ML25006A096
| ML25006A096 | |
| Person / Time | |
|---|---|
| Site: | 07000026 |
| Issue date: | 12/20/2024 |
| From: | Brandt J US Dept of Interior, Fish & Wildlife Service |
| To: | Arlene B Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML25006A096 (1) | |
Text
IN REPLY REFER TO:
2024-0103109 December 20, 2024 Briana Arlene U.S. Nuclear Regulatory Commission, Environmental Technical Review Branch 1 Division of Rulemaking, Environment, and Financial Support Office of Nuclear Material Safety and Safeguards Washington D.C. 20555-0001
Subject:
Informal Consultation for the Diablo Canyon Independent Spent Fuel Storage Installation (ISFSI) Proposed License Renewal, San Luis Obispo County, California
Dear Briana Arlene:
We are responding to your request for our concurrence with your determination that the proposed Diablo Canyon Independent Spent Fuel Storage Installation (ISFSI) license renewal (project) may affect, but is not likely to adversely affect, the federally listed California red-legged frog (Rana draytonii) and California condor (Gymnogyps californianus). The request was submitted by the U.S. Nuclear Regulatory Commission (NRC) via electronic mail and received in our office October 21, 2024 and then revised and received on November 4, 2024.
Proposed Action NRC is proposing to renew the license for the existing Independent Spent Fuel Storage Installation (ISFSI) that operates as a part of the Diablo Canyon power plant (DCPP). The facility is located on the coast of San Luis Obispo County, approximately 8 miles south of Los Osos. The license would permit PG&E to operate the ISFSI of the nuclear power plant for an additional 40 years, until March 2064. The power plant facilities are located on 750 acres of land and includes two reactor buildings, a turbine building, an auxiliary building, a training building, a main warehouse, storage tanks, a cooling water intake structure, the Raw Water Storage Reservoir, 230 kilovolt (kV) and 500 kV switchyards, and the Old Steam Generator Storage Facility, in addition to the ISFSI.
The ISFSI consists of storage pads, a cask transfer facility, an onsite cask transporter, and a dry cask storage system. If the license is approved, PG&E would continue to store spent nuclear fuel (SNF) and the other radioactive waste at the ISFSI. Because the ISFSI and DCPP are already established, this project does not include any additional construction. SNF not already stored at the ISFSI is stored in a SNF pool; from that pool, SNF is moved to a multipurpose container
which is placed inside a transfer cask and transported to the ISFSI, where the multipurpose container is then placed into an overpack. The HI-STORM 100SA overpack used at the ISFSI is a cylindrical steel structure that provides radiation shielding and cooling to the multipurpose container and is designed to withstand high seismic activity. For a more detailed description of the project, see the Draft Environmental Assessment (NRC 2024). This temporary storage of SNF at the ISFSI is necessary for the operation of Units 1 and 2 until an interim or permanent offsite solution is available. The projects activities that have potential to affect federally listed species are as follows:
Transportation of spent nuclear fuel on DCPP roads (collision);
Movement of outdoor equipment and materials, such as the transfer casks (crushing)
Potential attractiveness of the site (condor habituation and potential exposure to harm)
Protection and Mitigation Enhancements:
The following protection measures with respect to the California red-legged frog would also be implemented as a part of the project:
- DCPP personnel and contractors will not handle any California red-legged frogs.
- A biological monitor shall be present for any activities with potential to impact California red-legged frog in Diablo Creek, such as vegetation management, moving of heavy equipment or materials, or ground disturbance.
- Work within Diablo Creek should be limited to the dry season (May through October).
- DCPP personnel and contractors will look for California red-legged frogs when lifting materials, such as plastic or plywood, moving equipment, or storage bins.
- DCPP work activities will minimize standing water to the greatest extent possible.
- DCPP personnel and contractors will collect and remove all trash daily.
- DCPP personnel and contractors keep all hazardous materials at least 100 feet from Diablo Creek (e.g., fuel, oil, or other harmful chemicals).
- DCPP personnel and contractors will respond to spills, leaks, and drips immediately to protect adjacent water quality.
- DCPP personnel and contractors will drive slowly (5 mph) on the north access road between Gate Charlie and Gate Alpha when its wet, foggy, or dark outside.
- On-site DCPP personnel and contractors will receive a training on how to identify, avoid, and report California red-legged frogs (Arlene, et al., pers. comm. 2024).
- If any frog is found, PG&E personnel and contractors must:
o Stop work near the frog and carefully secure a buffer of at least 50 ft around the frog.
o Contact Environmental Operations.
o Monitor the frog to ensure it will not be harmed; expand the buffer if necessary.
o Continue monitoring until input is received, or the frog leaves the work site.
o Work may not resume until the frog has left on its own volition or the area can be entirely isolated and protected from operations.
California condor Based on Global Positioning System (GPS) transmitter data, California condors consistently travel along the Santa Lucia range more than 10 miles away from the project area. While there is no indication of California condors occurring in the close vicinity of the project area, condors may expand into the area in the future and occasionally fly over the power plant facilities.
Work activities at the ISFSI have the potential to create microtrash which can be harmful to condor nests. If California condors landed at the ISFSI facilities, they could become habituated by interacting with workers. Based on the absence of any California condor GPS transmitter data near the powerplant facilities, California condor presence in the area is considered unlikely.
Therefore, the risks from microtrash and habituation are discountable for this project and we concur with your determination that the project may affect but is not likely to adversely affect the California condor.
California red-legged frog California red-legged frogs are present near the ISFSI project area. In March 2020, a targeted survey found one adult California red-legged frog in a pool near Diablo Creek and the north access road (Terra Verde 2020). Subsequent surveys in April and May of 2022 recorded 9 adult sightings within Lower Diablo Creek and 1 adult and 11 subadult sightings in Toms Pond, located on a coastal terrace to the north of Diablo Creek and the industrial portions of DCPP land (Terra Verde 2022). California red-legged frogs were not found in any other nearby streams during the 2022 surveys, but other non-breeding, temporary habitat may include an ephemeral drainage and a retention basin near the culverted section of Diablo Creek and two small wetlands (Terra Verde 2022). DCPP project activities may affect California red-legged frogs in the project area by injuring or killing them on roadways and crushing them during the movement of outdoor equipment.
The project will avoid these affects by implementing protective measures as a part of the project.
DCPP staff and contractors will inspect for California red-legged frogs when moving outdoor materials and equipment to avoid crushing California red-legged frogs. Regarding the risk of collision, the cask transporter travels no faster than 1 mph and staff monitor the roads for California red-legged frogs during transfer of SNF to the ISFSI. This slow speed and staff monitoring prevent all potential road collisions with California red-legged frogs during SNF transfer. Finally, the training for all on-site staff will help identify, avoid, and protect California red-legged frogs throughout DCPP facilities (Arlene, et al., pers. comm. 2024).
We concur with your determination that the project may affect but is not likely to adversely affect the Californian red-legged frog. California red-legged frog interactions with roads and the industrial sections of the DCPP project area are likely and the implementation of protective measures makes the potential for adverse effects insignificant or discountable.
Conclusion We concur with your determination that the ISFSI Proposed License Renewal may affect, but is not likely to affect, the federally listed species discussed above. Further consultation pursuant to section 7(a)(2) of the Act is not required. If the proposed action changes in any manner that may affect a listed species or critical habitat or if new information becomes available about the listed species in the project area that would change your determination, you must contact us immediately to determine whether additional consultation is required. If you have any questions regarding this matter, please contact our office at (805)677-1766 or by electronic mail at fw8venturasection7@fws.gov.
Sincerely, Joseph Brandt Asst. Field Supervisor JOSEPH BRANDT Digitally signed by JOSEPH BRANDT Date: 2024.12.20 14:43:38 -08'00'
LITERATURE CITED Terra Verde (Terra Verde Environmental Consulting, LLC and ERM). 2022. Site Assessment for California Tiger Salamander (Ambystoma californiense) Diablo Canyon Power Plant.
San Luis Obispo, California.
Terra Verde (Terra Verde Environmental Consulting, LLC and ERM). 2020. Diablo Canyon Decommissioning, Terrestrial Biological Resources Assessment. San Luis Obispo, California. TN10098.
U.S. Nuclear Regulatory Commission (NRC). 2024. Environmental Assessment for the Proposed Renewal of U.S. Nuclear Regulatory Commission License Number SNM-2511 for Pacific Gas & Electric Companys Diablo Canyon Independent Spent Fuel Storage Installation in San Luis Obispo County, California. Office of Nuclear Material Safety and Safeguards. ADAMS Accession No. ML24296A038 IN LITTERIS Arlene, B., Conway, K., Healy, S., Gould, B., et al. 2024. Conservation Biologist & ESA Consultation Coordinator, U.S. Nuclear Regulatory Commission. Video call with Bryce Koester, U.S. Fish and Wildlife Service, Region 8, on December 12, 2024.