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==Subject:==
==Subject:==
 
[External_Sender]
[External_Sender]
San Onofre failed to mitigate marine damage from once-through cooling -don't allow Diablo Canyon to play the same game Folks  
San Onofre failed to mitigate marine damage from once-through cooling -don't allow Diablo Canyon to play the same game Folks  


==Subject:==
==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. S a nta Barbara report shows the San Onofre mitigation plan for all the damage oncethrough cooling doe s has never worked. There i s no plan in place to s how it ever will. Diablo Can yon s hould not be allowed to use "mitigation".
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 oncethrough 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 need s to be s hut down. Learn more at http://sanonofresafety.org/once-through-cooling/
Diablo needs to be shut down. Learn more at http://sanonofresafety.org/once-through-cooling/
Year 2009 2010 2011 2012 2013 2014 TOTAL M i tigation T arget Summary of mitigation credit for Wheeler North Reef Mitigation credit Reason for no mitigation credit No Kelp & fish standing stock too low No Fish standing stock too low No Fish standing stock too low No Fish standing stock too low No Fish s t anding stock too low No Fish standing stock too low O years 30 years (minimum) https ://sanonofresafety.files.
Year 2009 2010 2011 2012 2013 2014 TOTAL Mitigation Target Summary of mitigation credit for Wheeler North Reef Mitigation credit Reason for no mitigation credit No Kelp & fish standing stock too low No Fish standing stock too low No Fish standing stock too low No Fish standing stock too low No Fish standing stock too low No Fish standing stock too low O years 30 years (minimum) https ://sanonofresafety.files.
wordpress.com/2013/04/mi ti gationresults2014-wheelernorthreef.
wordpress.com/2013/04/mi ti gationresults2014-wheelernorthreef.
jpg?w=640 1
jpg?w=640 1
Once-Through Cooling I San Onofre Safety 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 offish 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 2011. Federal Clean Water Act §316Cb) regulations ban once-through cooling.
Once-Through Cooling I San Onofre Safety San Onofre Safety Y1 */cu Sa(c _y und Co s t Once-Through Cooling The San Onofre and Diahlo Can y on nuclear reactors kill and maim millions offi s h and other marine life every year , and damage the ecos y stem -more than all other California once-through cooling sy stem power plants. They are among the wor s t in the nation. See Sierra Club Giant Fish B l enders Juh 1 2011. Federal Clean Water Act §316Cb) regulations ban once-through cooling. NRC: U.S. Nuclear Power P l ant coo l ing sys t ems (NUREG-1437).
NRC: U.S. Nuclear Power Plant cooling systems (NUREG-1437).
Page 1of7 Of(---... --*-***--*---(--*11 ----
Page 1of7 Of(---... --*-***--*---(--*11 ----
.. *--* --..._....
.. *--* --..._.... __ .. _________ ------*------
__ .. _________ ------*------
-------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)
-------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 the ocean in Southern California.
* The California Coastal Commission issued a coa s tal de v elopment permit for reactor Units 2 and 3, a llowin g S a n Onfor e to b e built b y th e oc e an in South e rn 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.
* 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. P e rmit No. 6-81-330-A r e quir e s South e rn C a liforni a E di so n (S C E) t o d es i g n a nd build mit iga ti o n pro j ec t s th a t a d e quat e l y http://sa nonofresafety.org
Permit No. 6-81-330-A requires Southern California Edison (SCE) to design and build mitigation projects that adequately http://sanonofresafety.org
/once-through-cool ing/ 02/29/2016 Once-T hr o u g h Coo lin g I San O n ofre Safety co mp ensa t e fo r the a dv e r se e ff e cts o f th e p owe r pl a nt's o n ce-thr o u g h seawa t e r coo lin g sys t e m o n co a s t a l marin e r eso ur ces.
/once-through-cool ing/ 02/29/2016 Once-Through Cooling I San Onofre Safety compensate for 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 Page 2of7 California Otters by Cleve Nash mitigating the damage caused by San Onofre. See UCSB San Onofre Mitigation Monitoring website.
* The mitigation reef project has NOT been successful at Page 2of7 California Otters by Cleve Nash mitigating the damage caused by San Onofre. See UCSB San Onofre Mitigation Monitoring website.
* Long-term U C Santa Barbara 2014 M1tigat1on Program Annual Status Report 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 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.
* Long-term U C Santa Barbara 2014 M1tigat1on Program Annual Status Report Summary of mitigation credit for Wheeler North Reef Year Mitigation credit Reason for no m i tigation cred i t 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  
* 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.
$1 million annually.
The San Onofre Mitigation Monitoring Program is based at the Marine Science Institute, University of California Santa Barbara.
The San Onofre Mitigation Monitoring Program is based at the Marin e Science Institute, University of California Santa Barbara. California Public Utilities Commission (CPUC)
California Public Utilities Commission (CPUC)
* Annual Funding for the San Onofre (SONGS) Mitigation Monitoring Program is provided b y SCE (paid by ratepayers) as a requirement of their coastal development permit for operating San Onofr e. The UCSB portion of the costs is approximately  
* 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.
$1 million annually.
* The California Public Utilities Commission approves charges to ratepayers.
* The California Public Utilities Commission approves charges to ratepayers.
They also determine if the plant is cost-effective and reliable for ratepayers and California
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)
* 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
* California's State Water Resources Control Board is responsible for implementing the Federal Clean Water Act §316(b) regulations on cooling water http://s anonofresafety.org
/once-through-cooling
/once-through-cooling
/ 02/29/2016 Once-Through Cooling I San Onofre Safety intake structures.  
/ 02/29/2 016 Once-Through Cooling I San Onofre Safety intake structures.
: However, they have delayed implementation
However, they have delayed implementation , resulting in the death of more marine life, including California Sea Lions.
, 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. Page 3of7 Location:
* 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.
Page 3of7 Location:
Joe Serna Jr. Cal/EPA Headquarters Building.
Joe Serna Jr. Cal/EPA Headquarters Building.
Coastal Hearing Room, 1001 I Street. 2nd floor. Sacramento, CA 95814.
Coastal Hearing Room, 1001 I Street. 2nd floor. Sacramento, CA 95814.
Line 67: Line 57:
* Appendix A-Proposed Amendment to the Water Quality Control Policy on the Use of Coastal and Estuarine Waters for Power Plant Cooling
* 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
* 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.
* If the WRCB enf01*ced compliance, the costs would be prohibitive, resulting in the probable shutdown of San Onofre. Some reports ha ve been done regarding cost to r etrofit San Onofre and more are being done.
* Edison estimates  
* Edison estimates  
$2.5 billion to retrofit San Onofre -NC Times 8/8/2009
$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
* 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.
: 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.
* SWRCB Alternative Cooling System Analysis for San Onofre 2/27/2008
* NOTE: New Jersey's Oyster Creek nuclear plant is closing due to the e x pense of complying with their once-through cooling rules.
: 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
* Early closure for Oyster Creek -World Nuclear News 12/9/2010
* New Jersey Administrative Consent Order 12/9/2010
* New Jersey Administrative Consent Order 12/9/2010
Line 86: Line 74:
* 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
* 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
* SWRCB Map of OTC Plants affected
* California OTC plants affected  
* California OTC plants affected -SWRCB website
-SWRCB website
* EPA Fact Sheet for Proposed Regulations for Cooling Water Intake Structures
* EPA Fact Sheet for Proposed Regulations for Cooling Water Intake Structures
* EPA website for Cooling Water Intake Structures-CWA  
* EPA website for Cooling Water Intake Structures-CWA  
§316(b)
§316(b)
* State Water Resources Control Board Calendar California Independent System Operator (CAISO) http://sanonofresafety
* 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 4of7
.org/ once-through-cooling/ 02/29/2016 Once-Through Cooling I San Onofre Safety Pag e 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  
* 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
* 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)
. 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 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.
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.
In short, the CSLC's jurisdiction extends to more than 120 rivers and sloughs, 40 lakes and the state's coastal waters. See S t a t e L ands broch ur e for de t ails.
* 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.
* 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:
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.
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.
* 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.
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:
This required approval from the State Lands Commission:
* San Onofre Large Organism Exclusion Device Marine Mammal Monitoring and Protection Plan 8/6/2012
* San Onofre Large Organism E x clu s ion Device Marine Mammal Monitoring and Protection Plan 8/6/2012
* Revision of Rent and Lease amendment 10/19/2012:
* Revision of Rent and Lea s e amendm e nt 10/19/2012:
Approve the revision of rent for Lease No. 6785.1from  
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.
$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:
Further approvals required:
* California Coastal Commission
* Cal i fornia Coas t al Commission
* California Department of Fish and Game
* California De p artment of Fish and Game
* San Diego Regional Water Quality Control Board http://sanonofresafety.org
* San Diego R egiona l Wa t er Q uality Control Board http://sanonofresafety.org
/once-through
/once-through
-cooling/ 02/29/2016 Once-Through Cooling I San Onofre Safety
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* U.S. Army Corps of Engineers
* U.S. Army Corps of Engineers
* U.S. Coast Guard U.S. Fish and Wildlife Service
* U.S. Coast Guard U.S. Fish and Wildlife Service
* National Oceanic and Atmospheric Administration
* National Oceanic and Atmospheric Administration
* Fisheries Service ONCE-THROUGH COOLING POWER PLANTS IN CALIFORNIA Power Compliance State water-quality regulators r plant rdue date Humboldt Bay 2010 I
* Fisheries Service ONCE-THROUGH COOLING POWER PLANTS IN CALIFORNIA Power Compliance State water-quality regulators r plant rdue date Humboldt Bay 2010 I
* CALIFORNIA 80 set deadlines for coastal power plants to phase out once-through cooling technology, which kills huge volumes of fish and larvae. Contra Costa 2017----...... Pittsburg 2017-------*1 Potrero -NEVADA Moss Landing Morro Bay 2015 --------.
* CALIFORNIA 80 set deadlines for coastal power plants to phase out once-through cooling techno l ogy, which kills huge vo l umes of fish and larvae. Contra Costa 2017----...... Pittsburg 2017-------*1 Potrero -NEVADA Moss Landing Morro Bay 2015 --------.
l Dlablo Canyon 2024 l.J '-Mandalay 2020 Scattergood lf El Segundo 2020 2015 Redondo Harbor 2015 Beach 2020-tl Ji Haynes 2019 TJ Alamitos 2020 i Ormond Beach 2020 -. 11' -8 ( l Huntington Beach 2020 SOURCE: State Water Resources Control Board AARON STECKELBERG I Union-Tribune Power plants face closures  
l Dlablo Canyon 2024 l.J '-Mandalay 2020 Scattergood lf El Segundo 2020 2015 Redondo Harbor 2015 Beach 2020-tl Ji Haynes 2019 TJ Alamitos 2020 i Ormond Beach 2020 -. 11' -8 ( l Huntington Beach 2020 SOURCE: State Water Resources Control Board AARON STECKELBERG I Union-Tribune Power plants face closures -UTSanDi e go 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.
-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 intake pipes each year. This "once-through cooling" (OTC) process draws fish, larvae, plankton, and other marine life P age 5o f7 Arnmat1on 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
The State Water Board estimates that the plants' cooling systems kill billions of marine species unlucky enough to be near the intake pipes each year. This "once-through cooling" (OTC) process draws fish, larvae, plankton, and other marine life Page 5of7 Arnmat1on 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
/once-through-cooling
/ 02/29/2016 Once-Through Cooling I San Onofre Safety 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) 0 Humboldt Bay Region 1 PGtE -e 416:.'006 Power Pt<ml Norm Coast
/ 02/29/2016 Once-Through Cooling I San Onofre Safety 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 Exp i ration per day) 0 Humboldt Bay Region 1 PGtE -e 4 16:.'006 Power Pt<ml Norm Coast
* Potiero Power Region::'.!
* Potiero Power Region::'.!
f..W-anlDf'lla 505 1231 :008 Plant SF 8&)
f..W-anlDf'lla 505 1231 :008 Plant SF 8&)
* Pittsburg Power Rtgio":!  
* Pittsburg P ow er Rtgio":! ,,1nn1Dflla 676 531 '2007 U>I* Beds Pl;1n1 SF Bat ,_,4C<m>
,,1nn1Dflla 676 531 '2007 U>I* Beds Pl;1n1 SF Bat ,_,4C<m>
* Mou Region 3 LS Power 1226 10'27'2005 Po w er Pl*nl C.n1raf Coast
* Mou Region 3 LS Power 1226 10'27'2005 Power Pl*nl C.n1raf Coast
* Diabk> Canyon Reg i on 3 PG&E 511 H1a5 Po w er Pl*nl Centra1Coasi
* Diabk> Canyon Region 3 PG&E 511 H1a5 Power Pl*nl Centra1Coasi
* Morro Bay Rtg1on 3 688 10 12000 P ow er Pl ant Ctn41al Coast Redding
* Morro Bay Rtg1on 3 688 10 12000 Power Plant Ctn41al Coast Redding
* Contril Regt0nS t.Wan1Delt;, 4 50 4 l :i'.:006 P ow er Plant Central Vaite,. ""I/ob El Segundo Region 4 NRG E nergt 607 5 102005 .,....Pi 0 Generillmg SlatK>n Los Angeles
* Contril Regt0nS t.Wan1Delt;,
* fMndalay Gener *ting Reg i on 4 Rei.am Energy 588 310:"1.)()6 Station lOi./._ngtlH t.Unaala)
450 4 l :i'.:006 Power Plant Central Vaite,. ""I/ob El Segundo Region 4 NRG Energt 607 5 102005 .,....Pi 0 Generillmg SlatK>n Los Angeles
* Scallergood Region4 LA Dept of 496 5 10:?005 Chico Gent>r;1lin9 Slalion Los Angele& wa 1 t1 & Po1"Yer
* fMndalay Gener *ting Region 4 Rei.am Energy 588 310:"1.)()6 Station lOi./._ngtlH t.Unaala)
* Alamitos G e neralmg Re910n 4 AES AllnlltOI 12!2 5 10'2005 Starion LOI Angtlts e Ormond Beach Re910n 4 Rel..ant Energf 688 5 102006 Genera 1 1n9 S t atton Los Mandala,
* Scallergood Region4 LA Dept of 496 5 10:?005 Chico Gent>r;1lin9 Slalion Los Angele& wa1t1 & Po1"Yer
* Redondo Generating Pegron 4 AES R edondo 1146 510':!005 St.anon Los .t.ogeld Beach 0 Harbof Gen e rating Regior1 4 LA Oep1 of 108 fl 10 2006 St.-.Hon Los Angelfs Water & Po ** ef 0 Haynes Gener.tiling R*g10n 4 LA a.pt of 1014 s 102005 St.itton losAngetu  
* Alamitos Generalmg Re910n 4 AES AllnlltOI 12!2 5 10'2005 Starion LOI Angtlts e Ormond Beach Re910n4 Rel..ant Energf 688 5 102006 Genera11n9 Statton Los  
: Mandala,
* Redondo Generating Pegron 4 AES Redondo 1146 510':!005 St.anon Los .t.ogeld Beach 0 Harbof Generating Regior14 LA Oep1 of 108 fl 10 2006 St.-.Hon Los Angelfs Water & Po ** ef 0 Haynes Gener.tiling R*g10n 4 LA a.pt of 1014 s 102005 St.itton losAngetu  
*w'.'ater  
*w'.'ater  
& Po.*.er Hununglon 8eaeh Reg1on8 AES 516 81 :?011 0 Generahng Sl.idon Santa An& Hunlln.gton Beach
& Po.*.er Hununglon 8ea e h Reg1on8 AES 516 81 :?011 0 Generahng Sl.idon Santa An& Hunlln.gton Beach
* Onolfe Nulcear Reg.one SouttlemCA 2588 5 11 '2010 Gener.umg Station San Ottgo E<'500 0 ErKina Power Pl*nt Re910n9 t'4RG Energy 860 101 '2011 S.>n01f90 0 South Bay Power RegionV LS Power 602 I 1 102009 Pl.illnt San Diego PLANT STATUS KEV 9 P&anls uting Onc:e-Tluough Coohng iOTCI 0 Plants with plans 10 phase out OTC Bakersfield llojave llallanal Pt ...... Vletorvllle source http.//cawaterkeeper
* Onolf e Nulcear Reg.one SouttlemCA 2588 5 11 '2010 Gener.umg S t ation San Ottgo E<'500 0 ErKina Power Pl*nt Re910n9 t'4RG Energy 860 101 '2011 S.>n01f90 0 South Bay P ow er RegionV LS Power 602 I 1 102009 Pl.illnt San Diego PLANT STATUS KEV 9 P&anls u t ing Onc: e-Tluough Coohng iOTCI 0 Plants w ith plans 1 0 pha se out OTC Bakersfield llojave llallanal Pt ...... Vletorvllle source http.//cawaterkeeper
.org/power-plants-once-through php log end e Coastal Plants local Rettabitity ArNs (generalized)
.org/power-plants-once-through php log end e Coastal Plan t s loca l Rettabitity ArNs (generalized)
Page 6of7 C.l.romia Transmission System (partial generalized) http://sanonofresafety.org
Page 6of7 C.l.romia Transmission S ystem (partial generalized) http://s anonofresafety.org
/once-through-cooling
/once-through-cooling
/ 02/29/2016 Once-Through Cooling I San Onofre Safety 1il Jones & Stokes 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 Page 7of7 Figure 1 locations of Power Plants, local Reliability Areas, and California
/ 02/29/2016 Once-Through Cooling I San Onofre Safety 1il Jones & Stokes Share this: i:ii Email r;t Pnnt f Facebook 9 'fl Twitter G* Google $ More *Like Be the fir s t to like this One Response to Once-Through Cooling Page 7of7 Figure 1 locations of Power Plants, local Reliability Areas , and California
's Major Transmission System Pingback 04/lz/2013 WRCB meeting:
's Major Transmission System 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/
Once-throuq/J cooling nuclear reactors I San Onofre Safetu San Onofre Safety 71u Tu*enty T n Tht!me. B/<)(/ 11/
http://sanonofresafety.org
http://sanonofresafety.org
/ once-through-coo ling/ 02/29/2016 CHAIRMAN Resource From: joeholtzman@gmail.com Sent: Sunday, February 28, 2016 12:05 PM To: Jeffrey Mcdonald; tsforza@ocregister
/ o n ce-thro u g h-coo l ing/ 02/2 9/2016 CHAIRMAN Resource From: joeholtzman@gmail.com Sent: Sunday, February 28, 2016 12:05 PM To: Jeffrey Mcdonald; tsforza@ocregister
.com; CHAIRMAN Resource  
.com; CHAIRMAN Resource  


==Subject:==
==Subject:==
 
[External_Sender]
[External_Sender]
San Onofre failed to mitigate marine damage from once-through cooling -don't allow Diablo Canyon to play the same game Folks  
San Onofre failed to mitigate marine damage from once-through cooling -don't allow Diablo Canyon to play the same game Folks  


==Subject:==
==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. S a nta Barbara report shows the San Onofre mitigation plan for all the damage oncethrough cooling doe s has never worked. There i s no plan in place to s how it ever will. Diablo Can yon s hould not be allowed to use "mitigation".
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 oncethrough 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 need s to be s hut down. Learn more at http://sanonofresafety.org/once-through-cooling/
Diablo needs to be shut down. Learn more at http://sanonofresafety.org/once-through-cooling/
Year 2009 2010 2011 2012 2013 2014 TOTAL M i tigation T arget Summary of mitigation credit for Wheeler North Reef Mitigation credit Reason for no mitigation credit No Kelp & fish standing stock too low No Fish standing stock too low No Fish standing stock too low No Fish standing stock too low No Fish s t anding stock too low No Fish standing stock too low O years 30 years (minimum) https ://sanonofresafety.files.
Year 2009 2010 2011 2012 2013 2014 TOTAL Mitigation Target Summary of mitigation credit for Wheeler North Reef Mitigation credit Reason for no mitigation credit No Kelp & fish standing stock too low No Fish standing stock too low No Fish standing stock too low No Fish standing stock too low No Fish standing stock too low No Fish standing stock too low O years 30 years (minimum) https ://sanonofresafety.files.
wordpress.com/2013/04/mi ti gationresults2014-wheelernorthreef.
wordpress.com/2013/04/mi ti gationresults2014-wheelernorthreef.
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Once-Through Cooling I San Onofre Safety 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 offish 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 2011. Federal Clean Water Act &sect;316Cb) regulations ban once-through cooling.
Once-Through Cooling I San Onofre Safety San Onofre Safety Y1 */cu Sa(c _y und Co s t Once-Through Cooling The San Onofre and Diahlo Can y on nuclear reactors kill and maim millions offi s h and other marine life every year , and damage the ecos y stem -more than all other California once-through cooling sy stem power plants. They are among the wor s t in the nation. See Sierra Club Giant Fish B l enders Juh 1 2011. Federal Clean Water Act &sect;316Cb) regulations ban once-through cooling. NRC: U.S. Nuclear Power P l ant coo l ing sys t ems (NUREG-1437).
NRC: U.S. Nuclear Power Plant cooling systems (NUREG-1437).
Page 1of7 Of(---... --*-***--*---(--*11 ----
Page 1of7 Of(---... --*-***--*---(--*11 ----
.. *--* --..._....
.. *--* --..._.... __ .. _________ ------*------
__ .. _________ ------*------
-------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)
-------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 the ocean in Southern California.
* The California Coastal Commission issued a coa s tal de v elopment permit for reactor Units 2 and 3, a llowin g S a n Onfor e to b e built b y th e oc e an in South e rn 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.
* 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. P e rmit No. 6-81-330-A r e quir e s South e rn C a liforni a E di so n (S C E) t o d es i g n a nd build mit iga ti o n pro j ec t s th a t a d e quat e l y http://sa nonofresafety.org
Permit No. 6-81-330-A requires Southern California Edison (SCE) to design and build mitigation projects that adequately http://sanonofresafety.org
/once-through-cool ing/ 02/29/2016 Once-T hr o u g h Coo lin g I San O n ofre Safety co mp ensa t e fo r the a dv e r se e ff e cts o f th e p owe r pl a nt's o n ce-thr o u g h seawa t e r coo lin g sys t e m o n co a s t a l marin e r eso ur ces.
/once-through-cool ing/ 02/29/2016 Once-Through Cooling I San Onofre Safety compensate for 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 Page 2of7 California Otters by Cleve Nash mitigating the damage caused by San Onofre. See UCSB San Onofre Mitigation Monitoring website.
* The mitigation reef project has NOT been successful at Page 2of7 California Otters by Cleve Nash mitigating the damage caused by San Onofre. See UCSB San Onofre Mitigation Monitoring website.
* Long-term U C Santa Barbara 2014 M1tigat1on Program Annual Status Report 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 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.
* Long-term U C Santa Barbara 2014 M1tigat1on Program Annual Status Report Summary of mitigation credit for Wheeler North Reef Year Mitigation credit Reason for no m i tigation cred i t 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  
* 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.
$1 million annually.
The San Onofre Mitigation Monitoring Program is based at the Marine Science Institute, University of California Santa Barbara.
The San Onofre Mitigation Monitoring Program is based at the Marin e Science Institute, University of California Santa Barbara. California Public Utilities Commission (CPUC)
California Public Utilities Commission (CPUC)
* Annual Funding for the San Onofre (SONGS) Mitigation Monitoring Program is provided b y SCE (paid by ratepayers) as a requirement of their coastal development permit for operating San Onofr e. The UCSB portion of the costs is approximately  
* 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.
$1 million annually.
* The California Public Utilities Commission approves charges to ratepayers.
* The California Public Utilities Commission approves charges to ratepayers.
They also determine if the plant is cost-effective and reliable for ratepayers and California
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)
* 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 &sect;316(b) regulations on cooling water http://sanonofresafety.org
* California's State Water Resources Control Board is responsible for implementing the Federal Clean Water Act &sect;316(b) regulations on cooling water http://s anonofresafety.org
/once-through-cooling
/once-through-cooling
/ 02/29/2016 Once-Through Cooling I San Onofre Safety intake structures.  
/ 02/29/2 016 Once-Through Cooling I San Onofre Safety intake structures.
: However, they have delayed implementation
However, they have delayed implementation , resulting in the death of more marine life, including California Sea Lions.
, 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. Page 3of7 Location:
* 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.
Page 3of7 Location:
Joe Serna Jr. Cal/EPA Headquarters Building.
Joe Serna Jr. Cal/EPA Headquarters Building.
Coastal Hearing Room, 1001 I Street. 2nd floor. Sacramento, CA 95814.
Coastal Hearing Room, 1001 I Street. 2nd floor. Sacramento, CA 95814.
Line 206: Line 171:
* Appendix A-Proposed Amendment to the Water Quality Control Policy on the Use of Coastal and Estuarine Waters for Power Plant Cooling
* 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
* 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.
* If the WRCB enf01*ced compliance, the costs would be prohibitive, resulting in the probable shutdown of San Onofre. Some reports ha ve been done regarding cost to r etrofit San Onofre and more are being done.
* Edison estimates  
* Edison estimates  
$2.5 billion to retrofit San Onofre -NC Times 8/8/2009
$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
* 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.
: 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.
* SWRCB Alternative Cooling System Analysis for San Onofre 2/27/2008
* NOTE: New Jersey's Oyster Creek nuclear plant is closing due to the e x pense of complying with their once-through cooling rules.
: 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
* Early closure for Oyster Creek -World Nuclear News 12/9/2010
* New Jersey Administrative Consent Order 12/9/2010
* New Jersey Administrative Consent Order 12/9/2010
Line 225: Line 188:
* 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
* 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
* SWRCB Map of OTC Plants affected
* California OTC plants affected  
* California OTC plants affected -SWRCB website
-SWRCB website
* EPA Fact Sheet for Proposed Regulations for Cooling Water Intake Structures
* EPA Fact Sheet for Proposed Regulations for Cooling Water Intake Structures
* EPA website for Cooling Water Intake Structures-CWA  
* EPA website for Cooling Water Intake Structures-CWA  
&sect;316(b)
&sect;316(b)
* State Water Resources Control Board Calendar California Independent System Operator (CAISO) http://sanonofresafety
* 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 4of7
.org/ once-through-cooling/ 02/29/2016 Once-Through Cooling I San Onofre Safety Pag e 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  
* 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
* 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)
. 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 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.
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.
In short, the CSLC's jurisdiction extends to more than 120 rivers and sloughs, 40 lakes and the state's coastal waters. See S t a t e L ands broch ur e for de t ails.
* 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.
* 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:
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.
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.
* 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.
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:
This required approval from the State Lands Commission:
* San Onofre Large Organism Exclusion Device Marine Mammal Monitoring and Protection Plan 8/6/2012
* San Onofre Large Organism E x clu s ion Device Marine Mammal Monitoring and Protection Plan 8/6/2012
* Revision of Rent and Lease amendment 10/19/2012:
* Revision of Rent and Lea s e amendm e nt 10/19/2012:
Approve the revision of rent for Lease No. 6785.1from  
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.
$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:
Further approvals required:
* California Coastal Commission
* Cal i fornia Coas t al Commission
* California Department of Fish and Game
* California De p artment of Fish and Game
* San Diego Regional Water Quality Control Board http://sanonofresafety.org
* San Diego R egiona l Wa t er Q uality Control Board http://sanonofresafety.org
/once-through
/once-through
-cooling/ 02/29/2016 Once-Through Cooling I San Onofre Safety
-cooling/ 02/29/2016 Once-Through Cooling I San Onofre Safet y
* U.S. Army Corps of Engineers
* U.S. Army Corps of Engineers
* U.S. Coast Guard U.S. Fish and Wildlife Service
* U.S. Coast Guard U.S. Fish and Wildlife Service
* National Oceanic and Atmospheric Administration
* National Oceanic and Atmospheric Administration
* Fisheries Service ONCE-THROUGH COOLING POWER PLANTS IN CALIFORNIA Power Compliance State water-quality regulators r plant rdue date Humboldt Bay 2010 I
* Fisheries Service ONCE-THROUGH COOLING POWER PLANTS IN CALIFORNIA Power Compliance State water-quality regulators r plant rdue date Humboldt Bay 2010 I
* CALIFORNIA 80 set deadlines for coastal power plants to phase out once-through cooling technology, which kills huge volumes of fish and larvae. Contra Costa 2017----...... Pittsburg 2017-------*1 Potrero -NEVADA Moss Landing Morro Bay 2015 --------.
* CALIFORNIA 80 set deadlines for coastal power plants to phase out once-through cooling techno l ogy, which kills huge vo l umes of fish and larvae. Contra Costa 2017----...... Pittsburg 2017-------*1 Potrero -NEVADA Moss Landing Morro Bay 2015 --------.
l Dlablo Canyon 2024 l.J '-Mandalay 2020 Scattergood lf El Segundo 2020 2015 Redondo Harbor 2015 Beach 2020-tl Ji Haynes 2019 TJ Alamitos 2020 i Ormond Beach 2020 -. 11' -8 ( l Huntington Beach 2020 SOURCE: State Water Resources Control Board AARON STECKELBERG I Union-Tribune Power plants face closures  
l Dlablo Canyon 2024 l.J '-Mandalay 2020 Scattergood lf El Segundo 2020 2015 Redondo Harbor 2015 Beach 2020-tl Ji Haynes 2019 TJ Alamitos 2020 i Ormond Beach 2020 -. 11' -8 ( l Huntington Beach 2020 SOURCE: State Water Resources Control Board AARON STECKELBERG I Union-Tribune Power plants face closures -UTSanDi e go 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.
-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 intake pipes each year. This "once-through cooling" (OTC) process draws fish, larvae, plankton, and other marine life P age 5o f7 Arnmat1on 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
The State Water Board estimates that the plants' cooling systems kill billions of marine species unlucky enough to be near the intake pipes each year. This "once-through cooling" (OTC) process draws fish, larvae, plankton, and other marine life Page 5of7 Arnmat1on 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
/once-through-cooling
/ 02/29/2016 Once-Through Cooling I San Onofre Safety 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) 0 Humboldt Bay Region 1 PGtE -e 416:.'006 Power Pt<ml Norm Coast
/ 02/29/2016 Once-Through Cooling I San Onofre Safety 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 Exp i ration per day) 0 Humboldt Bay Region 1 PGtE -e 4 16:.'006 Power Pt<ml Norm Coast
* Potiero Power Region::'.!
* Potiero Power Region::'.!
f..W-anlDf'lla 505 1231 :008 Plant SF 8&)
f..W-anlDf'lla 505 1231 :008 Plant SF 8&)
* Pittsburg Power Rtgio":!  
* Pittsburg P ow er Rtgio":! ,,1nn1Dflla 676 531 '2007 U>I* Beds Pl;1n1 SF Bat ,_,4C<m>
,,1nn1Dflla 676 531 '2007 U>I* Beds Pl;1n1 SF Bat ,_,4C<m>
* Mou Region 3 LS Power 1226 10'27'2005 Po w er Pl*nl C.n1raf Coast
* Mou Region 3 LS Power 1226 10'27'2005 Power Pl*nl C.n1raf Coast
* Diabk> Canyon Reg i on 3 PG&E 511 H1a5 Po w er Pl*nl Centra1Coasi
* Diabk> Canyon Region 3 PG&E 511 H1a5 Power Pl*nl Centra1Coasi
* Morro Bay Rtg1on 3 688 10 12000 P ow er Pl ant Ctn41al Coast Redding
* Morro Bay Rtg1on 3 688 10 12000 Power Plant Ctn41al Coast Redding
* Contril Regt0nS t.Wan1Delt;, 4 50 4 l :i'.:006 P ow er Plant Central Vaite,. ""I/ob El Segundo Region 4 NRG E nergt 607 5 102005 .,....Pi 0 Generillmg SlatK>n Los Angeles
* Contril Regt0nS t.Wan1Delt;,
* fMndalay Gener *ting Reg i on 4 Rei.am Energy 588 310:"1.)()6 Station lOi./._ngtlH t.Unaala)
450 4 l :i'.:006 Power Plant Central Vaite,. ""I/ob El Segundo Region 4 NRG Energt 607 5 102005 .,....Pi 0 Generillmg SlatK>n Los Angeles
* Scallergood Region4 LA Dept of 496 5 10:?005 Chico Gent>r;1lin9 Slalion Los Angele& wa 1 t1 & Po1"Yer
* fMndalay Gener *ting Region 4 Rei.am Energy 588 310:"1.)()6 Station lOi./._ngtlH t.Unaala)
* Alamitos G e neralmg Re910n 4 AES AllnlltOI 12!2 5 10'2005 Starion LOI Angtlts e Ormond Beach Re910n 4 Rel..ant Energf 688 5 102006 Genera 1 1n9 S t atton Los Mandala,
* Scallergood Region4 LA Dept of 496 5 10:?005 Chico Gent>r;1lin9 Slalion Los Angele& wa1t1 & Po1"Yer
* Redondo Generating Pegron 4 AES R edondo 1146 510':!005 St.anon Los .t.ogeld Beach 0 Harbof Gen e rating Regior1 4 LA Oep1 of 108 fl 10 2006 St.-.Hon Los Angelfs Water & Po ** ef 0 Haynes Gener.tiling R*g10n 4 LA a.pt of 1014 s 102005 St.itton losAngetu  
* Alamitos Generalmg Re910n 4 AES AllnlltOI 12!2 5 10'2005 Starion LOI Angtlts e Ormond Beach Re910n4 Rel..ant Energf 688 5 102006 Genera11n9 Statton Los  
: Mandala,
* Redondo Generating Pegron 4 AES Redondo 1146 510':!005 St.anon Los .t.ogeld Beach 0 Harbof Generating Regior14 LA Oep1 of 108 fl 10 2006 St.-.Hon Los Angelfs Water & Po ** ef 0 Haynes Gener.tiling R*g10n 4 LA a.pt of 1014 s 102005 St.itton losAngetu  
*w'.'ater  
*w'.'ater  
& Po.*.er Hununglon 8eaeh Reg1on8 AES 516 81 :?011 0 Generahng Sl.idon Santa An& Hunlln.gton Beach
& Po.*.er Hununglon 8ea e h Reg1on8 AES 516 81 :?011 0 Generahng Sl.idon Santa An& Hunlln.gton Beach
* Onolfe Nulcear Reg.one SouttlemCA 2588 5 11 '2010 Gener.umg Station San Ottgo E<'500 0 ErKina Power Pl*nt Re910n9 t'4RG Energy 860 101 '2011 S.>n01f90 0 South Bay Power RegionV LS Power 602 I 1 102009 Pl.illnt San Diego PLANT STATUS KEV 9 P&anls uting Onc:e-Tluough Coohng iOTCI 0 Plants with plans 10 phase out OTC Bakersfield llojave llallanal Pt ...... Vletorvllle source http.//cawaterkeeper
* Onolf e Nulcear Reg.one SouttlemCA 2588 5 11 '2010 Gener.umg S t ation San Ottgo E<'500 0 ErKina Power Pl*nt Re910n9 t'4RG Energy 860 101 '2011 S.>n01f90 0 South Bay P ow er RegionV LS Power 602 I 1 102009 Pl.illnt San Diego PLANT STATUS KEV 9 P&anls u t ing Onc: e-Tluough Coohng iOTCI 0 Plants w ith plans 1 0 pha se out OTC Bakersfield llojave llallanal Pt ...... Vletorvllle source http.//cawaterkeeper
.org/power-plants-once-through php log end e Coastal Plants local Rettabitity ArNs (generalized)
.org/power-plants-once-through php log end e Coastal Plan t s loca l Rettabitity ArNs (generalized)
Page 6of7 C.l.romia Transmission System (partial generalized) http://sanonofresafety.org
Page 6of7 C.l.romia Transmission S ystem (partial generalized) http://s anonofresafety.org
/once-through-cooling
/once-through-cooling
/ 02/29/2016 Once-Through Cooling I San Onofre Safety 1il Jones & Stokes 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 Page 7of7 Figure 1 locations of Power Plants, local Reliability Areas, and California
/ 02/29/2016 Once-Through Cooling I San Onofre Safety 1il Jones & Stokes Share this: i:ii Email r;t Pnnt f Facebook 9 'fl Twitter G* Google $ More *Like Be the fir s t to like this One Response to Once-Through Cooling Page 7of7 Figure 1 locations of Power Plants, local Reliability Areas , and California
's Major Transmission System Pingback 04/lz/2013 WRCB meeting:
's Major Transmission System 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/
Once-throuq/J cooling nuclear reactors I San Onofre Safetu San Onofre Safety 71u Tu*enty T n Tht!me. B/<)(/ 11/
http://sanonofresafety.org
http://sanonofresafety.org
/ once-through-coo ling/ 02/29/2016}}
/ o n ce-thro u g h-coo l ing/ 02/2 9/2016}}

Revision as of 15:02, 8 July 2018

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  Southern California Edison icon.png
Issue date: 02/28/2016
From: Holtzman J
- No Known Affiliation
To: Burns S G, McDonald J, Sforza T
NRC/Chairman, Orange County Register
References
LTR-16-0103
Download: ML16060A309 (8)
v • d • e


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. S a nta Barbara report shows the San Onofre mitigation plan for all the damage oncethrough cooling doe s has never worked. There i s no plan in place to s how it ever will. Diablo Can yon s hould not be allowed to use "mitigation".

Diablo need s to be s hut down. Learn more at http://sanonofresafety.org/once-through-cooling/

Year 2009 2010 2011 2012 2013 2014 TOTAL M i tigation T arget Summary of mitigation credit for Wheeler North Reef Mitigation credit Reason for no mitigation credit No Kelp & fish standing stock too low No Fish standing stock too low No Fish standing stock too low No Fish standing stock too low No Fish s t anding stock too low No Fish standing stock too low O years 30 years (minimum) https ://sanonofresafety.files.

wordpress.com/2013/04/mi ti gationresults2014-wheelernorthreef.

jpg?w=640 1

Once-Through Cooling I San Onofre Safety San Onofre Safety Y1 */cu Sa(c _y und Co s t Once-Through Cooling The San Onofre and Diahlo Can y on nuclear reactors kill and maim millions offi s h and other marine life every year , and damage the ecos y stem -more than all other California once-through cooling sy stem power plants. They are among the wor s t in the nation. See Sierra Club Giant Fish B l enders Juh 1 2011. Federal Clean Water Act §316Cb) regulations ban once-through cooling. NRC: U.S. Nuclear Power P l ant coo l ing sys t ems (NUREG-1437).

Page 1of7 Of(---... --*-***--*---(--*11 ----

.. *--* --..._.... __ .. _________ ------*------

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 coa s tal de v elopment permit for reactor Units 2 and 3, a llowin g S a n Onfor e to b e built b y th e oc e an in South e rn 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. P e rmit No. 6-81-330-A r e quir e s South e rn C a liforni a E di so n (S C E) t o d es i g n a nd build mit iga ti o n pro j ec t s th a t a d e quat e l y http://sa nonofresafety.org

/once-through-cool ing/ 02/29/2016 Once-T hr o u g h Coo lin g I San O n ofre Safety co mp ensa t e fo r the a dv e r se e ff e cts o f th e p owe r pl a nt's o n ce-thr o u g h seawa t e r coo lin g sys t e m o n co a s t a l marin e r eso ur ces.

  • The mitigation reef project has NOT been successful at Page 2of7 California Otters by Cleve Nash mitigating the damage caused by San Onofre. See UCSB San Onofre Mitigation Monitoring website.
  • Long-term U C Santa Barbara 2014 M1tigat1on Program Annual Status Report Summary of mitigation credit for Wheeler North Reef Year Mitigation credit Reason for no m i tigation cred i t 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 Marin e Science Institute, University of California Santa Barbara. California Public Utilities Commission (CPUC)

  • Annual Funding for the San Onofre (SONGS) Mitigation Monitoring Program is provided b y SCE (paid by ratepayers) as a requirement of their coastal development permit for operating San Onofr e. 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://s anonofresafety.org

/once-through-cooling

/ 02/29/2 016 Once-Through Cooling I San Onofre Safety 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. Page 3of7 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 ha ve been done regarding cost to r etrofit 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 e x pense of complying with their once-through cooling rules.
  • Early closure for Oyster Creek -World Nuclear News 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
  • EPA Fact Sheet for Proposed Regulations for Cooling Water Intake Structures
  • EPA website for Cooling Water Intake Structures-CWA

§316(b)

.org/ once-through-cooling/ 02/29/2016 Once-Through Cooling I San Onofre Safety Pag e 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 S t a t e L ands broch ur e for de t ails.

  • 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 E x clu s ion Device Marine Mammal Monitoring and Protection Plan 8/6/2012
  • Revision of Rent and Lea s e amendm e nt 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:

  • Cal i fornia Coas t al Commission

/once-through

-cooling/ 02/29/2016 Once-Through Cooling I San Onofre Safet y

  • U.S. Army Corps of Engineers
  • National Oceanic and Atmospheric Administration
  • Fisheries Service ONCE-THROUGH COOLING POWER PLANTS IN CALIFORNIA Power Compliance State water-quality regulators r plant rdue date Humboldt Bay 2010 I
  • CALIFORNIA 80 set deadlines for coastal power plants to phase out once-through cooling techno l ogy, which kills huge vo l umes of fish and larvae. Contra Costa 2017----...... Pittsburg 2017-------*1 Potrero -NEVADA Moss Landing Morro Bay 2015 --------.

l Dlablo Canyon 2024 l.J '-Mandalay 2020 Scattergood lf El Segundo 2020 2015 Redondo Harbor 2015 Beach 2020-tl Ji Haynes 2019 TJ Alamitos 2020 i Ormond Beach 2020 -. 11' -8 ( l Huntington Beach 2020 SOURCE: State Water Resources Control Board AARON STECKELBERG I Union-Tribune Power plants face closures -UTSanDi e go 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 intake pipes each year. This "once-through cooling" (OTC) process draws fish, larvae, plankton, and other marine life P age 5o f7 Arnmat1on 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 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 Exp i ration per day) 0 Humboldt Bay Region 1 PGtE -e 4 16:.'006 Power Pt<ml Norm Coast

  • Potiero Power Region::'.!

f..W-anlDf'lla 505 1231 :008 Plant SF 8&)

  • Pittsburg P ow er Rtgio":! ,,1nn1Dflla 676 531 '2007 U>I* Beds Pl;1n1 SF Bat ,_,4C<m>
  • Mou Region 3 LS Power 1226 10'27'2005 Po w er Pl*nl C.n1raf Coast
  • Diabk> Canyon Reg i on 3 PG&E 511 H1a5 Po w er Pl*nl Centra1Coasi
  • Morro Bay Rtg1on 3 688 10 12000 P ow er Pl ant Ctn41al Coast Redding
  • Contril Regt0nS t.Wan1Delt;, 4 50 4 l :i'.:006 P ow er Plant Central Vaite,. ""I/ob El Segundo Region 4 NRG E nergt 607 5 102005 .,....Pi 0 Generillmg SlatK>n Los Angeles
  • fMndalay Gener *ting Reg i on 4 Rei.am Energy 588 310:"1.)()6 Station lOi./._ngtlH t.Unaala)
  • Scallergood Region4 LA Dept of 496 5 10:?005 Chico Gent>r;1lin9 Slalion Los Angele& wa 1 t1 & Po1"Yer
  • Alamitos G e neralmg Re910n 4 AES AllnlltOI 12!2 5 10'2005 Starion LOI Angtlts e Ormond Beach Re910n 4 Rel..ant Energf 688 5 102006 Genera 1 1n9 S t atton Los Mandala,
  • Redondo Generating Pegron 4 AES R edondo 1146 510':!005 St.anon Los .t.ogeld Beach 0 Harbof Gen e rating Regior1 4 LA Oep1 of 108 fl 10 2006 St.-.Hon Los Angelfs Water & Po ** ef 0 Haynes Gener.tiling R*g10n 4 LA a.pt of 1014 s 102005 St.itton losAngetu
  • w'.'ater

& Po.*.er Hununglon 8ea e h Reg1on8 AES 516 81 :?011 0 Generahng Sl.idon Santa An& Hunlln.gton Beach

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

.org/power-plants-once-through php log end e Coastal Plan t s loca l Rettabitity ArNs (generalized)

Page 6of7 C.l.romia Transmission S ystem (partial generalized) http://s anonofresafety.org

/once-through-cooling

/ 02/29/2016 Once-Through Cooling I San Onofre Safety 1il Jones & Stokes Share this: i:ii Email r;t Pnnt f Facebook 9 'fl Twitter G* Google $ More *Like Be the fir s t to like this One Response to Once-Through Cooling Page 7of7 Figure 1 locations of Power Plants, local Reliability Areas , and California

's Major Transmission System 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/

http://sanonofresafety.org

/ o n ce-thro u g h-coo l ing/ 02/2 9/2016 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. S a nta Barbara report shows the San Onofre mitigation plan for all the damage oncethrough cooling doe s has never worked. There i s no plan in place to s how it ever will. Diablo Can yon s hould not be allowed to use "mitigation".

Diablo need s to be s hut down. Learn more at http://sanonofresafety.org/once-through-cooling/

Year 2009 2010 2011 2012 2013 2014 TOTAL M i tigation T arget Summary of mitigation credit for Wheeler North Reef Mitigation credit Reason for no mitigation credit No Kelp & fish standing stock too low No Fish standing stock too low No Fish standing stock too low No Fish standing stock too low No Fish s t anding stock too low No Fish standing stock too low O years 30 years (minimum) https ://sanonofresafety.files.

wordpress.com/2013/04/mi ti gationresults2014-wheelernorthreef.

jpg?w=640 1

Once-Through Cooling I San Onofre Safety San Onofre Safety Y1 */cu Sa(c _y und Co s t Once-Through Cooling The San Onofre and Diahlo Can y on nuclear reactors kill and maim millions offi s h and other marine life every year , and damage the ecos y stem -more than all other California once-through cooling sy stem power plants. They are among the wor s t in the nation. See Sierra Club Giant Fish B l enders Juh 1 2011. Federal Clean Water Act §316Cb) regulations ban once-through cooling. NRC: U.S. Nuclear Power P l ant coo l ing sys t ems (NUREG-1437).

Page 1of7 Of(---... --*-***--*---(--*11 ----

.. *--* --..._.... __ .. _________ ------*------

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 coa s tal de v elopment permit for reactor Units 2 and 3, a llowin g S a n Onfor e to b e built b y th e oc e an in South e rn 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. P e rmit No. 6-81-330-A r e quir e s South e rn C a liforni a E di so n (S C E) t o d es i g n a nd build mit iga ti o n pro j ec t s th a t a d e quat e l y http://sa nonofresafety.org

/once-through-cool ing/ 02/29/2016 Once-T hr o u g h Coo lin g I San O n ofre Safety co mp ensa t e fo r the a dv e r se e ff e cts o f th e p owe r pl a nt's o n ce-thr o u g h seawa t e r coo lin g sys t e m o n co a s t a l marin e r eso ur ces.

  • The mitigation reef project has NOT been successful at Page 2of7 California Otters by Cleve Nash mitigating the damage caused by San Onofre. See UCSB San Onofre Mitigation Monitoring website.
  • Long-term U C Santa Barbara 2014 M1tigat1on Program Annual Status Report Summary of mitigation credit for Wheeler North Reef Year Mitigation credit Reason for no m i tigation cred i t 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 Marin e Science Institute, University of California Santa Barbara. California Public Utilities Commission (CPUC)

  • Annual Funding for the San Onofre (SONGS) Mitigation Monitoring Program is provided b y SCE (paid by ratepayers) as a requirement of their coastal development permit for operating San Onofr e. 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://s anonofresafety.org

/once-through-cooling

/ 02/29/2 016 Once-Through Cooling I San Onofre Safety 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. Page 3of7 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 ha ve been done regarding cost to r etrofit 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 e x pense of complying with their once-through cooling rules.
  • Early closure for Oyster Creek -World Nuclear News 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
  • EPA Fact Sheet for Proposed Regulations for Cooling Water Intake Structures
  • EPA website for Cooling Water Intake Structures-CWA

§316(b)

.org/ once-through-cooling/ 02/29/2016 Once-Through Cooling I San Onofre Safety Pag e 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 S t a t e L ands broch ur e for de t ails.

  • 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 E x clu s ion Device Marine Mammal Monitoring and Protection Plan 8/6/2012
  • Revision of Rent and Lea s e amendm e nt 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:

  • Cal i fornia Coas t al Commission

/once-through

-cooling/ 02/29/2016 Once-Through Cooling I San Onofre Safet y

  • U.S. Army Corps of Engineers
  • National Oceanic and Atmospheric Administration
  • Fisheries Service ONCE-THROUGH COOLING POWER PLANTS IN CALIFORNIA Power Compliance State water-quality regulators r plant rdue date Humboldt Bay 2010 I
  • CALIFORNIA 80 set deadlines for coastal power plants to phase out once-through cooling techno l ogy, which kills huge vo l umes of fish and larvae. Contra Costa 2017----...... Pittsburg 2017-------*1 Potrero -NEVADA Moss Landing Morro Bay 2015 --------.

l Dlablo Canyon 2024 l.J '-Mandalay 2020 Scattergood lf El Segundo 2020 2015 Redondo Harbor 2015 Beach 2020-tl Ji Haynes 2019 TJ Alamitos 2020 i Ormond Beach 2020 -. 11' -8 ( l Huntington Beach 2020 SOURCE: State Water Resources Control Board AARON STECKELBERG I Union-Tribune Power plants face closures -UTSanDi e go 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 intake pipes each year. This "once-through cooling" (OTC) process draws fish, larvae, plankton, and other marine life P age 5o f7 Arnmat1on 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 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 Exp i ration per day) 0 Humboldt Bay Region 1 PGtE -e 4 16:.'006 Power Pt<ml Norm Coast

  • Potiero Power Region::'.!

f..W-anlDf'lla 505 1231 :008 Plant SF 8&)

  • Pittsburg P ow er Rtgio":! ,,1nn1Dflla 676 531 '2007 U>I* Beds Pl;1n1 SF Bat ,_,4C<m>
  • Mou Region 3 LS Power 1226 10'27'2005 Po w er Pl*nl C.n1raf Coast
  • Diabk> Canyon Reg i on 3 PG&E 511 H1a5 Po w er Pl*nl Centra1Coasi
  • Morro Bay Rtg1on 3 688 10 12000 P ow er Pl ant Ctn41al Coast Redding
  • Contril Regt0nS t.Wan1Delt;, 4 50 4 l :i'.:006 P ow er Plant Central Vaite,. ""I/ob El Segundo Region 4 NRG E nergt 607 5 102005 .,....Pi 0 Generillmg SlatK>n Los Angeles
  • fMndalay Gener *ting Reg i on 4 Rei.am Energy 588 310:"1.)()6 Station lOi./._ngtlH t.Unaala)
  • Scallergood Region4 LA Dept of 496 5 10:?005 Chico Gent>r;1lin9 Slalion Los Angele& wa 1 t1 & Po1"Yer
  • Alamitos G e neralmg Re910n 4 AES AllnlltOI 12!2 5 10'2005 Starion LOI Angtlts e Ormond Beach Re910n 4 Rel..ant Energf 688 5 102006 Genera 1 1n9 S t atton Los Mandala,
  • Redondo Generating Pegron 4 AES R edondo 1146 510':!005 St.anon Los .t.ogeld Beach 0 Harbof Gen e rating Regior1 4 LA Oep1 of 108 fl 10 2006 St.-.Hon Los Angelfs Water & Po ** ef 0 Haynes Gener.tiling R*g10n 4 LA a.pt of 1014 s 102005 St.itton losAngetu
  • w'.'ater

& Po.*.er Hununglon 8ea e h Reg1on8 AES 516 81 :?011 0 Generahng Sl.idon Santa An& Hunlln.gton Beach

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

.org/power-plants-once-through php log end e Coastal Plan t s loca l Rettabitity ArNs (generalized)

Page 6of7 C.l.romia Transmission S ystem (partial generalized) http://s anonofresafety.org

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/ 02/29/2016 Once-Through Cooling I San Onofre Safety 1il Jones & Stokes Share this: i:ii Email r;t Pnnt f Facebook 9 'fl Twitter G* Google $ More *Like Be the fir s t to like this One Response to Once-Through Cooling Page 7of7 Figure 1 locations of Power Plants, local Reliability Areas , and California

's Major Transmission System 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/

http://sanonofresafety.org

/ o n ce-thro u g h-coo l ing/ 02/2 9/2016

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