DCL-26-006, License Renewal Application, Amendment 8 Regarding the Coastal Zone Management Act Consistency Certification

License Renewal Application, Amendment 8 Regarding the Coastal Zone Management Act Consistency Certification

ML26042A359
Person / Time
Site:	Diablo Canyon   (DPR-080, DPR-082)
Issue date:	02/11/2026
From:	Bradley Jones Pacific Gas & Electric Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
DCL-26-006
Download: ML26042A359 (0)

Text

Blair C. Jones Vice President Business and Technical Services Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424 805.545.3715 Blair.Jones@pge.com A member of the STARS Alliance Callaway x Diablo Canyon x Palo Verde x Wolf Creek PG&E Letter DCL-26-006 ATTN: Document Control Desk 15 CFR 930.4(a)(2)

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 Supplement 5: Diablo Canyon Power Plant License Renewal Application, Amendment 8 Regarding the Coastal Zone Management Act Consistency Certification

References:

1. PG&E Letter DCL-23-118, License Renewal Application, dated November 7, 2023 (ML23311A154)

2. NUREG-1437, Supplement 62, Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 62 Regarding License Renewal of Diablo Canyon Nuclear Power Plant, Units 1 and 2, dated June 2025 (ML25156A357)

3. California Coastal Commission Letter DCL-25-046, Consistency Certification CC-0003-23 (Relicense and Extend Operation of Diablo Canyon Power Plant and Associated Development), dated January 26, 2026 (ML26028A148)

Dear Commissioners and Staff:

In Reference 1, Pacific Gas and Electric Company (PG&E) submitted an operating license renewal application (LRA) for Diablo Canyon Power Plant (DCPP) Units 1 and 2 to extend the current Facility Operating Licenses an additional 20 years beyond their current expiration dates. NRC completed the environmental review of the DCPP LRA, as documented in Reference 2. In Reference 3, the California Coastal Commission issued a conditional concurrence on the Coastal Zone Management Act (CZMA) consistency certification for DCPP license renewal.

Pursuant to the CZMA and its implementing regulations, PG&E is supplementing the DCPP LRA as follows: PG&E will comply with Special Conditions 1 through 191, as stipulated in Reference 3, and copied in the Enclosure.

1 The California Coastal Commission website does not allow for direct link to the Special Conditions.

Follow link provided, then click on the tab for "Thursday December 11, 9:00am," and select item 8b to see the Special Conditions.

Pacific Gas anti Ber:mc Company*

Document Control Desk PG&E Letter DCL-26-006 Page 2 A member of the STARS Alliance Callaway x Diablo Canyon x Palo Verde x Wolf Creek In addition, PG&E confirms that there is no new and significant information related to DCPP license renewal since NRC's issuance of Reference 2 in June 2025.

PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this submittal.

If you have any questions or require additional information, please contact Mr. Philippe Soenen at (805) 459-3701.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on ____________________.

Sincerely, Blair C. Jones Vice President, Business and Technical Services Enclosure cc:

Diablo Distribution Anthony Chu, Chief, California Department of Public Health Kim Conway, NRC Environmental Project Manager Brian Harris, NRC Senior Project Manager Mahdi O. Hayes, NRC Senior Resident Inspector Wesley Horn, California Coastal Commission Senior Environmental Scientist Delphine Hou, California Department of Water Resources Samson S. Lee, NRR Senior Project Manager John D. Monninger, NRC Region IV Administrator Alissa Neuhausen, NRC Acting License Renewal Branch Chief Joseph Street, California Coastal Commission, EORFC Program Manager Cassidy Teufel, California Coastal Commission Deputy Director February 11, 2026

Enclosure PG&E Letter DCL-26-006 Page 1 of 22 Coastal Zone Management Act Consistency Certification Special Conditions No. Special Condition 1

Recorded Documents 1.1 Fee Title Transfer to a Public Agency and Conservation EasementNorth Ranch (Phase I). Within 12 months of license approval by the Nuclear Regulatory Commission, PG&E shall endeavor to transfer fee title of approximately 4,500 acres as described below and as shown in Exhibit 5 [of Reference 3] (Land Dedication Area) to a public agency acceptable to the Executive Director of the Coastal Commission (the Executive Director). If no such agency accepts the transfer within 18 months of license approval by the Nuclear Regulatory Commission, then PG&E shall endeavor to transfer the Land Dedication Area additionally to a non-profit land conservation organization, including those of California Native American Tribes, approved by the Executive Director, for an additional 18-month period. Any transfer of fee title to any successor over the dedicated lands covered under this Special Condition 1.1 shall require the prior written approval of the Executive Director to help ensure effectuation of and compliance with the easements described in this Special Condition 1.1 and Special Conditions 3 and 4. The fee title transfer will be completed within 5 years of the initiating period. The Executive Director may extend this timeframe for up to an additional 5 years based on a showing by PG&E of good cause.

A. Land Dedication Area Location: The Land Dedication Area shall cover approximately 4,500 acres of land and shoreline owned or controlled by PG&E within the coastal watersheds in the North Ranch area surrounding the Diablo Canyon Power Plant as shown in Exhibit 5 [of Reference 3] and including Assessor Parcel Numbers 076-011-030, 076-011-031, 076-011-032, 076-021-010, 076-021-023, 076-031-007, 076-032-017, 076-091-002, 076-091-005, 076-091-015, 076-091-016. All APNs and other real property particulars (including the legal descriptions) of the Land Dedication Area will be verified with PG&E during the land transfer and conservation easement establishment process. As specified below, the requirements for recordation of the offer to dedicate a conservation easement and the development of the stewardship plan shall apply prior to the execution of the fee title transfer.

B. Conservation Easement. Within 12 months of license approval by the Nuclear Regulatory Commission, unless extended by the Executive Director for good cause, and prior to execution of the fee title transfer, PG&E shall record an irrevocable offer to dedicate a conservation easement, in a form and content acceptable to the Executive Director, over the entire Land Dedication Area as mitigation for the adverse effects on marine biology and water quality (OTD). Provided, however, if a public agency is to accept transfer of fee title and is unable to do so if the land is encumbered with a conservation easement, PG&E may apply for a permit amendment to modify this condition to instead require establishment of a deed restriction on the property for the same primary purposes listed below in Section C(i) of this Special Condition 1.1. Until such time as the offer to dedicate the conservation easement over the Land Dedication Area is made, PG&E shall retain ownership of the Land Dedication Area. As used in this Special Condition 1.1, the areas covered in the OTD are referred to as the Easement Area, and the

Enclosure PG&E Letter DCL-26-006 Page 2 of 22 No. Special Condition easement subject to the OTD is referred to as the Easement. The OTD shall be to a public agency or to a non-profit land conservation organization (including those of California Native American Tribes) subject to approval by the Executive Director.

C. Stewardship Plan: For the OTD, PG&E shall prepare for Executive Director review and approval a stewardship plan to be attached to and incorporated into the terms of the OTD (as used in this Special Condition 1.1, the Stewardship Plan). The Stewardship Plan shall be submitted to the Executive Director no later than six months prior to the recordation deadline for the OTD. The Stewardship Plan shall include the following:

i.

A description of the allowable and prohibited uses in the Easement Area consistent with the primary purpose of the Easement. The primary purpose of the Easement shall be to provide habitat protection and conservation benefits through permanent protection of intertidal and terrestrial habitat from industrial, commercial, residential and associated development. In addition to habitat protection and conservation, the Easement shall provide for open space for the purpose of habitat protection and for public and tribal access (including but not limited to Tribal ceremonial use, Tribal gathering of natural materials, trails, signage, benches, shade structures and restroom facilities) that can be implemented consistent with the Easements primary purpose. The Stewardship Plan may also allow for sustainable coastal agriculture, where these uses can be implemented consistent with the Easements primary purpose. The Stewardship Plan shall also allow for restoration of native habitat and measures that may be needed to improve water quality. The Stewardship Plan shall also allow for maintenance of existing power transmission rights-of-way and associated existing roads, and unrestricted access to existing PG&E facilities. Moreover, existing electric and gas facilities shall be recognized as an authorized use.

ii.

A description of existing conditions within the Easement Area, including existing habitat types, existing and proposed development, current agricultural practices, existing and proposed public accessways, and the locations thereof.

iii. A description of how the Easement will be managed by the receiving entity to provide the allowable and existing uses described above. The plan shall also describe how currently required and anticipated accessways will be completed.

These include continued access and development necessary to support access along the Point Buchon Trail, and access to be developed for the additional trail alignments proposed by PG&E and shown on Exhibit 5 [of Reference 3].

iv. The plan shall include necessary and reasonable restrictions on timing, number of people allowed on all public accessways, and group activities for public access on the site that are consistent with the primary purpose of the easement; provided, however, that nothing in the plan or easement shall be used or construed to allow anyone to interfere with any rights of public access acquired through use, coastal development permits, or other approvals, nor shall this special condition impair or affect the requirements in Special Condition 3 of this permit, including but not limited to the requirement to record an OTD for the public access easements specified therein. Executive Director review of the plan shall include tribal consultation to inform the inclusion of

Enclosure PG&E Letter DCL-26-006 Page 3 of 22 No. Special Condition reasonable measures for the protection of Tribal Cultural Resources (as defined in Cal. Public Resources Code § 21074) and provisions for allowing tribal access, consistent with the primary purpose of the easement.

v.

The plan shall also describe how PG&E and its successors and assigns will ensure that agricultural uses on the property are carried out consistent with sustainable coastal agricultural practices in the Easement Area, including rotation of grazing areas, and avoidance or minimization of pesticides and herbicides use.

D. Recordation of Offer To Dedicate: Within 30 days of recordation of the OTD, PG&E shall provide documentation to the Executive Director confirming that it has recorded the OTD with the County of San Luis Obispo for acceptance by a public agency or non-profit land conservation organization approved by the Executive Director.

i.

The OTD shall include a legal description and corresponding graphic depiction of the legal parcel(s) subject to this permit and a metes and bounds legal description and a corresponding graphic depiction, drawn to scale, of the Easement Area prepared by a licensed surveyor based on an on-site inspection of the Easement Area.

ii.

The OTD shall be recorded free of liens and prior encumbrances that the Executive Director determines may affect the interest being conveyed. The OTD shall provide that it shall not be used or construed to allow anyone, prior to acceptance of the Offer, to interfere with any rights of public access acquired through use which may exist in the Easement Area. The OTD shall run with the land in favor of the State of California binding successors and assigns of the applicant or landowner in perpetuity. The OTD shall be irrevocable for a period of 18 years, such period running from the date of recording, and indicate that the restrictions on the Easement Area shall be in effect upon recording and remain as covenants, conditions and restrictions running with the land in perpetuity, notwithstanding any revocation of the OTD.

1.2. South Ranch Deed Restriction. In the event that the California Public Utilities Commission authorizes operations of DCPP beyond October 31, 2030, within 12 months of the date of that authorization, or the actual date recording occurs as described below, whichever is earlier (Recordation Date), PG&E, on behalf of itself and its subsidiaries and affiliates (as used in this Special Condition 1.2, PG&E) shall cause to be recorded an irrevocable open space conservation deed restriction, in a form and content acceptable to the Executive Director, over approximately 1,290 acres as described below and as shown in Exhibit 5 [of Reference 3], as mitigation for the adverse effects on marine biology and water quality (the Deed Restriction).

A. Location: The Deed Restriction area shall cover approximately 1,290 acres of land held by PG&Es wholly owned subsidiary, Eureka Energy, within the coastal zone of the South Ranch area surrounding the Diablo Canyon Power Plant as shown in Exhibit 5 [of Reference 3] (as used in this Special Condition 1.2, the Deed Restriction Area) and including Assessor Parcel Numbers 076-151-012 and 076-151-013 All APNs and other real property particulars (including the legal descriptions) of the Deed Restriction area will be verified with PG&E during the deed restriction establishment process. No development, as defined in section

Enclosure PG&E Letter DCL-26-006 Page 4 of 22 No. Special Condition 30106 of the Coastal Act, shall occur within the Deed Restriction Area except pursuant to the stewardship plan described below.

B. Stewardship Plan: PG&E shall prepare for Executive Director review and approval a stewardship plan to be attached to and incorporated into the terms of the Deed Restriction (as used in this Special Condition 1.2, the Stewardship Plan). The Stewardship Plan shall be submitted to the Executive Director no later than six months prior to the recordation deadline for the Deed Restriction. The Stewardship Plan shall include the following:

i.

A description of the allowable and prohibited uses in the Deed Restriction area consistent with the primary purpose of the Deed Restriction, which shall be to provide habitat protection and conservation benefits through permanent protection of intertidal and terrestrial habitat from industrial, commercial, residential and associated development. In addition to habitat protection and conservation, the plan shall provide for open space for the purpose of public and tribal access (including but not limited to Tribal ceremonial use, Tribal gathering of natural materials, trails, signage, benches, shade structures and restroom facilities) that can be implemented consistent with the Deed Restrictions primary purpose. The plan may also allow for sustainable coastal agriculture, where these uses can be implemented consistent with the easements primary purpose. The plan shall also allow for restoration of native habitat and measures that may be needed to improve water quality. The plan shall also allow for maintenance of existing power transmission rights-of-way and associated existing roads, and unrestricted access to existing PG&E facilities. Moreover, existing electric and gas facilities shall be recognized as an authorized use. The deed restriction may additionally allow for activities for the perpetual preservation of human remains, funerary objects, sacred objects and items of cultural patrimony originating in San Luis Obispo County that may require relocation and reburial for protection at the direction of the recognized descendants or as otherwise designated by the Native American Heritage Commission, and approved by Commission or its Executive Director in writing.

ii.

A description of existing conditions within the Deed Restriction area, including existing habitat types, existing and proposed development, current agricultural practices and existing and proposed public accessways, and the locations thereof.

iii.

A description of how the Deed Restriction area will be managed to provide the allowable and existing uses described above. The plan shall also describe how currently required and anticipated accessways will be completed.

iv.

The Stewardship Plan shall include necessary and reasonable restrictions on timing, number of people allowed on all public accessways, and group activities for public access on the site that are consistent with the primary purpose of the Deed Restriction; provided, however, that nothing in the plan or Deed Restriction shall be used or construed to allow anyone to interfere with any rights of public access acquired through use, coastal development permits, or other approvals, nor shall this special condition impair or affect

Enclosure PG&E Letter DCL-26-006 Page 5 of 22 No. Special Condition the requirements in Special Condition 3 of this permit, including but not limited to the requirement to record an offer to dedicate for the public access easements specified therein. Executive Director review of the plan shall include tribal consultation to inform the inclusion of reasonable measures for the protection of Tribal Cultural Resources (as defined in Cal. Public Resources Code § 21074) and provisions for allowing tribal access, consistent with the primary purpose of the Deed Restriction.

v.

The plan shall also describe how PG&E and its successors and assigns will ensure that agricultural uses in the Deed Restriction area are carried out consistent with sustainable coastal agricultural practices, including rotation of grazing areas, and avoidance or minimization of pesticides and herbicides use.

C. Recordation: Within 30 days of the Recordation Date, PG&E shall provide documentation to the Executive Director confirming that it has recorded the Deed Restriction with the County of San Luis Obispo in the form approved by the Executive Director.

i.

The Deed Restriction shall include a formal legal description of the entire property subject to this condition, and a metes and bounds legal description and corresponding graphic depiction (drawn to scale) of the Deed Restriction area, prepared by a licensed surveyor and based on an on-site inspection of thereof.

ii.

The Deed Restriction shall be recorded free of liens and prior encumbrances that the Executive Director determines may affect the property interest being encumbered. The Deed Restriction shall run with the land in favor of the State of California binding successors and assigns of the applicant or landowner in perpetuity. The Deed Restriction shall indicate that the restrictions on the Deed Restriction area shall be in effect upon recording and remain as covenants, conditions and restrictions running with the land in perpetuity.

2 Rights of First Refusal 2.1. South Ranch - Right of First Refusal A. PG&E, on behalf of itself and its subsidiaries and affiliates (as used in this Special Condition 2.1, PG&E), shall not sell, offer for sale, transfer, encumber, or otherwise convey any real property (or portion thereof) within the South Ranch area of the Diablo Canyon lands, comprised of approximately 5,000 acres and [APN Nos. 076-151-009, 076-151-012, 076-151-013, 076-171-016, 076-171-019, 076-171-032, 076-172-016, 076-172-018, 076-172-020, 940-000-583] (as used in this Special Condition 2.1, the Property) before December 31, 2040, except as provided in this Special Condition 2.1 and Special Conditions 1.2, 3 and 4.

B. In the event that the California Public Utilities Commission authorizes operations of DCPP beyond October 31, 2030, within 12 months of the date of that authorization, prior to or upon any offer for sale, transfer, encumbrance, or other conveyance of the Property or any portion thereof (as used in this Special Condition 2.1, an Offer), PG&E shall enter into an agreement with Eureka Energy to require Eureka

Enclosure PG&E Letter DCL-26-006 Page 6 of 22 No. Special Condition Energy to offer and grant the Option (as defined below) as described in this Special Condition 2.1 with respect to such Property (pre-Option Agreement); provided, however, the pre-Option Agreement shall not be executed without the prior review and written approval by the Executive Director. PG&E shall provide the fully executed pre-Option Agreement to the Executive Director within 10 days after its execution.

PG&E shall provide the Executive Director with a copy of the terms of such Offer, after which an Approved Purchaser (defined below) shall have the right to enter into an agreement for an exclusive option to purchase of the Property, on the same terms in the Offer or discounted, subject to the condition that such purchase shall be for the primary purpose of habitat protection, as well as for open space protection, public and tribal access (including but not limited to Tribal ceremonial use, Tribal gathering of natural materials, trails, signage, benches, shade structures and restroom facilities), consistent with the primary purpose and with the protection of tribal cultural resources (the Option). The terms in the Offer may not be above the fair market value of the Property. The Option shall recognize that PG&E may reserve a necessary and reasonable easement for its existing electric and gas facilities on the Property. The Property may be purchased, under an exclusive option, by a local, State or federal government agency, or, if no such agency exercises the Option within 18 months (Initial Exercise Deadline), then additionally to a non-profit land conservation organization, including those of California Native American Tribes, approved by the Executive Director (an Approved Purchaser),

which purchaser may exercise the Option within 18 months after the Initial Exercise Deadline. As part of the vesting documentation for the purchase of the Property pursuant to the Option, terms shall be incorporated to require that title shall vest subject to terms and conditions ensuring the Property is irrevocably protected for the above-referenced purposes in perpetuity through establishment of a conservation easement, which terms and conditions shall be reviewed and approved in writing by the Executive Director before the transfer of the Property pursuant the Option takes effect. Such conservation easement shall run with the land in favor of the People of the State of California, binding successors and assigns of the applicant or landowner in perpetuity, and shall be irrevocable for a period of 18 years, such period running from the date of recording, and indicate that the restrictions on the use of the land shall be in effect upon recording and remain as covenants, conditions and restrictions running with the land in perpetuity, notwithstanding any revocation of the offer. Any transfer of fee title to any successor over the lands covered under an exercise of the Right of First Refusal pursuant to this special condition shall require the prior written approval of the Executive Director to help ensure effectuation of and compliance with the easements described in this special condition and Special Conditions 3 and 4. Within 90 days of any CPUC authorization for any extended operations beyond October 31, 2030, PG&E shall develop and submit for the Executive Directors review and approval an agreement with the Commission that effectuates the Option described herein. The agreement shall set forth the terms and conditions consistent herewith under which the Option may be exercised, including but not limited to a perpetual option term, notice requirements, purchase procedures, and closing obligations. PG&E shall sign the agreement upon its approval by the Executive Director, and the agreement

Enclosure PG&E Letter DCL-26-006 Page 7 of 22 No. Special Condition or a memorandum thereof shall be recorded in the County where the Property is located within 30 calendar days thereafter. In the event that no Approved Purchaser exercises the Option or no Approved Purchaser acquires legal title after exercising the Option as specified in this condition, PG&E shall submit an amendment application to this CDP to propose alternative mitigation.

C. Notwithstanding the foregoing provisions, nothing in this Special Condition 2.1 shall be used or construed to allow anyone to invalidate or otherwise interfere with rights of public access acquired through use, coastal development permits, or other approvals, nor shall this special condition impair or affect the requirements in Special Conditions 1, 3, and 4 of this CDP, including but not limited to the requirement to record an OTD for the public access easements specified therein.

Furthermore, the existing deed restriction for the 1,200 acres near Point San Luis recorded pursuant to CDP No. E-06-011 and the deed restriction required under Special Condition 1.2 shall remain in effect until an approved entity accepts the OTD for a conservation easement through a binding and effective acceptance.

D. Nothing in this Special Condition 2.1 prevents PG&E from electing to initiate and effectuate the Right of First Refusal provisions specified in Subsection B of Special Condition 2.1 earlier than October 31, 2030. In that event, PG&E shall provide notice to the Executive Director of its intent to initiate the Right of First Refusal, and within 30 days of such notice of intent, PG&E shall submit to the Executive Director for the Executive Directors review and approval both the pre-Option Agreement and the agreement with the Commission that effectuates the Option as set out in Subsection B of Special Condition 2.1.

2.2 Wild Cherry Canyon - Right of First Refusal.

A. In the event that the California Public Utilities Commission authorizes operations of DCPP beyond October 31, 2030, within 12 months of the date of that authorization, PG&E, on behalf of itself and its subsidiaries and affiliates (as used in this Special Condition 2.2, PG&E) prior to or upon any offer for sale, transfer, encumbrance, or other conveyance of the Property or any portion thereof (as used in this Special Condition 2.2, an Offer) within the Wild Cherry Canyon area of the Diablo Canyon lands, comprised of approximately 2,400 acres and APN Nos. 076-161-001, 076-161-002, 076-161-004 (portion), 076-171-017, 076-171-021, and 076-172-013 (as used in this Special Condition 2.2, the Property), by Eureka Energy, PG&E shall enter into an agreement with Eureka Energy to require Eureka Energy to offer and grant the Option (as defined below) as described in this Special Condition 2.2 with respect to such Property (pre-Option Agreement); provided, however, the pre-Option Agreement shall not be executed without the prior review and written approval by the Executive Director.

B. PG&E shall provide the fully executed pre-Option Agreement to the Executive Director within 10 days after its execution. PG&E shall provide the Executive Director with a copy of the terms of such Offer, after which an Approved Purchaser (defined below) shall have the right to enter into an agreement for an exclusive option to purchase of the Property, on the same terms for fair market value in the Offer or discounted, subject to the condition that fee title shall be held for the

Enclosure PG&E Letter DCL-26-006 Page 8 of 22 No. Special Condition primary purpose of habitat protection, as well as for open space protection, public and tribal access (including but not limited to Tribal ceremonial use, Tribal gathering of natural materials, trails, signage, benches, shade structures and restroom facilities), consistent with the primary purpose and with the protection of tribal cultural resources (the Option). Notwithstanding the foregoing, the Option shall recognize and be subject to any leasehold interests on the Property that are in effect and valid as of the date of the Commissions approval of this permit and which remain in effect and valid as of the date of the Offer. The terms in the Offer may not be above the fair market value of the Property. The Property may be purchased, under an exclusive option, by a California state government agency, or, if no such agency exercises the Option within 18 months (Initial Exercise Deadline), then additionally the property may be purchased by a non-profit land conservation organization, including those of California Native American Tribes, approved by the Executive Director (an Approved Purchaser), which purchaser may exercise the Option within 18 months after the Initial Exercise Deadline. As part of the vesting documentation for the purchase of the Property pursuant to the Option, terms shall be incorporated to require that title shall vest subject to terms and conditions ensuring that fee title to the Property is irrevocably subject to the protections for the above-referenced purposes in perpetuity. Any transfer of fee title to any successor over the lands covered under an exercise of the Right of First Refusal pursuant to this special condition shall require the prior written approval of the Executive Director to help ensure effectuation of and compliance with the protections described in this special condition and any Alternative Wild Cherry Canyon Alignment under Special Condition 3. Within 90 days of any CPUC authorization for any extended operations beyond October 31, 2030, PG&E shall develop and submit for the Executive Directors review and approval an agreement with the Commission that effectuates the Option described herein. The agreement shall set forth the terms and conditions consistent herewith under which the Option may be exercised, including but not limited to a perpetual option term, notice requirements, purchase procedures, and closing obligations. PG&E shall sign the agreement upon its approval by the Executive Director, and the agreement or a memorandum thereof shall be recorded in the County where the Property is located within 30 calendar days thereafter.

C. Notwithstanding the foregoing provisions, nothing in this Special Condition 2.2 shall be used or construed to allow anyone to invalidate or otherwise interfere with rights of public access acquired through use, coastal development permits, or other approvals, nor shall this special condition impair or affect the requirements in Special Conditions 1, 3 and 4 of this CDP, including but not limited to the requirement to record an OTD for the public access easements specified therein.

D. The requirements of this Special Condition 2.2 do not apply to or affect any leasehold interests held by HomeFed Corporation and other third parties unrelated to PG&E as to Wild Cherry Canyon properties to the extent those leasehold interests remain in effect.

Enclosure PG&E Letter DCL-26-006 Page 9 of 22 No. Special Condition E. The requirements of this Special Condition 2.2 do not prevent the sale of the subject property by Eureka Energy to a California state government agency prior to the exercise of the right of first refusal.

2.3 Wild Cherry Canyon - Purchase Option A. Within 120 days of license approval by the Nuclear Regulatory Commission, PG&E, on behalf of itself and its subsidiaries and affiliates (as used in this Special Condition 2.3, PG&E) shall enter into an agreement with Eureka Energy to require Eureka Energy to offer and grant the Option for purchase (as defined below) with respect to the Wild Cherry Canyon area of the Diablo Canyon lands (pre-Option Agreement), comprised of approximately 2,200 acres and APN Nos. 076-161- 001, 076-161-002, 076-161-004 (portion), 076-171-017, 076-171-021, and 076-172-013, but excluding certain areas as generally depicted on Exhibit 5 that are necessary for DCPP security and for access and infrastructure for certain existing uses (as used in this Special Condition 2.3, the Property); provided, however, the pre-Option Agreement shall not be executed without the prior review and written approval by the Executive Director. Following Executive Director Approval, PG&E shall provide the fully executed pre-Option Agreement to the Executive Director within 10 days after its execution.

B. Within 120 days of Executive Director approval of the pre-Option Agreement, PG&E shall cause Eureka Energy to develop and submit for the Executive Directors review and approval an agreement that effectuates the Option described herein.

The agreement shall set forth the terms and conditions consistent herewith under which the Option may be exercised, including but not limited to that it may be exercised exclusively by an Approved Purchaser (as defined in this Special Condition 2.3), the option term, notice requirements, purchase preconditions and procedures, reciprocal easement rights over certain areas within the Property necessary for PG&E access and within adjacent property retained by PG&E for public access trail connectivity, and closing obligations. PG&E shall cause Eureka Energy to sign the agreement upon its approval by the Executive Director, and the agreement or a memorandum thereof shall be recorded in San Luis Obispo County within 30 calendar days thereafter.

C. The Option may be exercised by a local, State or federal government agency, or non-profit land conservation organization, including those of California Native American Tribes, approved by the Executive Director (an Approved Purchaser).

An Approved Purchaser may exercise the Option only upon submission of evidence to the satisfaction of the Executive Director that the Approved Purchaser has executed an agreement with HomeFed Corporation to acquire its leasehold interests in the Property. The Option shall have a term that expires on October 31, 2030; provided, however that the Option shall also provide that, upon its expiration, it shall convert to a Right of First Refusal, subject to the provisions of Condition 2.2.

D. Upon submission to the Executive Director of evidence that the Approved Purchaser has reached an agreement with HomeFed Corporation to acquire its leasehold interests in the Property, the Approved Purchaser shall have the right to enter into an agreement with Eureka Energy for an exclusive option to purchase of

Enclosure PG&E Letter DCL-26-006 Page 10 of 22 No. Special Condition the Property for fair market value, subject to the condition that fee title shall be held for the primary purpose of habitat protection, as well as for open space protection, public and tribal access (including but not limited to Tribal ceremonial use, Tribal gathering of natural materials, trails, signage, benches, shade structures and restroom facilities), consistent with the primary purpose an with the protection of tribal cultural resources (the Option). Fair Market Value shall be determined by a licensed real estate appraiser holding the MAI designation from the Appraisal Institute. The appraiser shall be selected jointly by PG&E and the Approved Purchaser and, if agreement cannot be reached, by the Executive Director. The cost of such appraisal shall be borne by PG&E.

E. As part of the vesting documentation for the purchase of the Property pursuant to the Option, terms shall be incorporated to require that title shall vest subject to terms and conditions ensuring that fee title to the Property is irrevocably subject to the protections for the above-referenced purposes in perpetuity. Any transfer of fee title to any successor over the lands covered under an exercise of the Option pursuant to this special condition shall require the prior written approval of the Executive Director to help ensure effectuation of and compliance with the protections described in this special condition and any Alternative Wild Cherry Canyon Alignment under Special Condition 3.

F. Nothing in this Special Condition 2.3 shall impair, diminish, or modify the leasehold rights and interests of HomeFed, LLC without its voluntarily written consent and agreement and subject to the terms of such an agreement, including but not limited to any financial and payment terms. Furthermore, nothing in this Special Condition 2.3 shall impose or be construed as imposing any limitation on HomeFed, LLC from conveying or transferring all or some of its leasehold interests to a willing and acceptable buyer of HomeFed, LLCs choosing or from pursuing any rights to use the property for any lawful purpose pursuant to the lease.

3 Offer to Dedicate New Trail Easements for Public Access A. Offer to Dedicate Recordation. Within 12 months of license approval by the Nuclear Regulatory Commission, PG&E, on behalf of itself and its subsidiaries and affiliates (as used in this special condition, PG&E), shall cause to be recorded document(s) in a form and content acceptable to the Executive Director, irrevocably offering to dedicate to a public agency or a non-profit land conservation organization that is subject to approval by a the Executive Director, floating easements for the public access trails identified as Crowbar Canyon (approximately 1.7 miles), Buchon Hills Loop (approximately 3.2 miles), Coon Creek Connector (approximately 1 mile), San Luis Bay Overlook (approximately 2.7 miles), Pecho Loop Trail (approximately 1.7 miles), Diablo Canyon Trail (approximately 9.7 miles), and South Ranch Connector (approximately 1.3 miles),

as generally depicted in Exhibit 5 [of Reference 3] (individually referred to as a Trail and collectively as the Trails). No structure or access will be required to cross the DCPP primary access road during plant operations. As an alternative to the South Ranch Connector trail, PG&E may irrevocably offer to dedicate, subject to the same conditions as with the South Ranch Connector trial, the Alternative Wild

Enclosure PG&E Letter DCL-26-006 Page 11 of 22 No. Special Condition Cherry Canyon Alignment (approximately 3.3 miles), provided that PG&E demonstrates to the Executive Director that it has the legal capacity to do so. If the South Ranch Connector option is carried forward, physical improvements associated with the DCPP primary access road crossing would be completed within 180 days of planned plant shutdown, or within 18 months of unplanned permanent plant shutdown, provided that all necessary permits have been issued in time to complete the work.

In the event that PG&E can secure public access for the Alternative Wild Cherry Canyon Alignment, PG&E shall seek Executive Director approval for the final alignment and easement width.

The floating easements shall be no less than 25 feet wide on the North Ranch lands and no less than 50 feet wide on the South Ranch lands identified in Exhibit 5 [of Reference 3] and shall specify that the trails are to be provided for multiple access uses (hiking, biking and equestrian) to the maximum extent feasible.

The recorded document(s) shall include descriptions and corresponding graphic depictions of both PG&Es entire parcel(s) and the trail easement areas prepared by a licensed surveyor and based on an on-site inspection thereof. The offers to dedicate required under this special condition (Trail OTDs) shall be recorded free of prior liens and encumbrances that the Executive Director determines may affect the interest being conveyed. The Trail OTDs shall run with the land in favor of the People of the State of California, binding all successors and assignees, and shall be irrevocable for a period of 21 years, such period running from the date of recording.

Any development, as defined in Section 30106 of the Coastal Act, that would diminish permanent public access and recreational use of the easement areas is prohibited. The Executive Director may extend, in writing, for good cause, the 12-month period for execution and recordation of the offer.

B. Alignment of Public Access Easements. Upon acceptance of the offered dedications described in Part A of this condition, the accepting entity shall determine the exact alignments of the public access trails and any necessary and reasonable restrictions to avoid significant impacts to environmental or cultural tribal resources, subject to the review and approval of the Executive Director. The determination shall be based on site-specific analyses of existing ranch roads, established cattle trails as well as cultural resource data and tribal consultation to inform the inclusion of reasonable measures for the protection of Tribal Cultural Resources (as defined in Cal. Public Resources Code § 21074), environmental and topographic conditions existing at the time and physical development related to trails to be constructed (collectively referred to as Existing Data), and may be subject to an amendment to this permit or a separate CDP, as determined by the Executive Director of the Commission. PG&E shall additionally provide Existing Data to the accepting entity (with a copy to the Executive Director) and fund additional studies for environmental, topographic, and/or cultural resources conditions concerning trails to be constructed and for which there is no Existing Data available, and provide those additional studies to the accepting entity, with a copy to the Executive Director. If the studies contain cultural resource or other

Enclosure PG&E Letter DCL-26-006 Page 12 of 22 No. Special Condition information protected as confidential under existing law, PG&E shall protect the confidentiality of that information through confidentiality agreements with the receiving entities.

C. Public Trail Access Easement Management. Once the offered dedications described in Part A of this condition have been accepted, management and maintenance of the respective easement areas and physical improvements constructed within the easement areas shall be the responsibility of the accepting entity. The accepting entity may receive assistance and enter into partnerships with public entities, conservation organizations, and nonprofit groups for the construction, management, and maintenance of the public access trails.

D. Nothing in this special condition shall be used or construed to allow anyone to interfere with any rights of public access acquired through use, coastal development permits, or other approvals.

4 Offer to Dedicate Easements for Point Buchon Trail and Pecho Coast Trail A. Offer to Dedicate Recordation. Within 12 months of license approval by the Nuclear Regulatory Commission, PG&E, on behalf of itself and its subsidiaries and affiliates (as used in this special condition, PG&E), shall cause to be recorded an irrevocable offer to dedicate a public access easement, in a form and content acceptable to the Executive Director, over the existing Point Buchon Trail (Point Buchon OTD) required under CDP No. A-3-SLO-04-035, for which a deed restriction was recorded on July 29, 2019 in San Luis Obispo County (Point Buchon Deed Restriction). Except as otherwise provided in this special condition, the Point Buchon OTD shall include the same area and the same covenants, restrictions and conditions in the Point Buchon Deed Restriction. The Point Buchon OTD shall be to a public agency or to a non-profit land conservation that is subject to approval by the Executive Director. The existing Point Buchon Deed Restriction shall remain in effect until an approved entity accepts the OTD through a binding and effective acceptance.

Within 12 months of license approval by the Nuclear Regulatory Commission, PG&E shall record an irrevocable offer to dedicate a public access easement, in a form and content acceptable to the Executive Director, over the existing Pecho Coast Trail (Pecho Coast OTD) that was required under CDP No. A-4-82-593 (Pecho Coast Trail), and under which PG&E developed and has implemented a Pecho Coast Trail Accessway Management Plan. Except as otherwise provided in this special condition, the Pecho Coast OTD shall include the same area and the same requirements, restrictions and conditions in the Pecho Coast Trail Accessway Management Plan. The Pecho Coast OTD shall be to a public agency or to a non-profit land conservation that is subject to approval by the Executive Director. In the alternative to the Pecho Coast OTD, PG&E may instead propose to modify the existing alignment for the Pecho Coast Trail (Modified Pecho Coast Trail). In that event, the Modified Pecho Coast Trail shall be included as a Trail under Special Condition 3, and PG&E shall instead follow the requirements of Special Condition 3 for an offer to dedicate a public access easement for a Modified Pecho Coast Trail.

Enclosure PG&E Letter DCL-26-006 Page 13 of 22 No. Special Condition The Pecho Coast Trail Accessway Management Plan shall remain in effect until an approved entity accepts the Pecho Coast OTD or, alternatively, until an approved entity accepts an offer to dedicate an easement for the Modified Pecho Coast Trail, through a binding and effective acceptance.

Within 30 days of recordation of the Point Buchon OTD and the Pecho Coast OTD (collectively referred to in this special condition as the OTDs), PG&E shall provide documentation to the Executive Director showing that it has recorded the OTDs with San Luis Obispo County for acceptance by a public agency or non-profit land conservation organization approved by the Executive Director. The OTDs shall be recorded free of liens and prior encumbrances that the Executive Director determines may affect the interest being conveyed. The OTDs shall run with the land in favor of the State of California, binding successors and assigns of the applicant or landowner. The OTDs shall be irrevocable for a period of 18 years, such period running from the date of recording. Any development, as defined in Section 30106 of the Coastal Act, that would diminish permanent public access and recreational use of the easement areas is prohibited. The Executive Director may extend, in writing, for good cause the 12-month period for execution and recordation of the OTDs.

B. Public Trail Access Easement Management. Once the OTDs described in this special condition have been accepted, management and maintenance of the respective easement areas and any physical improvements constructed within the easement area shall be the responsibility of the accepting entity. The accepting entity may receive assistance and enter into partnerships with public entities, conservation organizations, and nonprofit groups for the construction, management, and maintenance of the public access trails.

C. Nothing in this special condition shall be used or construed to allow anyone to interfere with any rights of public access acquired through use, coastal development permits, or other approvals.

5 Alternative Trail Alignment. Nothing in this coastal development permit shall be construed as precluding the consideration of any public trail alignment alternatives that are the subject of this permit, including alignments that may be partially or wholly located outside the easements offered pursuant to the special condition above. Any public trail alignment alternative(s) shall be as proximal as possible to the originally proposed alignment(s).

6 Easement Funding. PG&E shall provide $10 million in funding (Easement Funding) for the public access easements specified in Special Conditions 3 and 4 (Public Access Easements) for the planning, development, construction, improvement, management, maintenance, and operation of public access trails in the Public Access Easements and for stewardship of the easements specified in this permit. Furthermore, of the Easement Funding, PG&E shall provide $500,000 in funding for additional studies for environmental, topographic, and/or cultural resource conditions concerning trails to be constructed as specified in this permit and for which there is no Existing Data available; provided, however, if any funds from this $500,000 allocation are not expended within three years of

Enclosure PG&E Letter DCL-26-006 Page 14 of 22 No. Special Condition the effective date of the funding agreement, these proceeds shall be returned to PG&E for customer refunds. In addition, of the Easement Funding, PG&E shall provide $100,000 in funding for administration of the Easement Funding. Within 120 days of CDP approval, PG&E shall submit to the Executive Director for review and approval a proposed Funding Agreement, which shall include, at a minimum: (i) the amounts and eligible uses of the Easement Funding, as specified above; (ii) terms regarding the funding method and schedule; (iii) any other reasonable and necessary terms to ensure timely and effective implementation of the Easement Funding and the Public Access Easements. PG&E shall sign the agreement upon its approval by the Executive Director.

7 Supplemental Seismic Hazards Analysis. Any future CDP or CDP Amendment application for continued operations of the DCPP beyond October 31, 2030 shall be supported by a supplemental evaluation of seismic hazards at the site, using the best available science in relation to (a) the slip rate of the Hosgri fault, and (b) the fault geometry and fault slip rates of the Irish Hills faults, including but not limited to results of sensitivity analyses showing related seismic hazard impact, and will include an evaluation of the recommendations of the Independent Peer Review Panel (IPRP) for Seismic Hazard Studies of the Diablo Canyon Nuclear Power Plant, Report No. 16 (dated August 26, 2024) and the Commission Geologists October 16, 2025 Technical Memorandum (Appendix C

[of Reference 3]).

The supplemental analysis shall generate a ground motion response spectrum for the site that shall be compared to the plant design basis, and make recommendations as to whether any upgrades, repairs or modifications to plant structures or equipment are necessary to assure the non-radiological stability and structural integrity of the plant for the proposed period of extended operations. The supplemental analysis shall be made available to the IPRP and the Diablo Canyon Independent Safety Committee (DCISC) for review and comment. If the full supplemental evaluation cannot practicably be completed by the time the CDP or CDP Amendment application is submitted, it shall, at a minimum, include (1) an analysis of the ground shaking hazard at DCPP using the Hosgri Fault slip rates recommended in the IPRP and Commission Geologists reviews, (2) any other elements that have been completed, including any new data and analysis of the Irish Hills faults, and (3) a summary of planning and initiation for those remaining elements, along with a description of status and expected completion dates.

8 Future Entrainment Studies. Within 90 days of completing new entrainment studies, if any are required by the Regional Water Quality Control Board (Regional Board), PG&E shall submit all such entrainment studies, including all results, data, and other information used for the studies, to the Executive Director. The Executive Director may determine, on the basis of those studies and other related information, that DCPP operations are being conducted or having an effect on any coastal use or resource that is substantially different and more harmful than described and evaluated in this consistency certification and, as a result, is no longer consistent with the enforcement policies of the California Coastal Management Plan (CCMP), pursuant to 15 C.F.R. § 930.65. In that event, the Executive Director shall schedule a subsequent Commission hearing, with public review and comment, to seek authorization of remedial or other action to ensure consistency with the enforceable policies of the CCMP.

Enclosure PG&E Letter DCL-26-006 Page 15 of 22 No. Special Condition 9

Assumption of Risk, Waiver of Liability and Indemnity. By acceptance of this permit, PG&E acknowledges and agrees (a) that the site may be subject to hazards from coastal erosion, storm conditions, wave uprush, and tsunami runup; (b) to assume the risks to PG&E and the property that is the subject of this permit of injury and damage from such hazards in connection with this permitted development; (c) to unconditionally waive any claim of damage or liability against the Commission, its officers, agents, and employees for injury or damage from such hazards; and (d) to indemnify and hold harmless the Commission, its officers, agents, and employees with respect to the Commissions approval of the project against any and all liability, claims, demands, damages, costs (including costs and fees incurred in defense of such claims), expenses, and amounts paid in settlement arising from any injury or damage due to such hazards. The terms in this special condition shall continue to apply even if the CDP authorization becomes ineffective.

10 Liability for Costs and Attorneys Fees. PG&E shall reimburse the Coastal Commission in full for all Coastal Commission costs and attorneys fees -- including (1) those charged by the Office of the Attorney General, and (2) any court costs and attorneys fees that the Coastal Commission may be required by a court to pay - that the Coastal Commission incurs in connection with the defense of any action brought by a party other than PG&E against the Coastal Commission, its officers, employees, agents, successors and assigns challenging the approval or issuance of this permit, the interpretation and/or enforcement of permit conditions, or any other matter related to this permit. PG&E shall reimburse the Coastal Commission within 60 days of being informed by the Executive Director of the amount of such costs and fees. The Coastal Commission retains complete authority to conduct and direct the defense of any such action against the Coastal Commission. The terms of this special condition shall continue to apply even if the CDP authorization becomes ineffective.

10.1. General Deed Restriction. PRIOR TO ISSUANCE OF THE COASTAL DEVELOPMENT PERMIT, PG&E, on behalf of itself and its subsidiaries and affiliates, shall submit to the Executive Director for review and approval documentation demonstrating that the it has executed and recorded against the parcel(s) governed by this permit a deed restriction, in a form and content acceptable to the Executive Director: (1) indicating that, pursuant to this permit, the California Coastal Commission has authorized development on the subject property, subject to terms and conditions that restrict the use and enjoyment of that property; and (2) imposing the Special Conditions of this permit as covenants, conditions and restrictions on the use and enjoyment of the Property. The deed restriction shall include a legal description of the entire parcel or parcels governed by this permit. The deed restriction shall also indicate that, in the event of an extinguishment or termination of the deed restriction for any reason, the terms and conditions of this permit shall continue to restrict the use and enjoyment of the subject property so long as either this permit or the development it authorizes, or any part, modification, or amendment thereof, remains in existence on or with respect to the subject property. The Executive Director may waive the above requirement for the General Deed Restriction to be recorded prior to issuance of the Coastal Development Permit upon a showing by PG&E of good cause.

10.2. New Development Pending OTD Recordation. PG&E, on behalf of itself, its subsidiaries, affiliates, successors, and assigns, shall not seek to undertake any new

Enclosure PG&E Letter DCL-26-006 Page 16 of 22 No. Special Condition development on North and South Ranch properties (as depicted in Exhibit 4, which shall be an exhibit to the notice of intent to issue the permit), except as authorized under this permit, without the express written permission of the Executive Director, until the OTD for a conservation easement specified in Special Condition 1.1 for North Ranch properties, the deed restriction for 1,290 acres of South Ranch properties specified in Special Condition 1.2, and the conservation easement specified in Special Condition 2.1 as applicable (i.e. if the right of first refusal option is exercised) for South Ranch properties is recorded. The restrictions of this special condition shall no longer apply to the North and South Ranch properties once such OTDs are recorded against these properties, respectively.

11 Final Breakwater Repair Plan This coastal development permit (CDP) does not authorize breakwater repair activities not described in this CDPs application materials. No less than 120 days prior to the start of breakwater repair activities, PG&E shall provide, for Executive Director review, a Draft Breakwater Repair Plan. The permittee shall submit an application for a new or amended CDP for breakwater repair activities included in the Breakwater Repair Plan and not included in this CDPs application materials, unless the Executive Director determines that additional Commission authorization is not required.

No less than 90 days prior to the start of breakwater repair activities, PG&E shall provide a final version of the Breakwater Repair Plan for the review and approval of the Executive Director. Any proposed changes to the approved final plans shall be reported to the Executive Director. No changes to the approved final plans shall occur without Commission approval unless the Executive Director determines that Commission approval is not legally required.

12 Final Dock Replacement Plan No less than 90 days prior to the start of dock replacement activities, PG&E shall provide a final version of the Dock Replacement Plan for the review and approval of the Executive Director. Any proposed changes to the approved final plans shall be reported to the Executive Director. No changes to the approved final plans shall occur without Commission approval unless the Executive Director determines that Commission approval is not legally required.

13 Development Responsibilities and Debris Removal PG&E agrees to comply with the following construction related requirements for all project development that includes work in, or near, the marine environment:

A. No demolition or construction debris or waste shall be placed or stored in the water, or where it may enter sensitive habitat, receiving waters, or a storm drain, or be subject to wave, wind, rain or tidal erosion and dispersion; B. Any and all debris resulting from demolition or construction activities, and any remaining construction material, shall be stored in a designated area with appropriate stormwater BMPs to prevent leaching of material into receiving waters.

Enclosure PG&E Letter DCL-26-006 Page 17 of 22 No. Special Condition No such material may be stored onsite for more than 30 consecutive days of no demolition or construction activities. Dock demolition debris shall be removed from the water as quickly as possible in order to prevent the spread of invasive aquatic plant species, but in no case later than the end of each day; C. Demolition or construction debris and sediment shall be removed from work areas each day that demolition or construction occurs and stored in a designated area with appropriate stormwater BMPs to prevent the accumulation of sediment and other debris that may be discharged into coastal waters; D. Machinery or construction materials not essential for project improvements will not be allowed at any time in the subtidal or intertidal zones; E. If turbid conditions are generated during inwater construction that exceed naturally occurring turbidity within the Intake Cove, PG&E shall install a silt curtain to control turbidity; F. Eelgrass shall not be disturbed to the extent feasible. Anchors shall not be placed in mapped eelgrass beds; G. Floating booms will be used to contain debris discharged into coastal waters and any debris discharged will be removed as soon as possible but no later than the end of each day; H. Non buoyant debris discharged into coastal waters will be recovered by divers as soon as possible after loss; I.

All trash and debris shall be disposed in the proper trash and recycling receptacles at the end of every construction day; J. The applicant shall provide adequate disposal facilities for solid waste, including excess concrete, produced during demolition or construction; K. Debris shall be disposed of at a legal disposal site or recycled at a recycling facility.

If the disposal site is located in the coastal zone, a coastal development permit or an amendment to this permit shall be required before disposal can take place unless the Executive Director determines that no amendment or new permit is legally required; L. All stockpiles and construction materials shall be covered, enclosed on all sides, shall be located as far away as possible from drain inlets and any waterway, and shall not be stored in contact with the soil; M. Machinery and equipment shall be maintained and washed in confined areas specifically designed to control runoff. Thinners or solvents shall not be discharged into sanitary or storm sewer systems;

Enclosure PG&E Letter DCL-26-006 Page 18 of 22 No. Special Condition N. The discharge of any hazardous materials into any receiving waters shall be prohibited; O. Spill prevention and control measures shall be implemented to ensure the proper handling and storage of petroleum products and other construction materials.

Measures shall include a designated fueling and vehicle maintenance area with appropriate berms and protection to prevent any spillage of gasoline or related petroleum products or contact with runoff. The area shall be located as far away from the receiving waters and storm drain inlets as possible; P. Best Management Practices (BMPs) and Good Housekeeping Practices (GHPs) designed to prevent spillage and/or runoff of demolition or construction-related materials, and to contain sediment or contaminants associated with demolition or construction activity, shall be implemented prior to the on-set of such activity; Q. Any wood treatment used shall conform to the specifications of the American Wood Preservation Association for saltwater use. Wood treated with Creosote, CCA (Chromated Copper Arsenate), or ACA (Ammoniacal Copper Arsenate) is prohibited. No wood treated with ACZA (Ammoniacal Copper Zinc Arsenate) shall be used where it could come into direct contact with the water. All treated timber shall be free of chromium and arsenic; and R. All BMPs shall be maintained in a functional condition throughout the duration of construction activity 14 Biological Resources Monitoring. No less than 120 days before starting maintenance or repair activities authorized by this CDP, PG&E shall submit, for the review and written approval of the Executive Director, a final plan for all project development involving work in the marine environment, that includes:

A. Eelgrass Protection: No more than 60 days prior to the start of boat dock replacement activities within the marine environment, an independent third party shall perform an eelgrass survey that includes the full area of the proposed activities as well as a 150-foot wide buffer around it, and is carried out in full compliance with the California Eelgrass Mitigation Policy (CEMP) (2014) The results of the eelgrass survey shall be submitted for the review and written approval of the Executive Director no later than 15 days prior to the start of project activities.

If the Executive Director determines that the survey shows eelgrass within 150 feet of the activities, two years of post-activity monitoring shall be carried out by an independent third party per the CEMP guidelines. This monitoring shall include a post-activity eelgrass survey carried out consistent with the CEMP guidance and completed no later than 30 days following project completion as well as two annual surveys completed thereafter during the eelgrass growing season (April through October). Survey reports shall quantify eelgrass areal extent, bottom coverage, and shoot density. Surveys shall include a detailed description of the survey coverage (e.g., number, location, and type of surveys), date of survey, and any interpolation methods used in the mapping. Transects, grids, or scale bars should be expressed in meters. All post-activity eelgrass survey reports shall be submitted to the

Enclosure PG&E Letter DCL-26-006 Page 19 of 22 No. Special Condition Executive Director for review and written approval within 30 calendar days of survey completion.

Mitigation: Should the Executive Director determine that the post-activity eelgrass monitoring demonstrates loss or damage to eelgrass occurred, PG&E shall prepare an eelgrass mitigation plan consistent with the CEMP. The mitigation plan shall include provisions for achieving the required 1.2:1 mitigation ratio found within California Eelgrass Mitigation Policy. The mitigation plan, including the location of and authorization to use the mitigation site, shall be submitted to the Executive Director for review and approval no later than 60 days prior to the scheduled commencement of the mitigation work. Implementation of the mitigation plan shall require an amendment to this permit or a new coastal development permit unless the Executive Director determines that no amendment or new permit is legally required.

B. Black Abalone: PG&E shall conduct a black abalone survey where project activities associated with boat dock replacement and east breakwater repair will occur within the marine environment, as well as rocky (or otherwise hardscaped) areas and intertidal areas within 10 meters (i.e., work area). The survey shall be completed in spring within 30 days prior to activities. The survey shall be completed by a National Marine Fisheries Service (NMFS)-qualified biologist visually on foot for intertidal areas located above the mean lower low water (MLLW) datum and by a diver for intertidal areas located below MLLW and for pilings proposed for removal. The survey results, including a map showing the locations of all black abalone identified during the survey within the work area and their maximum shell length to the nearest millimeter, shall be submitted to the Executive Director for review and approval no more than 15 days prior to commencement of activities. If any survey indicates the presence of black abalone within the work area, the survey report shall include a Mitigation Plan that identifies specific methods to remove and relocate black abalone to a suitable area.

C. Invasive Species: Not earlier than 90 days nor later than 30 days prior to commencement of project activities within the marine environment, PG&E shall undertake a survey of the project area and a buffer area at least 35 feet beyond the project area to determine the presence of invasive Caulerpa species. The survey shall include a visual examination of the substrate and inspection of construction equipment. In addition, the survey shall include an inspection of other non-native and invasive aquatic species.

Within fifteen (15) business days of completion of the survey, the permittee shall submit the survey:

i.

For the review and approval of the Executive Director; and ii.

To the Surveillance Subcommittee of the Southern California Caulerpa Action Team (SCCAT). The SCCAT Surveillance Subcommittee includes other resource agencies: the California Department of Fish & Wildlife, U.S. Fish and Wildlife Service, Army Corps of Engineers, and NOAA Fisheries.

Enclosure PG&E Letter DCL-26-006 Page 20 of 22 No. Special Condition iii. To the California Department of Fish & Wildlife via the Suspect Invasive Species Sighting Report form at https://wildlife.ca.gov/Conservation/Invasives/Species/Caulerpa#reportsightings in the event that Caulerpa is found within the project or buffer areas.

If Caulerpa species or other invasive aquatic species are found within the project activity or buffer areas, the permittee shall not proceed with the project until (1) the permittee provides evidence to the Executive Director that all Caulerpa and invasive aquatic species discovered within the project and buffer area have been eliminated in a manner that complies with all applicable governmental approval requirements, including but not limited to those of the California Coastal Act, or (2) the permittee has revised the project to avoid any contact with Caulerpa and/or invasive aquatic species. No revisions to the project shall occur without a Coastal Commission approved amendment to this Coastal Development Permit unless the Executive Director determines that no amendment is legally required.

15 Marine Wildlife Protection. No less than 120 days prior to the start of maintenance or repair activities authorized by this CDP, PG&E shall submit, for the review and written approval of the Executive Director, a final plan for all project development that involves work in the marine environment:

A. Use of a marine wildlife observer (MWO) during repair of the East Breakwater and replacement of the Boat Dock. The MWO shall assure that all work vessels and project activities within the Intake Cove and adjacent to the East Breakwater maintain a distance of at least 150 feet from any marine wildlife species whenever feasible. The MWO shall identify any scenarios that require an additional observer and, in these cases, make recommendations as to where they should be placed to ensure complete coverage of the surrounding environment.

B. Specify that MWOs will issue a stop work order if project activities pose a risk to any marine mammals or sea turtles, or if any marine mammal or sea turtle enters the 33-foot exclusion zone around project activities and vessels.

C. Specify that MWOs shall have the appropriate safety and monitoring equipment adequate to conduct any project activities occurring at night (including night-vision equipment, when applicable). Night-lighting required for project activities shall be shielded and directed to the immediate work area but must be bright enough to ensure the MWO can effectively monitor, maintain navigational safety, and sustain the minimum distance of 150 feet from any marine wildlife species whenever feasible as required by Special Condition 8(a).

D. Specify that MWOs shall issue a stop work order if visibility is reduced to a degree that MWOs cannot perform observational duties. Project activities may proceed once viewing conditions improve and MWOs are able to monitor effectively.

E. During in water work associated with repair of the East Breakwater and replacement of the Boat Dock, MWOs shall submit a daily sighting report to the

Enclosure PG&E Letter DCL-26-006 Page 21 of 22 No. Special Condition Executive Director no later than noon the following day that shall be of sufficient detail to determine whether observable effects to marine mammals are occurring.

F. Work shall stop and the Executive Director of the Commission shall be notified within four hours, or as soon as practicable, if PG&E determines that any monitoring requirements in this special condition are unable to be effectively implemented. PG&E shall undertake development in conformance with the approved final plan unless the Commission amends this permit or the Executive Director issues a written determination that no amendment is legally required for any proposed modifications.

16 CPUC and/or NRC Approval. If CPUC and/or NRC approval is required prior to PG&E conveying offers to dedicate easements or recording easements or deed restrictions specified in this CDP or selling lands subject to the right of first of refusal or transferring lands specified in this CDP, PG&E shall apply to the CPUC and/or NRC within 120 days of this CDP becoming effective for such approval in compliance with statutory and regulatory requirements. If the CPUC and/or NRC do not issue any required approvals for such easement or sale, PG&E shall promptly notify the Executive Director and submit an amendment to this CDP to propose alternative mitigation. PG&E shall also seek authorization of remedial or other action in response to NRC review to ensure consistency with the enforceable policies of the CCMP.

17 Federal Clean Water Act Approvals. Within 30 days of receipt from the Central Coastal Regional Water Quality Control Board, PG&E shall submit to the Executive Director a National Pollution Discharge Elimination System (NPDES) Permit for and Clean Water Act Section 401 certification relating to extended operations of DCPP. If the Central Coast Regional Water Quality Control Board (Regional Board) does not issue any required approvals, PG&E shall promptly notify the Executive Director and submit an amendment to this CDP. PG&E shall provide a copy to the Executive Director of all reports and data of monitoring or other testing that PG&E has conducted to evaluate compliance with water quality standards pursuant to Clean Water Act requirements under its operative NPDES permit and/or Section 401 certification. If the Central Coast Regional Water Quality Control Board determines that PG&E is not in compliance with its NPDES permit or any accompanying requirements, or the Section 401 certification, the Executive Director may determine, on the basis of those studies and other related information, that an application for a CDP amendment is required. In the event that the Executive Director determines that an application for a CDP amendment is required, PG&Es application shall include an evaluation of known and expected adverse water quality and marine life impacts and propose remedial action to address those impacts, including, as appropriate, avoidance, minimization and mitigation measures.

18 CDP Term. This CDP authorizes extended operations at DCPP until October 31, 2029, for Unit 1 and October 31, 2030, for Unit 2, to coincide with the authorization that the California Public Utilities Commission issued on December 15, 2023, in Rulemaking No. 23-01-007.

After October 31, 2030, the CDP authorization for all Project activities covered in this permit shall terminate; provided however, that the mitigation terms and conditions specified in Special Conditions 1 through 10.2 shall survive termination of this CDP. Notwithstanding the foregoing, if the Nuclear Regulatory Commission denies PG&Es license renewal

Enclosure PG&E Letter DCL-26-006 Page 22 of 22 No. Special Condition application, this CDP authorization shall terminate upon that denial and the CDP authorization and, except as otherwise provided, all the CDP conditions shall be deemed ineffective. PG&E shall apply for an amendment to this CDP if it seeks to extend operations beyond the authorization dates specified herein and the California Public Utilities Commission has authorized such continued operations. PG&E shall submit such application by January 31, 2029. PG&E shall apply for an amendment to this CDP if it does not seek to extend operations beyond the authorization dates specified herein and instead proposes decommissioning or other development activities relating to DCPP.

19 Federal Consistency Authorization Term. Unless the California Public Utilities Commission denies authorization to PG&E for the extended DCPP operations beyond October 31, 2030, the concurrence in the consistency certification shall be authorized until November 2, 2044, and August 26, 2045, for DCPP Units 1 and 2, respectively, or until the license expiration dates approved by the NRC for the license renewal application if earlier than such dates. Notwithstanding the foregoing, the mitigation terms and conditions specified in Special Conditions 1 through 10.2 shall survive termination of this federal consistency authorization.