ML24056A002
| ML24056A002 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/27/2024 |
| From: | Kimberly Conway NRC/NMSS/DREFS/ELRB |
| To: | Gerfen P Pacific Gas & Electric Co |
| References | |
| EPID L-2023-LNE-0004 | |
| Download: ML24056A002 (26) | |
Text
Paula Gerfen Senior Vice President, Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Nuclear Power Plant P.O. Box 56 Mail Code 104/6 Avila Beach, CA 93424
SUBJECT:
DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 - LICENSE RENEWAL REGULATORY AUDIT REGARDING THE ENVIRONMENTAL REVIEW OF THE LICENSE RENEWAL APPLICATION (EPID NUMBER L-2023-LNE-0004
Dear Paula Gerfen:
By letter dated November 7, 2023 (Agencywide Documents Access and Management System Package ML23311A154), Pacific Gas and Electric Company (PG&E, the applicant) submitted to the U.S. Nuclear Regulatory Commission (NRC) an application for the renewal of Facility Operating License Nos. DPR-80 and DPR-82 for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon, DCPP) pursuant to Section 103 of the Atomic Energy Act of 1954, as amended, and part 54 of title 10 of the Code of Federal Regulations, Requirements for renewal of operating licenses for nuclear power plants.
The NRC staff has initiated its environmental review for the application. An environmental audit will be conducted remotely by NRC staff in March 2024: a virtual audit the week of March 18, 2024, and a site-visit the week of March 25, 2024. The environmental audit activities will be conducted in accordance with the enclosed Environmental Audit Plan (Enclosure 1). An environmental audit for the severe accident mitigation alternatives review will be conducted separately by the NRC staff at a later date.
To the extent possible, the NRC staff requests the information identified in the Environmental Audit Needs List (Enclosure 2) be made available on the DCPP online reference portal prior to the audit. A draft schedule of tours and meetings is provided in Enclosure 3.
February 27, 2024 P. Gerfen If you have any questions, please contact me via email at kimberly.conway@nrc.gov.
Sincerely, Kimberly Conway Environmental Project Manager Environmental Project Management Branch 1 Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards Docket Nos. 50-275 and 50-323
Enclosures:
As stated cc w/encls: Listserv Signed by Conway, Kimberly on 02/27/24
ML24056A002 OFFICE PM:REFS/EPMB1 LA:REFS/EPMB2 BC:REFS/EPMB1 PM:REFS/EPMB1 NAME KConway AWalker-Smith SKoenick KConway DATE 2/26/2024 2/26/2024 2/26/2024 2/27/2024
Audit Plan
License Renewal Environmental Review Diablo Canyon Nuclear Power Plant Units 1 and 2
March 2024
Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission
Enclosure 1 2
License Renewal Environmental Review Diablo Canyon Nuclear Power Plant Units 1 and 2
- 1. Background
By letter dated November 7, 2023, (Agencywide Documents Access and Management System Package No. ML23311A154), Pacific Gas and Electric Company (PG&E or the applicant),
submitted to the U.S. Nuclear Regulatory Commission (NRC) an application for license renewal of Renewed Facility Operating License Nos. DPR-80 and DPR-82, Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon or DCPP). A Federal Register notice (88 FR 80780) dated November 20, 2023, noted the receipt and availability of the application, including the environmental report (ER).
The NRC staff is conducting an environmental audit of the Diablo Canyon site to improve understanding, to verify information, and to identify information for docketing to support the preparation of an environmental impact statement. Specifically, the NRC staff will be identifying pertinent environmental data, reviewing the facility, and seeking clarifications regarding information provided in the ER.
- 2. Environmental Audit Bases
License renewal requirements for environmental reports are specified in title 10 of the Code of Federal Regulations (10 CFR) part 51, Postconstruction environmental reports. As specified by 10 CFR 51.53(c): Operating license renewal stage, (1) Each applicant for renewal of a license to operate a nuclear power plant under part 54 of this chapter shall submit with its application a separate document entitled "Applicant's Environmental ReportOperating License Renewal Stage." Review guidance for the staff is provided in NUREG-1555, Supplement 1, Revision 1, Standard Review Plans for Environmental Reviews for Nuclear Power Plants:
Supplement 1 - Operating License Renewal.
The NRC staff is required to prepare a site-specific supplement to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants. During the scoping process required in 10 CFR part 51, the NRC staff is required to define the proposed action, identify significant issues which must be studied in depth, and to identify those issues that can be eliminated from further study.
- 3. Environmental Audit Scope
The scope of this environmental audit is to identify new and significant issues and issues which can be eliminated from further study. The NRC staff will also identify environmental resources that must be described and evaluated in the Supplemental Environmental Impact Statement.
Audit team members will review the documents and other requested information made available on the Diablo Canyon online reference portal identified on the environmental audit needs list (Enclosure 2) and discuss any questions and additional information needs with the applicants subject matter experts.
- 4. Information and Other Material Necessary for the Environmental Audit
As identified on the environmental audit needs list (Enclosure 2).
- 5. Environmental Audit Team Members and Resource Assignments 3
The environmental audit team members and their assignments are shown in the table below.
Discipline NRC Team Members Environmental Review Supervisor Steve Koenick Environmental Project Manager Kim Conway Air Quality Nancy Martinez Aquatic Resources Briana Arlene Cumulative Impacts Jeff Rikhoff Environmental Justice Jeff Rikhoff Federally Protected Ecological Resources Briana Arlene Geologic Environment Gerry Stirewalt Greenhouse Gases/Climate Change Nancy Martinez Groundwater (Hydrology and Hydrogeology) Gerry Stirewalt Historic and Cultural Resources Jean Trefethen & Beau Goldstein Human Health Beth Alferink Land Use and Visual Resources Caroline Hsu Meteorology and Climatology Nancy Martinez Noise Nancy Martinez Postulated Accidents John Parillo Replacement Power Alternatives Jeff Rikhoff Severe Accident Mitigation Alternatives John Parillo Socioeconomics Caroline Hsu Spent Nuclear Fuel Leah Parks Surface Water Lloyd Desotell Termination of Operations and DecommissioningBeth Alferink Terrestrial (Land Cover and Habitat) Caroline Hsu Uranium Fuel Cycle Beth Alferink Waste Management (Rad and Non-Rad) Leah Parks
- 6. Logistics
An environmental audit will be conducted remotely during the week of March 18, 2024, followed by a site-visit the week of March 25, 2024. An entrance meeting will be held with plant management at the beginning of the audit and an exit meeting will be held at the end of this audit following the site visit.
- 7. Special Requests
PG&E staff and contractors who are subject matter experts in the disciplines identified on the environmental audit needs list should be available for interviews and tours.
- 8. Deliverables
An audit summary report will be issued by the NRC staff within 90 days from the end of the environmental audit.
Diablo Canyon Nuclear Power Plant Audit and Information Needs
Described below in three categories (i.e., tours, meetings, and information needs) are the information needs of the Nuclear Regulatory Commission (NRC) staff, supported by Pacific Northwest National Laboratory (PNNL), related to the license renewal application for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon). Information needs are identified as either resource-specific questions or document requests. Please arrange for the tours and meetings to occur during the either the virtual environmental audit or site visit, as specified below.
Additionally, we ask that you provide responses to the information needs on the electronic portal and make subject matter experts available to discuss these items with the NRC staff.
Virtual Tours
Please arrange for, and provide appropriate subject matter experts to contribute to, the following virtual tours.
Title or Number Features Observed Essential PNNL Participants Participants
- 1. General site Virtual walk-through of the following via All All tour photographs, 3D tours, and/or diagrams:
- Exterior grounds
- Transmission lines, including transition from in-scope to offsite
- Historic sites
- Possible alternative power generation locations
- Independent Spent Fuel Storage Installation (ISFSI), including areas that could be used for future expansion, if applicable
- Plant views from publicly accessible areas
- North and South ranch areas
- 2. Plant intake Virtual walk-through of the following via All All and discharge photographs, 3D tours, and/or diagrams:
tour
- Tour of the major visible components of
the cooling water intake and discharge system, including the intake cove, shoreline intake structure, traveling water screens, and shoreline outfall structure
- 3. Radwaste tour Virtual walk-through of the following via Beth Alferink photographs, 3D tours, and/or diagrams: Leah Parks
- Liquid radwaste system
- Gaseous radwaste system
- Mixed waste storage area and proximity to other storage areas
- ISFSI and area planned for future expansion
Enclosure 2 2
- Reactor Vessel Head and Steam Generator Storage Mausoleum
- 4. Surface water Virtual walk-through of the following via Lloyd Desotell tour photographs and/or diagrams: Gerry Stirewalt
- Diablo Creek
- Stormwater Retention Basins
- National Pollutant Discharge Elimination System (NPDES) Outfalls
- 5. Groundwater Virtual walk-through of the following via Beth Alferink Phil Meyer tour photographs and/or diagrams: Leah Parks Gerry Stirewalt
- Locations of plant structures, systems, and components (SSCs) identified as potential sources for groundwater contamination
- Locations of known SSCs with previous contamination related to documented leaks, spills, or accidental releases.
- Location of any areas where refurbishments related to license extension might impact groundwater resources, if any
- Locations of groundwater monitoring wells, including the six sampled quarterly for assessment of groundwater quality
- Locations of on-site water supply wells, including deep well WW-2 that is used to supplement the fresh water supply when needed
- 6. Visual Virtual walk-through of the following via All All available resources tour photographs:
- View of the plant from the south from Rancho Guadalupe Dunes Preserve
- View of the plant from the north from Windy Point on the Point Buchon Trail
- View of the plant from the nearest residence
- View of the plant from the Pacific Ocean from a distance likely seen by the public
- 7. Geologic Virtual walk-through of the following via Gerry Stirewalt Phil Meyer environment tour photographs and/or diagrams:
- View of Patton Cove and toe of the active landslide; the head scarp and upslope expression of surficial features that indicate the landslide is actively moving; monitoring stations and equipment related to the landslide monitoring program, if any; and any faults that bound the landslide, if possible
- Location of any areas where refurbishments related to license 3
extension might impact the geologic environment or soils, if any
In-person Tours
Please arrange for, and provide appropriate subject matter experts to contribute to, the following in-person tours as part of the NRCs site visit.
Title or Number Features Observed NRC PNNL Participants Participants (Tentative) (Tentative)
- 1. General site
- Exterior grounds All All tour
- Possible alternative power generation locations
- Location of ISFSI, including areas that could be used for future expansion, if applicable
- Plant views from publicly accessible areas
- 2. Plant intake
- Tour of the major visible components of the Briana Arlene Caitlin Wessel and discharge cooling water intake and discharge system, Mitchell Dehmer Tracy Fuentes tour including the intake cove, shoreline intake Gerry Stirewalt Phil Meyer structure, traveling water screens, and Lloyd Desotell shoreline outfall structure Caroline Hsu
- 3. Ecological
- Tour of the major terrestrial and aquatic Briana Arlene Caitlin Wessel resources tour ecological habitats on the DCPP site, Mitchell Dehmer Tracey Fuentes including Toms Pond, Diablo Creek, and Caroline Hsu the areas of the site where the California red-legged frog has been observed
- Meteorological (MET) towers and installed flight diverters
- Artesian spring wetlands
- 4. Surface water
- Stormwater retention basins Lloyd Desotell resources tour
- Diablo Creek
- NPDES Outfalls
- 5. Groundwater
- Locations of plant structures, systems, and Gerry Stirewalt Phil Meyer tour components (SSC) identified as potential Lloyd Desotell sources for groundwater contamination
- Locations of known SSCs with previous contamination related to documented leaks, spills, or accidental releases
- Location of any areas where refurbishments related to license extension might impact groundwater resources, if any
- Locations of groundwater monitoring wells, including the six sampled quarterly for assessment of groundwater quality
- Locations of on-site water supply wells, including deep well WW-2 4
- 6. Geologic
- View of Patton Cove and toe of the active Gerry Stirewalt Phil Meyer environment tour landslide; the head scarp and upslope expression of surficial features that indicate the landslide is actively moving; monitoring stations and equipment related to the landslide monitoring program, if any; and any faults that bound the landslide, if possible
- Location of any areas where refurbishments related to license extension might impact the geologic environment or soils, if any
- 7. Historic and
- Archaeological sites in the industrial site Jean Trefethen Lindsey Cultural area Renaud Resources
- Archaeological sites that are part of the archaeological district and within the overall property
- Exterior of facilities/structures
- Cultural sites on the property
Meetings
Please provide for breakout meetings with the appropriate subject matter expert(s) and/or the contractor(s) regarding the following topics. Those in attendance should be prepared to discuss the corresponding questions as described in the Information Needs and Document Requests section below. The staff intends to use these meetings, as needed, to resolve or clarify any outstanding data needs or questions arising from the hybrid environmental audit. NRC intends to leverage virtual breakouts to the extent possible. Any in-person breakouts are specified.
- Air Quality and Noise (virtual)
- Aquatic Resources (virtual with any necessary follow-up on site)
- Cumulative Impacts (virtual)
- Federally Protected Ecological Resources (virtual with any necessary follow-up on site)
- Geologic Environment (virtual with any necessary follow-up on site)
- Greenhouse Gas Emissions and Climate Change (virtual)
- Groundwater (virtual with any necessary follow-up on site)
- Historic and Cultural Resources (virtual and in-person)
- Human Health (virtual)
- Land Use and Visual Resources (virtual)
- Socioeconomics (virtual)
- Surface Water (virtual with any necessary follow-up on site)
- Terrestrial Resources (virtual)
- Waste Management and Spent Nuclear Fuel (virtual) 5
Information Needs and Document Requests
Information needs and document requests are identified below by resource area.
General Requests
The following requests are generic to more than one environmental review area. Issues applicable to these questions are provided below along with the responsible NRC subject matter expert, as appropriate.
GEN-1Please provide any relevant updates to table 9.1-1 of the Environmental Report (ER). If any authorizations have expired since Pacific Gas and Electrics Application for Renewed Operating License, dated November 7, 2023 (ML23311A154), please provide the status of those permits and/or renewals.
GEN-2In table 9.1-1 of the ER, Authorizations for Current DCPP Operations, the first rows of Sheet 6 of 7 and Sheet 7 of 7 appear to be duplicate entries for Domestic Water Supply Permit information. Please confirm or clarify the difference between these rows. This comment also applies to table E-1 in attachment F.
Topic-Specific Requests
The following requests are specific to a single environmental review area. If a topic is not provided below, the discussion held in response to the generic requests above are expected to fully cover that topic.
Air Quality (Nancy Martinez, NRC)
Audit Needs
AQN-1Section 3.3.3.3 of the ER identifies Diablo Canyon Nuclear Power Plant, Units 1 and 2 (DCPPs) air permits and emission units. The ER states [o]ne 162-horsepower emergency diesel generator was recently transferred to the County of San Luis Obispo.
Its permit, Permit No. PTO-886-2, is not included in table 3.3-9, but its emissions are included in table 3.3-10 and 3.3-11. Please clarify what is meant by recently transferred to the County of San Luis Obispo.
AQN-2Section 3.3.3.2 of the ER states that there have been no notices of violation or non-compliances associated with DCPP air emissions from 2018-2022. Were there any notices of violations or non-compliances associated with DCPP air emission in 2023.
AQN-3Table 3.3-10 in the ER presents annual air emissions (volatile organic compounds (VOC) and diesel particulate matter (DPM)).
- a. Identify the air emission sources accounted for in ER table 3.3-10.
- b. In addition to VOCs and DPM, are quantified criteria pollutant air emissions (e.g., carbon monoxide, nitrogen oxides, sulfur dioxide) available for these sources? If so, please provide.
Document Needs
AQN-4Provide a copy of the Diesel Particulate Matter Health Risk Assessment for DCPP mentioned in Section 3.3.3.3 of the ER.
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AQN-5Provide a copy of the 12 DCPP air permits discussed in Section 3.3.3.2 of the ER.
AQN-6Provide a copy of DCPPs air emissions statements for the most recent 5 years.
Aquatic Resources (Briana Arlene, NRC)
Audit Needs
AQU-1Section 3.6.1.2.6 of the ER describes a settlement agreement reached between Pacific Gas and Electric Company (PG&E) and the Central Coast Regional Water Quality Control Board (CCRWQCB) concerning impacts on receiving waters from past and ongoing cooling water discharges. Please summarize the requirements imposed on PG&E under this settlement agreement and provide a copy of the agreement.
AQU-2Section 4.6.1.4 of the ER states: In accordance with the statutory guidelines set forth in the NPDES permit issued to PG&E for DCPP, and to maintain compliance under Section 316(b) of the Clean Water Act, impingement and entrainment studies were conducted to verify that DCPP is utilizing the best technologies available (BTA) to reduce entrainment and impingement. However, the ER does not specify whether the CCRWQCB has made BTA determinations concerning impingement mortality and entrainment under the 2014 final rule implementing Clean Water Act Section 316(b).
Please specify whether CCRWQCB has made such determinations. If the CSWRCB has not made BTA determinations, explain the status of the CCRWQCBs review and provide any supporting documentation that PG&E has submitted to the CCRWQCB.
AQU-3Section 4.6.2 of the ER analyzes thermal impacts on aquatic organisms but does not specify if PG&E has a Clean Water Act 316(a) variance. Has PG&E sought, or has the California Regional Water Quality Control Board issued, a 316(a) variance for Diablo Canyon? If so, please provide supporting documentation.
Document Needs
AQU-4Section 3.7.7.10 of the ER describes 2019, 2021, and 2023 Intake Cove Bathymetry Surveys. Please provide copies of the associated survey reports.
Cumulative Impacts (Jeff Rikhoff, NRC; Dave Goodman, PNNL)
Audit Needs
CI-1 Per 10 CFR 51.53(c)(3)(ii)(O), please provide information about other past, present, and reasonably foreseeable future actions occurring in the vicinity of the nuclear plant that may result in a cumulative effect that may have occurred since the ER was submitted.
CI-2 Please provide more description of potential future projects that may occur during the proposed license review timeframe. Also, provide more detail on the two projects identified to occur during the current licensing term, outlined in Section 3.1.4 of the ER.
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Federally Protected Ecological Resources (Briana Arlene, NRC)
Audit Needs
FPE-1Section 3.7.8.1 of the ER states: PG&E has permission from the California Department of Fish and Wildlife (CDFW) to secure and/or collect any sea otter carcass found on their property and surrounding marine waters to assist CDFW with their sea otter monitoring program. There have been no sea otter carcasses that have been discovered at the DCPP site in the last 5 years.
- a. Is there written documentation of this arrangement? If so, please provide copies of such documentation.
- b. Has PG&E coordinated with the U.S. Fish and Wildlife Service (FWS) in any capacity concerning sea otters?
FPE-2ER Section 4.6.6.4.5 states: Operation of the DCPP intake and discharge structures, sand replenishment, dredging, or inwater construction may alter black abalone habitat and subsequently influence nearshore circulation patterns. Please describe in more detail PG&Es plans for sand replenishment and inwater construction during the proposed license renewal term.
FPE-3ER Section 3.1.4 states that PG&E is currently in the planning for dredging of the Diablo Canyon intake cove.
- a. Would this project affect any federally listed species or critical habitats? If so, please identify the federally listed species and critical habitats that would be affected by this project and summarize the types of effects that would be experienced by these resources.
- b. Has the U.S. Army Corps of Engineers engaged in Endangered Species Act Section 7 consultation with FWS and/or National Marine Fisheries Service in connection with issuing the required Federal permits for dredging?
FPE-4On August 25, 2023, the National Oceanic and Atmospheric Administrations Office of National Marine Sanctuaries (ONMS) issued a proposed rule to designate Chumash Heritage National Marine Sanctuary. This sanctuary would encompass 5,617 square miles of submerged lands and marine waters from Montana de Oro State Park in San Luis Obispo County to Naples along the Gaviota Coast in Santa Barbara County, and the designation would protect ecological, historical, archaeological, and cultural resources within the sanctuary of national significance. According to ONMSs website, it intends to publish the final rule designating the sanctuary in Summer 2024 (see https://sanctuaries.noaa.gov/chumash-heritage/). Please provide an assessment of the potential impacts of Diablo Canyon license renewal on sanctuary resources of the proposed Chumash Heritage National Marine Sanctuary. As part of this assessment, make effect determinations according to the language prescribed in the National Marine Sanctuaries Act of: may affect and is likely to destroy, cause the loss of, or injure; may affect but is not likely to destroy, cause the loss of, or injure; or no effect.
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FPE-5Please confirm that the below table represents all reported marine mammal stranding events at Diablo Canyon since 2007. If additional strandings occurred, please provide copies of the associated stranding reports.
Date Species MMPA Report 10/25/2007 California sea lion ML073330470 1/23/2008 California sea lion ML080580202 5/16/2008 California sea lion ML081700237 6/27/2008 elephant seal ML082140271 10/31/2008 California sea lion ML083440312 4/20/2009 harbor seal ML091680382 4/20/2009 harbor seal ML091680382 7/2/2009 harbor seal ML092090196 5/19/2014 harbor seal ML14167A076 6/5/2014 California sea lion ML14191A634 2/22/2015 California sea lion ML15097A179 3/14/2015 California sea lion ML15097A261 5/6/2015 California sea lion ML15161A317
FPE-6On February 21, 2024, the FWS provided scoping comments on the proposed Diablo Canyon license renewal (ML24053A019). In its letter, the FWS included recommended avoidance and mitigation measures for the southern sea otter (Enhydra lutris nereis) and California red-legged frog (Rana draytonii), both of which occur at the Diablo Canyon site. For each species, please indicate which of the avoidance and mitigation measures PG&E has implemented or intends to implement and, as appropriate, a timeline for when such measures would be implemented.
Document Needs
FPE-7Section 3.7.1.2 of the ER states: Three-spined stickleback were also documented in Toms Pond during a 2022 survey. Please provide a copy of this survey.
FPE-8Section 3.7.7.1 of the ER describes a Terrestrial Biological Resources Assessment that was conducted from April through June 2020. Please provide a copy of this assessment.
FPE-9Section 3.7.7.2 of the ER describes a field survey conducted to assess the occurrence of the California red-legged frog on the DCPP, as well as a follow-up survey that was conducted in 2022. Please provide copies of the reports associated with each of these surveys.
FPE-10Section 3.7.7.6 of the ER describes a Marine Biological Resources Assessment that was conducted in 2020. Please provide a copy of this assessment.
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FPE-11Section 3.7.8.1 of the ER states: Humpback whales have been observed on 52 occasions on transects completed within 37 miles of the DCPP site between 1987 and 2015. More recent surveys conducted at several locations at the DCPP site have documented eight sightings of humpback whales between 2017 and May 2020.
Please provide copies of the reports associated with these surveys.
FPE-12Section 3.7.8.1 of the ER states: Steelhead have been documented in the lower reaches of Diablo Creek in the vicinity of the DCPP site. Please explain where this species occurrence is documented and provide copies of applicable reports or surveys, if available.
FPE-13Section 3.7.8.3 of the ER describes monthly to biweekly clifftop surveys of marine mammals conducted from 2017 through May 2020. Please provide copies of the reports associated with these surveys.
FPE-14Section 4.6.2.4 of the ER states: Regular surveys are conducted in accordance with the NPDES permit issued to DCPP which includes dedicated black abalone surveys.
Please provide copies of black abalone surveys conducted over the past 5 years.
FPE-15Please provide copies for the NRC staff review of annual sea turtle reports prepared pursuant to the September 18, 2006, biological opinion (ML063000348) for calendar years 2017 through 2023.
FPE-16Attachment C to the ER contains copies of letters related to threatened and endangered species. Please provide copies of any written correspondence concerning threatened and endangered species that has transpired since PG&E submitted the ER.
Geologic Environment (Gerry Stirewalt, NRC; Becka Bence, PNNL; Phil Meyer, PNNL)
Audit Needs
GE-1Section 3.5.2.2 of the ER discusses the Patton Cove landslide that resulted from wave erosion breaching of the resistant Obispo tuff and eroding 200 ft into the softer Obispo shale and weathered sandstone during a rising sea level stand about 5,000 years ago.
This active landslide is encroaching into Diablo Ocean Drive at the head of Patton Cove. Please discuss what feature(s) of the geologic environment enabled the development of Patton Cove along the coastline and any mapped faults related to the position of the Cove.
GE-2Section 3.5.2.2 of the ER states that larger displacements of the Patton Cove landslide are caused by (1) storm surges that undermine the toe of the landslide and (2) heavy rainfall events that cause groundwater to build up. Section 3.6.2 notes that fractured sandstones of the Obispo Formation comprise the primary aquifer related to discrete fracture sets and not pore space. Please comment on whether the recent storms and heavy rainfall in February 2024 resulted in movement of the landslide.
GE-3Please discuss the results of the seismic assessment directed by California Senate Bill (SB) 846 and whether any new data indicate earthquake magnitudes that are higher than those defined in the previous Senior Seismic Hazard Analysis Committee Level 3 analysis.
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Document Needs
GE-4Please provide a copy of the updated seismic assessment that was completed as directed by SB 846, if available.
Greenhouse Gas and Climate Change (Nancy Martinez, NRC; Kazi Tamaddun, PNNL; Julia Flaherty, PNNL)
Audit Needs
GHG-1Section 3.3.4 of the ER discusses greenhouse gas emission from direct emission sources, which includes stationary and portable combustion sources. This section states that stationary and portable combustion sources are shown in table 3.3-10.
However, table 3.3-10 provides the annual air emissions summary, not sources. Clarify if the appropriate table that should be referenced is table 3.3-9.
GHG-2Tables 3.3-10 and 3.3-11 of the ER provide annual air emissions and annual greenhouse gas emissions from 2018 to 2022. Please provide 2023 data (if available).
GHG-3Section 3.3.4 of the ER discusses DCPP site greenhouse gas emissions. Primary county-level greenhouse gas emission sources are not provided. Identify primary county-level greenhouse gas emission sources and associated reported greenhouse gas emission data.
GHG-4 Section 7.2.3.2.3 of the ER states that geothermal plants may release small amounts of carbon dioxide and sulfur dioxide and emit 1 percent of the carbon dioxide and 3 percent of the sulfur compounds of a similarly sized fossil-fuel plant. Provide quantified annual carbon dioxide equivalents and sulfur dioxide emissions associated with the geothermal portion of this alternative. As part of the response, identify emission factors applied, discuss assumptions, and provide calculations.
GHG-5Table 3.3-11 of the ER presents annual greenhouse gas emissions from combustion sources and workforce commuting.
- a. Does PG&E use sulfur hexafluoride in equipment onsite at DCPP? If so, provide estimated greenhouse gas emissions for 2018-2023.
- b. Please explain why greenhouse gas emissions for combustion sources for year 2022 are higher compared to the previous years.
- c. Provide the calculations for the quantified emissions presented for combustions sources. Include details used in calculating emissions (i.e., fuel usage, refrigerant used, emission factors).
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Water Resources - Groundwater (Gerry Stirewalt, NRC; Becka Bence, PNNL; Phil Meyer, PNNL)
Audit Needs
GW-1Section 3.6.2.4 of the ER discusses the identification of SSCs with a credible mechanism for the release of licensed material to groundwater: power block structures, auxiliary building sump, Units 1 and 2 refueling water storage tanks, and underground system piping. Identify the locations of these SSCs on a map. If groundwater monitoring is used as a leak detection method for these SSCs, identify the pathways from these SSCs to the site Groundwater Protection Initiative (GPI) monitoring locations.
GW-2Section 3.6.3.2 of the ER states that well WW2 was reconstructed to provide a larger water supply. When did this occur and what did this entail?
GW-3Section 3.6.4.2 of the ER states that tritium has been detected at monitoring locations OW1, OW2, and DY1 since 2006 at levels up to 64,000 pCi/L. Please provide additional details regarding when and where this peak tritium activity occurred and to what was it attributed. Was there any action taken in response to detecting tritium at this level? If so, what was that response?
GW-4Please provide additional information about the rain washout studies conducted to document the phenomenon of gaseous effluent deposition and washout affecting tritium levels at monitoring locations. How were these studies conducted. Is there a report documenting the methods and results?
GW-5Please provide additional information about why well DY1 was removed from the GPI program monitoring.
GW-6Figure 3.6-7 in the ER (contour map of groundwater levels) is based on data from 2012. How frequently is groundwater level measured? Is there more recent data for groundwater levels onsite? Are there any seasonal effects on groundwater levels?
GW-7Please confirm whether any plant-related radionuclides, including tritium, were detected in wells WW2, GW1, GW2, 8S3, or spring 1A2 during 2023.
Document Needs
GW-8Please provide clear, readable copies of Updated Final Safety Analysis Report (UFSAR) figures 2.5-8 to 2.5-18 and figures 2.5-22 to 2.5-28.
GW-9Please provide a copy of the report from the 2012 study to comply with portions of Nuclear Energy Institute 07-07 Objective 1.1, discussed in Section 3.6.2.4 of the ER.
GW-10Please provide a copy of the plants Groundwater Protection Program documentation including any implementing plant procedures.
GW-11If available, please provide borehole logs showing the hydrostratigraphic units, including the primary aquifer formed by fractured sandstones of the Lower to Middle Miocene Obispo Formation and, if any, perched groundwater horizons deemed to be important.
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Historic and Cultural Resources (Jean Trefethen, NRC; Beau Goldstein, NRC; Lindsey Renaud, PNNL; Cyler Conrad, PNNL)
Audit Needs
HCR-1 Figures 3.8-5 through 3.8-11 in the ER show construction of the DCPP between the 1960s and mid-1970s. However, the ER does not describe when construction ended.
Confirm when the power plant completed construction.
HCR-2 Please provide citations and references for the information used to write Section 3.8 of the ER, in particular Sections 3.8.1 through 3.8.5.
HCR-3 Section 3.8 of the ER indicates that most of the conversations with State Historic Preservation Office (SHPO) thus far have been regarding the decommissioning of the plant. Confirm if there have been additional conversations with SHPO about the license renewal. If so, provide all correspondence and other communication documents between SHPO and PG&E received after October 17, 2023.
HCR-4 Attachment D to the ER, Cultural Resource Agency Outreach Letters, provided copies of letters PG&E sent to Federal and state-recognized Tribes seeking input on the current license renewal. Provide all correspondence and other communication documents PG&E has received from federal and state-recognized Tribes since October 17, 2023.
HCR-5 Provide additional information on the Confidential Cultural Resources Database. How is cultural resources information safeguarded? Who has access to the database?
HCR-6 In 2015, as part of request for additional information HC-1, a map detailing the level of ground disturbance was requested from PG&E (ML15295A373). Please provide an updated map of site disturbance levels if it has changed since 2015. Additionally, provide an updated percentage of how much Diablo Canyon Lands have been previously surveyed for cultural resources.
HCR-7 Please clarify if the programmatic agreement (PA) required by SHPO in their March 2009 response letter was signed. It was unclear from the provided communication on whether the PA was no longer needed based on the scope of the license renewal related to the transmission lines.
HCR-8 Please provide an update on what steps have been taken to identify any Traditional Cultural Properties within the area of potential effects. Confirm if there are additional ethnographic studies conducted in addition to the 2020 John R. Johnson ethnohistory.
HCR-9 Sections 3.1.4 and 4.12.6 of the ER indicate that any foreseeable ground disturbing activities would include the ISFSI modification. Elaborate on what those modifications would consist of, including potential depths and widths of disturbance.
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Document Needs
HCR-10Provide the following documents and procedures (or updated versions):
- a. John R. Johnson ethnohistory submitted to PG&E in 2020
- b. NRHP nomination form for the Rancho Canada de Los Osos y Pecho y Islay archaeological district
- c. Diablo Canyon Decommissioning Cultural Resource Inventory and Study Plan-Enright et al. 2021 d.Page and Turnbull Historic Built Environment Evaluation and report from 2022 e.License Renewal feasibility report by Maggie Trumbly
- f. The 1980 Archaeological Resources Management Plan Diablo Canyon Site
- g. The Interdepartmental Administrative Procedure EV2.IDA (Rev. 5)
- h. The 1982 Access Agreement between PG&E and Santa Ynez Band of Mission Indians
- i. The 1987 Memorandum of Understanding for the Treatment of Human Burials and Grave Goods and the Curation of Artifacts for Archaeological Site CA-SLO-2 on DCPP Property
- j. DCPP Land Stewardship charter Cultural Resources Standard for Environmental Management (ENV-8005S)
- k. ENV-8005P-01, the Cultural Resource Constraints Report Procedure
- l. Cultural Resources Awareness and Response Brochure
- m. Other best management practices (training, guidance, etc.) not captured above
Human Health (Beth Alferink, NRC)
Audit Needs
HH-1Please provide an overview of the radiation control program with emphasis on the ALARA program to control worker radiation exposure (annual dose goals and status).
Are there any proposed changes or upgrades to the program being considered during the license renewal term?
HH-2Section 4.9.1.4 of the ER states that correspondence is included with the state. Based on the location of the discussion, this implies there is correspondence between the plant and state, but there is nothing specific to microbiological hazards in attachment E to the ER, nor is there a response from the state related to microbiological hazards.
HH-3Please have Diablo Canyon subject matter experts available to discuss the electrical safety program along with related Cal/Occupational Safety and Health Administration regulations as implemented at the site under the industrial safety program. Plan to discuss the safety specific policies for work conducted at electrical transmission locations as noted in Sections 2.2.5.1, 2,.2.5.5, and 3.10.2 of the ER and a walk-through of the workplace hazards identification process and jobsite analysis noting how change evaluations would identify electric shock hazards or potential human error to eliminate risk during work on the in-scope transmission lines.
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HH-4Please have Diablo Canyon subject matter experts available to discuss the in-scope transmission lines to include line counts within the 230-kV and 500-kV transmission corridors outlined in Figure 2.2-2, location, and maintenance to ensure the California Public Utilities Commission (CPUC) requirements are maintained. Please be prepared to walk through the CPUC requirements and how they relate to NESC criteria to ensure the criteria are met as presented in the generic environmental impact statement and ER.
Document Needs
HH-5Provide a copy of the Offsite Dose Calculation Procedure to review the methodology and parameters used in the calculation of offsite doses in accordance with the Offsite Dose Calculation Manual.
Land Use and Visual Resources (Caroline Hsu, NRC; Dave Goodman, PNNL)
Audit Needs
LV-1 Section 3.1.4 of the ER discusses a planned modification to the DCPP ISFSI. Please provide information about the Orano NUHOMS system for which the DC ISFSI will be modified. When will construction occur? Will construction be confined to the developed ISFSI area or will land outside the ISFSI area be permanently or temporarily disturbed?
LV-2 The Coastal Zone Management Act requires applicants for federal licenses to obtain state concurrence that the action complies with the states Coastal Zone Management Program if the project occurs in a state coastal zone. DCPP lies within the California coastal zone. PG&E submitted a federal consistency certification request to the California Coastal Commission and included this in appendix F of the ER. Please provide any updated information regarding this request and the California Coastal Commissions response and certification when received.
Noise (Nancy Martinez, NRC)
Audit Needs
NOI-1Section 3.4 of the ER states that the nearest resident to DCPP is approximately 1.5 miles northwest of the plant and the next closest residence are over 3 miles away.
Clarify the reference point these distances were measured from.
NOI-2Section 3.4 of the ER states that in 2020 an ambient sound measurement program was conducted to quantify the existing noise environment at DCPP. Provide a copy of this study.
NOI-3Section 3.4 of the ER states that PG&E has never received a noise related to DCPP activities. Have any noise complaints been received since submission of the ER?
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Spent Nuclear Fuel (Leah Parks, NRC)
Audit Needs
SNF-1As stated in Section 3.1.4 of the ER, please provide documentation that there is enough storage capacity to store spent nuclear fuel that will be produced over the license renewal period using either the existing ISFSI and/or the spent fuel pool. If there is not enough storage capacity, be prepared to discuss the expansion plan to store spent nuclear fuel during the license renewal period.
Socioeconomics (Caroline Hsu, NRC; Michelle Niemeyer, PNNL; Adrienne Rackley, PNNL)
Audit Needs
SOC-1Table 3.9-2 in the ER shows DCPP total property tax payments from 2018-2022.
Please provide the same information for 2017 and 2023 (if available).
SOC-2Section 3.9.5 of the ER discusses the Joint Proposal Agreement and SB 1090 which set DCPP taxes paid on a linear path to $0 by the presumed shut down of Unit 2 in August 2025. Given the extension in operation and the license renewal application, has any legislation been introduced that would alter the current tax structure for DCPP?
SOC-3Given the DCPP extension in operation to at least 2030 and the 20-year license renewal please provide an analysis of:
- a. The implications for the Joint Proposal Agreement and estimated tax payments thru 2030.
- b. The current and future status of the Community Impact Mitigation Program
- i. is the Essential Services Mitigation Fund ($75 million paid to the county in annual installments through 2025 of $8,333,333) fully funded?
ii. is the Economic Development Fund (one-time payment of $10 million) fully funded?
Surface Water Resources (Lloyd Desotell, NRC; Rajiv Prasad, PNNL; Kazi Tamaddun, PNNL)
Audit Needs
SW-1What is the regulatory/permitting basis that authorizes DCPPs use of Pacific Ocean surface water? Please provide a copy of the authorization documents.
SW-2Confirm that outfalls 006, 007, 010, 011, 012, and 014 do not have effluent limits which should be presented in table 3.6-2. Provide the basis for why effluent limits are not applicable at these locations.
SW-3Please update figures 3.6-4 and 3.6-5 in the ER to include 2023 data, if available.
SW-4Please update tables 3.6-4a and 3.6-4b in the ER to include 2023 data, if available.
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SW-5Section 3.6.4.1 of the ER discusses surface water quality data for years 2018-2021.
Please update this discussion to account for surface water samples collected after 2021 (if available).
SW-6Sections 3.6.4.2.1 and 3.6.4.2.2 of the ER discuss radioactive and nonradioactive releases, respectively for years 2018-2022. Have any abnormal or reportable releases occurred since 2022?
SW-7What is the Pacific Ocean surface water intake nearest to DCPP? What category of use does that intake serve?
SW-8Section 9.5.3.2 of the ER states that the CCRWQCB plans to reissue an updated NPDES permit following the NRCs relicensing action. Are there any changes to the NPDES permit anticipated?
SW-9Section 9.5.3.10 of the ER discusses the State of Californias once-through cooling policy. What changes, if any (and potential timeframes) are anticipated during the license renewal (LR) term as a result of this policy.
SW-10Section 3.6.1.2.4 of the ER indicates that a dredging project will be completed during the current license term. However, Section 9.5.3.9 states that DCPP does not have any active dredge and fill activities but is in the initial planning stages for dredging activities that will occur during the LR term. Please clarify these statements and provide additional available details.
Document Needs
SW-11Please provide a copy of the relevant document (or citation) that explains NPDES permit administrative extension status or provide update, if any.
SW-12Provide a clear version of figure 2.2-1 Water Balance Diagram. The notes at the bottom of the figure are not legible.
SW-13Please provide a copy of the Spill Prevention Control and Countermeasure Plan.
SW-14Please provide a copy of the Stormwater Pollution Prevention Plan.
SW-15Please provide a copy of domestic water supply permit No. 4000589.
SW-16Please provide a copy of the General Industrial Storm Water Discharge Permit WD ID No. 3401018248.
SW-17Please provide the applicable NPDES permit Fact Sheet.
SW-18Please provide CEC-1304 Schedule 3 Part A Annual Water Supply and Use, and Wastewater Discharge Reports for years 2019 through 2023.
SW-19Please provide Annual Summary Report of Discharge Monitoring at the Diablo Canyon Power Plant, (NPDES No. CA0003751) for years 2019 through 2023.
SW-20Please provide annual Receiving Water Monitoring Program reports for years 2018, 2019, 2021 and 2023.
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Terrestrial Resources (Caroline Hsu, NRC; Tracey Fuentes, PNNL; Ann Miracle, PNNL)
Audit Needs
TER-1Section 2.2.4 of the ER states that DCPP has a primary and backup MET towers.
However, the ER does not describe characteristics of these towers any further. Birds and bats can collide with towers; collision rates are influenced by factors such as height, lighting regime, and whether the tower is guyed or freestanding. Please provide the following information on the DCPP primary and backup MET towers: 1) Are the towers freestanding or guyed? 2) What is the height of each tower? 3) What is the lighting regime of each tower (color, steady or blinking)?
TER-2Section 2.2.5.3 of the ER states that PG&E has a companywide Nesting Bird Management Plan that was developed to avoid and minimize disturbance to nesting birds within the PG&E service area. Section 2.2.5.3 also states that PG&E holds a Special Use Utility Permit (SPUT) issued by FWS for nest management, as well as handling and transport of injured or dead birds. Section 3.7.2.6 states that the SPUT expired on March 31, 2021, that a permit renewal was filed prior to expiration, and that a new SPUT has not yet been received. Section 3.7.8.5 states that PG&E is required to submit annual reports of all activities conducted under the SPUT to FWS. Please clarify whether FWS has issued a new SPUT. Please provide the following: 1) current or most recent SPUT, 2) the last 10 years of SPUT reports to FWS relating to DCPP (2013-2023), and 3) any other corporate or site-specific procedures and protocols related to handling, managing, or transporting migratory birds or their nests.
TER-3Section 3.7.8.5 of the ER describes four bird mortality incidents at the DCPP site over the last 5 years (2018-2023). Two of these incidents involved red-necked phalaropes colliding with a MET tower. Because of the red-necked phalarope mortalities at the primary MET tower, bird flight diverters were installed on the guy wires of the MET tower to prevent future mortality. Please provide the following: 1) a summary of bird mortalities (species, date, cause if known) in chronological order from 2013-2024, 2) any detailed reports for each incident, 3) photographs of the MET tower, showing the surrounding and the installed bird flight diverters.
TER-4Table 3.7-4 in the ER lists 6 bat species known to occur in San Luis Obispo County.
Table 3.7-5 lists wildlife species observed at DCPP, but none of these are bats. Please clarify whether any bat studies have occurred on DCPP, whether any bat mortalities have occurred on DCPP, and whether PG&E has any site-specific procedures or mitigation measures for bats.
TER-5Section 3.1.4 of the ER states that PG&E is planning for dredging of the DCPP intake cove. Would this project affect any State-listed species or their habitats? Would this project affect birds protected by the Bald and Golden Eagle Protection Act or the Migratory Bird Treaty Act or their habitats. If so, please identify the protected species and habitats that would be affected and summarize the types of effects that would be experienced by these resources.
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Document Needs
TER-6Sections 3.7.6 and 9.6 of the ER discuss administrative controls to ensure operational changes or construction activities reviewed. Please provide copies of corporate and DCPP site-specific environmental administrative procedures, controls, and best management practices if not already covered in TER-2 and TER-4.
TER-7Section 3.7.7.1 of the ER describes the terrestrial biological resource assessment conducted in 2020. Please provide a copy of this assessment.
TER-8Section 3.7.7.3 of the ER describes two invasive plant studies. Please provide copies of these two invasive plant studies.
TER-9Section 3.7.2.4.1 of the ER discusses two wetland delineations. Please provide copies of these two wetland delineations.
TER-10Please provide PG&Es corporate Nesting Bird Management Plan.
Waste Management (Rad and Non-Rad) (Leah Parks, NRC)
Audit Needs
WM-1As part of the effluent control systems, plan to discuss the provisions made to sample and analyze fluids before discharge as discussed in Section 2.2.6.1 of the ER. In addition, plan to discuss how the plant processes radioactive effluents to maintain radiation doses to the public to levels that are as low as is reasonably achievable (ALARA). Are there any proposed changes or upgrades to the program being considered during the license renewal term?
WM-2Section 2.2.6 of the ER notes that DCPP provides onsite storage of mixed waste in Bay 5 and 6 of the Solid Radwaste Storage Facility in the Radiological Control Area. Are any other wastes besides mixed waste stored in this location? What are the plans and procedures associated with long-term storage of mixed waste?
WM-3Section 2.2.6.3 of the ER discusses the Solid Waste Processing Systems. What are the plans to store or ship low-level waste (e.g., are there minimum quantity shipment plans or procedures for decision making)? In addition, plan to discuss how the plant plans to handle low-level radioactive waste (Class A, B, and C, mixed waste, and spent nuclear fuel) during the license renewal term (onsite storage, potential expansion of storage facilities, and disposal options). Are there any proposed changes or upgrades to the program being considered during the license renewal term? Does the site currently have any greater than Class C waste stored?
WM-4DCPP is subject to the reporting provisions of 40 CFR Part 110 as it relates to the discharge of oil in such quantities as may be harmful pursuant to Section 311(b)(4) of the Federal Water Pollution Control Act. In Section 9.5.3.6 of the ER, the applicant discusses reportable spills and states that for the period of 2018-2022, there were no reportable releases at DCPP that have triggered this notification requirement. If there have been any reportable releases which would trigger this notification requirement since the ER was written, please provide a description of the releases.
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WM-5If there have been any reportable unplanned releases of radioactive materials (unplanned/inadvertent radioactive liquid or gaseous releases) which would trigger a notification requirement since the ER was written, please provide a description of the releases. Please be prepared to discuss your plan to handle unplanned releases of radioactive materials.
WM-6If there have been any reportable inadvertent releases or spills of nonradioactive contaminants which would trigger a notification requirement since the ER was written, please provide a description of spills/releases. Please be prepared to discuss your plan to handle inadvertent nonradioactive releases.
Document Needs
WM-7Provide procedures related to the radioactive and nonradioactive Waste Management Program, Waste Minimization Program, and Stormwater Pollution Prevention Plan.
WM-8Drawings and/or photos that are highlighted/marked showing the flow paths for releases for both radiological and non-radiological waste paths. Please have subject matter experts available to discuss the flow paths.
WM-9Provide the log of approved waste vendors used to manage and dispose of hazardous and non-hazardous waste as discussed in Section 2.2.7 of the ER.
Diablo Canyon Units 1 and 2 - Environmental Audit Schedule Monday, March 18, 2024 START END ACTIVITY 10:00 am ET 10:30 am ET Entrance meeting between U.S. Nuclear Regulatory Commission (NRC), PG&E, and contractors 10:30 am ET 4:00 pm ET Virtual tours/virtual meetings between NRC, PG&E, and contractor subject matter experts (SMEs)
Tuesday, March 19, 2024 START END ACTIVITY 10:00 am ET 4:00 pm ET Virtual meetings between NRC, PG&E, and contractor SMEs
Wednesday, March 20, 2024 START END ACTIVITY 10:00 am ET 4:00 pm ET Virtual meetings between NRC, PG&E, and contractor SMEs
Thursday, March 21, 2024 START END ACTIVITY 10:00 am ET 4:00 pm ET Virtual meetings between NRC, PG&E, and contractor SMEs
Friday, March 22, 2024 START END ACTIVITY 10:00 am ET 12:00 pm ET Virtual meetings between NRC, PG&E, and contractor SMEs
Monday, March 25, 2024 START END ACTIVITY 9:00 am PT 4:00 pm PT NRC site visit
Tuesday, March 26, 2024 START END ACTIVITY 9:00 am PT 4:00 pm PT NRC site visit
Wednesday, March 27, 2024 START END ACTIVITY 9:00 am PT 4:00 pm PT NRC site visit
Friday, March 29, 2024 START END ACTIVITY 11:00 am PT 11:30 am PT Exit meeting between NRC, PG&E, and contractors
Enclosure 3