DCL-24-116, Draft Supplemental Environmental Impact Statement Comment Letter
| ML24348A232 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/13/2024 |
| From: | Jones T Pacific Gas & Electric Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| DCL-24-116 | |
| Download: ML24348A232 (1) | |
Text
Pacific Gas and Electric Compa.ny"'
Thomas P. Jones Senior Director Diablo Canyon Power Plant P.O. Box 56 Regulatory, Environmental &
Avila Beach, CA 93424 PG&E Letter DCL-24-116 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Diablo Canyon Units 1 and 2 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Repurposing 805.459.4530 Tom.Jones@pge.com 10 CFR 54 Diablo Canyon Power Plant Draft Supplemental Environmental Impact Statement Comment Letter
Dear Commissioners and Staff:
On October 28, 2024, Pacific Gas and Electric Company (PG&E) received "Diablo Canyon Power Plant, Units 1 and 2 - Notice of Availability of Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 62, Regarding License Renewal of Diab/a Canyon Nuclear Power Plant, Units 1 and 2, Draft Report for Comment (NUREG-1437)" (DSEIS). PG&E has reviewed the DSEIS and has developed the following comments:
- 1. Section 3.5.1.3.1 (page 3-35, Line 24-25)
The 2020/2022 Integrated report 303(d) list for San Luis Obispo Creek includes benthic community effects, chloride, E.coli, nitrate, dissolved oxygen, sodium, and toxicity. The DSEIS included fecal coliform and urea and omitted dissolved oxygen.
- 2. Section 3.5.1.3.2 (page 3-36, Line 8)
While it is true that the Central Coast Regional Water Quality Control Board did not specify required changes to Diablo Canyon Power Plant's (DCPP's)
National Pollutant Discharge Elimination System (NPDES) permit during license renewal coordination prior to the May 2024 Responses to NRC Requests for Additional Information on the Diab/a Canyon Power Plant License Renewal Application Environmental Report, coordination regarding the NPDES permitting process is ongoing and specific NPDES requirements for DCPP may be refined based on the current California Ocean Plan (last revised in 2019) or other information considered during the permitting process.
- 3. Section 3.6.3.2 (page 3-57, Line 18)
The oak tree impact avoidance, minimization, and mitigation plan was developed for implementation during DCPP decommissioning.
A member of the STARS Alliance Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek
Document Control Desk Page 2
- 4. Section 3.7.5.1 (page 3-76, Line 28)
PG&E Letter DCL-24-116 On April 17, 2024, the State Water Resources Control Board (SWRCB) adopted revised interim mitigation payment calculations. The default cost is now $12.51 per million gallons of intake water and is subject to annual increases.
- 5. Section 3. 7.5.1 (page 3-76, Line 33)
The interim mitigation payment for DCPP for the operating period October 1, 2021, through September 30, 2022, was $4,826,784.58. PG&E anticipates receiving the next invoice soon for the period October 1, 2022, through September 30, 2023. PG&E will pay this invoice and subsequent invoices pursuant to the updated mitigation fee requirements that were adopted by the SWRCB on April 17, 2024.
- 6. Section 3.7.5.1 (page 3-77, Line 19)
The State of California once-through cooling (OTC) Policy expresses a preference for closed-cycle wet cooling systems as the selected best technology available (BTA) but allows for the Water Board to establish site-specific BTA requirements for nuclear power plants based on the results of special studies required under the Implementation Provisions (Section 3.D) of the OTC Policy. The SWRCB has determined, based on numerous studies, that there are no feasible alternatives to modify the DCPP OTC system, such as closed-cycle cooling, onshore mechanical intake fine mesh screening systems, or offshore modular wedge wire screens at DCPP. On April 17, 2024, the SWRCB updated the OTC mitigation fee amounts. PG&E is and will continue to demonstrate compliance with the OTC policy via payment of the interim mitigation fees through October 31, 2030, pursuant to California Senate Bill (SB) 846.
- 7. Section 3.8.1.1 (page 3-91, Table 3-11)
Monarch butterfly occur commonly throughout the California Central Coast region and are often observed flying south to north during the winter migration season. Overwintering roosting sites are protected in California, and it is correct that no overwintering roost sites are present at DCPP. However, monarchs are considered a "seasonal migrant" in the vicinity of DCPP and are known to pass through or over DCPP lands; individuals may temporarily roost or forage on DCPP lands in transit to Montana de Oro State Park or other overwintering roost sites. "Seasonal migrant" status should also be noted in Table 3-15 on page 3-119. Temporary stop-over roosts are typically only utilized less than one day, away from DCPP infrastructure, so the DSEIS effects analysis for this species remains accurate.
- 8. Section 3.8.1.1 (page 3-94, Line 24)
Terra Verde conducted additional surveys and prepared a California red-legged frog (CRLF) Survey Addendum in 2022 that has updated locations where CRLF were found, both in Diablo Creek and Tom's Pond. This should also be noted in Section 3.8.4.1.1 on page 3-120.
A member of the STARS Alliance Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek
Document Control Desk Page 3
- 9. Section 3.8.3-1 (page 3-117, Line 2)
PG&E Letter DCL-24-116 Figure 3-7 shows an old sanctuary boundary. In September 2024, the National Oceanic and Atmospheric Administration published the Final Environmental Impact Statement for the Chumash Heritage National Marine Sanctuary, which updated the preferred sanctuary boundary. The sanctuary was formally designated on November 30, 2024, and the adopted boundary does not include the DCPP intake or discharge sites.
10.Section 3.9.1.1 (page 3-142, Line 7)
Greenwood's excavation took place in 1968 and was reported in 1972.
11.Section 3.9.3 (page 3-151, Lines 7 and 11)
PG&E has one professional archaeologist dedicated to DCPP (including the Land Stewardship Team) and several others in the region.
12.Section 3.9.3 (page 3-151, Lines 11 -12)
Suggest editing the sentence for clarity "... provides recommendations for avoiding impacts to cultural resources and oversees implementation of protection measures."
- 13. Section 3.15-3 (page 3-205, Table 3-33)
Footnote "a" is not clear on the units of measure for the values in the table.
The footnote says greenhouse gas emissions are reported in metric tons and converted to short tons, so it seems to imply that N RC converted reported values to short tons. However, the values are those reported by PG&E in metric tons. The combustion sources values match those reported in the PG&E 2024-TN10032 (i.e., RCI GHG-2). The workforce commuting values are those reported by PG&E in the ER Table 3.3-11 using the calculation noted in footnote "c." It is suggested that the units of measure be identified in the table title or header and the footnote wording be clarified.
- 14. Section 3.15-3 (page 3-207, Table 3-34)
In Table 3-34, the value for the proposed action is 1,152 CO2eq tons/yr, the same value presented in Table 3-33 for combustion sources for 2023. The footnote for Table 3-33 implies that unit of measure is short tons; however, the values in Table 3-33 match those reported by PG&E as metric tons. It is suggested that units of measure be confirmed or revised as appropriate.
15.Section 3.16-1 (page 3-214, Line 20)
The DSEIS states "there remains enough storage in the existing independent spent fuel storage installation (ISFSI) to accommodate spent fuel generated during the license renewal (LR) period." To clarify, there remains enough storage capacity in the existing ISFSI and spent fuel pools to accommodate the spent fuel generated during the LR period.
A member of the STARS Alliance Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek
Document Control Desk Page4 16.Section G.2.3-1 (page G-11, Line 14)
PG&E Letter DCL-24-116 Suggested revision for clarity: "The SWRCB used the results of the studies to inform the decision to allow PG&E to continue operating DCPP through October 31, 2030, in accordance with California Senate Bill 846." The SWRCB did not use the results of these studies to inform its decision to require PG&E to cease operating DCPP by October 31, 2030. Instead, the SWRCB and SB 846 relied on previous studies and analyses and mitigation program (Resolution Number 2010-0020) to specify that the final compliance dates of the once-through policy for DCPP is October 31, 2030.
PG&E makes no new or revised regulatory commitments (as defined in NEI 99-04) in this letter.
If you have any questions or require additional information, please contact Mr. Trevor Rebel at (805) 441-5435 or by email at Trevor.Rebel@pge.com.
Sincerely, Thomas P. Jones Senior Director, Regulatory, Environmental & Repurposing Date cc:
Anthony Chu, California Department of Public Health Kimberly Conway, NRC Environmental Project Manager Mahdi 0. Hayes, NRC Senior Resident Inspector Delphine Hou, California Department of Water Resources John D. Monninger, NRC Region IV Administrator Diablo Distribution A
member of the STARS Alliance Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek