factors that greatly reduce the potential for entrainmentto adversely impact the species population. The duration of time that abalone larvae are in the water column where they might be subject to entrainment is limited by the short dispersalpotentialfor this species. Laboratory studies at DCPPalso showed that the larvalstage where dispersalis most likely to occur is limited to 10 to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />. Therefore, any larvae would be subject to entrainmentfor a limited periodof time and within an area limited to the direct vicinity of the intake cove, and any minimal entrainment would not adversely affect the population. Thus, PG&E concludes impacts to the species from DCPPcontinued operationdue to entrainment would be SMALL.

" Temperatures found in Diablo Cove are within the range of the optimum temperaturesfor the species. The biogeographicalwater temperature range of black abalone is from 53.6 to 770F, but they are most abundantin areas where the water temperatureranges from 64.4 to 71.6°F (Reference 31). This is further demonstratedby laboratorystudies at DCPPshowing tolerance of the species for seawatertemperatureshigherthan the temperaturesexperienced inside Diablo Cove during plant operationand abundancesinside Diablo Cove remaining consistentwith abundancesoutside Diablo Cove priorto the discovery of WS. While elevated water temperaturehas been demonstrated to accelerate the mortality of black abalone with withering syndrome (WS), it is not a direct cause of WS. The rate of decline due to WS was greaterin areas within the range of the DCPPthermal plume. However areaswithin the range of the thermalplume and areasoutside the range of the thermal plume (otherareas of the centralcoast south of Cayucos) eventually reachedthe same level of absolute population decline. This is shown in the DCPPmonitoring data depicted in Figure 2.5-2. Therefore, PG&E concludes impacts to this species from continued DCPPthermal discharge during the renewal period would be SMALL.

• There would be no anticipatedimpingement of juvenile or adult black abalone because black abalone are a sessile species, not free swimming. In addition, black abalone do not occur within or on the submerged exterior of the intake structure itself due to the lack of suitableprotective habitat. Thus, PG&E concludes that impacts to black abalone from continuedoperation of DCPPdue to impingement would be SMALL.

Diablo Canyon Power Plant Page 4.10-8 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I 4.11 AIR QUALITY DURING REFURBISHMENT (NON-ATTAINMENT AREAS)

NRC

"...If the applicant's plant is located in or near a nonattainment or maintenance area, an assessment of vehicle exhaust emissions anticipated at the time of peak refurbishment workforce must be provided in accordance with the Clean Air Act as amended ....." 10 CFR 51.53(c)(3)(ii)(F)

"...Air quality impacts from plant refurbishment associated with license renewal are expected to be small. However, vehicle exhaust emissions could be cause for concern at locations in or near nonattainment or maintenance areas. The significance of the potential impact cannot be determined without considering the compliance status of each site and the numbers of workers expected to be employed during the outage...." 10 CFR 51, Subpart A, Appendix B, Table B-I, Issue 50 The NRC made impacts to air quality during refurbishment a Category 2 issue because vehicle exhaust emissions could be cause for some concern, and a general conclusion about the significance of the potential impact could not be drawn without considering the compliance status at each site and the number of workers expected to be employed during an outage (Reference 18). Information needed would include: (1) the attainment status of the plant-site area, and (2) the number of additional vehicles as a result of refurbishment activities.

DCPP is located in a State non-attainment area for ozone and PM10 (Refer to Section 2.10). The issue of air quality during refurbishment is not applicable to DCPP because, as discussed in Section 3.2, PG&E has no plans for refurbishment or other license renewal-related construction activities at DCPP. Further, since air emissions from the site, including emissions from testing emergency diesel generators, is regulated by a site-specific permit (Refer to Table 9-1) based on review of emissions in order to be protective of the State's air quality standards, impacts from continued operation are anticipated to be SMALL.

Diablo Canyon Power Plant Page 4.11-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 4.17 OFFSITE LAND USE 4.17.1 OFFSITE LAND USE - REFURBISHMENT NRC The environmental report must contain "...an assessment of the impact of the proposed action on... land-use... (impacts from refurbishment activities only) within the vicinity of the plant..." 10 CFR 51.53(c)(3)(ii)(I)

"...Impacts may be of moderate significance at plants in low population areas...." 10 CFR 51, Subpart A, Appendix B, Table B.-1, Issue 68

"...[I]f plant-related population growth is less than 5 percent of the study area's total population, off-site land-use changes would be small, especially if the study area has established patterns of residential and commercial development, a population density of at least 60 persons per square mile, and at least one urban area with a population of 100,000 or more within 50 miles...." (NRC 1996)

The NRC made impacts to offsite land use as a result of refurbishment activities a Category 2 issue because land-use changes could be considered beneficial by some community members and adverse by others. Local conditions to be ascertained include: (1) plant-related population growth, (2) patterns of residential and commercial development, and (3) proximity to an urban area with a population of at least 100,000.

This issue is not applicable to DCPP because, as Section 3.2 discusses, PG&E has no plans for refurbishment as a result of license renewal at DCPP.

Diablo Canyon Power Plant Page 4.17-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 4.17.2 OFFSITE LAND USE - LICENSE RENEWAL TERM NRC The environmental report must contain "...an assessment of the impact of the proposed action on ... land-use...within the vicinity of the plant..." 10 CFR 51.53(c)(3)(ii)(I)

"Significant changes in land use may be associated with population and tax revenue changes resulting from license renewal." 10 CFR 51, Subpart A, Appendix B, Table B-1, Issue 69

"...[I]f plant-related population growth is less than five percent of the study area's total population, off-site land-use changes would be small..." (NRC 1996, Section 3.7.5)

"If the plant's tax payments are projected to be small, relative to the community's total revenue, new tax-driven land-use changes during the plant's license renewal term would be small, especially where the community has pre-established patterns of development and has provided adequate public services to support and guide development." (NRC 1996, Section 4.7.4.1)

The NRC made impacts to offsite land use during the license renewal term a Category 2 issue because land-use changes may be perceived as beneficial by some community members and adverse by others. Therefore, the NRC could not assess the potential significance of site-specific offsite land-use impacts (Reference 18, Section 4.7.4.1).

Site-specific factors to be considered in an assessment of new tax-driven land-use impacts include: (1) the size of plant-related population growth compared to the area's total population, (2) the size of the plant's tax payments relative to the community's total revenue, (3) the nature of the community's existing land-use pattern, and (4) the extent to which the community already has public services in place to support and guide development.

The GElS presents an analysis of offsite land use for the renewal term that is characterized by two components: population-driven and tax-driven impacts (Reference 18, Section 4.7.4.1).

4.17.2.1 Population-Related Impacts As discussed in Section 2.6.1, from 1970 through 20002010, the population increases in San Luis Obispo County and Santa Barbara County were relatively large. Only a small fraction of these increases could be attributed to construction and operation of DCPP.

During the period of extended operation, PG&E has no plans to increase DCPP staff Diablo Canyon Power Plant Page 4.17-2 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I because no refurbishment-related activities required for extended operations have been identified.

Further, based on the GElS case-study analysis, the NRC concluded that all new population-driven land-use changes during the license renewal term at all nuclear plants would be small. Population growth caused by license renewal would represent a much smaller percentage of the local area's total population than the percentage presented by operations-related growth (Reference 18, Section 4.7.4.2).

4.17.2.2 Tax-Revenue-Related Impacts The NRC has determined that the significance of tax payments as a source of local government revenue would be large if the payments are greater than 20 percent of revenue, moderate if the payments are between 10 and 20 percent of revenue, and small if the payments are less than 10 percent of revenue (Reference 18, Section 3.7.3).

The NRC defined the magnitude of land-use changes as follows (Reference 18, Section 4.7.4):

SMALL - very little new development and minimal changes to an area's land-use pattern MODERATE - considerable new development and some changes to an area's land-use pattern LARGE - large-scale new development and major changes in land-use pattern The NRC further determined that, if a plant's tax payments are projected to be small relative to the community's total revenue, new tax-driven land-use changes would be small, especially where the community has pre-established patterns of development and has provided adequate public services to support and guide development.

Table 2.7-1 provides a comparison of total tax payments made by PG&E to San Luis Obispo County's property tax revenues. For the 310-year period from 2004 through 2-002014, PG&E's tax payments to San Luis Obispo represented about 6 percent of the San Luis Obispo County's total annual property tax revenues. Using the NRC's criteria, PG&E's tax payments are of SMALL significance to San Luis Obispo County.

As stated in Section 2.6, San Luis Obispo County is a fast growing county in California (San Luis Obispo County 1980-2000-2010 population growth of ,9-74 percent compared to Calfornia State 1980-2000-2010 population growth of 43-57 percent). San Luis Obispo County has a growing population and the region's economic base is increasingly diverse, with a variety of industries now supplementing traditional tourist-related businesses.

Diablo Canyon Power Plant Page 4.17-3 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I The surrounding population and the level of commercial and industrial activity in this region support the conclusion that DCPP has a small impact on the local economy and tax base. The local tax base is very large and tax payments made by PG&E are comparatively small.

PG&E does not anticipate refurbishment or license renewal-related construction during the license renewal period. Therefore, PG&E does not anticipate any increase in the assessed value of DCPP due to refurbishment-related improvements, or any related tax-increase-driven changes to offsite land-use and development patterns.

Any changes to the infrastructures of San Luis Obispo County would be attributable to the large population immigration already experienced by the County and a large pool of residential, industrial, and commercial tax payers.

4.17.2.3 Land Use and Public Services Impacts San Luis Obispo County uses comprehensive land use plans and zoning and subdivision ordinances to guide development. These plans and ordinances have been in place for several decades. The ordinances promote open space preservation; protect agricultural land from urban sprawl; and provide a basis for orderly development. The ordinances require building permits, conditional use permits, minor use permits, plot and site plans, zoning clearances, and variance requests.

San Luis Obispo County has a pre-established pattern of development with controls for future development and has been able to provide the infrastructure needed to accommodate this growth. DCPP's presence is not expected to directly attract support industries and commercial development or to encourage or deter residential development. For these reasons, PG&E concludes that the land use impact would be SMALL. Mitigation for land-use impacts during the license renewal term would not be warranted.

Diablo Canyon Power Plant Page 4.17-4 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I 4.18 TRANSPORTATION NRC The environmental report must "...assess the impact of highway traffic generated by the proposed project on the level of service of local highways during periods of license renewal refurbishment activities and during the term of the renewed license." 10 CFR 51.53(c)(3)(ii)(J)

"...Transportation impacts... are generally expected to be of small significance. However, the increase in traffic associated with additional workers and the local road and traffic control conditions may lead to impacts of moderate or large significance at some sites...." 10 CFR 51, Subpart A, Table B-I, Issue 70 Small impacts would be associated with U.S. Transportation Research Board Level of Service A, having the following condition: "...Free flow of the traffic stream; users are unaffected by the presence of others." And Level of Service B, having the following condition: "...Stable flow in which the freedom to select speed is unaffected but the freedom to maneuver is slightly diminished...." (NRC 1996)

The NRC made impacts to transportation a Category 2 issue because impacts are determined primarily by road conditions existing at the time of the project, which the NRC could not forecast for all facilities (Reference 18). Local road conditions to be ascertained are: (1) level of service conditions, and (2) incremental increase in traffic associated with refurbishment activities and license renewal staff.

As described in Section 3.2, no refurbishment is planned and no refurbishment impacts to local transportation are anticipated. Further evaluation for this impact is not applicable.

DCPP workforce currently includes approximately 14,361,440 employees. On a nominal 18-month cycle for each Unit, as many as 1,200 additional workers join the permanent workforce during a refueling outage, which typically lasts approximately 40 days. Given these employment projections and the average number of vehicles per day currently using the surrounding roads to DCPP (Table 2.9-1), PG&E concludes that impacts to transportation would be SMALL and mitigative measures would be unwarranted.

Diablo Canyon Power Plant Page 4.18-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 4.21 ENVIRONMENTAL JUSTICE From Regulatory Guide 4.2, Supplement 1 Environmental Justice was not reviewed in NUREG-1437. Executive Order 12898, "Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations," issued on February 11, 1994, is designed to focus the attention of Federal agencies on the human health and environmental conditions in minority and low-income communities. The NRC Office of Nuclear Reactor Regulation (NRR) is guided in its consideration of environmental justice by Attachment 4, "NRR Procedures for Environmental Justice Reviews," to NRR Office Letter No.

906, Revision 2, "Procedural Guidance for Preparing Environmental Assessments and Considering Environmental Issues," September 21, 1999. NRR Office Letter No. 906 is revised periodically. The environmental justice review involves identifying off-site environmental impacts, their geographic locations, minority and low-income populations that may be affected, the significance of such effects and whether they are disproportionately high and adverse compared to the population at large within the geographic area, and if so, what mitigative measures are available, and which will be implemented. The NRC staff will perform the environmental justice review to determine whether there will be disproportionately high human health and environmental effects on minority and low-income populations and report the review in its SEIS.

The staffs review will be based on information provided in the ER and developed during the staffs site-specific scoping process.

The consideration of environmental justice is required to assure that federal programs and activities will not have "disproportionately high and adverse human health or environmental effects... on minority populations and low income populations...."

Section 2.6.2 notes minority and low-income groups within a 50-mile radius of this site.

As part of its environment assessment of this proposed action, PG&E has determined that the environmental impacts of renewing the DCPP license are SMALL. This conclusion is supported by the review of the Category 2 issues defined in 10 CFR 51.53(c)(3)(ii) presented in this ER.

No sigiftatdiscemable adverse impacts to the general population from the renewal of the DCPP license have been identified. Likewise, no unique disproportionately high or adverse impacts on minority or low-income populations would occur from the proposed action. Accordingly, no detailed review for environmental justice is necessary.

Diablo Canyon Power Plant Page 4.21-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 4.22 REFERENCES

1. Diablo Canyon Power Plant NPDES Permit, CA 0003751: Order No. 90-09, Central Coast Regional Water Quality Control Board, May 1990.

2. PG&E Diablo Canyon, Continuation of NPDES Permit No. CA0003751. Central Coast Regional Water Quality Control Board, Letter Dated June 26, 1995.

3. ["regulations (Title 23, Section 2235.4) allow your permit to remain valid until the new permit is issued"]. Central Coast Regional Water Quality Control Board, Letter Dated August 29, 1996.

4. Staff Testimony for Regular Meeting of July 10, 2003 Pacific Gas and Electric Company's (PG&E's) Diablo Canyon Power Plant Renewal of NPDES Permit.

Central Coast Regional Water Quality Control Board, 2003.

5. Transmission Line Reference Book. 345 kV and Above. Third Edition, Revised.

Electric Power Research Institute. Palo Alto, California. 2004.

6. Archaeological Resources Management Plan: Diablo Canyon Site, Greenwood, Roberta S., Pacific Gas and Electric Company, April 1980.

7. Diablo Canyon License Renewal Feasibility Study Environmental Report: Heat Shock Technical Data Report. Pacific Gas and Electric Company, San Francisco, CA. 2008.

8. Best Management Practices to Reduce Environmental Impacts. Revision 2.

Pacific Gas and Electric Company. March 1, 2006.

9. Diablo Canyon License Renewal Feasibility Study Environmental Report:

Impingement of Fish and Shellfish Technical Data Report. Pacific Gas and Electric Company, San Francisco, CA. 2009.

10. Diablo Canyon License Renewal Feasibility Study Environmental Report:

Entrainment of Fish and Shellfish Technical Data Report. Pacific Gas & Electric Company, 2009.

11. DCPP Procedure EVI.ID2, CA-SLO-2 Site Management. Revision 3. Pacific Gas and Electric Company. May 14, 2008.

12. Diablo Canyon Power Plant Transmission Lines Induced Current Analyses.

Prepared by Enercon Services, Inc. for Pacific Gas and Electric Company. 2009.

13. Diablo Canyon Power Plant Cooling Water Intake Structure 316(b)

Demonstration. Tenera Inc. 1988.

Diablo Canyon Power Plant Page 4.22-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1

14. Diablo Canyon Power Plant Thermal Effects Monitoring Program Analysis Report. Chapter 1. Changes in the marine environment resulting from the Diablo Canyon Power Plant thermal discharge. Prepared by Tenera Inc. for Pacific Gas and Electric Company, San Francisco, CA. 1997.

15. Diablo Canyon Power Plant 316(b) Demonstration Report. Tenera Inc. 2000.

16. Diablo Canyon Power Plant Receiving Water Monitoring Program: 1995 - 2002 Analysis Report. Prepared by Tenera Inc. for Pacific Gas and Electric Company, San Francisco, CA. 2002.

17. Final Environmental Statement related to operation of Diablo Canyon Power Plant Units 1 and 2. Pacific Gas & Electric Company, Docket Nos. 50-275 and 50-323, U.S. Atomic Energy Commission. May 1973.

18. NUREG-1437: Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Volumes 1 and 2. U. S. Nuclear Regulatory Commission.

Washington, D.C. May 1996.

19. Diablo Canyon Power Plant Cooling Tower Feasibility Study. Prepared by Enercon Services Inc. for Pacific Gas and Electric Company. March 2009.

20. Regulatory Guide 4.2, Supplement 1. Preparationof Environmental Reports for Nuclear PowerPlant License Renewal Applications, Revision 1. Office of Nuclear Regulatory Research. June 2013.

21. Area DesLqnation Maps/ State and National. CaliforniaAir Resources Board.

September 2012. Accessed on March 25, 2014 at:

http://www.arb.ca.gov/desiq/adm/adm.htm

22. Energqy Almanac, Databaseof Califomia Power Plants.CaliforniaEnergy Commission. May 1, 2014. Accessed on May 7, 2014 at:

http://energyalmanac.ca.,qov/powerplants/ndex.html

23. Permit Compliance System (PCS)and Integrated Compliance Information System (ICIS) databasesin Envirofacts. United States Environmental Protection Agency. March 26, 2014. Accessed on May 7, 2014 at:

http://www. epa.gov/enviro/facts/pcs-icis/search.html

24. EndangeredSpecies Act Section 7 Consultation, Biological Opinion, and Incidental Take Statement. National Oceanicand Atmospheric Administration (NOAA) National Marine FisheriesService (NMFS). 2006.

25. 52488 FederalRegister/ Vol. 70, No. 170/ Friday, September 2, 2005 / Rules and Regulations. National Oceanic and Atmospheric Administration (NOAA).

Department of Commerce. 2005.

Diablo Canyon Power Plant Page 4.22-2 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I

26. Year 2 MonitorinaReport for the Coon Creek Culvert Removal and Steelhead PassageEnhancement Project. City of San Luis Obispo, NaturalResources Program.2006.

27. Alternative Cooling Technologies or Modification to the Existing Once-Through Cooling System for the Diablo Canyon Power Plant.Preparedfor PG&E and the State Water Resources Control Board Nuclear Review Committee. Bechtel Power Corporation.Report No. 25762-000-30H-GOIG-00001.September 17, 2014. Accessed on 11112/2014 at:

http://www.swrcb.ca.gov/water issues/promrams/ocean/cwa316/rcnfpp/

28. Rockfish Resources of the South Central California Coast: Analysis of the Resource from PartyboatData, 1980-2005. Stephens et al. California Cooperative Oceanic FisheriesInvestigations Report, Vol. 47, 2006.

29. Compilation of California Coastal PowerPlant Entrainmentand Impingement Estimates for California State Water Resources Control Board Staff Draft Issue Paperon Once-Through Cooling. Preparedfor Dr. Michael Foster,Coastal Solutions Group. Steinbeck, July 2008.

30. FacilityOperatingLicenses DPR-80 and DPR-82 Diablo Canyon Nuclear GeneratingStation, Units I and 2. Appendix B: EnvironmentalProtectionPlan (Non-Radiological). Pacific Gas & Electric Company. August 1985.

31. Endangeredand Threatened Wildlife and Plants:Final Rulemaking to Designate CriticalHabitatfor Black Abalone. National Marine Fisheries Service (NMFS),

National Oceanic and Atmospheric Administration (NOAA). FederalRegister!

Vol. 76, No. 208, pp 66806 - 66844.

Diablo Canyon Power Plant Page 4.22-3 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 CHAPTER 5 - ASSESSMENT OF NEW AND SIGNIFICANT INFORMATION NRC S...The environmental report must contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware." 10 CFR 51.53(c)(3)(iv)

The U.S. Nuclear Regulatory Commission (NRC) licenses the operation of domestic nuclear power plants and provides for license renewal. License renewal applications must include an environmental report (10 CFR 54.23) with the content as prescribed in 10 CFR 51. In an effort to streamline the environmental review, the NRC has resolved most of the environmental issues generically and only requires an applicant's analysis of the remaining issues.

While NRC regulations do not require an applicant's environmental report to contain analyses of the impacts of those environmental issues that have been generically resolved

[10 CFR 51.53(c)(3)(i)], the regulations do require that an applicant identify any new and significant information of which the applicant is aware [10 CFR 51.53(c)(3)(iv)]. The purpose of this requirement is to alert the NRC staff to such information so the staff can determine whether to seek the Commission's approval to waive or suspend application of the rule with respect to the affected generic analysis. The NRC has explicitly indicated, however, that an applicant is not required to perform a site-specific validation of Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GELS) conclusions (Reference 1).

New and significant information would include:

• Information that identifies a significant environmental issue not covered in the GElS and codified in the regulation, or

• Information that was not covered in the GElS analyses and that leads to an impact finding different from that codified in the regulation.

The NRC does not specifically define the term "significant". For the purpose of its review, review, PG&E used guidance available in Council on Environmental Quality (CEQ) regulations. CEQ guidance provides that federal agencies should prepare environmental environmental impact statements for actions that would significantly affect the environment (40 CFR 1502.3), focus on significant environmental issues (40 CFR 1502.1),

1502.1), and eliminate from detailed study issues that are not significant [40 CFR 1501.7(a)(3)]. The CEQ guidance includes a lengthy definition of "significantly" that requires consideration of the context of the action and the intensity or severity of the impact(s) (40 CFR 1508.27). PG&E expects that moderate or large impacts, as defined by Diablo Canyon Power Plant Page 5-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 by the NRC, would be significant. Chapter 4 presents the NRC definitions of "moderate" and and "large" impacts.

The new and significant assessment process that PG&E used during preparation of the license renewal application included:

• Interviews with PG&E subject-matter experts on the validity of the conclusions in the GElS as they relate to DCPP;

" A review of internal and external documents related to environmental issues at DCPP, including, but not limited to: environmental assessments and monitoring reports, procedures and other management controls, compliance history reports, and environmental resource plans and data;

" Correspondence with state and federal agencies to determine if the agencies had concerns not addressed in the GElS;

" A review of other nuclear power plant license renewal applications for pertinent issues; and

• Credit for the oversight provided by inspections of plant facilities by state and federal regulatory agencies.

More specifically, PG&E environmental and license renewal personnel interviewed internal subject-matter experts, providing them with a written list of GElS issue(s). The interviews focused on three general and five issue-specific questions in an effort to identify any new and potentially significant information, and participants were encouraged to identify any other information beyond that in the GElS of which they may be aware. All responses were reviewed and documented with concurrence from each individual.

As a result of this assessment, PG&E is aware of no new and significant information regarding the environmental impacts of renewing DCPP's operating licenses.

Several issues have been deemed new issues, but their impacts are not considered significant. These issues are: (1) groundwater monitoring for tritium, (2) long-term storage of low level radioactive waste, (3) the potential-presence of athe Shoreline faultFault,4&-45km in length, located approximately 1 km offshore, and (4) the September 11, 2001 terrorist attack.

TRITIUM GROUNDWATER MONITORING Tritium groundwater sampling was initiated at DCPP in 2003-2006 through the Radiological Environmental Monitoring Program (REMP). Groundwater sampling became became an industry wide initiative in 2006. DCPPis committed to the NEI 07-07 GroundwaterProtectionInitiative (GPI) and implements this initiative through a plant Diablo Canyon Power Plant Page 5-2 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I procedure. Results of this monitoring program are submitted to local, State, and Federal Federal agencies on an annual basis via the Annual RadiologicalEnvironmental Operating OperatingReport (AREOR).

DCPP Radiation Protection personnel undertook a review of the hydro-geological environment and the potential for a proximal receptor source for water borne pathways.

As described in Sections 2.3 and 4.5, the only groundwater that is used for drinking water at the DCPP site is from Deep Well #2, located at a higher elevation (333.3 ft MSL) east of the power plant. Deep Well #2 draws from an isolated source specific to Diablo Canyon that is replenished by flows through the alluvium near 200 ft MSL (Section 2.3). The well is only a supplemental resource that is used as a backup to the primary SeawaterReverse Osmosis syste: tha-t... is ,,in*iifrequently us. . Freshwater production from the Seawater Reverse Osmosis (SWRO) Unit is the primary drinking water source. The reverse osmosis drinking water supply is sampled monthly by the REMP at station DWI and results reportedin the AREOR. Potential releases of tritiated water from the operating power plant at 85 ft MSL cannot lead to any drinking water source due to overall site hydro-geological characteristics, and the higher elevation of the aquifer replenishing the location tapped by the deep water well. Thus, the DCPP Radiation Protection analysis concluded that DCPP site releases of tritiated water, should they occur, would not affect domestic water sources since there is no groundwater under the DCPP site that would lead to sources of offsite drinking water. There has been no detectable plant-relatedtritium in any possible sources of drinking water.

Furthermore, PG&E conducted studies of tritium contribution sources around the DCPP site from 2006-2008. Tritium was found to "wash-out" during rain events due to gaseous releases from the plant vents (direct rain collection and building downspouts). Tritium was found to concentrate into stagnant water due to diffusion in air from the plant vents and in condensation of air moisture in proximity to the plant vents.

ki-From 2008 to 2014, PG&E has consistently discovered tritium levels in excess of 400 pCi/L within French drains beneath the DCPP powerblock. The low levels and the location of the tritium found in groundwater-theFrench drains at DCPP do not indicate a leak from the spent fuel pool or any other major-plantequipment source of tritium.

Instead, the low levels are consistent with the minor tritium "wash-out" pathways discussed above.

Based on the above assessments and environmental staff evaluation, it was concluded that the potential for the communication of contaminated waters originating at the DCPP site with domestic water supplies regulated, owned, managed, or certified by State and Local governmental bodies does not exist. Therefore, impacts associated with tritium found in groundwater are determined to be SMALL and would not invalidate the NRC conclusions found in the DCPP FESor the GELS.

Diablo Canyon Power Plant Page 5-3 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 LONG-TERM STORAGE OF LOW LEVEL RADIOACTIVE WASTE PG&E's assessment process for potentially new and significant information regarding the environmental impacts of renewing the DCPP operating licenses identified a potential issue related to long-term storage of Low Level Radioactive Waste (LLW). Specifically, after June 30,2008, LLW generators and licensees in 36 States, the District of Columbia, the Commonwealth of Puerto Rico, and the U.S. Territories no longer have access to the full-service LLW disposal facility in Barnwell, South Carolina. Consequently, many LLW generators storedaccumulated wastes on s.t ..M t ore a portion of their LLW forF an indefinite period. This Will inclde Class and C wAqte as well as certain Class A warte streams that do not meet the Waste aceptance criteria of the LLI, disposal facilityin Clive, Utah. However, the Waste Control Specialist (WCS) LLC Facilityin Texas is now licensed for disposalof Class A, B, and C wastes; therefore, this facility could be utilized for disposal of DCPP Class B and Class C wastes as needed'in the future. Disposalof greaterthan Class C waste remains the responsibilityof the federal government.

The Commission also concluded in Section 6.4.4.6 of the GElS (Reference 2) "that there is reasonable assurance that sufficient LLW disposal capacity will be made available when needed for facilities to be decommissioned consistent with NRC decommissioning requirements" and that "LLW storage and disposal will have small environmental impacts."

Consequently, LLW storage and disposal is a Category 1 issue.

Based on the review of the discussion of the environmental impacts of LLW storage and disposal in the GELS, PG&E concludes that the closure of Barnwell to out-of-compact waste and the opening of WCS is not new and-or significant information that warrants further discussion in this report. The environmental impacts of extended on-site storage are addressed in the GELS.

POTENTIAL-SHORELINE FAULT On November 14, 2008, PG&E notified the NRCthat preliminary results from ongoing studies by PG&E and the U.S. Geological Survey (USGS) indicate that there is a zone of seismicity that could indicate the presence of a fault approximately 15 km in length, located approximately 1 km offshore from DCPP. Subsequently, PG&E has informally referred to this zone of seismicity as the potential-"Shoreline Fault Zone." PG&E has been collaborating with the USGS to collect and analyze new geological, geophysical, and seismic data to develop improved tectonic models for the central California coastal region through the Collaborative Research and Development Agreement.

In its November 2008 notification,PG&E informed the NRC staff that it had performed an an initial evaluation of the potential ground motion levels at DCPP from the hypothesi hypthesizedfault which concluded that these motions would be bounded by the ground ground motion levels previously determined for the current licensing basis (the larger Hosgri fault). In addition, PG&E stated that the tsunami hazard threat is relatively small since it is a strike-slip fault rather than a reverse fault and, therefore, the tsunami hazard Diablo Canyon Power Plant Page 5-4 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I from the potential-new fault is not expected to exceed the plant's design basis tsunami hazard levels.

The NRC staff undertook a preliminary independent review of possible implications of the potential-Shoreline Fault to DCPP using the initial information provided by USGSthrough PG&E. This review is documented in Research Information Letter RIL 09-001, "Preliminary Deterministic Analysis of Seismic Hazard at Diablo Canyon Nuclear Power Plant from Newly Identified 'Shoreline Fault'," and can be found in Agencywide Documents Access and Management System (ADAMS) Accession No. ML090330523 (Reference 3).

The NRC staff's assessment indicates that the best estimate 84th percentile deterministic seismic-loading levels predicted for a maximum magnitude earthquake on the potential Shoreline Fault are below those levels for which the plant was previously analyzed in the DCPP Long-Term Seismic Program. Considering the results of the deterministic analyses as a whole and the current level of uncertainty, the NRC staff concludes that the postulated Shoreline Fault will not likely cause ground motions that exceed those for which DCPP has already been analyzed. The NRC staff also concludes that the potential-Shoreline Fault has a dominant strike-slip faulting mechanism. It is highly unusual for strike-slip faulting to cause the type of significant seafloor elevation change necessary to cause a sizable tsunami and so the NRC staff would not expect any significant changes in the tsunami hazard assessment.

PG&E submitted a comprehensive reporton the Shoreline Faultto the NRC on January7, 2011 (Reference 6). The Shoreline FaultReport confirmed the seismic safety of continued operationof Diablo Canyon.

In a September 2012 report,the NRC Staff documented its review of PG&E's Shoreline FaultReport and confirmed its earlier,preliminaryassessmentin RIL 09-001 (Reference 7). In RIL 12-01 the NRC Staff presenteda conservative deterministic assessment intended to allow the NRC Staff to determine if a safety concern exists as a result of the Shoreline fault. The NRC Staff concluded that deterministicseismic-loading levels predictedfor the Shoreline fault earthquake scenariosdeveloped and analyzed by NRC are at, or below, those levels consideredpreviously and demonstratedto have reasonableassuranceof safety. There NRC Staff concluded that the existing design basis for the plant alreadyis sufficient to withstand those ground motions.

Between 2010 and 2013, PG&E conducted advanced seismic researchby land and sea to furtherdocument the seismic characteristicsof the fault zones in the region surroundingDCPP,including the Shoreline Fault. In September 2014, PG&E submitted the results of the study to the NRC (Reference 5). Applying deterministicmethodology to the updated seismic information, and consistent with priorPG&E and NRC Staff conclusions, the report concluded that the researchconfirmed previous analyses that the plant and its majorcomponents are designed to withstand andperform theirsafety functions during and after a majorseismic event. Deterministicground motions (84th Diablo Canyon Power Plant Page 5-5 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I percentile) for the Shoreline Fault scenariosare bounded by the 1977 Hosgri Earthquakeand the 1991 L TSP spectra for both the DCPPpowerblock and the turbine building.

Although the presence of the potential-Shoreline Fault offshore of DCPP is new information, based on the PG&E and NRC assessments of the petential Shoreline Fault, it is not significant information since the design and licensing basis evaluations of the DCPP structures, systems, and components are not expected to be adversely affected.

TERRORISM The NRC has evaluated whether the environmental impacts of the September 11, 2001 terrorist act need to be considered under NEPA as part of the renewed operating license review. The NRC has concluded, for license renewal applications, that terrorist attacks are too far removed from natural or expected consequences of NRC action to require an environmental impact analysis (Reference 4). Moreover, the NRC has nonetheless already included a sabotage/terrorism assessment in the license renewal GElS, Chapter 5 (Reference 2). The NRCconcludes (at 5-18) that "the regulatory requirements under 10 CFR part 73 provide reasonable assurance that the risk from sabotage is small. Although the th reat of sabotage events cannot be accurately quantified, the commission believes that acts of sabotage are not reasonably expected. Nonetheless, if such events were to occur, the Commission would expect that the resultant core damage and radiological releases would be no worse that those expected from internally initiated events."

Given the inherent inability to quantify the probability of hypothetical aircraft impacts and other terrorist-initiated events, and the NRC's previous conclusion that impacts initiated by by a terrorist attack can be correlated to the generic assessment of other internally initiated severe accidents, intentional aircraft impacts and other terrorist-initiated events are not considered further in the DCPP environmental analysis (see Attachment F). To the the extent necessary, the NRC can address this issue further based on information available available in agency records.

Diablo Canyon Power Plant Page 5-6 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I

5.1 REFERENCES

1. NUREG-1 529: Public Comments on the Proposed 10 CFR Part 51 Rule for Renewal of Nuclear Power Plant Operating Licenses and Supporting Documents: Review of Concerns and NRC Staff Response. U.S. Nuclear Regulatory Commission. Office of Nuclear Regulatory Research, Washington, D.C. May 1996.

2. NUREG-1437: Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GELS), Volumes I and 2. U.S. Nuclear Regulatory Commission.

Washington, D.C. May 1996.

3. Research Information Letter RIL 09-001. Preliminary Deterministic Analysis of Seismic Hazard at Diablo Canyon Nuclear Power Plant from Newly Identified

'Shoreline Fault'. U.S. Nuclear Regulatory Commission. 2009. Available at Agencywide Documents Access and Management System (ADAMS) Accession No.

ML090330523.

4. New Jersey Department of Environmental Protection v. U.S. Nuclear Regulatory Commission &Amercqen Energy Company. U.S. Court of Appeals for the Third Circuit. Case 07-2271, Document 00318362723, Date Filed: 03/31/2009.

5. Central CoastalCalifomia Seismic Imaging ProiectReport. Pacific Gas and Electric Company. September 2014. Available at Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML14260A024 through ML14260A069.

6. PG&E Letter No. DCL-1 1-005, "Reporton the Analysis of the Shoreline Fault Zone, Central CoastalCalifornia,"dated January 7, 2011 ("Shoreline Fault Report"). Available at ADAMS Accession No. MLI 10140431.

7. Research Information Letter 12-01 "ConfirmatoryAnalysis of Seismic Hazardat the Diablo Canyon PowerPlant from the Shoreline FaultZone" (September 2012) Available at ADAMS Accession No. ML121230035.

Diablo Canyon Power Plant Page 5.1-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 CHAPTER 6 -

SUMMARY

OF LICENSE RENEWAL IMPACTS &

MITIGATING ACTIONS 6.1 LICENSE RENEWAL IMPACTS PG&E has reviewed the environmental impacts of renewing the DCPP operating licenses and has concluded that all impacts would be SMALL and would not require additional mitigation. This environmental report documents the basis for PG&E's conclusion. Chapter 4 incorporates by reference the NRC findings for the ,2-59Category 1 issues that apply to DCPP, all of which have impacts that are SMALL (Attachment A, Table A-1 andA-2). Chapter 4 also analyzes Category 2 issues, all of which are either not applicable or have impacts that would be SMALL. Table 6-1 identifies the impacts that DCPP license renewal would have on resources associated with Category 2 issues.

Diablo Canyon Power Plant Page 6.1-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I 6.2 MITIGATION NRC "The report must contain a consideration of alternatives for reducing adverse impacts.. .for all Category 2 license renewal issues..." 10 CFR 51.53(c)(3)(iii)

"The environmental report shall include an analysis that considers and balances... alternatives available for reducing or avoiding adverse environmental effects..." 10 CFR 51.45(c) as incorporated by 10 CFR 51.53(c)(2) and 10 CFR 51.45(c)

Impacts of license renewal are SMALL and would not require mitigation. Current operations include monitoring activities that would likely continue during the license renewal term. PG&E performs routine mitigation and monitoring in accordance with the current operating license requirements (DPR-80 and DPR-82, Appendix B) to ensure the safety of workers, the public, and the environment. These activities include, but are not limited to:

" Biological Monitoring (Proximal Marine and Terrestrial Environments)

• Radiological Environmental Monitoring Program

• Once-Through Cooling System Influent and Effluent Monitoring

" Receiving Water Monitoring Program (Thermal Discharge Impacts Assessment)

" Plant Systems Waste Water Discharge Quality Monitoring

• Diesel Fuel Oil Use and Combustion Emissions Monitoring Results of these monitoring programs are submitted to local, state, and federal agencies on a periodic basis. Additionally, the NRC periodically performs inspections and evaluates the effectiveness of the programs. Recent NRC inspection report findings (IR 2004-009; IR 2006-013; IR 2008-009; IR 2012-004) have not identified any findings of significance.

The monitoring programs ensure that the plant's permitted emissions and discharges are within regulatory limits and any unusual or off-normal emissions/discharges would be quickly detected, mitigating potential impacts.

Therefore, this environmental report finds that no additional mitigation measures are sufficiently beneficial as to be warranted.

Diablo Canyon Power Plant Page 6.2-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 6.3 UNAVOIDABLE ADVERSE IMPACTS NRC The environmental report shall discuss "Any adverse environmental effects which cannot be avoided should the proposal be implemented;" 10 CFR 51.45(b)(2) as adopted by 10 CFR 51.53(c)(2)

This environmental report adopts by reference the NRC findings for applicable Category I issues, including discussions of any unavoidable adverse impacts (Attachment A, Table A-1). PG&E examined 21-24 Category 2 issues and identified the following unavoidable adverse impacts of license renewal.

" Water for cooling would continue to be withdrawn from the Pacific Ocean.

" Waste heat from operation of DCPP would continue to be discharged to the Pacific Ocean.

• Small numbers of juvenile and adult fish, and some shellfish, would continue to be impinged on the intake traveling screens.

• Sea turtles may occasionally be impiRgedstrandedwithin the intake structures. DCPP has mitigation measures in place to minimize adverse impacts.

" A small percentage of larval fish and shellfish in the cooling system source water would continue to be entrained at the intake structure.

" Operation of DCPP would result in a very small increase in radioactivity in the air and Pacific Ocean. However, fluctuations in natural background radiation would be expected to exceed the small incremental increase in dose to the local population. Operation of DCPP also would create a very low probability of accidental radiation exposure to inhabitants of the area.

• Procedures for the disposal of sanitary, chemical, and radioactive wastes are intended to reduce adverse impacts from these sources to acceptably low levels. Solid radioactive wastes are a product of plant operations and long-term disposal of these materials will be required.

Based on the discussion and analyses presented in Chapter 4, PG&E expects that all unavoidable adverse impacts resulting from renewal of the DCPP operating licenses would be SMALL.

Diablo Canyon Power Plant Page 6.3-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I 6.4 IRREVERSIBLE AND IRRETRIEVABLE RESOURCE COMMITMENTS NRC The environmental report shall discuss "Any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented." 10 CFR 51.45(b)(5) as adopted by 10 CFR 51.53(c)(2)

The continued operation of DCPP for the period of extended operation will result in irreversible and irretrievable resource commitments, including the following:

• Nuclear fuel, which is consumed in the reactor and converted to radioactive waste.

• The land required to store, or dispose of low-level radioactive wastes generated as a result of plant operations, and solid and sanitary wastes generated from normal industrial operations.

• PG&E's preferred approach for additional spent fuel storage is to either ship the spent fuel to a Federal waste repository or waste reprocessing facility.

In the Agency's 1990 Waste Confidence findings, the NRC previously assessed its degree of confidence that radioactive wastes produced by nuclear power plants could be safely disposed of, and made 5 findings (55 FR 38474, September 18, 1990). These 5 findings form the basis of the NRC's generic determination of no significant environmental impact from temporary storage of spent nuclear fuel. In 1999, the NRC confirmed these findings (64 FR 68005, December 6, 1999). In 2008, the NRC proposed updated Waste Confidence findings (FR 59551, dated October 9, 2008),

including findings that there is reasonable assurance a sufficient mined geologic repository can reasonably be expected to be available within 50-60 years beyond the licensed life for operation of any reactor to dispose of the commercial high-level waste and spent fuel. The NRC further concluded there is reasonable assurance that, if necessary, spent fuel generated in any reactor can be stored safely without significant environmental impacts for at least 60 years beyond the licensed life for operation (which may include the term of a revised or renewed license) of that reactor in a combination of storage in its spent fuel storage basin and either onsite or offsite independent spent fuel storage installations. In 2014, the NRC issued a final rule on the environmental effects of continued storageof spent nuclearfuel (73 FR 59551) and NUREG-2157, Generic Environmental Impact Statement (GElS) for Continued Storage of Spent NuclearFuel (Reference 2). The GElS concluded that impacts from continued storageof spent nuclearfuel for 60 years would be SMALL. The continued storage Diablo Canyon Power Plant Page 6.4-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I rule adopts the findings of the GElS regardingthe environmentalimpacts of storing spent fuel at any reactorsite after the reactor'slicensed period of operations. As a result, those generic impacts do not need to be re-analyzed in the environmentalreviews for individuallicenses.

Elemental materials that will become radioactive.

Materials used for the normal industrial operations of the plant that cannot be recovered or recycled or that are consumed or reduced to unrecoverable forms.

PG&E has not identified any activities during the license renewal term that would irreversibly or irretrievably commit additional resources beyond those committed during the construction and operation of DCPP during the initial operating license terms, and the preemption of land and consumption of materials such as those discussed above. Consistent with conclusions of the AEC with regard to operations in the current license terms (Reference 1), PG&E concludes that these resource commitments are appropriate for the benefits gained by license renewal and extended DCPP operation.

Diablo Canyon Power Plant Page 6.4-2 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I

6.6 REFERENCES

1. Final Environmental Statement related to the Nuclear Generating Station Diablo Canyon Units 1 and 2, Docket Numbers 50-275 and 50-323, Pacific Gas and Electric Company. U.S. Atomic Energy Commission. 1973.

2. Generic EnvironmentalImDact Statement (GEIS) for Continued Stora-/e of Spent Nuclear Fuel, NUREG-2157. NuclearRegulatory Commission.

September 2014.

Diablo Canyon Power Plant Page 6.6-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDEMENT 1 TABLE 6-1 Sheet 1 of 5 CATEGORY 2 ENVIRONMENTAL IMPACTS RELATED TO LICENSE RENEWAL AT DCPP 1996 Revised Issue Environmental Impact GElS GElS No. No. g :

13 17 Water use conflicts NONE. This issue does not apply (plants with cooling because DCPP does not use ponds or cooling towers cooling ponds or cooling towers that using make-up water withdraw makeup water from a small from a small river with river with no flow.

25 36 Entrainment of fish and SMALL. PG&E has a current shellfish in early life NPDES permit which constitutes stages (for plants with compliance with CWA Section once-through and 316(b) requirements.

cooling pond heat dissipations systems) 26 36 Impingement of fish and SMALL. PG&E has a current shellfish in early life NPDES permit which constitutes stages (for plants with compliance with CWA Section once-through and 316(b) requirements.

cooling pond heat dissipations systems) 27 39 Heat shock (for plants SMALL. PG&E has a current with once-through and NPDES permit which constitutes cooling pond heat compliance with CWA Section 33 22 Groundwater use SMALL. DCPP does not withdraw conflicts (potable, groundwater at an average rate service water, and greater than 100 gpm.

dewatering; plants that use >100 gpm) 34 23 Groundwater use NONE. This issue does not apply conflicts (plants using because DCPP does not use cooling towers cooling towers that withdraw withdrawing makeup makeup water from a small river.

water from a small river) 35 22 Groundwater use NONE. This issue does not apply conflicts (Ranney wells) because DCPP no longer uses Ranney wells.

APPENDIX E ENVIRONMENTAL REPORT AMENDEMENT 1 TABLE 6-1 Sheet 2 of 5 1996 Revised Issue Environmental Impact GElS GElS No. No.

39 26 Groundwater quality NONE. This issue does not apply degradation (cooing because DCPP is not located at an ponds at inland sites) inland site and does not use cooling ponds.

None 27 Radionuclides released SMALL. Groundwatermonitoring at to groundwater DCPPwas initiatedin 2003 through the REMP. The potentialfor the communication of contaminated waters originatingat the DCPPsite with domestic water supplies regulated,owned, managed,or certified by State and Local Rovernmental bodies does not exist.

40 28 Refurbishment impact N

• ,ONE. N im t xpect.d teEffects on terrestrial because PG&E has no p!ans to resources (non-cooling undtaW

• ,efUr-ish*mo*nt bocauso o.

system impacts) lonso ronowal.

SMALL. PG&E has no plans for refurbishmentor other license renewal-relatedconstruction activitiesat DCPP.DCPP operationshave had a small impact on terrestrialecosystems.

The impacts to terrestrial ecosystems from continued plant operationsand maintenance are expected to be unchanged.

Environmenta Jutk.U None 67 Minority and low-income SMALL. The impacts of the population extended operation of DCPPwere determined to be SMALL for all issues. No disproportionatelyhigh and adverse human health or environmentaleffects on low-income or minority populationswould result from license renewal.

49 50 Threatened or SMALL. No-effeets-The impacts on endangered species any state or federally-listed or other special status plant or animal species, including designated critical habitat, are anticipated to be SMALL

APPENDIX E ENVIRONMENTAL REPORT AMENDEMENT 1 TABLE 6-1 Sheet 3 of 5 1996 Revised Issue Environmental Impact GElS GElS No. No.

as a result of extending the operating license. PG&E does not plan to alter current operations over the license renewal eriod.

50 5 Air quality during NONE. No impacts are expected refurbishment (non- because PG&E will not undertake attainment and refurbishment because of license maintenance areas) renewal.

57 60 Microbiological NONE. This issue does not apply organisms (plants using because DCPP does not use lakes or canals, or cooling ponds, lakes, canals, or cooling towers or cooling small rivers.

ponds that discharge to a small river) 59 64 Electromagnetic fields, SMALL. The largest modeled acute effects induced current under the DCPP lines is less than the 5-mA limit.

Therefore, the DCPP transmission lines conform to the National Electrical Safety Code provisions for preventing electric shock from induced current.

63 53 Housing impacts SMALL. For the purpose of license renewal, PG&E does not plan on any refurbishment and does not plan to add employees. Therefore, there will be no increased demand on housing because of license renewal.

65 54 Public services: public SMALL. For the purpose of license utilities renewal, PG&E does not plan on any refurbishment and does not plan to add employees. Therefore, there will be no increased demand on public utilities because of license renewal.

66 54 Public services: NONE. No impacts are expected education because PG&E will not undertake (refurbishment) refurbishment because of license renewal.

68 2 Offsite land use NONE. No impacts are expected (refurbishment) because PG&E will not undertake

APPENDIX E ENVIRONMENTAL REPORT AMENDEMENT 1 TABLE 6-1 Sheet 4 of 5 1996 Revised Issue Environmental Impact GElS GElS No. No.

refurbishment because of license renewal.

69 2 Offsite land use (license SMALL. Although taxes paid by the renewal term) plant constitute a large fraction of the county revenue, the county has not shown significant offsite land use change since DCPP construction. No plant-induced changes to offsite land use are expected from license renewal.

Therefore, continued operation is expected to have positive impacts.

70 56 Public services: SMALL. For the purpose of license transportation renewal, PG&E does not plan on any refurbishment and does not plan to add employees. Therefore, there will be no increased demand on local transportation because of license renewal.

71 51 Historic and SMALL. PG&E does not plan on archaeological any refurbishment or transmission-resources line corridor changes because of license renewal. Continued plant site operations are not expected to im act cultural resources.

76 66 Severe accidents SMALL. The benefit/cost analysis did not identify any cost-effective aging-related severe accident mitigation alternatives.

APPENDIX E ENVIRONMENTAL REPORT AMENDEMENT 1 TABLE 6-1 Sheet 5 of 5 1996 Revised Issue Environmental Impact GElS GElS No. No.

N/A 73 Cumulative Impacts SMALL. Evaluations of the groundwater,air,threatenedor endangeredspecies, critical habitats,cultural resources, socioeconomics, and radiological doses concluded that all impacts from DCPPare SMALL. DCPP operationswill not change during the license renewal term.

Radiologicaldoses are limited by regulation. Threatenedor endangeredspecies and cultural resources are protected by state and federal regulations. The County of San Luis Obispo expects growth during the license renewal term and is planning for growth. However, no development would occur within the approximately 12,000 acres of land adjoiningthe DCPP,such that no cumulative impacts to these resourceswould occur.

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I CHAPTER 9 - STATUS OF COMPLIANCE 9.1 PROPOSED ACTION NRC "The environmental report shall list all Federal permits, licenses, approvals and other entitlements which must be obtained in connection with the proposed action and shall describe the status of compliance with applicable environmental quality standards and requirements including, but not limited to, applicable zoning and land-use regulations, and thermal and other water pollution limitations or requirements which have been imposed by Federal, State, regional, and local agencies having responsibility for environmental protection..." 10 CFR 51.45(d) as adopted by 10 CFR 51.53(c)(2) 9.1.1 GENERAL Table 9-1 lists environmental authorizations that PG&E has obtained for current DCPP operations. In this context, PG&E uses "authorizations" to include any permits, licenses, approvals, or other entitlements. PG&E expects to continue renewing these authorizations during the current license period. PG&E is in compliance with applicable environmental standards and requirements.

Table 9-2 lists additional environmental authorizations and consultations related to NRC renewal of the DCPP licenses to operate. As indicated, PG&E anticipates needing relatively few such authorizations and consultations. Sections 9.1.2 through 9.1.5 discuss some of these items in more detail.

9.1.2 THREATENED OR ENDANGERED SPECIES Section 7 of the Endangered Species Act (16 USC 1536) requires federal agencies to ensure that agency action is not likely to jeopardize any species that is listed or proposed for listing as threatened or endangered. If review of the proposed action indicates the potential for adversely affecting listed or candidate species, the federal agency must consult with the U.S. Fish and Wildlife Service (USFWS) regarding effects on non-marine species, the National Marine Fisheries Service (NMFS) for marine species, or both. USFWS and NMFS have issued joint procedural regulations at 50 CFR 402, Subpart B, that address consultation, and USFWS maintains the joint list of threatened and endangered species at 50 CFR 17.

Although not required by federal law or NRC regulation, PG&E has chosen to invite comment from federal and state agencies regarding potential effects that DCPP license renewal might have. Attachment C includes copies of PG&E correspondence with Diablo Canyon Power Plant Page 9-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I USFWS, NMFS, California Department of Fish and WildlifeGame (CDF&GW), State Lands Commission (CSLC), and Bureau of Land Management (BLM).

9.1.3 HISTORIC PRESERVATION Section 106 of the National Historic Preservation Act (16 USC 470f) requires federal agencies having the authority to license any undertaking to, prior to issuing the license, take into account the effect of the undertaking on historic properties and to afford the Advisory Council on Historic Preservation an opportunity to comment on the undertaking. Although not r.qu.*,d of an applicant by federal law or NRC regulation-,

PG&E has Ghesen-to-invited comment by the California SHPO. Attachment D includes a copy of PG&E correspondence with the SHPO regarding potential effects that DCPP license renewal might have on cultural resources. The SHPO requested that DCPP develop a Programmatic Agreement and Historic Resources Management Plan to replace the current Archaeological Resources Management Plan.

9.1.4 COASTAL ZONE MANAGEMENT PROGRAM COMPLIANCE The federal Coastal Zone Management Act (16 USC 1451 et seq.) imposes requirements on applicants for a federal license to conduct an activity that could affect a state's coastal zone. The Act requires the applicant to certify to the licensing agency that the proposed activity would be consistent with the state's federally approved coastal zone management program [16 USC 1456(c)(3)(A)]. The National Oceanic and Atmospheric Administration has promulgated implementing regulations that indicate that the requirement is applicable to renewal of federal licenses for activities not previously reviewed by the state [15 CFR 930.51(b)(1)]. The regulation requires that the license applicant provide its certification to the federal licensing agency and a copy to the applicable state agency [15 CFR 930.57(a)].

California has a coastal zone management program and DCPP, located in San Luis Obispo County, is within the California coastal zone. Therefore, concurrence from the California Coastal Commission (CCC) is necessary. The original certification prepared by PG&E is in Attachment E. PG&E is awaiting concurrence of the certification by the GGC The response from the CCC, dated December 29, 2009, is also provided in Attachment E.

9.1.5 WATER QUALITY (401) COMPLIANCE Federal Clean Water Act (CWA) Section 401 requires an applicant for a federal license to conduct an activity that might result in a discharge into navigable waters to provide the licensing agency a certification from the state that the discharge will comply with applicable Clean Water Act requirements (33 USC 1341). NRC has indicated in its Generic Environmental Impact Statement for License Renewal (GELS) (Reference 1) that issuance of a National Pollutant Discharge Elimination System (NPDES) permit ampies is consideredcertification by the state.

Diablo Canyon Power Plant Page 9-2 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I Consistent with the GELS, PG&E is providing DCPP's NPDES permit, in Attachment B, as evidence of state water quality (401) certification. As discussed in Section 4.2, the Central Coast Regional Water Quality Control Board (CCRWQCB) issued a NPDES Permit (CA0003751) to PG&E in 1990. The permit was due to expire in 1995 and has since been in administrative extension. PG&E is aGtiVeycontinuing to working with the CCRWQCB and the SWRCB to renew this permit. In accordance with permit requirements, PG&E monitors discharge characteristics and reports the results to the CCRWQCB.

Diablo Canyon Power Plant Page 9-3 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 TABLE 9-1 Page 1 of 6 ENVIRONMENTAL AUTHORIZATIONS FOR CURRENT DCPP OPERATIONS Issue or Agency Authority Requirement Number Expiration Date' Activity Covered U.S. Nuclear Atomic Energy Act License to Operate DPR Unit 1 Issued 11/02/1984 Operation of Units 1 Regulatory (42 USC 2011, et Expires 11/02/2024 and 2 Commission seq.), 10 CFR DPR Unit 2 Issued 11/26/1985 50.10 Expires 08/26/2025 Central Coast Clean Water Act California Pollutant CA0003751 Issued 05/11/1990 Plant discharges to Regional Water (33 USC 1251 et Discharge Expired 07/01/1995 the Pacific Ocean Quality Control seq.) Elimination System (in administrative Board Permit extension)

State Water State of California State General 97-03-DWQ Renewed Annually Storm water Resources Control IndustrialStorm dischargesto Board Water Discharge Diablo Creek and the Pacific Ocean State Lands Public Resources Lease 2231-10-0044 Issued 08/28/1969 Lease for Commission Code 4307.91 Expires 08/28/2018 Breakwaters State Lands Public Resources Right-of-Way 2231-10-0048 Issued 06/01/1970 Right-of-Way for Commission Code 4449.91 Expires 06/01/2019 Breakwaters Department of Bureau of Land Right-of-Way 2231-10-0041 Issued 08/22/1969 Right-of-Way for Interior Management Renewed 06/17/2014 Construction and Expires Maintenance of 0822/2018122/31/2042 Breakwaters California Ca H&S Code RCRA Equivalent CAD077966349 Issued 11/16/2006 Operation of Department of Section 25200, Waste Treatment Expires 07/30/2016 Hazardous Waste Toxic Substances CCR Title 22 Storage & Disposal Facility at DCPP Control Division 4.5. (TSDF) Permit 1 Issuance and expiration dates are accurate as of 08/30/2009.

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I TABLE 9-1 Page 2 of 6 ENVIRONMENTAL AUTHORIZATIONS FOR CURRENT DCPP OPERATIONS Issue or Agency Authority Requirement Number Expiration Date' Activity Covered San Luis Obispo 40 CFR 112 (et. Permit to Operate 0301 PR0002823 Issued Operationof County seq.) (UST) 01/01/2014 undergroundand Environmental 0728 PR0002022 aboveground Health Department CA H&S Code (HM) Expired petroleum storage 1126 PR0002512 12/31/2014 tanks, hazardous 19 CCR (et. seq.) (HW9 materials handling, 22 CCR (et. seq.) 1201 PR0015253 hazardous waste 23 CCR (et. seq.) (AST) generation, SPCC Plan San Luis Obispo NIACA H&S Code WndeFgFOWnd 40 000 1:760*1 06 Issued Opcrntion of Diesel County StOFage Tank~ 01/01/12092014 StG~age Environmental 19 CCR (et. seq.) Ope~ating-Perm it 40 000 17604 002 TanksEmergency Health Department 22 CCR (et. seq.) & Haza~dews -0726 PR0001853 Expires OperationsFacility 23 CCR (et. seq.) Materia!c Handler (HM) 12/31/20092014 (EOF)

Awthe~iZatiGWO operate Hazardous materials handling, and operation of above ground petroleum storage tank National Marine Endangered Biological Opinion Issued 09/18/2008 Possession and Fisheries Service Species Act of and Incidental Expires 08/26/2025 disposition of 1973 (16 USC Take Statement impinged or 1531-1544) stranded sea turtles San-Luis-ObispG- G*ean AiF At (-42 PeFrmit to Operatc 919-s I*ssud 07/21200I Qperatien of the Geunty~ USC 7-01, et sog.) Exp-ire 06/302Q01 Emorgoncy Dicese Gencrntorc (DCPP)

Diet~iit

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I TABLE 9-1 Page 3 of 6 ENVIRONMENTAL AUTHORIZATIONS FOR CURRENT DCPP OPERATIONS Issue or Agency Authority Requirement Number Expiration Date' Activity Covered San Luis Obispe Gean AiF AG, 42 issued Gpwat"9A-the Gounty-A USC 7401, et seq.) Permit to Operate 88641 0413012009 Emergency Diesel Polutiont Cntro GereFat9r (EOF) 0313112040 San Luis Obispo Clean AiF Aot-(2 Permit to Operate 49-1 Issued 0712112009 Operation of the County Air USGCFR 7401, et 07/15/2014 DCPP Auxiliary Pollution Control seq4. Boiler District Expires 06/30/2010 06/30/2015 San Lus Gbispe Permit to Operate 6332- Issued 07/21/2009 Gpesstien-e9h GeuntyL~ USG 7401Tet-* EXPire 06/30/2010 Abrzicive Blast Po!Iution Control seq+ FaG4iliy Diet~iot 47- GR et seq.

San Luis Obispo Glean AFAot-( Permit to Operate 338-1 Issued Operation of a County Air 42 USGCFR 7401, 0712- 200007/15/2014 DCPP Paint Spray Pollution Control et seq4. Expires Booth District 06/30/20402015 17 CCR et seq.

San Luis Obispo Clean AiF A Permit to Operate Issued 08/22/2007 Operation of DCPP County Air 42 USGCFR 7401, 41543 07/15/2014 Portable Sandblast Pollution Control et seq.-.4 Equipmenteviees District Expires 17 CCR et seq. 061301204-02015

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 TABLE 9-1 Page 4 of 6 ENVIRONMENTAL AUTHORIZATIONS FOR CURRENT DCPP OPERATIONS Issue or Agency Authority Requirement Number Expiration Date1 Activity Covered San Luis Obispo Permit to Operate 533-2 Issued Operation of the County Air 42 CFR 7401, et 06/12/2013 DCPPAbrasive Pollution Control seq. Blast Facility District Expires 17 CCR et seq. 06/30/2014 San Luis Obispo Glean#4,iF A(42 Permit to Operate Issued 981W2909 Operation of a County Air USCFR 7401, et 546-42 07-021201307/25/2014 DCPP non-retail Pollution Control seq.-). gasoline dispensing District Expires facility 17 CCR 94010, 07314204!006/30/2015

^ A ^.#.I San Luis Obispo 42 CFR 7401, et Issued Operationof the County Air seq. Permit to Operate 886-2 06/11/2014 EOF stationary Pollution Control Expires Emergency Diesel District 17 CCR 93115 03/31/2015 Generator San Luis Obispo 42 CFR 7401, et. Permit to Operate 919-3 Issued Operationof the County Air seq. 0715/2014 DCPPstationary Pollution Control Expires Emergency Diesel District 17 CCR 931115 06/30/2015 Generators San Luis Obispo Permit to Operate Issued 0712412009 Operation of a County Air USGCFR 7401, et 1065-56 07/15/2014 DCPP t-ansportable Pollution Control seq4.). diesel-fueled District Expires internal combustion 17 CCR 93115 06/30/204-02015 ut engines 17 CCR 93116

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 TABLE 9-1 Page 5 of 6 ENVIRONMENTAL AUTHORIZATIONS FOR CURRENT DCPP OPERATIONS Issue or Agency Authority Requirement Number Expiration Date' Activity Covered San Luis Obispo 42 CFR 7401, et. Permit to Operate 1820-1 Issued Operation of JIC County Air seq. 06/11/2014 stationary Pollution Control Expires emergency diesel District 17 CCR 93115 03/31/2015 generator San Luis Obispo 42 CFR 7401, et. Permit to Operate 1845-1 Issued Operationof DCPP County Air seq. 06/1212013 emergency portable Pollution Control diesel-fueled District 17 CCR 93115 Expires internalcombustion 17 CCR 93116 06/30/2014 engines San Luis Obispo 42 CFR 7401, et. Permit to Operate 1944-1 Issued Operation of DCPP County Air seq. 09/09/2014 emergency portable Pollution Control diesel-fueled District 17 CCR 93115 Expires internalcombustion 17 CCR 93116 06/30/2015 engines San Luis Obispo 42 CFR 7401, et Issued Operationof the County Air seq. Permit to Operate 1946-1 09/0212014 Kendall Road Pollution Control Expires Campus District 17 CCR 93115 08/31/2015 Emergency Diesel Generator San Luis Obispo Safe Drinking Non-Community PT 0004769 N/A Authorization to County Public Water Act (42 USC Drinking Water operate non-Health Department 300 F, et seq.) System Permit community drinking and domestic water system

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 TABLE 9-1 Page 6 of 6 ENVIRONMENTAL AUTHORIZATIONS FOR CURRENT DCPP OPERATIONS Issue or Agency Authority Requirement Number Expiration Date1 Activity Covered PeFt San Luise N/A Lease Agreement 2232-1-1-0044- issued 07-/01/1 986 For aoce6e ad HarborDitrc 2232 11 0037 Expires 06A30/120114 enlaFgement and 2232 44 0038 teGate s,!en California California License 710027-01 Issued 04/23/2009 Surface Canopy Secretary of Department of Fish Expireds Kelp Harvesting Resources and GameWildlife 12/31/20092013, pending renewal on necessity California California Special Use Permit 710006-02 Issued 12/31/1999 Removal of Benthic Secretary of Department of Fish Does not expire Kelp from the Resources and Game Wildlife DCPP Intake Cove Exclusion Zone

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I TABLE 9-2 ENVIRONMENTAL AUTHORIZATIONS FOR DCPP LICENSE RENEWAL Agency Authority Requirement Remarks U.S. Nuclear Reaulatorv Atomic Enerav Act (42 USC 2011 License Renewal Environmental Report submitted in support of Commission et seq.) license renewal application.

U.S. Fish and Wildlife Endangered Species Act Section Consultation Requires federal agency issuing a license to Service (USFWS) 7 (16 USC 1536) consult with USFWS (Attachment C).

California Central Coast Clean Water Act Section 401 (33 Certification State issuance of NPDES permit (Section 9.1.5)

Regional Water Quality USC 13411) constitutes 401 certification (Attachment B)

Control Board California Coastal Federal Coastal Zone Certification Requires applicant to pFeveobtain Coastal Commission Management Act (16 USC 1452 et Development Permitand certification te-Federal seq.) ... I .... ing thcthat license renewal would be consistent with the Federally approved State Coastal Zone Management program.

Based on it. e...... of the p.. pI sed amtivity, the appic,,nt', ,,,tific.,tin (Attachment E).

California State Office of National Historic Preservation Act Consultation Requires federal agency issuing a license to Historic Preservation Section 106 (16 USC 470f consider impacts to historical properties and consult with State Historic Preservation Officer (SHPO).

SHPO must concur that license renewal will not affect any sites listed or eligible for listing (Attachment D).

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I ATTACHMENT A - NRC NEPA ISSUES FOR LICENSE RENEWAL OF NUCLEAR POWER PLANTS PG&E has prepared this environmental report in accordance with the requirements of NRC regulation 10 CFR 51.53. NRC included in the regulation a list of National Environmental Policy Act (NEPA) issues for license renewal of nuclear power plants.

Table A-1 lists these 92 issues and identifies the section in which PG&E addressed each applicable issue in this environmental report. For organization and clarity, PG&E has assigned a number to each issue and uses the issue numbers throughout the environmental report.

As discussed in Section 4.02, on June 20, 2013, the NRC published a final rule (78 FR 37282) revising its environmentalprotection regulation, 10 CFR 51, and the associated GELS. The final rule identified 78 environmental impact issues, of which 19 require plant-specific analysis. The final rule consolidatedsimilar Category I and 2 issues, changed some Category 2 issues into Category I issues, and consolidatedsome of those issues with existing Category I issues. The final rule also addednine new Category I and 2 issues.

In the same manner as was done for the 92 issued identified in the 1996 GELS, PG&E has assigneda number to each of the 78 issues. The issue numbers mentioned in Table A-2 below are based on those numbers. Only the nine new Category I and Category 2 issues are named in Table A-2. For each applicable issue, Table A-2 identifies the sections in this environmental report and in the revised GElS hat address the issue Diablo Canyon Power Plant Page A-1 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I TABLE A-2 DCPPENVIRONMENTAL REPORT CROSS-REFERENCE OF NEW LICENSE RENEWAL NEPA ISSUES IDENTIFIEDIN THE REVISED GElS Section of this Environmental Revised GElS Issue' Cate o Re ort Section/Pa e"

8. Geology and Soils 1 2.13 and 4.02 4.4/4-29

27. Radionuclidesreleased to 2 4.02 4.5.1.214-51 groundwater

28. Effects on terrestrialresources 2 4.02 4.6.1.1/4-59 (non-cooling system impacts)

29. Exposure of terrestrial 1 4.02 4.6.1.1/4-61 resourcesto radionuclides

44. Exposure of aquaticresources 1 4.02 4.6.1.2/4-105 to radionuclides

59. Human health impact from 1 4.02 4.9.1.1.2/4-147 chemicals

63. Physicaloccupationalhazards 1 4.02 4.9.1.1.5/4-156

67. Minority and low-income 2 2.6.2 and 4.02 4.10.1/4-167 populations

73. Cumulative impacts 2 4.02 4.13/4-243

a. Source: 10 CFR 51, SubpartA, Appendix A, Table B-1. (Issue numbers added to facilitatediscussion.)

b. Source: Generic Environmental Impact Statement for License Renewal of NuclearPlants (NUREG-1437, Revision 1).

Diablo Canyon Power Plant License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 ATTACHMENT E - COASTAL ZONE CONSISTENCY CERTIFICATION This is the Diablo Canyon Power Plant (DCPP) certification to the U.S. Nuclear Regulatory Commission (NRC) that the renewal of the DCPP Units 1 and 2 Operating Licenses will be consistent with enforceable policies of the federally approved state coastal zone management program. The certification describes the proposed action (i.e. license renewal), DCPP background, anticipated environmental impacts, California Coastal Management Program (CCMP) policies, and DCPP compliance status.

This original Certification ha .notyet beenwas submitted to the California Coastal Commission for review in 2009. The response from the CCC, dated December 29, 2009, is also provided in this Attachment (PageE-51).

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I STATE OF CALIFORNIA-NATURAL RESOURCES AGENCY ARNOLD SCHWARZENEGOER, GOVERNOR CALIFORNIA COASTAL COMMISSION 45 FREMONT, SUITE 2000 SAN FRANCISCO, CA 94105-2219 VOICE (415) 904-5200 FAX (415) 904- 5400 1m0 (415) 597-5985 December 29, 2009 Mr. James Becker Pacific Gas & Electric Company Diablo Canyon Power Plant Mail Code 104/6/601 P.O. Box 3 Avila Beach, CA 93424 RE: Consistency Certification for Pacific Gas & Electric Company's Requested Nuclear Regulatory Commission License Renewal for Diablo Canyon Power Plant, San Luis Obispo County

Dear Mr. Becker:

Thank you for your submittal of the above-referenced consistency certification for the Diablo Canyon nuclear power plant license renewal that you are seeking from the Nuclear Regulatory Commission. The California Coastal Commission (Commission) received your consistency certification here in our headquarters office on December 1, 2009.

Our review shows the certification is not yet complete, for the reasons provided below.

Accordingly, the Commission's six-month review period under the Coastal Zone Management Act (CZMA), see 16 U.S.C. §§ 1456(c)(3)(A), has not commenced and will not commence until we receive the missing necessary data and information, pursuant to CZMA implementing regulations. 15 C.F.R. § 930.60(a). Additionally, as we discussed at our December 17, 2009 meeting, the project will require a coastal development permit (CDP) from the Commission.

Because the Commission's CDP review and approval would also be sufficient for purposes of confirming the project's consistency with the California Coastal Management Program (CCMP),

and thus establishing the Commission's concurrence with your federal consistency certification, we recommend you submit a CDP application instead of completing the consistency certification. This will allow for a single and more efficient review process.

Nonetheless, pursuant to requirements of the CZMA, we have identified below the information that would be needed to complete the consistency certification. Please note that much of the requested information will also need to be submitted as part of PG&E's permit application. We are happy to assist and answer any questions you may have about the needed information and the review process.

REQUIRED ADDITIONAL INFORMATION AND ANALYSES As we discussed at the December 17, 2009 meeting, the Commission did not receive some of the necessary data and information as described in the CZMA implementing regulation at 15 C.F.R.

section 9 4 0.58(a), and, accordingly, we will need several additional informational items to allow Diablo Canyon Power Plant Page E-51 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 Review of Consistency Certificationfor PG&E Diablo Canyon NRC License Renewal December 29, 2009 Page 2 of 5 us to adequately evaluate this proposal and to complete consistency review.' These include two general elements that apply to several sections of the consistency certification as well as a number of specific information needs.

General Information Requests and Additional Analyses Applying the CCMP definition of "development": The certification states in several sections 2

that "[L]icense renewal is not a new development, but a continuation of existing development."

Several other sections state that a particular CCMP policy is not applicable to the requested license renewal because the renewal does not include development that would be subject to those policies.' However, it appears that in reaching these conclusions, the certification did not fully apply the CCMP's definition of "development",' resulting in the need for some of the additional information and analyses identified herein as necessary to complete the certification.

The CZMA regulations at Section 930.58 state: "Necessary dataand information. (a) The applicantshallffurnish the State agency with necessary data and information along with the consistency certification.Such information and data shall include thefollowing: (I) A detailed descriptionof the proposedactivity, its associatedfacilities, the coastal effects, and comprehensive data and information sufficient to supportthe applicant'sconsistency certification. Maps, diagrams, technicaldata and other relevant material shall be submitted when a written description alone will not adequately describe the proposal (a copy of thefederal applicationand all supporting materialprovided to the Federalagency should also be submitted to the State agency); ... and (3) An evaluation that includes a set offindings relatingthe coastal effects of the proposaland its associatedfacilities to the relevant enfbrceable policies of the managementprogram.Applicants shall demonstrate that the activity will be consistent with the enforceablepolicies of the managementprogram.Applicants shall demonstrate adequateconsideration of policies which are in the nature ofrecommendations.Applicants need not make findings with respect to coastal effects for which the managementprogram does not contain enforceable or recommendedpolicies."

The CZMA regulations also authorize the Commission to not start the review period if it has not received all the necessary data and information to analyze the proposed activity for consistency with the enforceable policies of the California Coastal Management Program (CCMP). Specifically, Section 930.60 of those regulations provides:

"Commencement ofState agency review. (a) Except as provided in §930.54(e) andparagraph(a)(1) of this section, State agency review of an applicant'sconsistency certification begins at the time the State agency receives a copy of the consistency certification,and the information and data requiredpursuant to §930.58. (1) If an applicantfails to submit a consistency certification in accordancewith §930.57, orfails to submit necessary data and information requiredpursuantto §930.58, the Slate agency shall, within 30 days of receipt of the incomplete information, notify the applicantand the Federalagency of the missing certification or Information, andthat: (i) The State agency's review has not yet begun, and that its review will commence once the necessarycertification or information deficiencies have been corrected; or (i) The State agency'sreview has begun, and that the certification or information deficiencies must be cured by the applicant during the State's review period 2 Including, for example, Sections 30200, 30212, 30251, 30252, and 30253.

3 'lese include Sections 30234.5, 30253, and 30260.

' The CCMP's Section 30106 states, in relevant part: "'Development' means, on land, in or under water, the placement or erection of any solid materialor structure; dischargeor disposal of any dredged material or of any gaseous, liquid, solid, or thermal waste; grading,removing, dredging, mining, or extraction of any materials; change in the density or intensity of use of land, including,but not limited to, subdivisionpursuantto the Subdivision Map Act (commencing with Section 66410 of the Government Code), and any other division of land, including lot splits, except where the land division is brought about in connection with the purchase of such land by a public agencyforpublicrecreationaluse; change in the intensity ofuse of water, or of access thereto; construction, reconstruction,demolition, or alteration of the size of any structure, including anyfacility of any private,public, or municipal utility..."

Diablo Canyon Power Plant Page E-52 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT I Review of Consistency Certificationfor PG&EDiablo Canyon NRC License Renewal December 29, 2009 Page 3 of 5 The certification does not describe several forms of development that are part of the requested license renewal. The renewal would include new development in the form of "change in the intensity of use of water, or of access thereto", as it would result in twenty years of ocean water use for cooling purposes that would otherwise not occur. License renewal would also result in twenty years of restricted access to nearby ocean waters that would otherwise end or be phased out. Additionally, some of the studies PG&E is conducting to implement license renewal may result in other forms of development that would need to be evaluated for consistency with the CCMP. For example, studies needed to update the site's and facility's seismic characteristics may result in the need for license renewal to include modifying foundations, adding support structures, grading slopes, etc. - any of which would constitute "development" and require coastal development permit approval from either the Coastal Commission or San Luis Obispo County. Further, extending the life of the facility is likely to require an expansion of the Independent Spent Fuel Storage Installation (ISFSI), which was designed to hold spent fuel only until the end of the current licensed operations. Please therefore revise the relevant sections of the certification and needed analyses to incorporate the full CCMP definition of "development".

Please also identify any project-related development known or anticipated to result from the studies being implemented as part of PG&E's license renewal.

The consistency certification includes several statements of consistency without supporting analyses or documentation: Several sections of the certification state that the proposed project is consistent with an applicable CCMP provision but provide little or none of the necessary documentation or analyses to support that statement. For example, the certification's review of conformity to Section 30220 states only that "License renewal is consistent with Section 30220 of the Coastal Act requiring the protection of water-oriented recreational activities because it will not interfere with the recreational water activities at the adjacent San Luis Obispo Harbor District and nearby Avila Beach community." It does not analyze the additional twenty years of restricted access mentioned above or the effects of that restricted access on water-oriented recreational activities in the area around Diablo Canyon.' Therefore, pursuant to Section 930.58(a) of the CZMA regulations, please provide the comprehensive information and analyses necessary to support PG&E's consistency certification and its conclusions.

Specific Comments [Note: Page references are from PG&E's November 2009 DiabloCanyon Power PlantFederalConsistency Certificationfor FederalPermits and License Applications and License Renewal Application, Attachment E-1.]

• Filing fee: The Commission's filing fees are enforceable policies of the CCMP and constitute necessary data and information.6 Fees for consistency review are determined in the same manner Other sections of the certification with similar assertions and inadequate analyses include Sections 30210, 30211, 30221, 30224, 30230, 30231, and 30251.

6 In March 2008, the Coastal Commission amended Title 14, California Code of Regulations, Section 13055 to authorize filing fee increases for federal consistency certifications pursuant to 16 U.S.C. Sections 1356(c)(3)(A) or (B). On April 24, 2008, the National Oceanic and Atmospheric Administration's Office of Ocean and Coastal Resource Management approved the revised fee schedule as a routine program change to California's CCMP. The filing fees constitute necessary 93 data and information within the meaning of 15 CFR Sections 0.58(a) and 930:76(a)(3).

Diablo Canyon Power Plant Page E-53 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 Review of Consistency Certificationfor PG&E Diablo Canyon NRC License Renewal December 29, 2009 Page 4 of 5 as for coastal development permit applications. eased on your project description, please provide the fee based on project costs as described in the attached Coastal Commission Filing Fee Schedule, Section 13055(a)(5)(B).

" p. E-12, Table E-2, EnvironmentalAuthorizationsfor DCPPLicense Renewal: Please note that the requirement for a CDP is an additional authorization to be added to this table.

" pp. E-15-22, Table 3: Please note that CCMP review is likely to require more specific and detailed review than was conducted under the General EIS described in this table.

• p. E-28, CCMP Section 30200: As noted above, this section does not fully evaluate project-related development as defined by the CCMP. This section may need additional information for completeness, based on subsequent submittals for other sections of this certification.

" pp. E-29-35, CCMP Sections 30210 - 30224 Public Access and Recreation: The certification states that the proposed license renewal does not constitute new development; however, as noted above, this is not a correct application of the CCMP's definition of development. The certification also identifies use limitations on nearby shorelines and ocean waters due to the project's security needs, but does not adequately analyze the effects of those use limitations on public access and recreation in those areas. Please provide a revised analysis of the project's effects on recreation and public access to the shoreline and nearby coastal waters due to an additional twenty years of project-related access limitations.

• pp. E-35-41, CCMP Sections 30230 - 30233 Marine Environment: The certification does not identify how the proposed project will "maintain, enhance, and, where feasible, restore the marine environment", or how it will result in special protection of nearby areas of special biological significance, as required pursuant to CCMP Section 30230. It also does not provide complete analyses from the various entrainment, impingement, and thermal effects studies done at Diablo Canyon and does not identify feasible mitigation measures to minimize the adverse effects of entrainment, as required pursuant to CCMP Section 30231. Please provide copies of these studies, including results of Empirical Transport Model studies, to document the necessary analyses.

" pp. E-40-41, CCMP Section 30235 Construction Altering Natural Shoreline: The certification states that no shoreline alterations are necessary. However, by extending plant operations until about 2045, license renewal would subject the facility to the effects of sea level rise (which could include direct effects on the facility's intake and outfall as well as indirect effects due to coastal erosion, landslides, or other similar geomorphic changes). Please provide analyses of whether predicted sea level changes would result in the need for shoreline alterations during the term of the proposed renewed license (see also Section 30253(1) below).

• p. E-46, CCM1P Section 30253(1) Minimize Risks to Life and Property in Areas of High Geologic, Flood, and Fire Hazard: Please provide all data and interpretive summaries, such as those conducted by PG&E and USGS under their CRADA agreement and the Long Term Seismic Program of PG&E, characterizing the seismicity and tectonic structure in the vicinity of the plant.

These data should include characterization of the Hosgri and Shoreline Faults, including fault geometry, seismicity, and sense of movement; estimates of maximum credible earthquake (from a deterministic perspective) on these and all other faults; the ground shaking expected at the site Diablo Canyon Power Plant Page E-54 License Renewal Application

APPENDIX E ENVIRONMENTAL REPORT AMENDMENT 1 Review of Consistency Certificationfor PG&E DiabloCanyon NRC License Renewal December 29, 2009 Page 5 of 5 from such earthquakes; and the deep crustal structure beneath the plant (in particular an evaluation of the "Namson model" of thrust ramps beneath the plant). Additionally, and as recommended by the Technical Advisory Team established pursuant to AB 1632,' please provide the three-dimensional seismic data should be collected and interpreted as part of this evaluation. Please confer with the Commission's staff geologist, Dr. Mark Johnsson, at 415-904-5200 for any necessary clarification.

p. E-47, CCMP Sections 30255 and 30260 - Priority of Coastal-Dependent Developments and Industrial Development: The certification does not evaluate the project's "coastal-dependent"'

status or, as required by these CCMP Sections. Coastal Commission staff will likely address this issue as part of PG&E's permit application, but you may wish to provide additional information about the "coastal-dependent" nature of the project.

CONCLUSION In conclusion, the Commission staff has determined PG&E's submittal does not contain the information necessary for a complete consistency certification. Therefore, pursuant to 15 C.F.R.

section 930.60(a), the six-month time period for this submittal has not begun and will not begin until the Commission staff receives the information discussed above. However, as noted previously, we recommend PG&E instead submit a complete CDP application in lieu of completing this consistency certification to allow one, rather than two, review processes. Please feel free to contact me at (415) 904-5248 if you have any questions.

Sincerely, Tom Luster Energy, Ocean Resources, and Federal Consistency Division Cc (via email): PG&E - Mr. Mark Krausse NRC - Kimberly Green CEC - Barbara Byron 7 Assembly Bill 1632 (2006) directs the California Energy Commission to assess the vulnerability of the state's operating nuclear power plants to a major disruption due to a major seismic event or plant aging, the potential impacts of such a disruption, potential impacts from the accumulation of nuclear waste at the state's existing nuclear plants, and other key policy and planning issues regarding the future role of California's existing nuclear plants.

8The CCMP, at Section 30101, defines a "coastal-dependent development or use" as "any development or use which requires a site on, or adjacent to, the sea to be able to function at all."

Diablo Canyon Power Plant Page E-55 License Renewal Application