ML16060A309

LTR-16-0103 Joe Holtzman, E-mail San Onofre Failed to Mitigate Marine Damage from Once-through Cooling - Don'T Allow Diablo Canyon to Play the Same Game

ML16060A309
Person / Time
Site:	San Onofre
Issue date:	02/28/2016
From:	Holtzman J - No Known Affiliation
To:	Stephen Burns, Mcdonald J, Sforza T NRC/Chairman, Orange County Register
References
LTR-16-0103
Download: ML16060A309 (8)

Text

CHAIRMAN Resource From: joeholtzman@gmail.com Sent: Sunday, February 28, 2016 12:05 PM To: Jeffrey Mcdonald; tsforza@ocregister.com; CHAIRMAN Resource

Subject:

[External_Sender] San Onofre failed to mitigate marine damage from once -through cooling -

don't allow Diablo Canyon to play the same game Folks

Subject:

San Onofre failed to mitigate marine damage from once-through cooling - don't allow Diablo Canyon to play the same game The 2014 U.C. Santa Barbara report shows the San Onofre mitigation plan for all the damage once-through cooling does has never worked. There is no plan in place to show it ever will. Diablo Canyon should not be allowed to use "mitigation". Diablo needs to be shut down . Learn more at http://sanonofresafety.org/once-through-cooling/

Summary of mitigation credit for Wheeler North Reef Year Mitigation credit Reason for no mitigation credit 2009 No Kelp & fish standing stock too low 2010 No Fish standing stock too low 2011 No Fish standing stock too low 2012 No Fish standing stock too low 2013 No Fish standing stock too low 2014 No Fish standing stock too low TOTAL O years Mitigation 30 years Target (minimum) https ://sanonofresafety.files. wordpress.com/2013/04/mi ti gationresults2014-wheelernorthreef. jpg?w=640 1

Once-Through Cooling I San Onofre Safety Page 1of7 San Onofre Safety Y1 */cu Sa(c _y und Cost Once-Through Cooling The San Onofre and Diahlo Canyon nuclear reactors kill and maim millions offis h and other marine life every year, and damage the ecosystem - more than all other California once-through cooling system power plants.

They are among the worst in the nation. See Sierra Club Giant Fish Blenders Juh1 Federal Clean Water Act §316Cb) regulations ban once-through cooling.

2011.

Of(---.. _._--*

______- _---..*--* --1 --*-

• • • --*---(--*1

~. - --*------*- ..._....

NRC: U.S. Nuclear Power Plant cooling systems (NUREG-1437).

Worst marine life damage from OTC.

Numerous state agencies have jurisdiction to deny operating permits to California's nuclear power plants.

California Coastal Commission (CCC)

• The California Coastal Commission issued a coastal development permit for reactor Units 2 and 3, allowing San Onfore to be built by th e ocean in Southern California.

• A condition of the permit required study of the impacts of the operation of the nuclear reactors on the marine environment offshore from San Onofre, and mitigation of any adverse impacts. Permit No. 6-81-330-A requires Southern California Edison (SCE) to design and build mitigation proj ects that adequately http://sanonofresafety.org/once-through-cool ing/ 02/29/2016

Once-Through Cooling I San Onofre Safety Page 2of7 California Otters by Cleve Nash compensate fo r the adverse effects of the power plant's once-through seawater cooling system on coastal marine resources.

• The mitigation reef project has NOT been successful at mitigating the damage caused by San Onofre. See UCSB San Onofre Mitigation Monitoring website.

• Long-term U C Santa Barbara 2014 M1tigat1on Summary of mitigation credit for Program Annual Wheeler North Reef Status Report Year Mitigation credit Reason for no mitigation credit 2009 No Kelp & fish standing stock too low 2010 No Fish standing stock too low 2011 No Fish standing stock too low 2012 No Fish standing stock too low 2013 No Fish standing stock too low 2014 No Fish standing stock too low TOTAL 0 years Mitigation 30 years Target (minimum) monitoring and evaluation of the San Onofre mitigation projects is a condition of the coastal development permit. See 2012 Mitigation Program Annual Status Report and 2014 Mitigation Program Annual Status Report. UCSB San Onofre Mitigation Monitoring website.

• University of California Santa Barbara (UCSB) scientists working under the direction of the Executive Director of the CCC are responsible for designing and implementing monitoring programs aimed at determining the effectiveness of these mitigation projects at a cost to ratepayers of approximately $1 million annually. The San Onofre Mitigation Monitoring Program is based at the Marine Science Institute, University of California Santa Barbara.

California Public Utilities Commission (CPUC)

• Annual Funding for the San Onofre (SONGS) Mitigation Monitoring Program is provided by SCE (paid by ratepayers) as a requirement of their coastal development permit for operating San Onofre.

The UCSB portion of the costs is approximately $1 million annually.

• The California Public Utilities Commission approves charges to ratepayers. They also determine if the plant is cost-effective and reliable for ratepayers and California.

• Click here to find documents on CPUC's proceedings search webpage. Enter "onofre" in the Description Search box.

State Water Resources Control Board (SWRCB)

• California's State Water Resources Control Board is responsible for implementing the Federal Clean Water Act §316(b) regulations on cooling water http://sanonofresafety.org/once-through-cooling/ 02/29/2016

Once-Through Cooling I San Onofre Safety Page 3of7 intake structures. However, they have delayed implementation, resulting in the death of more marine life, including California Sea Lions.

• UPDATE: June 18, 2013 SWRCB Public Hearing . Comment deadline is June 4, 2013 by 12 noon. The Board will hold a public hearing to receive public comment on a proposed amendment to the Water Quality Control Policy on the Use of Coastal and Estuarine Waters for Power Plant Cooling. The Board will consider adoption of the proposed amendments following the hearing.

Location: Joe Serna Jr. Cal/EPA Headquarters Building. Coastal Hearing Room, 1001 I Street. 2nd floor.

Sacramento, CA 95814.

• Notice of Adoption Hearing

• Draft Staff Report

• Appendix A- Proposed Amendment to the Water Quality Control Policy on the Use of Coastal and Estuarine Waters for Power Plant Cooling

• Draft Resolution 2013-XXX

• If the WRCB enf01*ced compliance, the costs would be prohibitive, resulting in the probable shutdown of San Onofre. Some reports have been done regarding cost to retrofit San Onofre and more are being done.

• Edison estimates $2.5 billion to retrofit San Onofre - NC Times 8/8/2009

• Edison Feasibility Study for Installation of Cooling Towers at San Onofre 9/18/2009: Estimated initial costs of more than $3 billion, and annual costs of $85 million.

• SWRCB Alternative Cooling System Analysis for San Onofre 2/27/2008 : Estimated capital and start-up costs of $s93.1 million; all capital costs, operation and maintenance costs, and energy penalty costs over 20 years, discounted at 7.0% totals $2.62 billion.

• NOTE: New Jersey's Oyster Creek nuclear plant is closing due to the expense of complying with their once-through cooling rules.

• Early closure for Oyster Creek - World Nuclear News 12/9/2010

• New Jersey Administrative Consent Order 12/9/2010

• SWRCB Once-Through Cooling policy and status links:

• Review Committee for Nuclear Fueled Power Plants

• Once-through Cooling Policy Fact Sheet

• OTC Nuclear Power Plants Worst Damage to Marine Life Chart

• Once-through Cooling Water Use and CWA 316(b) Regulation

• Amended Policy 7/19/2011

• Federal Water Pollution Control Act

• Water Quality Control Policy on the Use of Coastal and Estuarine Waters for Power Plant Cooling, Final Substitute Environmental Document SWRCB/CEPA 5/4/2010

• SWRCB Map of OTC Plants affected

• California OTC plants affected - SWRCB website

• EPA Fact Sheet for Proposed Regulations for Cooling Water Intake Structures

• EPA website for Cooling Water Intake Structures-CWA §316(b)

• State Water Resources Control Board Calendar California Independent System Operator (CAISO) http://sanonofresafety.org/ once-through-cooling/ 02/29/2016

Once-Through Cooling I San Onofre Safety Page 4 of7

• The California Independent System Operator's annual transmission planning process is evaluating potential reliability impacts caused by retiring California once-through cooling gas plants and nuclear power reactors, the' off line time needed to retrofit them with alternative technologies, as well as the timing issues of when plants will implement their compliance strategies (2012-2020 ).

• Currently, the state's plan is to shut down the once-through cooling gas plants first. They do not have a plan in place to shut down the nuclear plants. See CAISO Once-through cooling generation.

California State Lands Commission (CSLC)

• The California State Lands Commission is an independent body, composed of three members-the Lieutenant Governor and State Controller, both statewide elected officials, and the Director of Finance, an appointee of the Governor. The CSLC has the authority and responsibility to manage and protect the natural and cultural resources on certain public lands within the state and the public's rights to access these lands. The public lands under the Commission's jurisdiction are of two distinct types-sovereign and school lands. Sovereign lands encompass approximately 4 million acres. These lands include the beds of California's naturally navigable rivers, lakes and streams, as well as the state's tide and submerged lands along the state's more than 1,100 miles of coastline, extending from the shoreline out to three miles offshore. In short, the CSLC's jurisdiction extends to more than 120 rivers and sloughs, 40 lakes and the state's coastal waters. See State Lands brochure for details.

• The Commission leases sovereign lands for public trust purpose, and is often called upon to prioritize competing trust values in deciding whether to issue a lease for a proposed project.

Commission leases of sovereign lands generally fall into several categories: recreational, commercial, industrial, right-of-way, and salvage. Specific examples of such leases include private recreational piers, commercial marinas, yacht clubs, marine terminals, industrial wharves, oil and gas pipelines, fiber optic cables, outfalls, bank stabilization, and wetlands and habitat management projects.

• San Onofre has leases with the State Lands Commission. One is for the coastal area used by the OTC intake system. The SWRCB required San Onofre to implement large organism exclusion device protection. This required approval from the State Lands Commission:

• San Onofre Large Organism Ex clusion Device Marine Mammal Monitoring and Protection Plan 8/6/2012

• Revision of Rent and Leas e amendment 10/19/2012: Approve the revision of rent for Lease No. 6785.1from $88,316 per year to $151,275 per year, effective March 1, 2013. Authorize the Amendment of Lease No. PRC 6785.1, a General Lease - Industrial Use, effective October 19, 2012, to amend the Land Use or Purpose and Special Conditions to include the installation, use, and maintenance of two Large Organism Exclusion Devices on the primary offshore intake structures of Units 2 and 3; and dredging as described in Exhibit A and shown on Exhibit B (for reference purposes only); and liability insurance in the amount of $5,00o,ooo; Lessee may satisfy all or part of the insurance requirements through maintenance of a self insurance program as outlined in the lease; lessee shall comply wilh all provisions of the Mitigation Monitoring Program as contained in Exhibit C, attached hereto; and all other terms and conditions of the lease as previously amended will remain in effect without amendment. Further approvals required:

• California Coastal Commission

• California Dep artment of Fish and Game

• San Diego Regional Water Quality Control Board http://sanonofresafety.org/once-through-cooling/ 02/29/2016

Once-Through Cooling I San Onofre Safety Page 5of7

• U.S. Army Corps of Engineers

• U.S. Coast Guard U.S. Fish and Wildlife Service

• National Oceanic and Atmospheric Administration

• Fisheries Service ONCE-THROUGH COOLING POWER PLANTS IN CALIFORNIA State water-quality Power Compliance regulators r plant rdue date set deadlines for Humboldt Bay 2010 I

• coastal power plants to phase out once-through cooling CALIFORNIA technology, which kills huge volumes of fish 80 and larvae.

Contra Costa 2017- - - -......

Pittsburg 2017-------*1 Potrero 2011 ----~' NEVADA Moss Landing 2 0 1 7 - - - - -

Morro Bay 2015 - - - - - - - - .

ll.JDlablo Canyon 2024

'- Mandalay 2020 Scattergood 2020 lf El Segundo 2015

~[ Ormond Beach 2020

-.11' (

Redondo Harbor 2015 Beach 2020-tl Haynes 2019 Ji TJ -l8 Alamitos 2020 Huntington Beach 2020 i

SOURCE: State Water Resources Control Board AARON STECKELBERG I Union-Tribune Power plants face closures - UTSanDiego 5/ 11 / 2010

Background

Many of California's coastal and bay-side power plants use an antiquated cooling technology that sucks in over 16 billion gallons of cold seawater per day to cool plant operations. The State Water Board estimates that the plants' cooling systems kill billions of marine species unlucky enough to be near the Arnmat1on intake pipes each year. This "once-through cooling" (OTC) process draws fish, larvae, plankton, and other marine life into the plant, and kills and injures larger marine species such as sea lions and turtles on the intake screens. The plants also pump the heated water back into the delicate coastal and http://sanonofresafety.org/once-through-cooling/ 02/29/2016

Once-Through Cooling I San Onofre Safety Page 6of7 Delta ecosystems, many of which serve as nurseries for marine life. This outdated technology dramatically impacts the health of our ocean.

Plant Name Regional Oper:.tor Intake Flow NPDES Board (1nmlllOl'l Permit galk>ns Expiration per day)

Humboldt Bay Region 1 PGtE -e 4 16:.'006 0 Power Pt<ml Norm Coast

• Potiero Power Plant Region::'.!

SF 8&)

f..W-anlDf'lla 505 1231 :008

,_,4C<m>

U>I* Beds

• Pittsburg Power Pl;1n1 Rtgio":!

SF Bat

,,1nn1Dflla 676 531 '2007

• Mou l ~mdmg Power Pl*nl Region 3 C.n1raf Coast LS Power 1226 10'27'2005

• Diabk> Canyon Power Pl*nl Region 3 Centra1Coasi PG&E ~70 511 H1a5

• Morro Bay Power Plant Rtg1on 3 Ctn41al Coast

~ogy 688 10 12000 Redding

.,....Pi

""I/ob 0

Contril Power Plant El Segundo COSI~ Regt0nS Central Vaite,.

Region 4 t.Wan1Delt;,

NRG Energt 450 607 4 l :i'.:006 5 102005 Generillmg SlatK>n Los Angeles

• fMndalay Gener *ting Station Region 4 lOi./._ngtlH Rei.am Energy t.Unaala) 588 310:"1.)()6 Chico

• Scallergood Gent>r;1lin9 Slalion Region4 Los Angele&

LA Dept of wa1t1 & Po1"Yer 496 5 10:?005

• Alamitos G eneralmg Starion Ormond Beach Re910n 4 LOI Angtlts Re910n 4 AES AllnlltOI Rel..ant Energf 12!2 688 5 10'2005 5 102006 e Genera11n9 Statton Los .Ange~s Mandala, 0

Redondo Generating St.anon Harbof Generating Pegron 4 Los .t.ogeld Regior1 4 AES Redondo Beach LA Oep1 of 1146 108 510':!005 fl 10 2006 St.-.Hon Los Angelfs Water & Po ** ef Haynes Gener.tiling R*g10n 4 LA a.pt of 1014 s 102005 0 St.itton losAngetu *w'.'ater & Po.*.er Hununglon 8eaeh Reg1on8 AES 516 81 :?011 0 Generahng Sl.idon Santa An& Hunlln.gton Beach 0

S~ Onolfe Nulcear Gener.umg St ation ErKina Power Pl*nt Reg.one San Ottgo Re910n9 SouttlemCA E<'500 t'4RG Energy 2588 860 5 11 '2010 101 '2011 S.>n01f90 South Bay Power RegionV LS Power 602 I 1 102009 0 Pl.illnt San Diego PLANT STATUS KEV 9 P&anls u t ing Onc:e-Tluough Coohng iOTCI 0 Plants w ith plans 10 phase out OTC Bakersfield llojave llallanal Pt......

Vletorvllle source http.//cawaterkeeper.org/power-plants-once-through php log end e Coastal Po\~r Plants local Rettabitity ArNs (generalized)

C.l.romia Transmission System (partial generalized) http://sanonofresafety.org/once-through-cooling/ 02/29/2016

Once-Through Cooling I San Onofre Safety Page 7of7 Figure 1 1il Jones & Stokes locations of Power Plants, local Reliability Areas, and California's Major Transmission System Share this:

i:ii Email r;t Pnnt f Facebook 9 'fl Twitter G* Google $ More

• Like Be the first to like this One Response to Once-Through Cooling Pingback 04/lz/2013 WRCB meeting: Once-throuq/J cooling nuclear reactors I San Onofre Safetu San Onofre Safety 71u Tu*enty T n Tht!me. B/<)(/ 11/ ~1'ord/>ress.com.

http://sanonofresafety.org/ once-thro ugh-coo ling/ 02/29/2016

CHAIRMAN Resource From: joeholtzman@gmail.com Sent: Sunday, February 28, 2016 12:05 PM To: Jeffrey Mcdonald; tsforza@ocregister.com; CHAIRMAN Resource

Subject:

[External_Sender] San Onofre failed to mitigate marine damage from once -through cooling -

don't allow Diablo Canyon to play the same game Folks

Subject:

San Onofre failed to mitigate marine damage from once-through cooling - don't allow Diablo Canyon to play the same game The 2014 U.C. Santa Barbara report shows the San Onofre mitigation plan for all the damage once-through cooling does has never worked. There is no plan in place to show it ever will. Diablo Canyon should not be allowed to use "mitigation". Diablo needs to be shut down . Learn more at http://sanonofresafety.org/once-through-cooling/

Summary of mitigation credit for Wheeler North Reef Year Mitigation credit Reason for no mitigation credit 2009 No Kelp & fish standing stock too low 2010 No Fish standing stock too low 2011 No Fish standing stock too low 2012 No Fish standing stock too low 2013 No Fish standing stock too low 2014 No Fish standing stock too low TOTAL O years Mitigation 30 years Target (minimum) https ://sanonofresafety.files. wordpress.com/2013/04/mi ti gationresults2014-wheelernorthreef. jpg?w=640 1

Once-Through Cooling I San Onofre Safety Page 1of7 San Onofre Safety Y1 */cu Sa(c _y und Cost Once-Through Cooling The San Onofre and Diahlo Canyon nuclear reactors kill and maim millions offis h and other marine life every year, and damage the ecosystem - more than all other California once-through cooling system power plants.

They are among the worst in the nation. See Sierra Club Giant Fish Blenders Juh1 Federal Clean Water Act §316Cb) regulations ban once-through cooling.

2011.

Of(---.. _._--*

______- _---..*--* --1 --*-

• • • --*---(--*1

~. - --*------*- ..._....

NRC: U.S. Nuclear Power Plant cooling systems (NUREG-1437).

Worst marine life damage from OTC.

Numerous state agencies have jurisdiction to deny operating permits to California's nuclear power plants.

California Coastal Commission (CCC)

• The California Coastal Commission issued a coastal development permit for reactor Units 2 and 3, allowing San Onfore to be built by th e ocean in Southern California.

• A condition of the permit required study of the impacts of the operation of the nuclear reactors on the marine environment offshore from San Onofre, and mitigation of any adverse impacts. Permit No. 6-81-330-A requires Southern California Edison (SCE) to design and build mitigation proj ects that adequately http://sanonofresafety.org/once-through-cool ing/ 02/29/2016

Once-Through Cooling I San Onofre Safety Page 2of7 California Otters by Cleve Nash compensate fo r the adverse effects of the power plant's once-through seawater cooling system on coastal marine resources.

• The mitigation reef project has NOT been successful at mitigating the damage caused by San Onofre. See UCSB San Onofre Mitigation Monitoring website.

• Long-term U C Santa Barbara 2014 M1tigat1on Summary of mitigation credit for Program Annual Wheeler North Reef Status Report Year Mitigation credit Reason for no mitigation credit 2009 No Kelp & fish standing stock too low 2010 No Fish standing stock too low 2011 No Fish standing stock too low 2012 No Fish standing stock too low 2013 No Fish standing stock too low 2014 No Fish standing stock too low TOTAL 0 years Mitigation 30 years Target (minimum) monitoring and evaluation of the San Onofre mitigation projects is a condition of the coastal development permit. See 2012 Mitigation Program Annual Status Report and 2014 Mitigation Program Annual Status Report. UCSB San Onofre Mitigation Monitoring website.

• University of California Santa Barbara (UCSB) scientists working under the direction of the Executive Director of the CCC are responsible for designing and implementing monitoring programs aimed at determining the effectiveness of these mitigation projects at a cost to ratepayers of approximately $1 million annually. The San Onofre Mitigation Monitoring Program is based at the Marine Science Institute, University of California Santa Barbara.

California Public Utilities Commission (CPUC)

• Annual Funding for the San Onofre (SONGS) Mitigation Monitoring Program is provided by SCE (paid by ratepayers) as a requirement of their coastal development permit for operating San Onofre.

The UCSB portion of the costs is approximately $1 million annually.

• The California Public Utilities Commission approves charges to ratepayers. They also determine if the plant is cost-effective and reliable for ratepayers and California.

• Click here to find documents on CPUC's proceedings search webpage. Enter "onofre" in the Description Search box.

State Water Resources Control Board (SWRCB)

• California's State Water Resources Control Board is responsible for implementing the Federal Clean Water Act §316(b) regulations on cooling water http://sanonofresafety.org/once-through-cooling/ 02/29/2016

Once-Through Cooling I San Onofre Safety Page 3of7 intake structures. However, they have delayed implementation, resulting in the death of more marine life, including California Sea Lions.

• UPDATE: June 18, 2013 SWRCB Public Hearing . Comment deadline is June 4, 2013 by 12 noon. The Board will hold a public hearing to receive public comment on a proposed amendment to the Water Quality Control Policy on the Use of Coastal and Estuarine Waters for Power Plant Cooling. The Board will consider adoption of the proposed amendments following the hearing.

Location: Joe Serna Jr. Cal/EPA Headquarters Building. Coastal Hearing Room, 1001 I Street. 2nd floor.

Sacramento, CA 95814.

• Notice of Adoption Hearing

• Draft Staff Report

• Appendix A- Proposed Amendment to the Water Quality Control Policy on the Use of Coastal and Estuarine Waters for Power Plant Cooling

• Draft Resolution 2013-XXX

• If the WRCB enf01*ced compliance, the costs would be prohibitive, resulting in the probable shutdown of San Onofre. Some reports have been done regarding cost to retrofit San Onofre and more are being done.

• Edison estimates $2.5 billion to retrofit San Onofre - NC Times 8/8/2009

• Edison Feasibility Study for Installation of Cooling Towers at San Onofre 9/18/2009: Estimated initial costs of more than $3 billion, and annual costs of $85 million.

• SWRCB Alternative Cooling System Analysis for San Onofre 2/27/2008 : Estimated capital and start-up costs of $s93.1 million; all capital costs, operation and maintenance costs, and energy penalty costs over 20 years, discounted at 7.0% totals $2.62 billion.

• NOTE: New Jersey's Oyster Creek nuclear plant is closing due to the expense of complying with their once-through cooling rules.

• Early closure for Oyster Creek - World Nuclear News 12/9/2010

• New Jersey Administrative Consent Order 12/9/2010

• SWRCB Once-Through Cooling policy and status links:

• Review Committee for Nuclear Fueled Power Plants

• Once-through Cooling Policy Fact Sheet

• OTC Nuclear Power Plants Worst Damage to Marine Life Chart

• Once-through Cooling Water Use and CWA 316(b) Regulation

• Amended Policy 7/19/2011

• Federal Water Pollution Control Act

• Water Quality Control Policy on the Use of Coastal and Estuarine Waters for Power Plant Cooling, Final Substitute Environmental Document SWRCB/CEPA 5/4/2010

• SWRCB Map of OTC Plants affected

• California OTC plants affected - SWRCB website

• EPA Fact Sheet for Proposed Regulations for Cooling Water Intake Structures

• EPA website for Cooling Water Intake Structures-CWA §316(b)

• State Water Resources Control Board Calendar California Independent System Operator (CAISO) http://sanonofresafety.org/ once-through-cooling/ 02/29/2016

Once-Through Cooling I San Onofre Safety Page 4 of7

• The California Independent System Operator's annual transmission planning process is evaluating potential reliability impacts caused by retiring California once-through cooling gas plants and nuclear power reactors, the' off line time needed to retrofit them with alternative technologies, as well as the timing issues of when plants will implement their compliance strategies (2012-2020 ).

• Currently, the state's plan is to shut down the once-through cooling gas plants first. They do not have a plan in place to shut down the nuclear plants. See CAISO Once-through cooling generation.

California State Lands Commission (CSLC)

• The California State Lands Commission is an independent body, composed of three members-the Lieutenant Governor and State Controller, both statewide elected officials, and the Director of Finance, an appointee of the Governor. The CSLC has the authority and responsibility to manage and protect the natural and cultural resources on certain public lands within the state and the public's rights to access these lands. The public lands under the Commission's jurisdiction are of two distinct types-sovereign and school lands. Sovereign lands encompass approximately 4 million acres. These lands include the beds of California's naturally navigable rivers, lakes and streams, as well as the state's tide and submerged lands along the state's more than 1,100 miles of coastline, extending from the shoreline out to three miles offshore. In short, the CSLC's jurisdiction extends to more than 120 rivers and sloughs, 40 lakes and the state's coastal waters. See State Lands brochure for details.

• The Commission leases sovereign lands for public trust purpose, and is often called upon to prioritize competing trust values in deciding whether to issue a lease for a proposed project.

Commission leases of sovereign lands generally fall into several categories: recreational, commercial, industrial, right-of-way, and salvage. Specific examples of such leases include private recreational piers, commercial marinas, yacht clubs, marine terminals, industrial wharves, oil and gas pipelines, fiber optic cables, outfalls, bank stabilization, and wetlands and habitat management projects.

• San Onofre has leases with the State Lands Commission. One is for the coastal area used by the OTC intake system. The SWRCB required San Onofre to implement large organism exclusion device protection. This required approval from the State Lands Commission:

• San Onofre Large Organism Ex clusion Device Marine Mammal Monitoring and Protection Plan 8/6/2012

• Revision of Rent and Leas e amendment 10/19/2012: Approve the revision of rent for Lease No. 6785.1from $88,316 per year to $151,275 per year, effective March 1, 2013. Authorize the Amendment of Lease No. PRC 6785.1, a General Lease - Industrial Use, effective October 19, 2012, to amend the Land Use or Purpose and Special Conditions to include the installation, use, and maintenance of two Large Organism Exclusion Devices on the primary offshore intake structures of Units 2 and 3; and dredging as described in Exhibit A and shown on Exhibit B (for reference purposes only); and liability insurance in the amount of $5,00o,ooo; Lessee may satisfy all or part of the insurance requirements through maintenance of a self insurance program as outlined in the lease; lessee shall comply wilh all provisions of the Mitigation Monitoring Program as contained in Exhibit C, attached hereto; and all other terms and conditions of the lease as previously amended will remain in effect without amendment. Further approvals required:

• California Coastal Commission

• California Dep artment of Fish and Game

• San Diego Regional Water Quality Control Board http://sanonofresafety.org/once-through-cooling/ 02/29/2016

Once-Through Cooling I San Onofre Safety Page 5of7

• U.S. Army Corps of Engineers

• U.S. Coast Guard U.S. Fish and Wildlife Service

• National Oceanic and Atmospheric Administration

• Fisheries Service ONCE-THROUGH COOLING POWER PLANTS IN CALIFORNIA State water-quality Power Compliance regulators r plant rdue date set deadlines for Humboldt Bay 2010 I

• coastal power plants to phase out once-through cooling CALIFORNIA technology, which kills huge volumes of fish 80 and larvae.

Contra Costa 2017- - - -......

Pittsburg 2017-------*1 Potrero 2011 ----~' NEVADA Moss Landing 2 0 1 7 - - - - -

Morro Bay 2015 - - - - - - - - .

ll.JDlablo Canyon 2024

'- Mandalay 2020 Scattergood 2020 lf El Segundo 2015

~[ Ormond Beach 2020

-.11' (

Redondo Harbor 2015 Beach 2020-tl Haynes 2019 Ji TJ -l8 Alamitos 2020 Huntington Beach 2020 i

SOURCE: State Water Resources Control Board AARON STECKELBERG I Union-Tribune Power plants face closures - UTSanDiego 5/ 11 / 2010

Background

Many of California's coastal and bay-side power plants use an antiquated cooling technology that sucks in over 16 billion gallons of cold seawater per day to cool plant operations. The State Water Board estimates that the plants' cooling systems kill billions of marine species unlucky enough to be near the Arnmat1on intake pipes each year. This "once-through cooling" (OTC) process draws fish, larvae, plankton, and other marine life into the plant, and kills and injures larger marine species such as sea lions and turtles on the intake screens. The plants also pump the heated water back into the delicate coastal and http://sanonofresafety.org/once-through-cooling/ 02/29/2016

Once-Through Cooling I San Onofre Safety Page 6of7 Delta ecosystems, many of which serve as nurseries for marine life. This outdated technology dramatically impacts the health of our ocean.

Plant Name Regional Oper:.tor Intake Flow NPDES Board (1nmlllOl'l Permit galk>ns Expiration per day)

Humboldt Bay Region 1 PGtE -e 4 16:.'006 0 Power Pt<ml Norm Coast

• Potiero Power Plant Region::'.!

SF 8&)

f..W-anlDf'lla 505 1231 :008

,_,4C<m>

U>I* Beds

• Pittsburg Power Pl;1n1 Rtgio":!

SF Bat

,,1nn1Dflla 676 531 '2007

• Mou l ~mdmg Power Pl*nl Region 3 C.n1raf Coast LS Power 1226 10'27'2005

• Diabk> Canyon Power Pl*nl Region 3 Centra1Coasi PG&E ~70 511 H1a5

• Morro Bay Power Plant Rtg1on 3 Ctn41al Coast

~ogy 688 10 12000 Redding

.,....Pi

""I/ob 0

Contril Power Plant El Segundo COSI~ Regt0nS Central Vaite,.

Region 4 t.Wan1Delt;,

NRG Energt 450 607 4 l :i'.:006 5 102005 Generillmg SlatK>n Los Angeles

• fMndalay Gener *ting Station Region 4 lOi./._ngtlH Rei.am Energy t.Unaala) 588 310:"1.)()6 Chico

• Scallergood Gent>r;1lin9 Slalion Region4 Los Angele&

LA Dept of wa1t1 & Po1"Yer 496 5 10:?005

• Alamitos G eneralmg Starion Ormond Beach Re910n 4 LOI Angtlts Re910n 4 AES AllnlltOI Rel..ant Energf 12!2 688 5 10'2005 5 102006 e Genera11n9 Statton Los .Ange~s Mandala, 0

Redondo Generating St.anon Harbof Generating Pegron 4 Los .t.ogeld Regior1 4 AES Redondo Beach LA Oep1 of 1146 108 510':!005 fl 10 2006 St.-.Hon Los Angelfs Water & Po ** ef Haynes Gener.tiling R*g10n 4 LA a.pt of 1014 s 102005 0 St.itton losAngetu *w'.'ater & Po.*.er Hununglon 8eaeh Reg1on8 AES 516 81 :?011 0 Generahng Sl.idon Santa An& Hunlln.gton Beach 0

S~ Onolfe Nulcear Gener.umg St ation ErKina Power Pl*nt Reg.one San Ottgo Re910n9 SouttlemCA E<'500 t'4RG Energy 2588 860 5 11 '2010 101 '2011 S.>n01f90 South Bay Power RegionV LS Power 602 I 1 102009 0 Pl.illnt San Diego PLANT STATUS KEV 9 P&anls u t ing Onc:e-Tluough Coohng iOTCI 0 Plants w ith plans 10 phase out OTC Bakersfield llojave llallanal Pt......

Vletorvllle source http.//cawaterkeeper.org/power-plants-once-through php log end e Coastal Po\~r Plants local Rettabitity ArNs (generalized)

C.l.romia Transmission System (partial generalized) http://sanonofresafety.org/once-through-cooling/ 02/29/2016

Once-Through Cooling I San Onofre Safety Page 7of7 Figure 1 1il Jones & Stokes locations of Power Plants, local Reliability Areas, and California's Major Transmission System Share this:

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http://sanonofresafety.org/ once-thro ugh-coo ling/ 02/29/2016