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#REDIRECT [[DCL-14-103, License Renewal Application Appendix E Applicant'S Environmental Report - Operating License Renewal Stage Amendment 1. Part 4 of 4]]
| number = ML14364A270
| issue date = 12/22/2014
| title = License Renewal Application Appendix E Applicant'S Environmental Report - Operating License Renewal Stage Amendment 1. Part 4 of 4
| author name =
| author affiliation = Pacific Gas & Electric Co
| addressee name =
| addressee affiliation = NRC/NRR
| docket = 05000275, 05000323
| license number = DPR-080, DPR-082
| contact person =
| case reference number = DCL-14-103, FOIA/PA-2016-0438
| package number = ML14364A259
| document type = Environmental Report, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 71
| project =
| stage = Other
}}
 
=Text=
{{#Wiki_filter:APPENDIX EENVIRONMENTAL REPORTAMENDMENT I4.2 ENTRAINMENT OF FISH AND SHELLFISH IN EARLY LIFE STAGESNRC"If the applicant's plant utilizes once-through cooling or cooling pond heatdissipation
: systems, the applicant shall provide a copy of current CleanWater Act 316(b) determinations...
or equivalent State permits andsupporting documentation.
If the applicant cannot provide thesedocuments, it shall assess the impact of the proposed action on fish andshellfish resources resulting from ... entrainment."
10 CFR 51.53(c)(3)(ii)(B)
"...The impacts of entrainment are small at many plants but may bemoderate or even large at a few plants with once-through and cooling-pond cooling systems.
: Further, ongoing efforts in the vicinity of theseplants to restore fish populations may increase the numbers of fishsusceptible to intake effects during the license renewal period, such thatentrainment studies conducted in support of the original license may nolonger be valid...."
10 CFR 51, Subpart A, Appendix B, Table B-I, Issue25The NRC made impacts on fish and shellfish resources resulting from entrainment aCategory 2 issue, because it could not assign a single significance level (small,moderate, or large) to the issue. The impacts of entrainment are small at manyfacilities, but may be moderate or large at others. Also, ongoing restoration efforts mayincrease the number of fish susceptible to intake effects during the period of extendedoperation (Reference 18). Accordingly, the NRC must determine the type of coolingsystem (whether one-through or cooling pond) and the status of any Clean Water ActSection 316(b) determination or equivalent state documentation.
DCPP has a once-through heat dissipation system that withdraws from and discharges to the Pacific Ocean. The general design and operational parameters of the coolingsystem are provided in Section 3.1.2.The NRC has indicated in the GElS for license renewal (Reference
: 18) that issuance ofa National Pollutant Discharge Elimination System (NPDES) Permit implies certification by the State. Consistent with the GELS, PG&E provides the current, enforceable, DCPPNPDES Permit No, CA0003751, Order 90-09 (Reference 1), as evidence of WaterQuality Certification under Clean Water Act (CWA) Section 401 (CCRWQCB, 1990)(see Attachment B). The permit issued to PG&E specifically states that the location, design, construction and capacity of cooling water intake structures at DCPP reflect theBest Technology Available (BTA) for minimizing adverse environmental impact under316(b). The permit was due to expire in 1995, and has since been in administrative extension.
PG&E is a-tively we.,ngcontinuing to work with the State Water Resources Diablo Canyon Power Plant Page 4.2-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT IControl Board (SWRCB) and Central Coast Regional Water Quality Control Board(CCRWQCB) to renew the permit. The current permit does not include anyrequirements for ongoing entrainment monitoring during power plant intake operations.
The significance of entrainment losses for early life stages of marine organisms as wellas cooling system discharge thermal impacts have been the subject of discussions between PG&E and the regulatory agency directly responsible for authorization andenforcement of plant specific NPDES requirements.
The issues have resulted inextensive communications and consultations between PG&E and the CCRWQCB.Other state agencies have also been involved in permit related consultations, including the Caliofeora Stato e.ourc. Control, (SWRCB) and the California StateDepartment of Fish and Game-Wildlife (CDFW&G).
The nature of thesecommunications and consultations are provided in the references for this Section andSection 4.4, Heat Shock.A summary of entrainment specific issues is provided in this section and theaccompanying technical data report (Reference 10). Issues related to thermaldischarge are discussed in Section 4.4. PG&E anticipates that final resolution of alloutstanding issues for both entrainment and thermal discharge impacts will occur duringthe current operating license period, and PG&E will be issued a renewed NPDESpermits prior to the period of extended operation.
The primary issue regarding entrainment is whether or not the absolute loss of larvalorganisms or eggs due to power plant cooling system operations constitutes an adverseenvironmental impact regardless of whether or not those losses result in degradation ofthe overall health of the aquatic ecosystem.
The regulatory community, including theSWRCB and CCRWQCB, has-prometedhave supported the viewpoint that absolutelosses are an adverse impact regardless of the presence or absence of detectable population level effects in the environment, and therefore entrainment reduction ormitigation measures may be warranted under any circumstances.
This has been ageneral issue throughout the electric power generation
: industry, as well as an issue ofrelevance regarding continued use of once-through cooling (OTC) systems at existingnuclear power plants that have applied for license renewal.
Generically, operators offacilities with OTC systems support the interpretation that observable population orecological level effects are the appropriate indicator of whether or not entrainment losses result in adverse environmental impacts.
This-While this issue continues to bediscussed among the generation
: industry, regulators, and ,omponents of the regulator;
..MMU.ityvarious stakeholders, the United States Environmental Protection Agency(USEPA) and the SWRCB have now adopted regulations and policies that provide acompliance framework discussed below. Final resolution of issues rolated to theSignificance of entrainment imnpacts for DCPP are pending, and current issues regarding continued use of OTC have the potential to remain open for an extended period of timRegarding the impacts of entrainment of phytoplankton and zooplankton, because ofthe large numbers and short regeneration times of plankton, and generally ubiquitous dispersion of these organisms in both nearshore and offshore marine habitat, localized Diablo Canyon Power Plant Page 4.2-2License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT Ientrainment impacts are considered to be of little ecological consequence.
: Further, anypotential effects from entrainment losses at a specific location would also not beexpected to contribute to detectable cumulative impacts in a nearshore region becausethe regeneration times of remaining non-entrained plankton are so rapid.PG&E anticipates continued operation of the existing OTC system at DCPP during theperiod of extended operation.
This is consistent with determinations regarding use ofthe installed cooling system within the Final Environmental Statement (FES) for theinitial operating license period. As such, the Environmental Report and the conclusions of individual assessments related to Aquatic Ecology are predicated on the continued exclusive use of OTC. Issues specific to NPDES Permitting of the cooling system areexpected to be resolved through the jurisdictional regulator,'
authority and associated pfOGesses-fOF-implementation and of Federal Clean Water Act the SWRCB's OTC policy for DCPP.4.2.1 STATUS OF WASTE DISCHARGE REQUIREMENTS PERMITCommercial plant operations began in May 1985 with cooling system wastewater discharges authorized under NPDES Permit No. CA0003751 Permit Order 82-54 asamended April 1983. In August 1985, the CCRWQCB issued modified NPDES PermitOrder No. 85-101. DCPP then applied for renewal of the permit, as required, prior toexpiration of Order No. 85-101.NPDES Permit No. CA0003751 Order 90-09, for DCPP Units 1 and 2, was adopted bythe CCRWQCB on May 11, 1990 with an expiration date of July 1, 1995. In accordance with Federal and State regulations (and Order 90-09 Section D. Provisions, Subsection 9), an application was submitted by PG&E for a new permit 180-days prior to theexpiration of Order 90-09 on November 7, 1994, and all applicable application fees paid.PG&E was notified on June 26, 1995 by the CCRWQCB that a timely and completeapplication for re-issuance of Permit No. CA0003751 was received, and pursuant to 40Code of Federal Regulations (CFR) Part 122.6, the existing permit order would remainvalid, enforceable, and fully effective until January 1, 1997 (Reference 2). Renewal ofthe permit was deferred pending preparation of a comprehensive final report assessing adequacy of the existing discharge thermal limits. Recommendations were beingconsidered by the CCRWQCB to modify the permit monitoring and reporting program,and a multi-agency workgroup was established to advise on the development of thecomprehensive thermal effects assessment.
These various efforts significantly impacted advancement of the permit renewal processOn August 29, 1996, PG&E was informed in a letter from the CCRWQCB that under theauthority of California State Code of Regulations (CCR) Title 23, Section 2235.4, theexisting NPDES Permit Order (90-09) would remain valid until a new permit was issuedprovided the facility complied with all requirements of the permit (Reference 3).Renewal of the permit continued to be deferred pending further development of thecomprehensive thermal impacts assessment, as well as initiation and completion of aDiablo Canyon Power Plant Page 4.2-3License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT I316(b) demonstration study developed and implemented under the direction of atechnical work group coordinated by CCRWQCB staff. The thermal assessment and316(b) demonstration study were subsequently completed, and reports submitted to theCCRWQCB.PG&E submitted an amended application for renewal of waste water discharge requirements under Permit No. CA0003751 to the CCRWQCB on January 24, 2001. Ahearing was conducted on July 23, 2003 to consider adoption of a renewed permit forDCPP Units 1 and 2. The draft updated permit was not adopted, and additional evaluations and analysis, primarily concerning alternative potential mitigation strategies to compensate for entrainment losses, were requested by the CCRWQCB.
The agencysubsequently directed a team of independent consultants to consider and developmitigation strategies for entrainment.
The consultant's draft report was presented to theCCRWQCB in a public hearing that took place in September of 2005. The draft reportconcluded that construction of a large scale artificial reef in the ocean could provide anacceptable mitigation strategy to provide in-kind compensation for larval organisms andegg loss due to operation of the power plant cooling system. Construction andmanagement of such a structure in the ocean however would likely result in projectcosts far in excess of the monetized losses caused by plant entrainment.
No further CCRWQCB-initiated activities related to renewal of the DCPP NPDES permithave occurred subsequent to the 2005 hearing.
Regulatory focus shifted to theUSEPA's development of regulations implementing Clean Water Act Section 316(b) andthe SWRCB's development of a OTC Policy to implement Section 316(b) in d.eferral o-f action has primnarilY been due to developmentn subsequent litigation surrounding the US EPA Phase 11 Rule for regulation ofimpingement and entrainment at existing pWer using ITC. Varid of facility cormplialnce provided in the initial 2C1004 PhDase IIH Rule were legallchallenged.
The Federal Second Circuit Court subsequently remanded substantial components of the rule back to US ElPA in the 2007 "RI eIkeeper I' decisin, as well asdetermined-that- costs, of compliance options versus benefits gained were notnappropriite when -eveloping cmOpliance strategies Or assessing ruleapplicabIlity.
The cost benefit portIIon f RivoIer I 11 was then subsequently appealedto the US Supremt e Curt. 1The' US Suprem Cort ruled on ! 1, 2009 that costversus benefit evaluations can be Used as a component.
Of Federal E=PA Rule mnaking,specifically as it relates, to the dev:elopment of M&E Fegulatiens.
Development andof a modified PhaIe 11 Rule by the EPA is pending.in addition to the outstanding issues involving a final Phase 11 Rule, the California SIA.RCB developed a draft State Policy in 2008 to standardize implementation of M&Eregulations by the various Regional WPater Quality Conrol1 Boards, including the,CCRWVQCB-that over-sees the DCGPP NPDE=S Permnit.
The draft state policy includesstringent requirements to implement significant M&E reduct~ios at existing power plantsalong the California Coast. The draft policy effective'ly directs facilities to implemnent 1&reductions commnensurate With closed cycle cooling (retrofit to coGolig towers)regardles~s Of cost Or technical feasibility, Or cease operations.
: However, the draft policyDiablo Canyon Power Plant Page 4.2-4License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1rui nrt lully ior all rFlWlVanT Uc~ Isse nnveing ecrGntomlt, Teaslonity OT1 e lunlnrgpermits Or licenses to implement facility moedifcation or replacement, other adyerseeenv~ieromental impacats that wou-ld- resul-t.
fromn policY imlmnatoo the overalleffects of the policy on the State's electric generation resources.
Fu~theF developmen of the policy is anlticipated to inc'ude input from an inter agency process, that wallfacdlitate re" and-of th osesues the did not adequately rad, Additionaly a 6pG,, P1GYWil;;l;,mle;edig hdevelopment of revised-Feea1Pae1 Roule. The 6CCR\.QGB has, therefoePermit pending further arations at both the Federal and State leve.'l regarding l&Eregulations for existing OTCG facilities.
Pending full resolution of outstanding regulatoIy issues involving nE, and subsequeRt final approval Of a revised permit, the existing NPDES Permit No. 0A00037-51 Ordter90 09 remains current and enfrc-eable for DCPP Units 1 and 2.USEPA issued final Section 316(b) regulations in August 2014. These regulations include separate assessments for entrainment and impingement:
a site-specific assessment for entrainment, allowing for the use of cost benefit considerations, and listof compliance options for impingement.
: However, there is exemption for facilities withvery low levels of impingement.
The cost benefit assessment was allowed after theSupreme Court's 2009 ruling in the Riverkeeper case. It should be noted that theseregulations have been challenged, so further changes may occur.In 2010, the State Board adopted a Once Through Cooling (OTC) Water Policy tostandardize implementation of I&E regulations by the various Regional Water QualityControl Boards, including the CCRWQCB that oversees the DCPP NPDES Permit. TheState Policy includes stringent requirements to implement significant I&E reductions atexisting fossil-fueled power plants along the California coast, effectively requiring reductions of at least 85 percent of flow or commensurate with closed-cycle cooling.However, the Policy acknowledges the unique contribution of the state's two nuclearplants (DCPP and Southern Califomia Edison's San Onofre Nuclear Generating Station)to meeting California's Greenhouse Gas reduction goals and creates a separateprocess for establishing OTC compliance at the two nuclear facilities.
The final Section316(b) regulations in August 2014 specify that the Califomia OTC policy is at least asstringent as the federal regulations, so it will govern Section 316(b) compliance inCalifomia.
The state's OTC Policy creates a nuclear review committee to oversee the development of an altemative technology assessment report by an independent third party consultant for each nuclear plant. Additionally, the Policy includes a variance provision whichrequires the State Board to modify the Policy to establish alternative compliance requirements for the nuclear plants if either the cost of installing alternative technologies (e.g., cooling towers) is wholly out of proportion to the costs considered by the StateBoard in adopting the Policy, or if the installation would be wholly unreasonable considering factors such as engineering, permitting, and space constraints, as wellDiablo Canyon Power Plant Page 4.2-5License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1safety concerns and adverse environmental impacts.
Mitigation is required for anyremaining impacts after implementation of the alternative requirements, with fundingprovided to the California Coastal Conservancy.
4.2.2 ONCE-THROUGH COOLING (OTC) SYSTEMSection 3.1.2 provides a general description of the DCPP OTC system. During fullpower operations, the plant circulates approximately 2.45 billion gallons (equivalent to9.275 million cubic meters) of raw seawater per day through the main steamcondensers.
Intake is from the Pacific Ocean at ambient temperature, and discharge isreturned to the Ocean approximately 20'F on average above ambient.The 3/8-inch mesh traveling debris screens located at the intake structure do not filterout or impinge microscopic phytoplankton and zooplankton, or the eggs and larval of thevast majority of marine fish and shellfish present in the source water body susceptible toentrainment in the cooling water flow. Microscopic and small organisms carried in theflow pass unobstructed through the mesh. These entrained organisms are thensubjected to pumping forces, exposure to macro-fouling cropping within the system(primarily filter feeding barnacles and mussels that populate the seawater conduitsurfaces),
rapid thermal change passing through the main steam condensers, andsignificant turbulence during discharge back to the Pacific Ocean.No specific technological or operational methods are employed to reduce entrainment offish and shellfish larvae or eggs. Losses for entrained fish and shellfish areadministratively set by agreement between PG&E and the CCRWQCB at 100 percentwhen considering entrainment impacts caused by cooling system operations.
Actuallosses for hard bodied more-durable organisms are likely much lower than 100 percent.Soft bodied organisms such as fish larvae, however, may in fact experience relatively low survival rates when transiting the system.The abundance and diversity of organisms present at any given time in the intake watercolumn, oceanographic and operational conditions, and the state of system conduitmacro fouling will affect actual entrainment losses during plant operations at any giventime. Regardless, for all regulatory and assessment
: purposes, entrainment lossescaused by DCPP are considered 100 percent of all organisms withdrawn form thePacific Ocean with the intake flow under all conditions.
Diablo Canyon Power Plant Page 4.2-6License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 14.2.3 EVALUATION OF PLANT INTAKE ENTRAINMENT AND IMPACTSThe aquatic ecosystem in the vicinity of DCPP has been extensively studied andmonitored both prior to operation of the plant, and throughout commercial operations.
DCPP has been the subject of an extensive marine ecological impacts assessment.
These studies have included extensive pre-operational evaluation and modeling, andpost-operational monitoring, of the impacts from thermal discharge to the Pacific Oceanreceiving waters at Diablo Cove. During operations, extensive monitoring has alsobeen conducted on ambient control areas North and South of the facility.
The detailedmonitoring has provided direct assessments of the abundance of multiple species oforganisms over the operational life of the facility, which provides evidence regarding population level impacts from cooling system entrainment.
The details of thermaldischarge assessment studies are included in Section 4.4.In addition to thermal impacts assessments, an extensive three-year long evaluation ofplant entrainment and source water body fish and shellfish larval diversity andabundance was conducted from 1996-1999 and submitted to the CCRWQCB inMarch 2000. Development and implementation of the study was directed by a technical work group of independent scientists established by the CCRWQCB.
The details ofdesign, implementation, study area, and the conclusions of this study are provided inthe 316(b) Demonstration Study Report (Reference 15). Descriptions of the fish andshellfish resources in the vicinity of DCPP susceptible to entrainment, including assessment of adult equivalent losses are also provided in the study report.As recommended by USEPA, the 2000 study did not evaluate entrainment ofphytoplankton and zooplankton.
This is because the large numbers of shortregeneration times of these forms of plankton and the generally ubiquitous dispersion ofthese organisms in both nearshore and offshore marine habitat.
Given thesecircumstances, localized entrainment impacts are considered to be of little ecological consequence.
Thus, the focus of the study was on the evaluation of fish and shellfish larvae.The summary conclusion from the e"densi*'.e entrainment and Source water bodyassessmeRt2000 316(b) Demonstration Study is that DCPP 4akesrentrains on averageapproximately 11 percent of the larval population susceptible to entrainment-(Nete.
dependi .on pees specific lar"al losses are generally greater than Or leso ethan 11 percent for iRdivedual species affected).
Considering the volume of watercirculated through DCPP, this results in significant absolute numbers of fish andshellfish larvae lost when the 100 percent administrative mortality estimate isappliedassumed.
Annual entrainment of larval fish is estimated to range between 1.48and 1.77 billion, dependent on flow.Though the absolute numbers are large, it is noteworthy that the natural survival rate foreggs and larvae to juvenile stages is generally
<1 percent, and survivorship to adultstage for most species is far less than 1 percent.
In terms of natural survivability, theloss of 11 percent of the available larval population on average is not significant in lightDiablo Canyon Power Plant Page 4.2-7License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1of the fact that 99 percent or more of larvae normally suffer mortality from natural factorsbefore reaching juvenile stages of development.
Biological compensation can be ...sidered moreis an important to-factor in thedevelopment and maintenance of a healthy aquatic ecological system thaR'-that cancompensate for the changes in the absolute la~vai-numbers of larvae produced eachyear. As long as habitat is present that supports successful recruitment anddevelopment of organisms from larvae stages to juvenile stages and beyond, available larvae can successfully develop to sustain stable reproductive adult populations.
This isespecially true for fishes such as the rockfishes, sculpinds, and cabezon that inhabit thenearshore rocky aquatic habitat in the area that provides for .helter and foraging forrckfish,
: sculpins, and cabazonvicinity of DCPP. These fish species are the mostprevalent in the vicinity, and therefore are also these-the most susceptible toentrainment in early life stages.Therefore, the loss of 11 percent of the larval population on average due to DCPPoperations is ultimately compensated for by the remaining 9 ..percent on ave..ge ,rvaethat remain available for recruitment to the habitat present in the vicinity and region ofDCPP. The health and viability of habitat immediately surrounding the power plant isshown in the data available from the extensive long-term ecological studies conducted in the vicinity.
During the current period of operation, available data from both DCPP-specific ecological
: studies, as well as independent studies of regional marine fisheries, provideevidence that local populations of fish susceptible to entrainment in larval stages haveremained relatively stable. In general, adult populations of individual species haveshown varying declines or increases in abundance over time that can be attributable tonumerous natural variation alonephysical and biological factors that vary in intensity from year to year. The conclusion from the extensive data from past and ongoingmonitoring has shown that overall population decreases have not occurred, and thelocal marine ecosystem remains healthy.DCPP is situated on an isolated stretch of pristine coastline with no other substantial human related influences that could negatively impact the health of the marineenvironment, with exception of limited commercial or recreational fishing.
DCPP hasprovided a unique setting for the assessment of OTC impacts.
The design capacity andactual operation of the facility define DCPP as the largest (by volume of watercirculated)
OTC system on the Pacific Coast. In addition to relative seclusion, a marineprotected area (MPA) exists to the immediate north of the facility, and a 1-mile securityexclusion zone around the plant site and extending offshore has further reduced fishingin the immediate plant vicinity since 2001. The DCPP setting has provided a relatively isolated crucible for assessing population level impacts of the large scale OTCoperation.
If DCPP operations were resulting in detrimental impacts to fish and shellfish populations in the vicinity, these impacts should be observable, even apparent, afterDiablo Canyon Power Plant Page 4.2-8License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1ever-2Oalmost 30 years of commercial operations, most of which has been at highcapacity factors -essentially maximizing potential ecological impacts.
However,population-level impacts have not been detected.
An independent study of fisheries catch data has shown that the number of rockfish caught per fisher hour in the vicinity(catch per unit effort) has remained stable, even increasing substantially in severalrecent seasons, despite the fact that the larvae of rockfish are among the species mostsusceptible to entrainment by DCPP (Reference 28). This and other similar factsprovide direct evidence that entrainment losses are not resulting in population leveleffects in the area. In summary, "The combination of length-frequency
: analyses, ETM[Empirical Transport Model] estimates, and other corroborating data support theconclusion that the local subpopulations of most nearshore taxa are not experiencing long-term declines in abundance due to entrainment" (Reference 15).4.2.4 CONSIDERATION OF CUMULATIVE ECOLOGICAL IMPACTS FROM OTCOPERATIONS Cumulative ecological impacts due to potential for additive (synergistic) impacts causedby entrainment, impingement, and thermal discharge by DCPP have been considered.
Cooling system thermal discharge
: impacts, as described in Section 4.4, are isolated toa relatively small geographic location (Diablo Cove) influenced directly by the thermalplume. Extensive thermal monitoring programs implemented throughout the history ofthe facility have shown that discharge impacts are localized, and do not result insubstantial local habitat disruption that would be necessary to cause population levelimpacts in the greater marine environment
-either in the immediate DCPP vicinity or inthe region. Degraded ecosystems and subsequent loss of species productivity andabundance can often be attributable to extensive losses of habitat available for larvalrecruitment and subsequent juvenile stage to adult development for multiple species.The limited/localized influence of the thermal discharge on the expansive rocky intertidal and rocky subtidal habitat running along the coast surrounding DCPP does not supportany conclusion that thermal impacts cause population levels effects, or any detrimental effects outside of the limited area directly influenced by the plume.Impingement impacts from DCPP operations are discussed in Section 4.3. Fish andshellfish biomass trapped on debris screens due to cooling system flow andsubsequently lost is very small both in absolute
: numbers, as well as when considered inrespect to the large volumes of water withdrawn by the plant intake. Population levelimpacts cannot be caused by DCPP impingement, because impingement lossesthemselves are insignificant.
Entrainment impacts may be less localized and have the potential to influence biological populations throughout the source water area. Due to the limited extent of DCPP'sthermal impact, and the design features that result in a small level of impingement, cumulative impacts on populations in the vicinity are expected to primarily reflectimpacts that result from entrainment.
Entrainment impacts have not been shown toresult in detectible population level effects in the vicinity of DCPP or in the region. Also,many of the fishes that are impinged, such as sharks, rays, and surfperches do notDiablo Canyon Power Plant Page 4.2-9License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT Iproduce planktonic larvae that would be subject to entrainment.
Therefore, aconclusion can be drawn that cumulative impacts from entrainment, impingement, andthermal discharge are likewise not significant 4.2.5 TECHNOLOGY OR MITIGATION MEASURES TO REDUCE ENTRAINMENT LOSSESThere have been no specific measures implemented during the initial operating licenseperiod to reduce the potential adverse impacts of entrainment.
As previously discussed, no population level or ecological system level adverse impacts have been identified.
The CRV^QGB h ly that the loss of .a..al organisms alon" mayconstitute an advore imat howeveF, this same Agency also determincd that"Regar-ding entrainment of. larp~ae in the cooling water system, the propertienal loss oflarvae; issignificant.
: However, the coests of DC-1PPmoedification oroeational changesare wA.holly to the benefit to be gained."
(Referene 4)The State OTCPolicy establishes a December 2024 deadline for DCPP to be in compliance and furtherestablishes a process to determine compliance requirements.
The policy requires theSWRCB to review the results of the Bechtel Alternatives Analysis and determine whether the costs of alternative technologies are "wholly out of proportion" to the costsconsidered by the Board in adopting the policy or if installation of alternative technologies are "wholly unreasonable" based on a number of factors including engineering, permitting, space and safety constraints, as well as adverse environmental impacts.
Any difference in impacts to marine life resulting from alternative, lessstingent requirements must be fully mitigated.
Consideration of technology or mitigation measures that have the potential to reduce oroffset entrainment losses from DCPP OTC system operations are detailed in thesupporting references for this report section (References 10, 19, and 27).As noted above, in accordance with the State's OTC policy, Bechtel was selected toprepare an alternative technologies report for the DCPP. The report developed a costassessment and schedule for each of the technically feasible
: options, including finemesh screens, offshore wedgewire
: screens, and closed-cycle cooling.
A final reportwas submitted to the SWRCB in September 2014 (Reference 27). The SWRCB isexpected to make a compliance determination by the second quarter of 2015.No available technologies, other than retrofitting DCPP to closed-cycle
: cooling, havebeen identified that could appreciably reduce entrainment losses from cooling systemoperations.
: However, retrofitting DCPP to a closed-cycle cooling system is only aconceptual possibility, and would require implementation of a project at anunprecedented scale compared to any other similar undertaking previously conducted inthe power generation industry.
Additionally, evaluation of retrofitting DCPP hasdetermined that likely insurmountable site-specific permitting, licensing, technical, andeconomic factors make such a project essentially infeasible.
There are no technology ormitigation measures available in which the costs of implementation would not be verysignificant in relation to potential benefits that could be gained (References 19 and 27).Diablo Canyon Power Plant Page 4.2-10License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1It Or unknown if implementaon of any mitigatiRn of required, durig the periodof operation would redu ce ongoin DP. entra.inment.
Any effo.t to increasethe abund"ane of larFac in the urce wate b (,uch as the GGRWQCB Gonsultaproeposal to establish an artificial reef OR the '.icinity Of DOP P1) could cause an increase inthe abundance of larwal populations susceptible to entrainment (Reference 4)-.InrGeases in abundance in the source water body could result in related inrae ntheahaui n*umkfar
,%4 inui dru Ot ih ne-"ngn system w~ithin ai given voluime ofwater-.i 1 M-.--- .. .i. 4. ..i 4 4..........!
.4.--.i* *
* V V ~I SUIUI~ -*u*
* j *. .. * * ....losses as those now exeined, ultimatel not changing the relative larval 'taeand/or impact of the power plant due to entrainment.
As population level attributable to entrainment are curently not witnessed, similarly none would beanticipated a9 any speiaGl mlnifgation strategy was in tme viclilnity.
4.
 
==2.6 CONCLUSION==
 
-IMPACTS ON FISH AND SHELLFISH RESOURCES RESULTING FROM ENTRAINMENT DURING THE PERIOD OF EXTENDEDOPERATION PG&E anticipates that current uncertainty regarding final regulator; policies regarding reduction OFr mitigation r iements for absolute entr.a;iment lasse"r resulting frompower plant cooling sytmoeations, wall be resoled through ongoing legislative andadministrative,
.procees, and ultimately the SWRCB will complete its evaluation of theBechtel study and make a compliance determination in 2015 and that the CCRWQCBwill then renew the NPDES permit, incorporating compliance findings and any requiredmitigation.
PG&E believes that the existing OTC system will continue to be considered best technology available for DCPP due to site specific considerations.
It is unknown currently what type of mitigation would ever be required for cooling systementrainment during a period of extended operation.
In a case in which mitigation wouldbe necessary to offset absolute entrainment losses, the specifics of the mitigation optionwould be developed and implemented under the guidance of the SWRQB andCCRWQCB as part of the NPDES permitting process.Based on evidence from the extensive ecological studies conducted during the initialoperating license period, entrainment losses of marine organism larvae and/or eggs donot result in observable population level impacts, and subsequently observable detrimental impacts to the overall ecological system susceptible to influence by coolingsystem withdrawal.
Therefore, entrainment impacts to marine fish and shellfish resources from operation of DCPP's OTC system during the period of extendedoperation are projected to be SMALL. Species-specific evaluations of impacts tothreatened or endangered species due to entrainment are discussed in further detail inSection 4.10.Diablo Canyon Power Plant Page 4.2-11License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT I4.3 IMPINGEMENT OF FISH AND SHELLFISH NRC"If the applicant's plant utilizes once-through cooling or cooling pond heatdissipation
: systems, the applicant shall provide a copy of current CleanWater Act 316(b) determinations..
.or equivalent State permits andsupporting documentation.
If the applicant cannot provide thesedocuments, it shall assess the impact of the proposed action on fish andshellfish resources resulting from... impingement...."
10 CFR 51.53(c)(3)(ii)(B)
"...The impacts of impingement are small at many plants but may bemoderate or even large at a few plants with once-through and cooling-pond cooling systems...."
10 CFR 51, Subpart A, Appendix B, Table B-i,Issue 26The NRC made impacts on fish and shellfish resources resulting from impingement aCategory 2 issue, because it could not assign a single significance level to the issue.Impingement impacts are small at many facilities, but might be moderate or large atother plants (Reference 18). Information that needs to be ascertained includes (1) typeof cooling system (whether once through or cooling pond) and (2) a current Clean WaterAct 316(b) determination or equivalent state documentation.
DCPP has a once-through heat dissipation system that withdraws from and discharges to the Pacific Ocean. The general design and operational parameters of the coolingsystem are provided in Section 3.1.2.As discussed in Section 4.2, the Central Coast Regional Water Quality Control Board(CCRWQCB) issued an NPDES Permit (CA0003751)
(see Attachment B) to PG&E in1990. The permit was-due-teoexpired in 1995, and has since been in administrative extension.
PG&E is aotivelycontinuing to working with the SWRCB and theCCRWQCB to renew this permit. The current permit does not include any requirements for ongoing impingement monitoring during plant intake operations.
PG&E completed an impingement assessment of the OTC system in 1986. The yearlong study concluded that impingement of all marine organisms was very low, andfurther studies have not been warranted.
The study found that impingement lossesduring full flow intake operations (4 main circulating water pumps and 2 auxiliary waterpumps in operation) amount to approximately 2.5 pounds of fish and shellfish biomassdaily for a maximum of between 900-1200 pounds of biomass on an annual basis. Thisis in comparison to intake system performance of other west coast power generation facilities using OTC in which impingement can exceed DCPP's annual biomass total ina single day, even with lower net intake withdrawal volumes at full power. The lowDiablo Canyon Power Plant Page 4.3-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT Iimpingement rates of the DCPP intake system are attributable to initial design andinstallation intended to reduce loss of fish due to impingement, as well as placement ofthe shoreline intake within an engineered protective cove. A study for the SWRCBshowed that DCPP has the lowest impingement rate of any power plant in California using coastal waters for cooling (Reference 29).In 2003, Tthe CCRWQCB staff found dete-mMiRed-that "regarding impingement of adultfish in the intake structure, the number of fish lost per year is so minor (a few hundredfish per year) that intake structure modifications or operational changes are notnecessary.
These losses are already minimized pursuant to Clean Water Act Section316(b)" (Reference 4). Additionally, as part of the 2000 316(b) Demonstration Study,the CCRWQCB's Technical Work Group reviewed the 1986 impingement study results,as well as additional data, and agreed that the low levels of impingement did notwarrant further study (Reference 13).aRnd 2 auxilia; water pmpe in operation) armount to apprOXimately 2.5 pounds of fishand Shellfish biomass al o maximum of betmAeen 000 1200 pounds of biomass onan annual basis. Thisis in comnparison to intake system pcrformance of other westcoastpoer ge erato facilities using OTCG in which Gmigmn an eXcccd DCPP1'sfull peweFe. The low iminemn raters oef thee DCPP in atake system are aftributable toinitialI dfersnn aind instaIation intendedt-to rediie 10enn~f firh d, -P to innmntp arfIan n I anana nG a~ *ka e.karn G r~a ;.-.*nL,~.
~. ,;.k ; n an ann innVl d Drotec.tive cave. Refer to theImpingement of Fish and Shellfish Technical Data Report for more information regarding intake structure design, and the results of impingement assessments conducted (Reference 9).PG&E concludes that impingement impacts to fish and shellfish resources fromoperation of the OTC system during the period of extended operation, based on thedetermination of impacts during the initial operating license period, are projected to beSMALL. Species-specific evaluations of impacts to threatened or endangered speciesdue to impingement are discussed in further detail in Section 4.10.Diablo Canyon Power Plant Page 4.3-2License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 14.4 HEAT SHOCKNRC"If the applicant's plant utilizes once-through cooling or cooling pond heatdissipation
: systems, the applicant shall provide a copy of current CleanWater Act...316(a) variance in accordance with 40 CFR 125, or equivalent State permits and supporting documentation.
If the applicant cannotprovide these documents, it shall assess the impact of the proposedaction on fish and shellfish resources resulting from heat shock..."
10 CFR51.53(c)(3)(ii)(B)
"...Because of continuing concerns about heat shock and the possibleneed to modify thermal discharges in response to changing environmental conditions, the impacts may be of moderate or large significance at someplants ....." 10 CFR 51, Subpart A, Table B-i, Issue 27The NRC made impacts on fish and shellfish resources resulting from heat shock aCategory 2 issue because of continuing concerns about thermal discharge effects andthe possible need to modify thermal discharges in the future in response to changingenvironmental conditions (Reference 18). Information to be ascertained includes(1) Type of cooling system (whether once-through or cooling pond), and (2) Evidence ofa CWA Section 316(a) variance or equivalent State documentation.
DCPP has a once-through heat dissipation system that withdraws from and discharges to the Pacific Ocean. The general design and operational parameters of the coolingsystem are provided in Section 3.1.2.As discussed in Section 4.2, the Central Coast Regional Water Quality Control Board(CCRWQCB) issued an NPDES Permit (CA0003751)
(see Attachment B) to PG&E in1990. The permit was-due-to-expired in 1995 and has since been in administrative extension.
PG&E is aGtWely-continuing to working with the SRWQCB and theCCRWQCB to renew this permit. The permit includes an effluent limit that requires thedischarge temperature be no more than 22&deg;F above the ambient receiving water andalso includes numerous narrative receiving water limits including requirements that thedischarge not cause objectionable aquatic growth or degradation of indigenous biota,degradation of marine communities, including vertebrate, invertebrate, and plantspecies and temperature of receiving water to adversely affect beneficial uses.In accordance with permit requirements, PG&E monitors discharge characteristics (including heat shock) and reports the results to the CCRWQCB.
Refer to the HeatShock Technical Data Report for more information regarding the history of studiescompleted for thermal discharge (Reference 7).Diablo Canyon Power Plant Page 4.4-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1The physical characteristics and biological effects of the DCPP thermal discharge havebeen extensively studied beginning in the mid-1 960s when the area was first considered as a power plant site. During plant operations in the initial license period, actual effectsof the thermal discharge were found to be only slightly greater in spatial extent thanpredicted, but are largely confined to the shoreline and shallow areas of Diablo Cove.The most recent completed detailed analysis of the effects of the thermal discharge using data through 2002 (Reference
: 16) showed that the nature and spatial extent ofthe effects had not increased since the previous assessment detailing changes through1995 (Reference 14). In general, pre-operational assessments have been confirmed byactual plant operations, and thermal discharge impacts are not significantly changingover time as a result of continued plant operations.
Currently, DCPP is updating the cooling system thermal discharge impacts assessment using data gathered through 2008-2013 from the ongoing Receiving Water Monitoring Program (RWMP). The final reporft from the effort expands the .econd operational period (p~erio ) data soet usred in the last comprohensiv.e analysis (Reference16 from 1995 2002 to 1995 2008. It is scheduled for completion during 4-61-2nd Quarter20-102015, and preliminary conclusions from the in-progress project are notsubstantially different from those in the earlier comprehensive reports.Continued monitoring of the marine environment influenced by the DCPP discharge isanticipated to further support previous conclusions regarding thermal impacts.
Once-through cooling system thermal effects are not significantly changing or increasing, andprotection of the beneficial uses of the receiving water will continue in the period ofextended operation.
PG&E concludes that heat shock impacts to fish and shellfish resources from operation of the OTC system during the period of extended operation, relative to thedeterminations of thermal discharge impacts during the initial operating license period,are projected to be SMALL. Species-specific evaluations of impacts to threatened orendangered species due to heat shock are discussed in further detail in Section 4.10.Diablo Canyon Power Plant Page 4.4-2License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 14.5 GROUNDWATER USE CONFLICTS (PLANTS USING >100 GPM OFGROUNDWATER)
NRC"If the applicant's plant...pumps more than 100 gallons (total onsite) ofground water per minute, an assessment of the impact of the proposedaction on groundwater use must be provided."
10 CFR 51.53(c)(3)(ii)(C)
"...Plants that use more than 100 gpm may cause ground-water useconflicts with nearby ground-water users...."
10 CFR 51, Subpart A, TableB-1, Issue 33The NRC made this groundwater use conflict a Category 2 issue because at awithdrawal rate of more than 100 gpm, a cone of depression could extend offsite.
Thiscould deplete the groundwater supply available to offsite users, creating an impact thatcould warrant mitigation.
Information needed to address this issue includes the DCPPgroundwater withdrawal rate (whether greater than 100 gpm), offsite drawdown, andimpact on neighboring wells.Based on information presented in Section 3.1.2, DCPP average1 groundwater use isless than 100 gpm. Groundwater reserves at the site are limited by the nature of theplant location, and lack of hydraulic connection with groundwater resources onproperties outside of plant controlled lands.DCPP has a groundwater well (Deep Well #2) available as a backup freshwater resource.
The deep well has a maximum capacity of 170 gpm, and a tested reliableproduction rate of 150-155 gpm that can be maintained even during drought conditions without depleting the trapped aquifer.
: However, the well is not intended to operatecontinuously, and is only in-service as needed. Average production from the well on anannual basis is projected to be 6igniftantly-less than 100 gpm during the period ofextended operation.
The estimate for total well use is approximately 12 weeks (orapproximately 350-2000 hours) on average per year at the 150 gpm production rate.Deep Well #2 will normally only be used in the event the Seawater Reverse Osmosis(SWRO) Unit freshwater production is insufficient to maintain plant makeup or firewater reserves.
This is anticipated to occur only during a non-routine period of unusually highfreshwater consumption by Unit 1 and/or Unit 2 (such as an extended dual unit forcedoutage with Units maintained in hot standby),
or during periodic planned or unplanned clearance of the SWRO. SWRO supply is generally only insufficient when the system isunavailable for an extended period of time due to scheduled equipment maintenance,
'Regulatory Guide 4.2 Supplement I Section 4.5 states that this section is applicable to plants that usemore than an annual average of 100 gpm. Thus, DCPP's evaluation is based on the annual average useof groundwater.
Diablo Canyon Power Plant Page 4.5-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1an unplanned equipment
: failure, or a system trip from a transient event such aselectrical power loss or excessive pump backpressures.
Continuous use of the well atmaximum rated capacity is therefore not anticipated during the period of extendedoperation.
The system will remain a back-up freshwater
: resource, and will be usedprimarily for SWRO backup, as well as conditioning of SWRO product waterer*y When in operation, the well draws from an isolated source specific to DCPP. Thetopography of the location precludes any connection between the well source water andoffsite water resources.
There are no neighboring wells (outside of the DCPP industrial site and adjacent controlled property) that can be impacted or made unavailable due tooperation of the onsite well. Therefore, no cone of depression can be created fromgroundwater use on the plant site that could extend offsite regardless of pumpwithdrawal rate or an extended period of withdrawal.
Further assessment of the issueof groundwater use conflicts (required for plants using more than 100 gpm groundwater) is not necessary and the impacts of this issue are SMALL.Diablo Canyon Power PlantLicense Renewal Application Page 4.5-2 APPENDIX EENVIRONMENTAL REPORTAMENDMENT I4.10 THREATENED OR ENDANGERED SPECIESNRC"Additionally, the applicant shall assess the impact of the proposed actionon threatened and endangered species in accordance with theEndangered Species Act." 10 CFR 51.53(c)(3)(ii)(E)
"Generally, plant refurbishment and continued operation are not expectedto adversely affect threatened or endangered species.
However,consultation with appropriate agencies would be needed at the time oflicense renewal to determine whether threatened or endangered speciesare present and whether they would be adversely affected."
10 CFR 51, Subpart A, Appendix B, Table B-i, Issue 49The NRC made impacts to threatened and endangered species a Category 2 issuebecause the status of many species is being reviewed continuously, and site-specific assessment is required to determine whether any identified species could be affectedby refurbishment activities or continued plant operations through the renewal period. Inaddition, compliance with the Endangered Species Act requires consultation with theappropriate federal agency (Reference 18, Sections 3.9 and 4.1).Section 2.2 describes the aquatic communities near the plant site, presents specialstatus (State and Federal) aquatic species that have the potential to occur in the vicinityof DCPP, and discusses population trends in recreationally and commercially important populations.
Section 2.4 describes important terrestrial habitats at DCPP and presentsspecial status (State and Federal) terrestrial species that have the potential to occur onthe Diablo Canyon lands. Section 2.5 discusses State- and Federally-listed threatened or endangered species that occur or may occur at-on the DCPP site (Parcel P), or alongassociated transmission corridors and potential impacts to these species.PG&E is currently unaware of any adverse issues that involve State and Federally listedthreatened or endangered specie assoc.iatod with the operation andlor mnaintenance
: ofDCPP, the existing transmission lines, towers, and access roads. PG&Ecorresponded with appropriate agencies (USFWS, CSLC, BLM, NMFS, andGDF=GCDFW) requesting information on the role each agency would expect to play inthe license renewal process and the scope of information that may be required to fulfillthose responsibilities.
Agency consultation correspondence is provided inAttachment C.As discussed in Section 3.2, PG&E has no plans to conduct refurbishment activities atDCPP during the license renewal term. Therefore, there would be no refurbishment-Diablo Canyon Power Plant Page 4.10-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1related impacts to special-status species and no further analysis of refurbishment-related impacts is warranted.
Furthermore, plant operations will continue to be conducted in accordance with theEnvironmental Protection Plan (Reference
: 30) which ensures that the plant is operatedin an environmentally acceptable manner, as established by the FES and other NRCenvironmental impact assessments.
FurthermrFe, bBecause PG&E has no plans toalter current operations, PG&E concludes that license renewal related impacts to Stateand Federally-listed threatened or endangered species from license renewal discussed below and to special status species listed in Tables 2.2-3 and 2.4-1 would be SMALLand do not warrant mitigation beyond current management programs and existingregulatory controls.
Threatened or endangered species are discussed in detail in Section 2.5. Thespecies-specific impact conclusions are summarized below:Terrestrial Species* California tiger salamander and California red-legged frog are the only terrestrial threatened or endangered species with the potential to occur on the DCPP site(Parcel P). There is only marginal habitat for these species on the DCPP siteand despite long-term monitoring and other site specific
: surveys, none have everbeen recorded on the plant site or even on the surrounding Diablo Canyon lands.In addition, there are no refurbishment or construction activities associated withDCPP license renewal.
Thus, there is no anticipated impact to these speciesdue to DCPP continued operation and PG&E concludes that impacts tothreatened or endangered terrestrial species would be SMALL.Aquatic Species* Cooling system thermal discharge
: impacts, as described in Section 4.4, areisolated to a relatively small geographic location (Diablo Cove) influenced directlyby the thermal plume. Extensive thermal monitoring programs implemented throughout the history of the facility have shown that discharge impacts arelocalized, and do not result in substantial local habitat disruption that would resultin population level impacts in the greater marine environment
-either in theimmediate DCPP vicinity or in the region. The limited/ocalized influence of thethermal discharge on the expansive rocky intertidal and rocky subtidal habitatrunning along the coast surrounding DCPP does not provide any evidence thatthermal impacts cause population levels effects, or any detrimental effectsoutside of the limited area directly influenced by the plume. Thus, PG&Econcludes that heat shock impacts to fish and shellfish resources from operation of the OTC system during the period of extended operation would be SMALL.* Discussion of potential impacts to threatened and endangered species due toimpingement and entrainment are discussed specific to each species below.* Because the NRC is responsible for licensing nuclear power plants to operate, itis their responsibility under Section 7 (a) (2) of the ESA to request consultation Diablo Canyon Power Plant Page 4.10-2License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT Ion the take of listed species during the operation of DCPP. The NMFS issued abiological opinion on the effects of continued operation of DCPP on federally listed aquatic species subsequent to formal consultation with the NRC enteredinto on July 20, 2005 (Reference 24). The biological opinion evaluated direct andindirect effects of DCPP operations over a study area including DCPP facilities, the intake and discharge structures, and the region where the discharge of warmand chlorinated water extends.
The biological opinion concluded that operation of DCPP is not likely to jeopardize federally listed green sea turtles, leatherback sea turtles, loggerhead sea turtles, and olive ridley sea turtles (Reference 24). Inaddition, blue whale, sperm whale, fin whale, humpback whale, sei whale,Guadalupe fur seal, white abalone, green sturgeon, and steelhead may be foundin the study area for limited amounts of time, but in the NMFS opinion, are notlikely to be adversely affected by DCPP operation.
Species specific conclusions of the 2006 biological opinion are provided below. While killer whale and northpacific right whale were not identified as a threatened or endangered species thatmay be present in the study area at the time the biological opinion waspublished, the effects to killer whale and north Pacific right whale would be thesame as those whale species discussed in the biological opinion and thus, PG&Econcludes killer whale and north Pacific right whale not likely to be adversely affected by DCPP operation.
Therefore, PG&E concludes impacts to thesespecies due to DCPP continued operation would be SMALL.SCCC Steelhead DPS* The Federal Register rule package identifies streams that provide habitat suitablefor this species.
Within the vicinity of DCPP, only Coon Creek, located north onthe boundary with Montana de Oro State Park, is described (Reference 25).Current freshwater habitat on the Diablo Canyon lands is not anticipated todecline with continued operations as current operation has no effect on thisdesignated critical habitat.
In contrast, beginning in 2002, PG&E partnered withthe City of San Luis Obispo, the NMFS, and the CDFW in a successful steelhead habitat restoration project on Coon Creek (Reference 26). Given that steelhead are an anadramous species (spawn in fresh water), there is no anticipated entrainment of steelhead larvae because the presence of larval steelhead in theintake cove is not likely. In addition, the likelihood of adult steelhead impingement is low due to the low uniform intake approach velocity (which allowsfish to swim away from the intake structure),
and lack of any steelhead identified in the vicinity of the intake cove in past DCPP monitoring efforts.
Therefore, incidental take is unlikely and PG&E concludes that impacts to the Federally-listed SCCC steelhead DPS from continued operations would not likely adversely affect the species, and thus, impacts will be SMALL.Tidewater Goby* No streams traversing the Diablo Canyon lands have designated critical habitatfor the tidewater goby (78 FR &sect; 8745). No suitable habitat is available in DiabloCreek, as the creek has no estuary and ascends steeply over rocky substrate Diablo Canyon Power Plant Page 4.10-3License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1from the mouth upstream, precluding the occurrence of gobies. Coon Creekpresents very limited and marginal habitat for the tidewater goby at the verymouth of the stream; however, no adult gobies are currently or historically knownto inhabit this stream. Entrainment of tidewater goby larvae is unlikely due to thelack of historical presence or potential habitat (coastal lagoon or estuary) in thevicinity of the intake cove. In addition, the likelihood of adult tidewater gobyimpingement is low due to the lack of habitat.
Tidewater gobies are uniquelyadapted to coastal lagoons and the uppermost brackish zone of larger estuaries, rarely occurring in marine habitats.
Therefore, it is highly unlikely that tidewater goby would be in the vicinity of the intake cove. This is supported by the fact thatthere are no records of adult tidewater goby presence in the vicinity of the inakecove throughout the history of DCPP operation during extensive marinemonitoring.
Therefore, incidental take is unlikely, and PG&E concludes thatimpacts to the tidewater goby from continued operations would not likelyadversely affect the species, and thus, impacts will be SMALL.Green Sturgeon* No critical habitat for the green sturgeon is designated in the vicinity of the DCPP(74 FR &sect; 52300). Given that green sturgeon are an anadramous species (spawnin fresh water), there is no anticipated entrainment of green sturgeon larvae. Inaddition, green sturgeon spawning grounds are very distant from DCPP (severalhundred miles away), with the nearest confirmed location in the Sacramento River. Therefore, the presence of larval green sturgeon in the vicinity of theintake cove is highly unlikely.
Although the marine habitat around DCPP is withinthe range of adult green sturgeon, the likelihood of adult green sturgeonimpingement is low due to the low uniform intake approach velocity (which wouldallow fish to swim away from the screens),
and the lack of any green sturgeonidentified in the vicinity of the intake cove throughout the history of DCPPoperation during extensive marine monitoring.
Therefore, incidental take isunlikely, and PG&E concludes that impacts to the green sturgeon from continued operations would not likely adversely affect the species, and thus, impacts will beSMALL.Coho Salmon* No critical habitat for the coho salmon is designated in the vicinity of the DCPP(64 FR &sect; 24049). Given that coho salmon are an anadramous species (spawn infresh water), there is no anticipated entrainment of coho salmon larvae becausepresence of larval coho salmon in the intake cove is not likely. Although themarine habitat around DCPP is within the range of adult coho salmon, thelikelihood of adult coho salmon impingement is low due to the low uniform intakeapproach velocity (which would allow fish to swim away from the screens),
andthe lack of any coho salmon identified in the vicinity of the intake cove throughout the history of DCPP operation during extensive marine monitoring.
Therefore, incidental take is unlikely, and PG&E concludes that impacts to the coho salmonDiablo Canyon Power Plant Page 4.10-4License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT Ifrom continued operations would not likely adversely affect the species, and thus,impacts will be SMALL.Southern Sea OtterSea otter populations from Point Buchon to near Point San Luis (including geographic area off the coast of DCPP) have been monitored since 1973. Thisextensive monitoring effort has identified no impact to southern sea otterpopulations from DCPP operation.
Therefore, incidental take is unlikely, andPG&E concludes that impacts to the southern sea otter from continued operations would not likely adversely affect the species, and thus, impacts will beSMALL.Guadalupe Fur Seal* Marine mammal populations off the coast of DCPP have been monitored throughout plant operation.
This monitoring effort has identified no impact toGuadalupe fur seal populations from DCPP operation.
Therefore, incidental takeis unlikely, and PG&E concludes that impacts to the Guadalupe fur seal fromcontinued operations would not likely adversely affect the species, and thus,impacts will be SMALL.Green Sea Turtle* During the period of 1977 (prior to reactor start-up and plant commercial operation) through 2014, there were 14 occurrences of a green sea turtle foundstranded in the forebay of the DCPP intake structure.
NMFS issued a Biological Opinion and Incidental Take Statement, in accordance with Section 7 of the ESA(16 U.S.C 1531 et seq.), on September 18, 2006 for the possession anddisposition of impinged or stranded sea turtles within the DCPP intake structure (Reference 24). The biological opinion on the effects of DCPP operation onfederally listed species issued by NMFS in September 2006 concluded operation of DCPP is not likely to jeopardize green sea turtles.
Sea turtles would not likelybe directly harmed by elevated water temperatures.
While it is possible thattemperature increases from thermal discharge could affect the turtle's normaldistribution or foraging patterns (as sea turtles have been known to aggregate inwarm water effluent elsewhere),
based on stranding and sighting data, therehave been no known cases of sea turtles aggregating near the DCPP discharge area. In addition, the warm water effluent does not extend to the intake coveand, therefore, would not likely modify turtle behavior near the intake structure (Reference 24). While PG&E is covered under the Biological Opinion andIncidental Take Statement for the possession and disposition of impinged orstranded sea turtles at DCPP, stranding of green sea turtles within the intakestructure at DCPP has never resulted in a green sea turtle mortality or injury, andthere has never been an instance of sea turtle impingement against the bar racksat DCPP due to the low uniform intake approach velocity.
Thus, PG&Econcludes that impacts to the green sea turtle from continued operations wouldnot likely adversely affect the species, and therefore, impacts will be SMALL.Diablo Canyon Power Plant Page 4.10-5License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1Leatherback Sea Turtle* While designated critical habitat for the leatherback turtle includes geographic area off the coast of the DCPP, in the almost 30 years since DCPP startedoperating, PG&E has never observed leatherback sea turtles in the vicinity ofDCPP. However, in the event that a leatherback sea turtle were encountered inthe vicinity of DCPP, PG&E is covered under the Biological Opinion andIncidental Take Statement for the possession and disposition of impinged orstranded sea turtles at DCPP. NMFS issued a Biological Opinion and Incidental Take Statement, in accordance with Section 7 of the ESA (16 U.S.C 1531 etseq.), on September 18, 2006 for the possession and disposition of impinged orstranded sea turtles within the DCPP intake structure (Reference 24). Thebiological opinion on the effects of DCPP operation on federally listed speciesissued by NMFS in September 2006 concluded operation of DCPP is not likely tojeopardize leatherback sea turtles.
Sea turtles would not likely be directlyharmed by elevated water temperatures.
While it is possible that temperature increases from thermal discharge could affect the turtle's normal districution orforaging patterns (as sea turtles have been known to aggregate in warm watereffluent elsewhere),
based on stranding and sighting data, there have been noknown cases of sea turtles aggregating near the DCPP discharge area. Inaddition, the warm water effluent does not extend to the intake cove and,therefore, would not likely modify turtle behavior near the intake structure (Reference 24). Based on past stranding events with green sea turtles, whichhave not resulted in an injury or mortality, there would be no anticipated injury ormortality from stranding of a leatherback.
Additionally, there would be noanticipated impingement of a leatherback sea turtle due to the low uniform intakeapproach velocity and the lack of any sea turtle impingement against the intakestructure bar racks throughout the history of DCPP operation.
Thus, PG&Econcludes that impacts to the leatherback sea turtle from continued operations would not likely adversely affect the species, and therefore, impacts will beSMALL. In addition, the limited range of the thermal plume from DCPP thermaldischarge in relation to the widespread species' range, lends to the conclusion that impacts to the species' critical habitat from DCPP thermal discharge wouldbe SMALL.Pacific Olive Ridley Sea Turtle* NMFS issued a Biological Opinion and Incidental Take Statement, in accordance with Section 7 of the ESA (16 U.S.C 1531 et seq.), on September 18, 2006 forthe possession and disposition of impinged or stranded sea turtles within theDCPP intake structure (Reference 24). The biological opinion on the effects ofDCPP operation on federally listed species issued by NMFS in September 2006concluded operation of DCPP is not likely to jeopardize olive ridley sea turtles.Sea turtles would not likely be directly harmed by elevated water temperatures.
While it is possible that temperature increases from thermal discharge couldaffect the turtle's normal distribution or foraging patterns (as sea turtles havebeen known to aggregate in warm water effluent elsewhere),
based on stranding Diablo Canyon Power Plant Page 4.10-6License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT Iand sighting data, there have been no known cases of sea turtles aggregating near the DCPP discharge area. In addition, the warm water effluent does notextend to the intake cove and, therefore, would not likely modify turtle behaviornear the intake structure (Reference 24). While PG&E is covered under theBiological Opinion and Incidental Take Statement for the possession anddisposition of impinged or stranded sea turtles at DCPP, in the almost 30 yearssince DCPP started operating, PG&E has never observed olive ridley sea turtlesin the vicinity of DCPP. However, in the event that an olive ridley sea turtle wereencountered in the vicinity of DCPP, based on past stranding events with greensea turtles, which have not resulted in an injury or mortality, there would be noanticipated injury or mortality from stranding of an olive ridley sea turtle.Additionally, there would be no anticipated impingement of an olive ridley seaturtle due to the low uniform intake approach velocity and the lack of any seaturtle impingement against the intake structure bar racks throughout the history ofDCPP operation.
Thus, PG&E concludes that impacts to the olive ridley seaturtle from continued operations would not likely adversely affect the species, andtherefore, impacts will be SMALL.Loggerhead Sea Turtle* NMFS issued a Biological Opinion and Incidental Take Statement, in accordance with Section 7 of the ESA (16 U.S. C 1531 et seq.), on September 18, 2006 forthe possession and disposition of impinged or stranded sea turtles within theDCPP intake structure (Reference 24). The biological opinion on the effects ofDCPP operation on federally listed species issued by NMFS in September 2006concluded operation of DCPP is not likely to jeopardize loggerhead sea turtles.Sea turtles would not likely be directly harmed by elevated water temperatures.
While it is possible that temperature increases from thermal discharge couldaffect the turtle's normal districution or foraging patterns (as sea turtles havebeen known to aggregate in warm water effluent elsewhere),
based on stranding and sighting data, there have been no known cases of sea turtles aggregating near the DCPP discharge area. In addition, the warm water effluent does notextend to the intake cove and, therefore, would not likely modify turtle behaviornear the intake structure (Reference 24). While PG&E is covered under theBiological Opinion and Incidental Take Statement for the possession anddisposition of impinged or stranded sea turtles at DCPP, in the almost 30 yearssince DCPP started operating, PG&E has never observed loggerhead sea turtlesin the vicinity of DCPP. However, in the event that a loggerhead sea turtle wereencountered in the vicinity of DCPP, based on past stranding events with greensea turtles, which have not resulted in an injury or mortality, there would be noanticipated injury or mortality from stranding of a loggerhead sea turtle.Additionally, there would be no anticipated impingement of aloggerhead seaturtle due to the low uniform intake approach velocity and the lack of any seaturtle impingement against the intake structure bar racks throughout the history ofDCPP operation.
Thus, PG&E concludes that impacts to the loggerhead seaturtle from continued operations would not likely adversely affect the species, andtherefore, impacts will be SMALL.Diablo Canyon Power Plant Page 4.10-7License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT IBlack Abalone" Entrainment of fish and shellfish larvae is discussed in detail in Section 4.2.While there is potential for entrainment of black abalone larvae at DCPP, thereare factors that greatly reduce the potential for entrainment to adversely impactthe species population.
The duration of time that abalone larvae are in the watercolumn where they might be subject to entrainment is limited by the shortdispersal potential for this species.
Laboratory studies at DCPP also showedthat the larval stage where dispersal is most likely to occur is limited to 10 to20 hours. Therefore, any larvae would be subject to entrainment for a limitedperiod of time and within an area limited to the direct vicinity of the intake cove,and any minimal entrainment would not adversely affect the population.
Thus,PG&E concludes impacts to the species from DCPP continued operation due toentrainment would be SMALL." Temperatures found in Diablo Cove are within the range of the optimumtemperatures for the species.
The biogeographical water temperature range ofblack abalone is from 53.6 to 770F, but they are most abundant in areas wherethe water temperature ranges from 64.4 to 71.6&deg;F (Reference 31). This is furtherdemonstrated by laboratory studies at DCPP showing tolerance of the speciesfor seawater temperatures higher than the temperatures experienced insideDiablo Cove during plant operation and abundances inside Diablo Coveremaining consistent with abundances outside Diablo Cove prior to the discovery of WS. While elevated water temperature has been demonstrated to accelerate the mortality of black abalone with withering syndrome (WS), it is not a directcause of WS. The rate of decline due to WS was greater in areas within therange of the DCPP thermal plume. However areas within the range of thethermal plume and areas outside the range of the thermal plume (other areas ofthe central coast south of Cayucos) eventually reached the same level ofabsolute population decline.
This is shown in the DCPP monitoring datadepicted in Figure 2.5-2. Therefore, PG&E concludes impacts to this speciesfrom continued DCPP thermal discharge during the renewal period would beSMALL.* There would be no anticipated impingement of juvenile or adult black abalonebecause black abalone are a sessile species, not free swimming.
In addition, black abalone do not occur within or on the submerged exterior of the intakestructure itself due to the lack of suitable protective habitat.
Thus, PG&Econcludes that impacts to black abalone from continued operation of DCPP dueto impingement would be SMALL.Diablo Canyon Power Plant Page 4.10-8License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT I4.11 AIR QUALITY DURING REFURBISHMENT (NON-ATTAINMENT AREAS)NRC"...If the applicant's plant is located in or near a nonattainment ormaintenance area, an assessment of vehicle exhaust emissions anticipated at the time of peak refurbishment workforce must be providedin accordance with the Clean Air Act as amended ....." 10 CFR51.53(c)(3)(ii)(F)
"...Air quality impacts from plant refurbishment associated with licenserenewal are expected to be small. However, vehicle exhaust emissions could be cause for concern at locations in or near nonattainment ormaintenance areas. The significance of the potential impact cannot bedetermined without considering the compliance status of each site and thenumbers of workers expected to be employed during the outage...."
10CFR 51, Subpart A, Appendix B, Table B-I, Issue 50The NRC made impacts to air quality during refurbishment a Category 2 issue becausevehicle exhaust emissions could be cause for some concern, and a general conclusion about the significance of the potential impact could not be drawn without considering thecompliance status at each site and the number of workers expected to be employedduring an outage (Reference 18). Information needed would include:
(1) the attainment status of the plant-site area, and (2) the number of additional vehicles as a result ofrefurbishment activities.
DCPP is located in a State non-attainment area for ozone and PM10 (Refer to Section2.10). The issue of air quality during refurbishment is not applicable to DCPP because,as discussed in Section 3.2, PG&E has no plans for refurbishment or other licenserenewal-related construction activities at DCPP. Further, since air emissions from thesite, including emissions from testing emergency diesel generators, is regulated by asite-specific permit (Refer to Table 9-1) based on review of emissions in order to beprotective of the State's air quality standards, impacts from continued operation areanticipated to be SMALL.Diablo Canyon Power Plant Page 4.11-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 14.17 OFFSITE LAND USE4.17.1 OFFSITE LAND USE -REFURBISHMENT NRCThe environmental report must contain "...an assessment of the impact ofthe proposed action on... land-use...
(impacts from refurbishment activities only) within the vicinity of the plant..."
10 CFR 51.53(c)(3)(ii)(I)
"...Impacts may be of moderate significance at plants in low population areas...."
10 CFR 51, Subpart A, Appendix B, Table B.-1, Issue 68"...[I]f plant-related population growth is less than 5 percent of the studyarea's total population, off-site land-use changes would be small,especially if the study area has established patterns of residential andcommercial development, a population density of at least 60 persons persquare mile, and at least one urban area with a population of 100,000 ormore within 50 miles...."
(NRC 1996)The NRC made impacts to offsite land use as a result of refurbishment activities aCategory 2 issue because land-use changes could be considered beneficial by somecommunity members and adverse by others. Local conditions to be ascertained include:
(1) plant-related population growth, (2) patterns of residential and commercial development, and (3) proximity to an urban area with a population of at least 100,000.This issue is not applicable to DCPP because, as Section 3.2 discusses, PG&E has noplans for refurbishment as a result of license renewal at DCPP.Diablo Canyon Power PlantLicense Renewal Application Page 4.17-1 APPENDIX EENVIRONMENTAL REPORTAMENDMENT 14.17.2 OFFSITE LAND USE -LICENSE RENEWAL TERMNRCThe environmental report must contain "...an assessment of the impact ofthe proposed action on ... land-use...within the vicinity of the plant..."
10CFR 51.53(c)(3)(ii)(I)
"Significant changes in land use may be associated with population andtax revenue changes resulting from license renewal."
10 CFR 51, SubpartA, Appendix B, Table B-1, Issue 69"...[I]f plant-related population growth is less than five percent of the studyarea's total population, off-site land-use changes would be small..."
(NRC1996, Section 3.7.5)"If the plant's tax payments are projected to be small, relative to thecommunity's total revenue, new tax-driven land-use changes during theplant's license renewal term would be small, especially where thecommunity has pre-established patterns of development and has providedadequate public services to support and guide development."
(NRC 1996,Section 4.7.4.1)The NRC made impacts to offsite land use during the license renewal term a Category 2issue because land-use changes may be perceived as beneficial by some community members and adverse by others. Therefore, the NRC could not assess the potential significance of site-specific offsite land-use impacts (Reference 18, Section 4.7.4.1).
Site-specific factors to be considered in an assessment of new tax-driven land-useimpacts include:
(1) the size of plant-related population growth compared to the area'stotal population, (2) the size of the plant's tax payments relative to the community's totalrevenue, (3) the nature of the community's existing land-use
: pattern, and (4) the extentto which the community already has public services in place to support and guidedevelopment.
The GElS presents an analysis of offsite land use for the renewal term that ischaracterized by two components:
population-driven and tax-driven impacts(Reference 18, Section 4.7.4.1).
4.17.2.1 Population-Related ImpactsAs discussed in Section 2.6.1, from 1970 through 20002010, the population increases inSan Luis Obispo County and Santa Barbara County were relatively large. Only a smallfraction of these increases could be attributed to construction and operation of DCPP.During the period of extended operation, PG&E has no plans to increase DCPP staffDiablo Canyon Power Plant Page 4.17-2License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT Ibecause no refurbishment-related activities required for extended operations have beenidentified.
: Further, based on the GElS case-study
: analysis, the NRC concluded that all newpopulation-driven land-use changes during the license renewal term at all nuclear plantswould be small. Population growth caused by license renewal would represent a muchsmaller percentage of the local area's total population than the percentage presented byoperations-related growth (Reference 18, Section 4.7.4.2).
4.17.2.2 Tax-Revenue-Related ImpactsThe NRC has determined that the significance of tax payments as a source of localgovernment revenue would be large if the payments are greater than 20 percent ofrevenue, moderate if the payments are between 10 and 20 percent of revenue, andsmall if the payments are less than 10 percent of revenue (Reference 18,Section 3.7.3).The NRC defined the magnitude of land-use changes as follows (Reference 18,Section 4.7.4):SMALL -very little new development and minimal changes to an area's land-usepatternMODERATE
-considerable new development and some changes to an area's land-usepatternLARGE -large-scale new development and major changes in land-use patternThe NRC further determined that, if a plant's tax payments are projected to be smallrelative to the community's total revenue, new tax-driven land-use changes would besmall, especially where the community has pre-established patterns of development and has provided adequate public services to support and guide development.
Table 2.7-1 provides a comparison of total tax payments made by PG&E to San LuisObispo County's property tax revenues.
For the 310-year period from 2004 through2-002014, PG&E's tax payments to San Luis Obispo represented about 6 percent ofthe San Luis Obispo County's total annual property tax revenues.
Using the NRC'scriteria, PG&E's tax payments are of SMALL significance to San Luis Obispo County.As stated in Section 2.6, San Luis Obispo County is a fast growing county in California (San Luis Obispo County 1980-2000-2010 population growth of ,9-74 percentcompared to Calfornia State 1980-2000-2010 population growth of 43-57 percent).
SanLuis Obispo County has a growing population and the region's economic base isincreasingly
: diverse, with a variety of industries now supplementing traditional tourist-related businesses.
Diablo Canyon Power Plant Page 4.17-3License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT IThe surrounding population and the level of commercial and industrial activity in thisregion support the conclusion that DCPP has a small impact on the local economy andtax base. The local tax base is very large and tax payments made by PG&E arecomparatively small.PG&E does not anticipate refurbishment or license renewal-related construction duringthe license renewal period. Therefore, PG&E does not anticipate any increase in theassessed value of DCPP due to refurbishment-related improvements, or any relatedtax-increase-driven changes to offsite land-use and development patterns.
Any changes to the infrastructures of San Luis Obispo County would be attributable tothe large population immigration already experienced by the County and a large pool ofresidential, industrial, and commercial tax payers.4.17.2.3 Land Use and Public Services ImpactsSan Luis Obispo County uses comprehensive land use plans and zoning andsubdivision ordinances to guide development.
These plans and ordinances have beenin place for several decades.
The ordinances promote open space preservation; protectagricultural land from urban sprawl; and provide a basis for orderly development.
Theordinances require building
: permits, conditional use permits, minor use permits, plot andsite plans, zoning clearances, and variance requests.
San Luis Obispo County has a pre-established pattern of development with controls forfuture development and has been able to provide the infrastructure needed toaccommodate this growth. DCPP's presence is not expected to directly attract supportindustries and commercial development or to encourage or deter residential development.
For these reasons, PG&E concludes that the land use impact would beSMALL. Mitigation for land-use impacts during the license renewal term would not bewarranted.
Diablo Canyon Power Plant Page 4.17-4License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT I4.18 TRANSPORTATION NRCThe environmental report must "...assess the impact of highway trafficgenerated by the proposed project on the level of service of localhighways during periods of license renewal refurbishment activities andduring the term of the renewed license."
10 CFR 51.53(c)(3)(ii)(J)
"...Transportation impacts...
are generally expected to be of smallsignificance.
: However, the increase in traffic associated with additional workers and the local road and traffic control conditions may lead toimpacts of moderate or large significance at some sites...."
10 CFR 51,Subpart A, Table B-I, Issue 70Small impacts would be associated with U.S. Transportation ResearchBoard Level of Service A, having the following condition:
"...Free flow ofthe traffic stream; users are unaffected by the presence of others."
AndLevel of Service B, having the following condition:
"...Stable flow in whichthe freedom to select speed is unaffected but the freedom to maneuver isslightly diminished...."
(NRC 1996)The NRC made impacts to transportation a Category 2 issue because impacts aredetermined primarily by road conditions existing at the time of the project, which theNRC could not forecast for all facilities (Reference 18). Local road conditions to beascertained are: (1) level of service conditions, and (2) incremental increase in trafficassociated with refurbishment activities and license renewal staff.As described in Section 3.2, no refurbishment is planned and no refurbishment impactsto local transportation are anticipated.
Further evaluation for this impact is notapplicable.
DCPP workforce currently includes approximately 14,361,440 employees.
On anominal 18-month cycle for each Unit, as many as 1,200 additional workers join thepermanent workforce during a refueling outage, which typically lasts approximately 40days. Given these employment projections and the average number of vehicles per daycurrently using the surrounding roads to DCPP (Table 2.9-1), PG&E concludes thatimpacts to transportation would be SMALL and mitigative measures would beunwarranted.
Diablo Canyon Power Plant Page 4.18-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 14.21 ENVIRONMENTAL JUSTICEFrom Regulatory Guide 4.2, Supplement 1Environmental Justice was not reviewed in NUREG-1437.
Executive Order 12898, "Federal Actions to Address Environmental Justice inMinority Populations and Low-Income Populations,"
issued on February11, 1994, is designed to focus the attention of Federal agencies on thehuman health and environmental conditions in minority and low-income communities.
The NRC Office of Nuclear Reactor Regulation (NRR) isguided in its consideration of environmental justice by Attachment 4, "NRRProcedures for Environmental Justice Reviews,"
to NRR Office Letter No.906, Revision 2, "Procedural Guidance for Preparing Environmental Assessments and Considering Environmental Issues,"
September 21,1999. NRR Office Letter No. 906 is revised periodically.
Theenvironmental justice review involves identifying off-site environmental
: impacts, their geographic locations, minority and low-income populations that may be affected, the significance of such effects and whether they aredisproportionately high and adverse compared to the population at largewithin the geographic area, and if so, what mitigative measures areavailable, and which will be implemented.
The NRC staff will perform theenvironmental justice review to determine whether there will bedisproportionately high human health and environmental effects onminority and low-income populations and report the review in its SEIS.The staffs review will be based on information provided in the ER anddeveloped during the staffs site-specific scoping process.The consideration of environmental justice is required to assure that federal programsand activities will not have "disproportionately high and adverse human health orenvironmental effects...
on minority populations and low income populations...."
Section 2.6.2 notes minority and low-income groups within a 50-mile radius of this site.As part of its environment assessment of this proposed action, PG&E has determined that the environmental impacts of renewing the DCPP license are SMALL. Thisconclusion is supported by the review of the Category 2 issues defined in 10 CFR51.53(c)(3)(ii) presented in this ER.No sigiftatdiscemable adverse impacts to the general population from the renewalof the DCPP license have been identified.
: Likewise, no unique disproportionately highor adverse impacts on minority or low-income populations would occur from theproposed action. Accordingly, no detailed review for environmental justice is necessary.
Diablo Canyon Power Plant Page 4.21-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 14.22 REFERENCES
: 1. Diablo Canyon Power Plant NPDES Permit, CA 0003751:
Order No. 90-09,Central Coast Regional Water Quality Control Board, May 1990.2. PG&E Diablo Canyon, Continuation of NPDES Permit No. CA0003751.
CentralCoast Regional Water Quality Control Board, Letter Dated June 26, 1995.3. ["regulations (Title 23, Section 2235.4) allow your permit to remain valid until thenew permit is issued"].
Central Coast Regional Water Quality Control Board,Letter Dated August 29, 1996.4. Staff Testimony for Regular Meeting of July 10, 2003 Pacific Gas and ElectricCompany's (PG&E's)
Diablo Canyon Power Plant Renewal of NPDES Permit.Central Coast Regional Water Quality Control Board, 2003.5. Transmission Line Reference Book. 345 kV and Above. Third Edition, Revised.Electric Power Research Institute.
Palo Alto, California.
2004.6. Archaeological Resources Management Plan: Diablo Canyon Site, Greenwood, Roberta S., Pacific Gas and Electric
: Company, April 1980.7. Diablo Canyon License Renewal Feasibility Study Environmental Report: HeatShock Technical Data Report. Pacific Gas and Electric
: Company, San Francisco, CA. 2008.8. Best Management Practices to Reduce Environmental Impacts.
Revision 2.Pacific Gas and Electric Company.
March 1, 2006.9. Diablo Canyon License Renewal Feasibility Study Environmental Report:Impingement of Fish and Shellfish Technical Data Report. Pacific Gas andElectric
: Company, San Francisco, CA. 2009.10. Diablo Canyon License Renewal Feasibility Study Environmental Report:Entrainment of Fish and Shellfish Technical Data Report. Pacific Gas & ElectricCompany, 2009.11. DCPP Procedure EVI.ID2, CA-SLO-2 Site Management.
Revision
: 3. Pacific Gasand Electric Company.
May 14, 2008.12. Diablo Canyon Power Plant Transmission Lines Induced Current Analyses.
Prepared by Enercon Services, Inc. for Pacific Gas and Electric Company.
2009.13. Diablo Canyon Power Plant Cooling Water Intake Structure 316(b)Demonstration.
Tenera Inc. 1988.Diablo Canyon Power Plant Page 4.22-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 114. Diablo Canyon Power Plant Thermal Effects Monitoring Program AnalysisReport. Chapter 1. Changes in the marine environment resulting from the DiabloCanyon Power Plant thermal discharge.
Prepared by Tenera Inc. for Pacific Gasand Electric
: Company, San Francisco, CA. 1997.15. Diablo Canyon Power Plant 316(b) Demonstration Report. Tenera Inc. 2000.16. Diablo Canyon Power Plant Receiving Water Monitoring Program:
1995 -2002Analysis Report. Prepared by Tenera Inc. for Pacific Gas and Electric Company,San Francisco, CA. 2002.17. Final Environmental Statement related to operation of Diablo Canyon PowerPlant Units 1 and 2. Pacific Gas & Electric
: Company, Docket Nos. 50-275 and50-323, U.S. Atomic Energy Commission.
May 1973.18. NUREG-1437:
Generic Environmental Impact Statement for License Renewal ofNuclear Plants, Volumes 1 and 2. U. S. Nuclear Regulatory Commission.
Washington, D.C. May 1996.19. Diablo Canyon Power Plant Cooling Tower Feasibility Study. Prepared byEnercon Services Inc. for Pacific Gas and Electric Company.
March 2009.20. Regulatory Guide 4.2, Supplement
: 1. Preparation of Environmental Reports forNuclear Power Plant License Renewal Applications, Revision
: 1. Office of NuclearRegulatory Research.
June 2013.21. Area DesLqnation Maps/ State and National.
California Air Resources Board.September 2012. Accessed on March 25, 2014 at:http://www.
arb. ca. gov/desiq/adm/adm.
htm22. Energqy Almanac, Database of Califomia Power Plants. California EnergyCommission.
May 1, 2014. Accessed on May 7, 2014 at:http://energyalmanac.ca.,qov/powerplants/ndex.html
: 23. Permit Compliance System (PCS) and Integrated Compliance Information System (ICIS) databases in Envirofacts.
United States Environmental Protection Agency. March 26, 2014. Accessed on May 7, 2014 at:http://www.
epa. gov/enviro/facts/pcs-icis/search.html
: 24. Endangered Species Act Section 7 Consultation, Biological
: Opinion, andIncidental Take Statement.
National Oceanic and Atmospheric Administration (NOAA) National Marine Fisheries Service (NMFS). 2006.25. 52488 Federal Register
/ Vol. 70, No. 170/ Friday, September 2, 2005 / Rulesand Regulations.
National Oceanic and Atmospheric Administration (NOAA).Department of Commerce.
2005.Diablo Canyon Power Plant Page 4.22-2License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT I26. Year 2 Monitorina Report for the Coon Creek Culvert Removal and Steelhead Passage Enhancement Project.
City of San Luis Obispo, Natural Resources Program.
2006.27. Alternative Cooling Technologies or Modification to the Existing Once-Through Cooling System for the Diablo Canyon Power Plant. Prepared for PG&E and theState Water Resources Control Board Nuclear Review Committee.
BechtelPower Corporation.
Report No. 25762-000-30H-GOIG-00001.
September 17,2014. Accessed on 11112/2014 at:http://www.swrcb.ca.gov/water issues/promrams/ocean/cwa316/rcnfpp/
: 28. Rockfish Resources of the South Central California Coast: Analysis of theResource from Partyboat Data, 1980-2005.
Stephens et al. California Cooperative Oceanic Fisheries Investigations Report, Vol. 47, 2006.29. Compilation of California Coastal Power Plant Entrainment and Impingement Estimates for California State Water Resources Control Board Staff Draft IssuePaper on Once-Through Cooling.
Prepared for Dr. Michael Foster, CoastalSolutions Group. Steinbeck, July 2008.30. Facility Operating Licenses DPR-80 and DPR-82 Diablo Canyon NuclearGenerating
: Station, Units I and 2. Appendix B: Environmental Protection Plan(Non-Radiological).
Pacific Gas & Electric Company.
August 1985.31. Endangered and Threatened Wildlife and Plants: Final Rulemaking to Designate Critical Habitat for Black Abalone.
National Marine Fisheries Service (NMFS),National Oceanic and Atmospheric Administration (NOAA). Federal Register!
Vol. 76, No. 208, pp 66806 -66844.Diablo Canyon Power PlantLicense Renewal Application Page 4.22-3 APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1CHAPTER 5 -ASSESSMENT OF NEW AND SIGNIFICANT INFORMATION NRCS...The environmental report must contain any new and significant information regarding the environmental impacts of license renewal ofwhich the applicant is aware." 10 CFR 51.53(c)(3)(iv)
The U.S. Nuclear Regulatory Commission (NRC) licenses the operation of domestic nuclearpower plants and provides for license renewal.
License renewal applications must includean environmental report (10 CFR 54.23) with the content as prescribed in 10 CFR 51. In aneffort to streamline the environmental review, the NRC has resolved most of theenvironmental issues generically and only requires an applicant's analysis of the remaining issues.While NRC regulations do not require an applicant's environmental report to containanalyses of the impacts of those environmental issues that have been generically resolved[10 CFR 51.53(c)(3)(i)],
the regulations do require that an applicant identify any new andsignificant information of which the applicant is aware [10 CFR 51.53(c)(3)(iv)].
Thepurpose of this requirement is to alert the NRC staff to such information so the staff candetermine whether to seek the Commission's approval to waive or suspend application ofthe rule with respect to the affected generic analysis.
The NRC has explicitly indicated,
: however, that an applicant is not required to perform a site-specific validation of GenericEnvironmental Impact Statement for License Renewal of Nuclear Plants (GELS) conclusions (Reference 1).New and significant information would include:* Information that identifies a significant environmental issue not covered in the GElSand codified in the regulation, or* Information that was not covered in the GElS analyses and that leads to an impactfinding different from that codified in the regulation.
The NRC does not specifically define the term "significant".
For the purpose of its review,review, PG&E used guidance available in Council on Environmental Quality (CEQ)regulations.
CEQ guidance provides that federal agencies should prepare environmental environmental impact statements for actions that would significantly affect theenvironment (40 CFR 1502.3),
focus on significant environmental issues (40 CFR 1502.1),1502.1),
and eliminate from detailed study issues that are not significant
[40 CFR1501.7(a)(3)].
The CEQ guidance includes a lengthy definition of "significantly" thatrequires consideration of the context of the action and the intensity or severity of theimpact(s)
(40 CFR 1508.27).
PG&E expects that moderate or large impacts, as defined byDiablo Canyon Power Plant Page 5-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1by the NRC, would be significant.
Chapter 4 presents the NRC definitions of "moderate" andand "large" impacts.The new and significant assessment process that PG&E used during preparation of thelicense renewal application included:
* Interviews with PG&E subject-matter experts on the validity of the conclusions inthe GElS as they relate to DCPP;" A review of internal and external documents related to environmental issues atDCPP, including, but not limited to: environmental assessments and monitoring
: reports, procedures and other management
: controls, compliance history reports,and environmental resource plans and data;" Correspondence with state and federal agencies to determine if the agencies hadconcerns not addressed in the GElS;" A review of other nuclear power plant license renewal applications for pertinent issues; and* Credit for the oversight provided by inspections of plant facilities by state andfederal regulatory agencies.
More specifically, PG&E environmental and license renewal personnel interviewed internalsubject-matter
: experts, providing them with a written list of GElS issue(s).
The interviews focused on three general and five issue-specific questions in an effort to identify any newand potentially significant information, and participants were encouraged to identify anyother information beyond that in the GElS of which they may be aware. All responses werereviewed and documented with concurrence from each individual.
As a result of this assessment, PG&E is aware of no new and significant information regarding the environmental impacts of renewing DCPP's operating licenses.
Several issues have been deemed new issues, but their impacts are not considered significant.
These issues are: (1) groundwater monitoring for tritium, (2) long-term storage of low level radioactive waste, (3) the potential-presence of athe Shoreline faultFault, 4&-45km in length, located approximately 1 km offshore, and (4) theSeptember 11, 2001 terrorist attack.TRITIUM GROUNDWATER MONITORING Tritium groundwater sampling was initiated at DCPP in 2003-2006 through theRadiological Environmental Monitoring Program (REMP). Groundwater sampling becamebecame an industry wide initiative in 2006. DCPP is committed to the NEI 07-07Groundwater Protection Initiative (GPI) and implements this initiative through a plantDiablo Canyon Power Plant Page 5-2License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT Iprocedure.
Results of this monitoring program are submitted to local, State, and FederalFederal agencies on an annual basis via the Annual Radiological Environmental Operating Operating Report (AREOR).DCPP Radiation Protection personnel undertook a review of the hydro-geological environment and the potential for a proximal receptor source for water borne pathways.
As described in Sections 2.3 and 4.5, the only groundwater that is used for drinking waterat the DCPP site is from Deep Well #2, located at a higher elevation (333.3 ft MSL) east ofthe power plant. Deep Well #2 draws from an isolated source specific to Diablo Canyonthat is replenished by flows through the alluvium near 200 ft MSL (Section 2.3). The well isonly a supplemental resource that is used as a backup to the primary Seawater ReverseOsmosis syste: tha-t...
is us. .Freshwater production from the SeawaterReverse Osmosis (SWRO) Unit is the primary drinking water source. The reverse osmosisdrinking water supply is sampled monthly by the REMP at station DWI and resultsreported in the AREOR. Potential releases of tritiated water from the operating powerplant at 85 ft MSL cannot lead to any drinking water source due to overall site hydro-geological characteristics, and the higher elevation of the aquifer replenishing the locationtapped by the deep water well. Thus, the DCPP Radiation Protection analysis concluded that DCPP site releases of tritiated water, should they occur, would not affect domesticwater sources since there is no groundwater under the DCPP site that would lead tosources of offsite drinking water. There has been no detectable plant-related tritium in anypossible sources of drinking water.Furthermore, PG&E conducted studies of tritium contribution sources around the DCPPsite from 2006-2008.
Tritium was found to "wash-out" during rain events due to gaseousreleases from the plant vents (direct rain collection and building downspouts).
Tritiumwas found to concentrate into stagnant water due to diffusion in air from the plant ventsand in condensation of air moisture in proximity to the plant vents.ki-From 2008 to 2014, PG&E has consistently discovered tritium levels in excess of400 pCi/L within French drains beneath the DCPP powerblock.
The low levels and thelocation of the tritium found in groundwater-the French drains at DCPP do not indicate aleak from the spent fuel pool or any other major-plant equipment source of tritium.Instead, the low levels are consistent with the minor tritium "wash-out" pathwaysdiscussed above.Based on the above assessments and environmental staff evaluation, it was concluded thatthe potential for the communication of contaminated waters originating at the DCPP sitewith domestic water supplies regulated, owned, managed, or certified by State and Localgovernmental bodies does not exist. Therefore, impacts associated with tritium found ingroundwater are determined to be SMALL and would not invalidate the NRC conclusions found in the DCPP FESor the GELS.Diablo Canyon Power Plant Page 5-3License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1LONG-TERM STORAGE OF LOW LEVEL RADIOACTIVE WASTEPG&E's assessment process for potentially new and significant information regarding theenvironmental impacts of renewing the DCPP operating licenses identified a potential issuerelated to long-term storage of Low Level Radioactive Waste (LLW). Specifically, after June30,2008, LLW generators and licensees in 36 States, the District of Columbia, theCommonwealth of Puerto Rico, and the U.S. Territories no longer have access to the full-service LLW disposal facility in Barnwell, South Carolina.
Consequently, many LLWgenerators stored accumulated wastes on s.t .. M t ore a portion of their LLW forF anindefinite period. This Will inclde Class and C wAqte as well as certain Class A wartestreams that do not meet the Waste aceptance criteria of the LLI, disposal facility in Clive,Utah. However, the Waste Control Specialist (WCS) LLC Facility in Texas is nowlicensed for disposal of Class A, B, and C wastes; therefore, this facility could be utilizedfor disposal of DCPP Class B and Class C wastes as needed' in the future. Disposal ofgreater than Class C waste remains the responsibility of the federal government.
The Commission also concluded in Section 6.4.4.6 of the GElS (Reference
: 2) "that there isreasonable assurance that sufficient LLW disposal capacity will be made available whenneeded for facilities to be decommissioned consistent with NRC decommissioning requirements" and that "LLW storage and disposal will have small environmental impacts."
Consequently, LLW storage and disposal is a Category 1 issue.Based on the review of the discussion of the environmental impacts of LLW storage anddisposal in the GELS, PG&E concludes that the closure of Barnwell to out-of-compact wasteand the opening of WCS is not new and-or significant information that warrants furtherdiscussion in this report. The environmental impacts of extended on-site storage areaddressed in the GELS.POTENTIAL-SHORELINE FAULTOn November 14, 2008, PG&E notified the NRCthat preliminary results from ongoingstudies by PG&E and the U.S. Geological Survey (USGS) indicate that there is a zone ofseismicity that could indicate the presence of a fault approximately 15 km in length, locatedapproximately 1 km offshore from DCPP. Subsequently, PG&E has informally referred tothis zone of seismicity as the potential-"Shoreline Fault Zone." PG&E has beencollaborating with the USGS to collect and analyze new geological, geophysical, and seismicdata to develop improved tectonic models for the central California coastal region throughthe Collaborative Research and Development Agreement.
In its November 2008 notification, PG&E informed the NRC staff that it had performed anan initial evaluation of the potential ground motion levels at DCPP from the hypothesi hypthesizedfault which concluded that these motions would be bounded by the groundground motion levels previously determined for the current licensing basis (the largerHosgri fault). In addition, PG&E stated that the tsunami hazard threat is relatively smallsince it is a strike-slip fault rather than a reverse fault and, therefore, the tsunami hazardDiablo Canyon Power Plant Page 5-4License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT Ifrom the potential-new fault is not expected to exceed the plant's design basis tsunamihazard levels.The NRC staff undertook a preliminary independent review of possible implications of thepotential-Shoreline Fault to DCPP using the initial information provided by USGSthrough PG&E. This review is documented in Research Information Letter RIL 09-001, "Preliminary Deterministic Analysis of Seismic Hazard at Diablo Canyon Nuclear Power Plant fromNewly Identified
'Shoreline Fault',"
and can be found in Agencywide Documents Access andManagement System (ADAMS) Accession No. ML090330523 (Reference 3).The NRC staff's assessment indicates that the best estimate 84th percentile deterministic seismic-loading levels predicted for a maximum magnitude earthquake on the potential Shoreline Fault are below those levels for which the plant was previously analyzed in theDCPP Long-Term Seismic Program.
Considering the results of the deterministic analyses asa whole and the current level of uncertainty, the NRC staff concludes that the postulated Shoreline Fault will not likely cause ground motions that exceed those for which DCPP hasalready been analyzed.
The NRC staff also concludes that the potential-Shoreline Fault hasa dominant strike-slip faulting mechanism.
It is highly unusual for strike-slip faulting tocause the type of significant seafloor elevation change necessary to cause a sizable tsunamiand so the NRC staff would not expect any significant changes in the tsunami hazardassessment.
PG&E submitted a comprehensive report on the Shoreline Fault to the NRC onJanuary 7, 2011 (Reference 6). The Shoreline Fault Report confirmed the seismicsafety of continued operation of Diablo Canyon.In a September 2012 report, the NRC Staff documented its review of PG&E's Shoreline Fault Report and confirmed its earlier, preliminary assessment in RIL 09-001(Reference 7). In RIL 12-01 the NRC Staff presented a conservative deterministic assessment intended to allow the NRC Staff to determine if a safety concern exists as aresult of the Shoreline fault. The NRC Staff concluded that deterministic seismic-loading levels predicted for the Shoreline fault earthquake scenarios developed andanalyzed by NRC are at, or below, those levels considered previously anddemonstrated to have reasonable assurance of safety. There NRC Staff concluded thatthe existing design basis for the plant already is sufficient to withstand those groundmotions.Between 2010 and 2013, PG&E conducted advanced seismic research by land and seato further document the seismic characteristics of the fault zones in the regionsurrounding DCPP, including the Shoreline Fault. In September 2014, PG&E submitted the results of the study to the NRC (Reference 5). Applying deterministic methodology to the updated seismic information, and consistent with prior PG&E and NRC Staffconclusions, the report concluded that the research confirmed previous analyses thatthe plant and its major components are designed to withstand and perform their safetyfunctions during and after a major seismic event. Deterministic ground motions (84thDiablo Canyon Power Plant Page 5-5License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT Ipercentile) for the Shoreline Fault scenarios are bounded by the 1977 HosgriEarthquake and the 1991 L TSP spectra for both the DCPP powerblock and the turbinebuilding.
Although the presence of the potential-Shoreline Fault offshore of DCPP is new information, based on the PG&E and NRC assessments of the petential Shoreline Fault, it is notsignificant information since the design and licensing basis evaluations of the DCPPstructures,
: systems, and components are not expected to be adversely affected.
TERRORISM The NRC has evaluated whether the environmental impacts of the September 11, 2001terrorist act need to be considered under NEPA as part of the renewed operating licensereview. The NRC has concluded, for license renewal applications, that terrorist attacks aretoo far removed from natural or expected consequences of NRC action to require anenvironmental impact analysis (Reference 4). Moreover, the NRC has nonetheless alreadyincluded a sabotage/terrorism assessment in the license renewal GElS, Chapter 5(Reference 2). The NRCconcludes (at 5-18) that "the regulatory requirements under 10CFR part 73 provide reasonable assurance that the risk from sabotage is small. Althoughthe th reat of sabotage events cannot be accurately quantified, the commission believes thatacts of sabotage are not reasonably expected.
Nonetheless, if such events were to occur,the Commission would expect that the resultant core damage and radiological releaseswould be no worse that those expected from internally initiated events."Given the inherent inability to quantify the probability of hypothetical aircraft impacts andother terrorist-initiated events, and the NRC's previous conclusion that impacts initiated byby a terrorist attack can be correlated to the generic assessment of other internally initiated severe accidents, intentional aircraft impacts and other terrorist-initiated eventsare not considered further in the DCPP environmental analysis (see Attachment F). To thethe extent necessary, the NRC can address this issue further based on information available available in agency records.Diablo Canyon Power Plant Page 5-6License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT I
 
==5.1 REFERENCES==
: 1. NUREG-1 529: Public Comments on the Proposed 10 CFR Part 51 Rule for Renewalof Nuclear Power Plant Operating Licenses and Supporting Documents:
Review ofConcerns and NRC Staff Response.
U.S. Nuclear Regulatory Commission.
Office ofNuclear Regulatory
: Research, Washington, D.C. May 1996.2. NUREG-1437:
Generic Environmental Impact Statement for License Renewal ofNuclear Plants (GELS), Volumes I and 2. U.S. Nuclear Regulatory Commission.
Washington, D.C. May 1996.3. Research Information Letter RIL 09-001. Preliminary Deterministic Analysis ofSeismic Hazard at Diablo Canyon Nuclear Power Plant from Newly Identified
'Shoreline Fault'. U.S. Nuclear Regulatory Commission.
2009. Available atAgencywide Documents Access and Management System (ADAMS) Accession No.ML090330523.
: 4. New Jersey Department of Environmental Protection
: v. U.S. Nuclear Regulatory Commission
& Amercqen Energy Company.
U.S. Court of Appeals for the ThirdCircuit.
Case 07-2271, Document 00318362723, Date Filed: 03/31/2009.
: 5. Central Coastal Califomia Seismic Imaging Proiect Report. Pacific Gas andElectric Company.
September 2014. Available at Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML14260A024 through ML14260A069.
: 6. PG&E Letter No. DCL-1 1-005, "Report on the Analysis of the Shoreline FaultZone, Central Coastal California,"
dated January 7, 2011 ("Shoreline FaultReport").
Available at ADAMS Accession No. MLI 10140431.
: 7. Research Information Letter 12-01 "Confirmatory Analysis of Seismic Hazard atthe Diablo Canyon Power Plant from the Shoreline Fault Zone" (September 2012) Available at ADAMS Accession No. ML 121230035.
Diablo Canyon Power Plant Page 5.1-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1CHAPTER 6 -SUMMARY OF LICENSE RENEWAL IMPACTS &MITIGATING ACTIONS6.1LICENSE RENEWAL IMPACTSPG&E has reviewed the environmental impacts of renewing the DCPP operating licenses and has concluded that all impacts would be SMALL and would notrequire additional mitigation.
This environmental report documents the basis forPG&E's conclusion.
Chapter 4 incorporates by reference the NRC findings forthe ,2-59 Category 1 issues that apply to DCPP, all of which have impacts thatare SMALL (Attachment A, Table A-1 and A-2). Chapter 4 also analyzesCategory 2 issues, all of which are either not applicable or have impacts thatwould be SMALL. Table 6-1 identifies the impacts that DCPP license renewalwould have on resources associated with Category 2 issues.Diablo Canyon Power PlantLicense Renewal Application Page 6.1-1 APPENDIX EENVIRONMENTAL REPORTAMENDMENT I6.2 MITIGATION NRC"The report must contain a consideration of alternatives forreducing adverse impacts..
.for all Category 2 license renewalissues..."
10 CFR 51.53(c)(3)(iii)
"The environmental report shall include an analysis that considers and balances...
alternatives available for reducing or avoidingadverse environmental effects..."
10 CFR 51.45(c) as incorporated by 10 CFR 51.53(c)(2) and 10 CFR 51.45(c)Impacts of license renewal are SMALL and would not require mitigation.
Currentoperations include monitoring activities that would likely continue during thelicense renewal term. PG&E performs routine mitigation and monitoring inaccordance with the current operating license requirements (DPR-80 andDPR-82, Appendix B) to ensure the safety of workers, the public, and theenvironment.
These activities
: include, but are not limited to:" Biological Monitoring (Proximal Marine and Terrestrial Environments)
* Radiological Environmental Monitoring Program* Once-Through Cooling System Influent and Effluent Monitoring
" Receiving Water Monitoring Program (Thermal Discharge ImpactsAssessment)
" Plant Systems Waste Water Discharge Quality Monitoring
* Diesel Fuel Oil Use and Combustion Emissions Monitoring Results of these monitoring programs are submitted to local, state, and federalagencies on a periodic basis. Additionally, the NRC periodically performsinspections and evaluates the effectiveness of the programs.
Recent NRCinspection report findings (IR 2004-009; IR 2006-013; IR 2008-009; IR 2012-004) have not identified any findings of significance.
The monitoring programs ensure that the plant's permitted emissions anddischarges are within regulatory limits and any unusual or off-normal emissions/discharges would be quickly detected, mitigating potential impacts.Therefore, this environmental report finds that no additional mitigation measuresare sufficiently beneficial as to be warranted.
Diablo Canyon Power Plant Page 6.2-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 16.3 UNAVOIDABLE ADVERSE IMPACTSNRCThe environmental report shall discuss "Any adverse environmental effects which cannot be avoided should the proposal beimplemented;"
10 CFR 51.45(b)(2) as adopted by 10 CFR51.53(c)(2)
This environmental report adopts by reference the NRC findings for applicable Category I issues, including discussions of any unavoidable adverse impacts(Attachment A, Table A-1). PG&E examined 21-24 Category 2 issues andidentified the following unavoidable adverse impacts of license renewal." Water for cooling would continue to be withdrawn from the Pacific Ocean." Waste heat from operation of DCPP would continue to be discharged to thePacific Ocean.* Small numbers of juvenile and adult fish, and some shellfish, would continueto be impinged on the intake traveling screens.* Sea turtles may occasionally be impiRgedstranded within the intakestructures.
DCPP has mitigation measures in place to minimize adverseimpacts." A small percentage of larval fish and shellfish in the cooling system sourcewater would continue to be entrained at the intake structure.
" Operation of DCPP would result in a very small increase in radioactivity inthe air and Pacific Ocean. However, fluctuations in natural background radiation would be expected to exceed the small incremental increase indose to the local population.
Operation of DCPP also would create a verylow probability of accidental radiation exposure to inhabitants of the area.* Procedures for the disposal of sanitary,
: chemical, and radioactive wastesare intended to reduce adverse impacts from these sources to acceptably low levels. Solid radioactive wastes are a product of plant operations andlong-term disposal of these materials will be required.
Based on the discussion and analyses presented in Chapter 4, PG&E expectsthat all unavoidable adverse impacts resulting from renewal of the DCPPoperating licenses would be SMALL.Diablo Canyon Power Plant Page 6.3-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT I6.4 IRREVERSIBLE AND IRRETRIEVABLE RESOURCE COMMITMENTS NRCThe environmental report shall discuss "Any irreversible andirretrievable commitments of resources which would be involved inthe proposed action should it be implemented."
10 CFR 51.45(b)(5) as adopted by 10 CFR 51.53(c)(2)
The continued operation of DCPP for the period of extended operation will resultin irreversible and irretrievable resource commitments, including the following:
* Nuclear fuel, which is consumed in the reactor and converted to radioactive waste.* The land required to store, or dispose of low-level radioactive wastesgenerated as a result of plant operations, and solid and sanitary wastesgenerated from normal industrial operations.
* PG&E's preferred approach for additional spent fuel storage is to either shipthe spent fuel to a Federal waste repository or waste reprocessing facility.
In the Agency's 1990 Waste Confidence
: findings, the NRC previously assessed its degree of confidence that radioactive wastes produced bynuclear power plants could be safely disposed of, and made 5 findings (55FR 38474, September 18, 1990). These 5 findings form the basis of theNRC's generic determination of no significant environmental impact fromtemporary storage of spent nuclear fuel. In 1999, the NRC confirmed thesefindings (64 FR 68005, December 6, 1999). In 2008, the NRC proposedupdated Waste Confidence findings (FR 59551, dated October 9, 2008),including findings that there is reasonable assurance a sufficient minedgeologic repository can reasonably be expected to be available within 50-60years beyond the licensed life for operation of any reactor to dispose of thecommercial high-level waste and spent fuel. The NRC further concluded there is reasonable assurance that, if necessary, spent fuel generated inany reactor can be stored safely without significant environmental impactsfor at least 60 years beyond the licensed life for operation (which mayinclude the term of a revised or renewed license) of that reactor in acombination of storage in its spent fuel storage basin and either onsite oroffsite independent spent fuel storage installations.
In 2014, the NRCissued a final rule on the environmental effects of continued storage ofspent nuclear fuel (73 FR 59551) and NUREG-2157, Generic Environmental Impact Statement (GElS) for Continued Storage of Spent Nuclear Fuel(Reference 2). The GElS concluded that impacts from continued storage ofspent nuclear fuel for 60 years would be SMALL. The continued storageDiablo Canyon Power Plant Page 6.4-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT Irule adopts the findings of the GElS regarding the environmental impacts ofstoring spent fuel at any reactor site after the reactor's licensed period ofoperations.
As a result, those generic impacts do not need to be re-analyzed in the environmental reviews for individual licenses.
Elemental materials that will become radioactive.
Materials used for the normal industrial operations of the plant that cannotbe recovered or recycled or that are consumed or reduced to unrecoverable forms.PG&E has not identified any activities during the license renewal term that wouldirreversibly or irretrievably commit additional resources beyond those committed during the construction and operation of DCPP during the initial operating licenseterms, and the preemption of land and consumption of materials such as thosediscussed above. Consistent with conclusions of the AEC with regard tooperations in the current license terms (Reference 1), PG&E concludes thatthese resource commitments are appropriate for the benefits gained by licenserenewal and extended DCPP operation.
Diablo Canyon Power PlantLicense Renewal Application Page 6.4-2 APPENDIX EENVIRONMENTAL REPORTAMENDMENT I
 
==6.6 REFERENCES==
: 1. Final Environmental Statement related to the Nuclear Generating StationDiablo Canyon Units 1 and 2, Docket Numbers 50-275 and 50-323, PacificGas and Electric Company.
U.S. Atomic Energy Commission.
1973.2. Generic Environmental ImDact Statement (GEIS) for Continued Stora-/e ofSpent Nuclear Fuel, NUREG-2157.
Nuclear Regulatory Commission.
September 2014.Diablo Canyon Power PlantLicense Renewal Application Page 6.6-1 APPENDIX EENVIRONMENTAL REPORTAMENDEMENT 1TABLE 6-1Sheet 1 of 5CATEGORY 2ENVIRONMENTAL IMPACTS RELATED TO LICENSERENEWAL AT DCPP1996 Revised Issue Environmental ImpactGElS GElSNo. No. g :13 17 Water use conflicts NONE. This issue does not apply(plants with cooling because DCPP does not useponds or cooling towers cooling ponds or cooling towers thatusing make-up water withdraw makeup water from a smallfrom a small river with river with no flow.25 36 Entrainment of fish and SMALL. PG&E has a currentshellfish in early life NPDES permit which constitutes stages (for plants with compliance with CWA Sectiononce-through and 316(b) requirements.
cooling pond heatdissipations systems)26 36 Impingement of fish and SMALL. PG&E has a currentshellfish in early life NPDES permit which constitutes stages (for plants with compliance with CWA Sectiononce-through and 316(b) requirements.
cooling pond heatdissipations systems)27 39 Heat shock (for plants SMALL. PG&E has a currentwith once-through and NPDES permit which constitutes cooling pond heat compliance with CWA Section33 22 Groundwater use SMALL. DCPP does not withdrawconflicts (potable, groundwater at an average rateservice water, and greater than 100 gpm.dewatering; plants thatuse >100 gpm)34 23 Groundwater use NONE. This issue does not applyconflicts (plants using because DCPP does not usecooling towers cooling towers that withdrawwithdrawing makeup makeup water from a small river.water from a small river)35 22 Groundwater use NONE. This issue does not applyconflicts (Ranney wells) because DCPP no longer usesRanney wells.
APPENDIX EENVIRONMENTAL REPORTAMENDEMENT 1TABLE 6-1Sheet 2 of 51996 Revised Issue Environmental ImpactGElS GElSNo. No.39 26 Groundwater quality NONE. This issue does not applydegradation (cooing because DCPP is not located at anponds at inland sites) inland site and does not use coolingponds.None 27 Radionuclides released SMALL. Groundwater monitoring atto groundwater DCPP was initiated in 2003 throughthe REMP. The potential for thecommunication of contaminated waters originating at the DCPP sitewith domestic water suppliesregulated, owned, managed, orcertified by State and LocalRovernmental bodies does not exist.40 28 Refurbishment impact N N im t xpect.dteEffects on terrestrial because PG&E has no p!ans toresources (non-cooling undtaW bocauso o.system impacts) lonso ronowal.SMALL. PG&E has no plans forrefurbishment or other licenserenewal-related construction activities at DCPP. DCPPoperations have had a smallimpact on terrestrial ecosystems.
The impacts to terrestrial ecosystems from continued plantoperations and maintenance areexpected to be unchanged.
Environmenta Jutk.UNone 67 Minority and low-income SMALL. The impacts of thepopulation extended operation of DCPP weredetermined to be SMALL for allissues. No disproportionately highand adverse human health orenvironmental effects on low-income or minority populations would resultfrom license renewal.49 50 Threatened or SMALL. No-effeets-The impacts onendangered species any state or federally-listed or otherspecial status plant or animalspecies, including designated criticalhabitat, are anticipated to be SMALL APPENDIX EENVIRONMENTAL REPORTAMENDEMENT 1TABLE 6-1Sheet 3 of 51996 Revised Issue Environmental ImpactGElS GElSNo. No.as a result of extending theoperating license.
PG&E does notplan to alter current operations overthe license renewal eriod.50 5 Air quality during NONE. No impacts are expectedrefurbishment (non- because PG&E will not undertake attainment and refurbishment because of licensemaintenance areas) renewal.57 60 Microbiological NONE. This issue does not applyorganisms (plants using because DCPP does not uselakes or canals, or cooling ponds, lakes, canals, orcooling towers or cooling small rivers.ponds that discharge toa small river)59 64 Electromagnetic fields, SMALL. The largest modeledacute effects induced current under the DCPPlines is less than the 5-mA limit.Therefore, the DCPP transmission lines conform to the NationalElectrical Safety Code provisions forpreventing electric shock frominduced current.63 53 Housing impacts SMALL. For the purpose of licenserenewal, PG&E does not plan onany refurbishment and does not planto add employees.
Therefore, therewill be no increased demand onhousing because of license renewal.65 54 Public services:
public SMALL. For the purpose of licenseutilities
: renewal, PG&E does not plan onany refurbishment and does not planto add employees.
Therefore, therewill be no increased demand onpublic utilities because of licenserenewal.66 54 Public services:
NONE. No impacts are expectededucation because PG&E will not undertake (refurbishment) refurbishment because of licenserenewal.68 2 Offsite land use NONE. No impacts are expected(refurbishment) because PG&E will not undertake APPENDIX EENVIRONMENTAL REPORTAMENDEMENT 1TABLE 6-1Sheet 4 of 51996 Revised Issue Environmental ImpactGElS GElSNo. No.refurbishment because of licenserenewal.69 2 Offsite land use (license SMALL. Although taxes paid by therenewal term) plant constitute a large fraction ofthe county revenue, the county hasnot shown significant offsite landuse change since DCPPconstruction.
No plant-induced changes to offsite land use areexpected from license renewal.Therefore, continued operation isexpected to have positive impacts.70 56 Public services:
SMALL. For the purpose of licensetransportation
: renewal, PG&E does not plan onany refurbishment and does not planto add employees.
Therefore, therewill be no increased demand onlocal transportation because oflicense renewal.71 51 Historic and SMALL. PG&E does not plan onarchaeological any refurbishment or transmission-resources line corridor changes because oflicense renewal.
Continued plantsite operations are not expected toim act cultural resources.
76 66 Severe accidents SMALL. The benefit/cost analysisdid not identify any cost-effective aging-related severe accidentmitigation alternatives.
APPENDIX EENVIRONMENTAL REPORTAMENDEMENT 1TABLE 6-1Sheet 5 of 51996 Revised Issue Environmental ImpactGElS GElSNo. No.N/A 73 Cumulative Impacts SMALL. Evaluations of thegroundwater, air, threatened orendangered
: species, criticalhabitats, cultural resources, socioeconomics, and radiological doses concluded that all impactsfrom DCPP are SMALL. DCPPoperations will not change duringthe license renewal term.Radiological doses are limited byregulation.
Threatened orendangered species and culturalresources are protected by stateand federal regulations.
The Countyof San Luis Obispo expects growthduring the license renewal term andis planning for growth. However, nodevelopment would occur within theapproximately 12,000 acres of landadjoining the DCPP, such that nocumulative impacts to theseresources would occur.
APPENDIX EENVIRONMENTAL REPORTAMENDMENT ICHAPTER 9 -STATUS OF COMPLIANCE 9.1 PROPOSED ACTIONNRC"The environmental report shall list all Federal permits,
: licenses, approvals and other entitlements which must be obtained in connection with theproposed action and shall describe the status of compliance withapplicable environmental quality standards and requirements including, but not limited to, applicable zoning and land-use regulations, and thermaland other water pollution limitations or requirements which have beenimposed by Federal, State, regional, and local agencies havingresponsibility for environmental protection..."
10 CFR 51.45(d) as adoptedby 10 CFR 51.53(c)(2) 9.1.1 GENERALTable 9-1 lists environmental authorizations that PG&E has obtained for current DCPPoperations.
In this context, PG&E uses "authorizations" to include any permits,licenses, approvals, or other entitlements.
PG&E expects to continue renewing theseauthorizations during the current license period. PG&E is in compliance with applicable environmental standards and requirements.
Table 9-2 lists additional environmental authorizations and consultations related to NRCrenewal of the DCPP licenses to operate.
As indicated, PG&E anticipates needingrelatively few such authorizations and consultations.
Sections 9.1.2 through 9.1.5discuss some of these items in more detail.9.1.2 THREATENED OR ENDANGERED SPECIESSection 7 of the Endangered Species Act (16 USC 1536) requires federal agencies toensure that agency action is not likely to jeopardize any species that is listed orproposed for listing as threatened or endangered.
If review of the proposed actionindicates the potential for adversely affecting listed or candidate
: species, the federalagency must consult with the U.S. Fish and Wildlife Service (USFWS) regarding effectson non-marine
: species, the National Marine Fisheries Service (NMFS) for marinespecies, or both. USFWS and NMFS have issued joint procedural regulations at50 CFR 402, Subpart B, that address consultation, and USFWS maintains the joint listof threatened and endangered species at 50 CFR 17.Although not required by federal law or NRC regulation, PG&E has chosen to invitecomment from federal and state agencies regarding potential effects that DCPP licenserenewal might have. Attachment C includes copies of PG&E correspondence withDiablo Canyon Power Plant Page 9-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT IUSFWS, NMFS, California Department of Fish and WildlifeGame (CDF&GW),
StateLands Commission (CSLC), and Bureau of Land Management (BLM).9.1.3 HISTORIC PRESERVATION Section 106 of the National Historic Preservation Act (16 USC 470f) requires federalagencies having the authority to license any undertaking to, prior to issuing the license,take into account the effect of the undertaking on historic properties and to afford theAdvisory Council on Historic Preservation an opportunity to comment on theundertaking.
Although not of an applicant by federal law or NRC regulation-,
PG&E has Ghesen-to-invited comment by the California SHPO. Attachment D includesa copy of PG&E correspondence with the SHPO regarding potential effects that DCPPlicense renewal might have on cultural resources.
The SHPO requested that DCPPdevelop a Programmatic Agreement and Historic Resources Management Plan toreplace the current Archaeological Resources Management Plan.9.1.4 COASTAL ZONE MANAGEMENT PROGRAM COMPLIANCE The federal Coastal Zone Management Act (16 USC 1451 et seq.) imposesrequirements on applicants for a federal license to conduct an activity that could affect astate's coastal zone. The Act requires the applicant to certify to the licensing agencythat the proposed activity would be consistent with the state's federally approvedcoastal zone management program [16 USC 1456(c)(3)(A)].
The National Oceanic andAtmospheric Administration has promulgated implementing regulations that indicate thatthe requirement is applicable to renewal of federal licenses for activities not previously reviewed by the state [15 CFR 930.51(b)(1)].
The regulation requires that the licenseapplicant provide its certification to the federal licensing agency and a copy to theapplicable state agency [15 CFR 930.57(a)].
California has a coastal zone management program and DCPP, located in San LuisObispo County, is within the California coastal zone. Therefore, concurrence from theCalifornia Coastal Commission (CCC) is necessary.
The original certification preparedby PG&E is in Attachment E. PG&E is awaiting concurrence of the certification by theGGC The response from the CCC, dated December 29, 2009, is also provided inAttachment E.9.1.5 WATER QUALITY (401) COMPLIANCE Federal Clean Water Act (CWA) Section 401 requires an applicant for a federal licenseto conduct an activity that might result in a discharge into navigable waters to providethe licensing agency a certification from the state that the discharge will comply withapplicable Clean Water Act requirements (33 USC 1341). NRC has indicated in itsGeneric Environmental Impact Statement for License Renewal (GELS) (Reference 1)that issuance of a National Pollutant Discharge Elimination System (NPDES) permita mpies is considered certification by the state.Diablo Canyon Power Plant Page 9-2License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT IConsistent with the GELS, PG&E is providing DCPP's NPDES permit, in Attachment B,as evidence of state water quality (401) certification.
As discussed in Section 4.2, theCentral Coast Regional Water Quality Control Board (CCRWQCB) issued a NPDESPermit (CA0003751) to PG&E in 1990. The permit was due to expire in 1995 and hassince been in administrative extension.
PG&E is aGtiVeycontinuing to working with theCCRWQCB and the SWRCB to renew this permit. In accordance with permitrequirements, PG&E monitors discharge characteristics and reports the results to theCCRWQCB.Diablo Canyon Power PlantLicense Renewal Application Page 9-3 APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1TABLE 9-1Page 1 of 6ENVIRONMENTAL AUTHORIZATIONS FOR CURRENT DCPP OPERATIONS Issue orAgency Authority Requirement Number Expiration Date' Activity CoveredU.S. NuclearRegulatory Commission Central CoastRegional WaterQuality ControlBoardState WaterResources ControlBoardAtomic Energy Act(42 USC 2011, etseq.), 10 CFR50.10Clean Water Act(33 USC 1251 etseq.)State of California License to OperateDPR- 80 -Unit 1DPR- 82 -Unit 2California Pollutant Discharge Elimination SystemPermitState GeneralIndustrial StormWater Discharge CA0003751 97-03-DWQ Issued 11/02/1984 Expires 11/02/2024 Issued 11/26/1985 Expires 08/26/2025 Issued 05/11/1990 Expired 07/01/1995 (in administrative extension)
Renewed AnnuallyOperation of Units 1and 2State LandsCommission State LandsCommission Department ofInteriorCalifornia Department ofToxic Substances ControlPublic Resources Code 4307.91Public Resources Code 4449.91Bureau of LandManagement Ca H&S CodeSection 25200,CCR Title 22Division 4.5.LeaseRight-of-Way Right-of-Way RCRA Equivalent Waste Treatment Storage & Disposal(TSDF) Permit2231-10-0044 2231-10-0048 2231-10-0041 CAD077966349 Issued 08/28/1969 Expires 08/28/2018 Issued 06/01/1970 Expires 06/01/2019 Issued 08/22/1969 Renewed 06/17/2014 Expires0822/2018122/31/2042 Issued 11/16/2006 Expires 07/30/2016 Plant discharges tothe Pacific OceanStorm waterdischarges toDiablo Creek andthe Pacific OceanLease forBreakwaters Right-of-Way forBreakwaters Right-of-Way forConstruction andMaintenance ofBreakwaters Operation ofHazardous WasteFacility at DCPP1 Issuance and expiration dates are accurate as of 08/30/2009.
APPENDIX EENVIRONMENTAL REPORTAMENDMENT ITABLE 9-1Page 2 of 6ENVIRONMENTAL AUTHORIZATIONS FOR CURRENT DCPP OPERATIONS Issue orAgency Authority Requirement Number Expiration Date' Activity CoveredSan Luis ObispoCountyEnvironmental Health Department San Luis ObispoCountyEnvironmental Health Department National MarineFisheries ServiceSan-Luis-ObispG-Geunty~Diet~iit40 CFR 112 (et.seq.)CA H&S Code19 CCR (et. seq.)22 CCR (et. seq.)23 CCR (et. seq.)NIACA H&S Code19 CCR (et. seq.)22 CCR (et. seq.)23 CCR (et. seq.)Endangered Species Act of1973 (16 USC1531-1544)AiF At (-42USC 7-01, et sog.)Permit to Operate0301 PR0002823 (UST)0728 PR0002022 (HM)1126 PR0002512 (HW91201 PR0015253 (AST)40 000 0640 000 17604 002-0726 PR0001853 (HM)Issued01/01/2014 Expired12/31/2014 WndeFgFOWnd StOFage Tank~Ope~ating-Perm it& Haza~dews Materia!c HandlerAwthe~iZatiGWO operateIssued01/01/12092014 Expires12/31/20092014 Issued 09/18/2008 Expires 08/26/202507/21200I Exp-ire 06/302Q01 Operation ofunderground andaboveground petroleum storagetanks, hazardous materials
: handling, hazardous wastegeneration, SPCC PlanOpcrntion of DieselStG~ageTanksEmergency Operations Facility(EOF)Hazardous materials
: handling, and operation ofabove groundpetroleum storagetankPossession anddisposition ofimpinged orstranded sea turtlesQperatien of theEmorgoncy DiceseGencrntorc (DCPP)Biological Opinionand Incidental Take Statement PeFrmit to Operatc 919-s APPENDIX EENVIRONMENTAL REPORTAMENDMENT ITABLE 9-1Page 3 of 6ENVIRONMENTAL AUTHORIZATIONS FOR CURRENT DCPP OPERATIONS Issue orAgency Authority Requirement Number Expiration Date' Activity CoveredSan Luis ObispeGounty-APolutiont CntroSan Luis ObispoCounty AirPollution ControlDistrictSan Lus GbispeGeuntyL~Po!Iution ControlDiet~iotSan Luis ObispoCounty AirPollution ControlDistrictSan Luis ObispoCounty AirPollution ControlDistrictGean AiF AG, 42USC 7401, et seq.)Clean AiF Aot-(2USGCFR 7401, etseq4.Permit to OperatePermit to Operate88641issued0413012009 0313112040 Gpwat"9A-the Emergency DieselGereFat9r (EOF)Operation of theDCPP Auxiliary Boiler49-1USG 7401Tet-*
seq+4 7- GR et seq.Glean AFAot-(42 USGCFR 7401,et seq4.Permit to Operate 6332-Permit to Operate 338-1Issued 0712112009 07/15/2014 Expires 06/30/2010 06/30/2015 Issued 07/21/2009 EXPire 06/30/2010 Issued0712- 200007/15/2014 Expires06/30/20402015 Issued 08/22/2007 07/15/2014 Gpesstien-e9h Abrzicive BlastFaG4iliyOperation of aDCPP Paint SprayBooth17 CCR et seq.Clean AiF A42 USGCFR 7401,et seq.-.4Permit to Operate41543Operation of DCPPPortable Sandblast Equipmenteviees Expires061301204-02015 17 CCR et seq.
APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1TABLE 9-1Page 4 of 6ENVIRONMENTAL AUTHORIZATIONS FOR CURRENT DCPP OPERATIONS Issue orAgency Authority Requirement Number Expiration Date1  Activity CoveredSan Luis Obispo Permit to Operate 533-2 Issued Operation of theCounty AirPollution ControlDistrictSan Luis ObispoCounty AirPollution ControlDistrictSan Luis ObispoCounty AirPollution ControlDistrictSan Luis ObispoCounty AirPollution ControlDistrictSan Luis ObispoCounty AirPollution ControlDistrict42 CFR 7401, etseq.17 CCR et seq.Glean#4,iF A(42USCFR 7401, etseq.-).17 CCR 94010,^ A ^.#.I42 CFR 7401, etseq.17 CCR 9311542 CFR 7401, et.seq.17 CCR 931115USGCFR 7401, etseq4.).17 CCR 9311517 CCR 9311606/12/2013 Expires06/30/2014 DCPP AbrasiveBlast FacilityPermit to Operate546-42Issued 981W290907-021201307/25/2014 Expires07314204!006/30/2015 Issued06/11/2014 Expires03/31/2015 Permit to Operate886-2Operation of aDCPP non-retail gasoline dispensing facilityOperation of theEOF stationary Emergency DieselGenerator Operation of theDCPP stationary Emergency DieselGenerators Operation of aDCPP t-ansportable diesel-fueled internal combustion ut enginesPermit to Operate919-3Issued0715/2014 Expires06/30/2015 Permit to Operate1065-56Issued 0712412009 07/15/2014 Expires06/30/204-02015 APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1TABLE 9-1Page 5 of 6ENVIRONMENTAL AUTHORIZATIONS FOR CURRENT DCPP OPERATIONS Issue orAgency Authority Requirement Number Expiration Date' Activity CoveredSan Luis Obispo 42 CFR 7401, et. Permit to Operate 1820-1 Issued Operation of JICCounty AirPollution ControlDistrictSan Luis ObispoCounty AirPollution ControlDistrictSan Luis ObispoCounty AirPollution ControlDistrictSan Luis ObispoCounty AirPollution ControlDistrictSan Luis ObispoCounty PublicHealth Department seq.17 CCR 9311542 CFR 7401, et.seq.17 CCR 9311517 CCR 9311642 CFR 7401, et.seq.17 CCR 9311517 CCR 9311642 CFR 7401, etseq.17 CCR 93115Safe DrinkingWater Act (42 USC300 F, et seq.)Permit to Operate1845-106/11/2014 Expires03/31/2015 Issued06/1212013 Expires06/30/2014 Issued09/09/2014 Expires06/30/2015 Issued09/0212014 Expires08/31/2015 Permit to Operate1944-1stationary emergency dieselgenerator Operation of DCPPemergency portablediesel-fueled internal combustion enginesOperation of DCPPemergency portablediesel-fueled internal combustion enginesOperation of theKendall RoadCampusEmergency DieselGenerator Authorization tooperate non-community drinkingand domestic watersystemPermit to Operate1946-1Non-Community Drinking WaterSystem PermitPT 0004769N/A APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1TABLE 9-1Page 6 of 6ENVIRONMENTAL AUTHORIZATIONS FOR CURRENT DCPP OPERATIONS Issue orAgency Authority Requirement Number Expiration Date1  Activity CoveredPeFt San Luise N/A Lease Agreement 2232-1-1-0044-issued 07-/01/1 986 For aoce6 e adHarborDitrc 2232 11 0037 Expires 06A30/120114 enlaFgement and2232 44 0038 s,!en teGateCalifornia California License 710027-01 Issued 04/23/2009 Surface CanopySecretary of Department of Fish Expireds Kelp Harvesting Resources and GameWildlife 12/31/20092013, pending renewal onnecessity California California Special Use Permit 710006-02 Issued 12/31/1999 Removal of BenthicSecretary of Department of Fish Does not expire Kelp from theResources and Game Wildlife DCPP Intake CoveExclusion Zone APPENDIX EENVIRONMENTAL REPORTAMENDMENT ITABLE 9-2ENVIRONMENTAL AUTHORIZATIONS FOR DCPP LICENSE RENEWALAgency Authority Requirement RemarksU.S. Nuclear Reaulatorv Atomic Enerav Act (42 USC 2011 License Renewal Environmental Report submitted in support ofCommission U.S. Fish and WildlifeService (USFWS)California Central CoastRegional Water QualityControl BoardCalifornia CoastalCommission et seq.)Endangered Species Act Section7 (16 USC 1536)Clean Water Act Section 401 (33USC 13411)Federal Coastal ZoneManagement Act (16 USC 1452 etseq.)Consultation Certification Certification license renewal application.
Requires federal agency issuing a license toconsult with USFWS (Attachment C).State issuance of NPDES permit (Section 9.1.5)constitutes 401 certification (Attachment B)Requires applicant to pFeveobtain CoastalDevelopment Permit and certification te-Federal
... I .... ing thcthat license renewal would beconsistent with the Federally approved StateCoastal Zone Management program.Based on it. e...... of the p. .pI sed am tivity, theCalifornia State Office of National Historic Preservation Act Consultation Historic Preservation Section 106 (16 USC 470fappic,,nt',
,,,tific.,tin (Attachment E).Requires federal agency issuing a license toconsider impacts to historical properties andconsult with State Historic Preservation Officer(SHPO).SHPO must concur that license renewal will notaffect any sites listed or eligible for listing(Attachment D).
APPENDIX EENVIRONMENTAL REPORTAMENDMENT IATTACHMENT A -NRC NEPA ISSUES FOR LICENSE RENEWAL OFNUCLEAR POWER PLANTSPG&E has prepared this environmental report in accordance with the requirements ofNRC regulation 10 CFR 51.53. NRC included in the regulation a list of NationalEnvironmental Policy Act (NEPA) issues for license renewal of nuclear power plants.Table A-1 lists these 92 issues and identifies the section in which PG&E addressed each applicable issue in this environmental report. For organization and clarity, PG&Ehas assigned a number to each issue and uses the issue numbers throughout theenvironmental report.As discussed in Section 4.02, on June 20, 2013, the NRC published a final rule (78 FR37282) revising its environmental protection regulation, 10 CFR 51, and the associated GELS. The final rule identified 78 environmental impact issues, of which 19 requireplant-specific analysis.
The final rule consolidated similar Category I and 2 issues,changed some Category 2 issues into Category I issues, and consolidated some ofthose issues with existing Category I issues. The final rule also added nine newCategory I and 2 issues.In the same manner as was done for the 92 issued identified in the 1996 GELS, PG&Ehas assigned a number to each of the 78 issues. The issue numbers mentioned inTable A-2 below are based on those numbers.
Only the nine new Category I andCategory 2 issues are named in Table A-2. For each applicable issue, Table A-2identifies the sections in this environmental report and in the revised GElS hat addressthe issueDiablo Canyon Power Plant Page A-1License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT ITABLE A-2DCPP ENVIRONMENTAL REPORT CROSS-REFERENCE OF NEW LICENSERENEWAL NEPA ISSUES IDENTIFIED IN THE REVISED GElSSection of thisEnvironmental Revised GElSIssue' Cate o Re ort Section/Pa e"8. Geology and Soils 1 2.13 and 4.02 4.4/4-2927. Radionuclides released to 2 4.02 4.5.1.214-51 groundwater
: 28. Effects on terrestrial resources 2 4.02 4.6.1.1/4-59 (non-cooling system impacts)29. Exposure of terrestrial 1 4.02 4.6.1.1/4-61 resources to radionuclides
: 44. Exposure of aquatic resources 1 4.02 4.6.1.2/4-105 to radionuclides
: 59. Human health impact from 1 4.02 4.9.1.1.2/4-147 chemicals
: 63. Physical occupational hazards 1 4.02 4.9.1.1.5/4-156
: 67. Minority and low-income 2 2.6.2 and 4.02 4.10.1/4-167 populations
: 73. Cumulative impacts 2 4.02 4.13/4-243
: a. Source: 10 CFR 51, Subpart A, Appendix A, Table B-1. (Issue numbers added to facilitate discussion.)
: b. Source: Generic Environmental Impact Statement for License Renewal of Nuclear Plants (NUREG-1437, Revision 1).Diablo Canyon Power PlantLicense Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1ATTACHMENT E -COASTAL ZONE CONSISTENCY CERTIFICATION This is the Diablo Canyon Power Plant (DCPP) certification to the U.S. NuclearRegulatory Commission (NRC) that the renewal of the DCPP Units 1 and 2 Operating Licenses will be consistent with enforceable policies of the federally approved statecoastal zone management program.
The certification describes the proposed action(i.e. license renewal),
DCPP background, anticipated environmental
: impacts, California Coastal Management Program (CCMP) policies, and DCPP compliance status.This original Certification ha .not yet beenwas submitted to the California CoastalCommission for review in 2009. The response from the CCC, dated December 29,2009, is also provided in this Attachment (Page E-51).
APPENDIX EENVIRONMENTAL REPORTAMENDMENT ISTATE OF CALIFORNIA-NATURAL RESOURCES AGENCY ARNOLD SCHWARZENEGOER, GOVERNORCALIFORNIA COASTAL COMMISSION 45 FREMONT, SUITE 2000SAN FRANCISCO, CA 94105-2219 VOICE (415) 904-5200FAX (415) 904- 54001m0 (415) 597-5985December 29, 2009Mr. James BeckerPacific Gas & Electric CompanyDiablo Canyon Power PlantMail Code 104/6/601 P.O. Box 3Avila Beach, CA 93424RE: Consistency Certification for Pacific Gas & Electric Company's Requested Nuclear Regulatory Commission License Renewal for Diablo Canyon Power Plant, San Luis Obispo County
 
==Dear Mr. Becker:==
Thank you for your submittal of the above-referenced consistency certification for the DiabloCanyon nuclear power plant license renewal that you are seeking from the Nuclear Regulatory Commission.
The California Coastal Commission (Commission) received your consistency certification here in our headquarters office on December 1, 2009.Our review shows the certification is not yet complete, for the reasons provided below.Accordingly, the Commission's six-month review period under the Coastal Zone Management Act (CZMA), see 16 U.S.C. &sect;&sect; 1456(c)(3)(A),
has not commenced and will not commence untilwe receive the missing necessary data and information, pursuant to CZMA implementing regulations.
15 C.F.R. &sect; 930.60(a).
Additionally, as we discussed at our December 17, 2009meeting, the project will require a coastal development permit (CDP) from the Commission.
Because the Commission's CDP review and approval would also be sufficient for purposes ofconfirming the project's consistency with the California Coastal Management Program (CCMP),and thus establishing the Commission's concurrence with your federal consistency certification, we recommend you submit a CDP application instead of completing the consistency certification.
This will allow for a single and more efficient review process.Nonetheless, pursuant to requirements of the CZMA, we have identified below the information that would be needed to complete the consistency certification.
Please note that much of therequested information will also need to be submitted as part of PG&E's permit application.
Weare happy to assist and answer any questions you may have about the needed information and thereview process.REQUIRED ADDITIONAL INFORMATION AND ANALYSESAs we discussed at the December 17, 2009 meeting, the Commission did not receive some of thenecessary data and information as described in the CZMA implementing regulation at 15 C.F.R.section 940.58(a),
and, accordingly, we will need several additional informational items to allowDiablo Canyon Power Plant Page E-51License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1Review of Consistency Certification for PG&E Diablo Canyon NRC License RenewalDecember 29, 2009Page 2 of 5us to adequately evaluate this proposal and to complete consistency review.'
These include twogeneral elements that apply to several sections of the consistency certification as well as anumber of specific information needs.General Information Requests and Additional AnalysesApplying the CCMP definition of "development":
The certification states in several sectionsthat "[L]icense renewal is not a new development, but a continuation of existing development."
2Several other sections state that a particular CCMP policy is not applicable to the requested license renewal because the renewal does not include development that would be subject to thosepolicies.'
: However, it appears that in reaching these conclusions, the certification did not fullyapply the CCMP's definition of "development",'
resulting in the need for some of the additional information and analyses identified herein as necessary to complete the certification.
The CZMA regulations at Section 930.58 state: "Necessary data and information.
(a) The applicant shallffurnish the State agency with necessary data and information along with the consistency certification.
Such information anddata shall include the following:
(I) A detailed description of the proposed
: activity, its associated facilities, thecoastal effects, and comprehensive data and information sufficient to support the applicant's consistency certification.
Maps, diagrams, technical data and other relevant material shall be submitted when a writtendescription alone will not adequately describe the proposal (a copy of the federal application and all supporting material provided to the Federal agency should also be submitted to the State agency);
... and (3) An evaluation thatincludes a set offindings relating the coastal effects of the proposal and its associated facilities to the relevantenfbrceable policies of the management program.
Applicants shall demonstrate that the activity will be consistent with the enforceable policies of the management program.
Applicants shall demonstrate adequate consideration ofpolicies which are in the nature of recommendations.
Applicants need not make findings with respect to coastaleffects for which the management program does not contain enforceable or recommended policies."
The CZMA regulations also authorize the Commission to not start the review period if it has not received all thenecessary data and information to analyze the proposed activity for consistency with the enforceable policies of theCalifornia Coastal Management Program (CCMP). Specifically, Section 930.60 of those regulations provides:
"Commencement of State agency review. (a) Except as provided in &sect;930.54(e) and paragraph (a)(1) of this section,State agency review of an applicant's consistency certification begins at the time the State agency receives a copy ofthe consistency certification, and the information and data required pursuant to &sect;930.58.
(1) If an applicant fails tosubmit a consistency certification in accordance with &sect;930.57, or fails to submit necessary data and information required pursuant to &sect;930.58, the Slate agency shall, within 30 days of receipt of the incomplete information, notifythe applicant and the Federal agency of the missing certification or Information, and that: (i) The State agency'sreview has not yet begun, and that its review will commence once the necessary certification or information deficiencies have been corrected; or (i) The State agency's review has begun, and that the certification orinformation deficiencies must be cured by the applicant during the State's review period2 Including, for example, Sections 30200, 30212, 30251, 30252, and 30253.3 'lese include Sections 30234.5, 30253, and 30260.' The CCMP's Section 30106 states, in relevant part: "'Development' means, on land, in or under water, theplacement or erection of any solid material or structure; discharge or disposal of any dredged material or of anygaseous, liquid, solid, or thermal waste; grading,
: removing, dredging, mining, or extraction of any materials; change in the density or intensity of use of land, including, but not limited to, subdivision pursuant to theSubdivision Map Act (commencing with Section 66410 of the Government Code), and any other division of land,including lot splits, except where the land division is brought about in connection with the purchase of such land bya public agencyforpublic recreational use; change in the intensity ofuse of water, or of access thereto;construction, reconstruction, demolition, or alteration of the size of any structure, including any facility of anyprivate, public, or municipal utility..."
Diablo Canyon Power Plant Page E-52License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT IReview of Consistency Certification for PG&E Diablo Canyon NRC License RenewalDecember 29, 2009Page 3 of 5The certification does not describe several forms of development that are part of the requested license renewal.
The renewal would include new development in the form of "change in theintensity of use of water, or of access thereto",
as it would result in twenty years of ocean wateruse for cooling purposes that would otherwise not occur. License renewal would also result intwenty years of restricted access to nearby ocean waters that would otherwise end or be phasedout. Additionally, some of the studies PG&E is conducting to implement license renewal mayresult in other forms of development that would need to be evaluated for consistency with theCCMP. For example, studies needed to update the site's and facility's seismic characteristics may result in the need for license renewal to include modifying foundations, adding supportstructures, grading slopes, etc. -any of which would constitute "development" and requirecoastal development permit approval from either the Coastal Commission or San Luis ObispoCounty. Further, extending the life of the facility is likely to require an expansion of theIndependent Spent Fuel Storage Installation (ISFSI),
which was designed to hold spent fuel onlyuntil the end of the current licensed operations.
Please therefore revise the relevant sections ofthe certification and needed analyses to incorporate the full CCMP definition of "development".
Please also identify any project-related development known or anticipated to result from thestudies being implemented as part of PG&E's license renewal.The consistency certification includes several statements of consistency without supporting analyses or documentation:
Several sections of the certification state that the proposed projectis consistent with an applicable CCMP provision but provide little or none of the necessary documentation or analyses to support that statement.
For example, the certification's review ofconformity to Section 30220 states only that "License renewal is consistent with Section 30220of the Coastal Act requiring the protection of water-oriented recreational activities because it willnot interfere with the recreational water activities at the adjacent San Luis Obispo Harbor Districtand nearby Avila Beach community."
It does not analyze the additional twenty years ofrestricted access mentioned above or the effects of that restricted access on water-oriented recreational activities in the area around Diablo Canyon.'
Therefore, pursuant to Section930.58(a) of the CZMA regulations, please provide the comprehensive information and analysesnecessary to support PG&E's consistency certification and its conclusions.
Specific Comments
[Note: Page references are from PG&E's November 2009 Diablo Canyon PowerPlant Federal Consistency Certification for Federal Permits and License Applications and LicenseRenewal Application, Attachment E-1.]* Filing fee: The Commission's filing fees are enforceable policies of the CCMP and constitute necessary data and information.
6 Fees for consistency review are determined in the same mannerOther sections of the certification with similar assertions and inadequate analyses include Sections 30210, 30211,30221, 30224, 30230, 30231, and 30251.6 In March 2008, the Coastal Commission amended Title 14, California Code of Regulations, Section 13055 to authorize filing fee increases for federal consistency certifications pursuant to 16 U.S.C. Sections 1356(c)(3)(A) or (B). On April 24,2008, the National Oceanic and Atmospheric Administration's Office of Ocean and Coastal Resource Management approved the revised fee schedule as a routine program change to California's CCMP. The filing fees constitute necessary data and information within the meaning of 15 CFR Sections 930.58(a) and 930:76(a)(3).
Diablo Canyon Power Plant Page E-53License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1Review of Consistency Certification for PG&E Diablo Canyon NRC License RenewalDecember 29, 2009Page 4 of 5as for coastal development permit applications.
eased on your project description, please providethe fee based on project costs as described in the attached Coastal Commission Filing FeeSchedule, Section 13055(a)(5)(B).
" p. E-12, Table E-2, Environmental Authorizations for DCPP License Renewal:
Please note thatthe requirement for a CDP is an additional authorization to be added to this table." pp. E-15-22, Table 3: Please note that CCMP review is likely to require more specific anddetailed review than was conducted under the General EIS described in this table.* p. E-28, CCMP Section 30200: As noted above, this section does not fully evaluate project-related development as defined by the CCMP. This section may need additional information forcompleteness, based on subsequent submittals for other sections of this certification.
" pp. E-29-35, CCMP Sections 30210 -30224 Public Access and Recreation:
The certification states that the proposed license renewal does not constitute new development;
: however, as notedabove, this is not a correct application of the CCMP's definition of development.
The certification also identifies use limitations on nearby shorelines and ocean waters due to the project's securityneeds, but does not adequately analyze the effects of those use limitations on public access andrecreation in those areas. Please provide a revised analysis of the project's effects on recreation and public access to the shoreline and nearby coastal waters due to an additional twenty years ofproject-related access limitations.
* pp. E-35-41, CCMP Sections 30230 -30233 Marine Environment:
The certification does notidentify how the proposed project will "maintain,
: enhance, and, where feasible, restore the marineenvironment",
or how it will result in special protection of nearby areas of special biological significance, as required pursuant to CCMP Section 30230. It also does not provide completeanalyses from the various entrainment, impingement, and thermal effects studies done at DiabloCanyon and does not identify feasible mitigation measures to minimize the adverse effects ofentrainment, as required pursuant to CCMP Section 30231. Please provide copies of these studies,including results of Empirical Transport Model studies, to document the necessary analyses.
" pp. E-40-41, CCMP Section 30235 Construction Altering Natural Shoreline:
The certification states that no shoreline alterations are necessary.
: However, by extending plant operations untilabout 2045, license renewal would subject the facility to the effects of sea level rise (which couldinclude direct effects on the facility's intake and outfall as well as indirect effects due to coastalerosion, landslides, or other similar geomorphic changes).
Please provide analyses of whetherpredicted sea level changes would result in the need for shoreline alterations during the term of theproposed renewed license (see also Section 30253(1) below).* p. E-46, CCM1P Section 30253(1)
Minimize Risks to Life and Property in Areas of HighGeologic, Flood, and Fire Hazard: Please provide all data and interpretive summaries, such asthose conducted by PG&E and USGS under their CRADA agreement and the Long Term SeismicProgram of PG&E, characterizing the seismicity and tectonic structure in the vicinity of the plant.These data should include characterization of the Hosgri and Shoreline Faults, including faultgeometry, seismicity, and sense of movement; estimates of maximum credible earthquake (from adeterministic perspective) on these and all other faults; the ground shaking expected at the siteDiablo Canyon Power Plant Page E-54License Renewal Application APPENDIX EENVIRONMENTAL REPORTAMENDMENT 1Review of Consistency Certification for PG&E Diablo Canyon NRC License RenewalDecember 29, 2009Page 5 of 5from such earthquakes; and the deep crustal structure beneath the plant (in particular an evaluation of the "Namson model" of thrust ramps beneath the plant). Additionally, and as recommended bythe Technical Advisory Team established pursuant to AB 1632,' please provide the three-dimensional seismic data should be collected and interpreted as part of this evaluation.
Pleaseconfer with the Commission's staff geologist, Dr. Mark Johnsson, at 415-904-5200 for anynecessary clarification.
: p. E-47, CCMP Sections 30255 and 30260 -Priority of Coastal-Dependent Developments andIndustrial Development:
The certification does not evaluate the project's "coastal-dependent"'
status or, as required by these CCMP Sections.
Coastal Commission staff will likely address thisissue as part of PG&E's permit application, but you may wish to provide additional information about the "coastal-dependent" nature of the project.CONCLUSION In conclusion, the Commission staff has determined PG&E's submittal does not contain theinformation necessary for a complete consistency certification.
Therefore, pursuant to 15 C.F.R.section 930.60(a),
the six-month time period for this submittal has not begun and will not begin untilthe Commission staff receives the information discussed above. However, as noted previously, werecommend PG&E instead submit a complete CDP application in lieu of completing this consistency certification to allow one, rather than two, review processes.
Please feel free to contact me at (415)904-5248 if you have any questions.
Sincerely, Tom LusterEnergy, Ocean Resources, and Federal Consistency DivisionCc (via email): PG&E -Mr. Mark KrausseNRC -Kimberly GreenCEC -Barbara Byron7 Assembly Bill 1632 (2006) directs the California Energy Commission to assess the vulnerability of the state's operating nuclear power plants to a major disruption due to a major seismic event or plant aging, the potential impacts of such adisruption, potential impacts from the accumulation of nuclear waste at the state's existing nuclear plants, and other keypolicy and planning issues regarding the future role of California's existing nuclear plants.8 The CCMP, at Section 30101, defines a "coastal-dependent development or use" as "any development or use whichrequires a site on, or adjacent to, the sea to be able to function at all."Diablo Canyon Power Plant Page E-55License Renewal Application}}

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