ML24106A288

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License Renewal Application Environmental Review RCIs and RAIs
ML24106A288
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 04/18/2024
From: Kimberly Conway
NRC/NMSS/DREFS/ELRB
To: Gerfen P
Pacific Gas & Electric Co
Shared Package
ML24106A290 List:
References
Download: ML24106A288 (1)
v • d • e


Text

DIABLO CANYON NUCLEAR POWER PLANT UNITS 1 AND 2 LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW REQUESTS FOR CONFIRMATION OF INFORMATION

Regulatory Basis

Licensees are required by Title 10 of the Code of Federal Regulations (10 CFR) Part 51.53(c)(1) to submit with its application a separate document entitled Applicant's Environmental ReportOperating License Renewal Stage. The U.S. Nuclear Regulatory Commissions (NRC) regulations at 10 CFR Part 51, which implement section 102(2) of the National Environmental Policy Act of 1969, as amended (NEPA), include requirements for applicants to provide information as may be useful in aiding the NRC staff in complying with NEPA. As part of its review, the NRC staff is required to prepare a Supplemental Environmental Impact Statement to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Review guidance for the staff is provided in NUREG-1555, Supplement 1, Revision 1, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Supplement 1 - Operating License Renewal.

Requests for Confirmation of Information

The letter to Paula Gerfen, Senior Vice President, Generation, and Chief Nuclear Officer, dated February 27, 2024 (Agencywide Documents Access and Management System ML24056A002),

contained an audit plan, which included a list of information needs with unique identifiers. During the environmental audit, the NRC staff reviewed documents that were made available on the applicants electronic information portal in response to the staff audit needs. The staff also participated in breakout sessions with applicant personnel for certain resource areas to gather information that will likely be used in the site-specific environmental impact statement. To the best of the staffs knowledge, this information on the applicants electronic information portal and discussed in breakout sessions is not currently on the docket or publicly accessible. The NRC staff requests that the applicant submits confirmation that the information gathered from the audit and listed below is correct or provides the associated corrected information.

1) RCI AQN-1

During the environmental audits Air Quality and Noise breakout session and in response to information need AQN-1, Pacific Gas and Electric Company (PG&E) provided clarification related to a 162-horsepower emergency diesel generator recently transferred to the County of San Luis Obispo. Confirm that the 162-horsepower emergency diesel generator was removed from service and dispositioned in November 2022.

2) RCI AQN-2

During the environmental audits Air Quality and Noise breakout session and in response to information AQN-2, PG&E stated that there have been no notices of violations or non-compliance associated with Diablo Canyon Nuclear Power Plant (DCPP) air emissions in 2023. Confirm that there were no notices of notices of violations or non-compliance associated with DCPP air emissions in 2023.

Enclosure 2

3) RCI AQN-3

During the environmental audits Air Quality and Noise breakout and Greenhouse Gas and Climate Change sessions and in response to information need GEN-1, AQN-3, GHG-1, and GHG-5, PG&E provided the clarifications regarding table 3.3-10 of the environmental report (ER). Confirm the following:

  • On January 4, 2024, PG&E was issued a Conditional Permit Exemption Number 2365-1 (CPE-2365-1) for 12 diesel engines (with a capacity rating less than 50 horsepower [hp])

at Diablo Canyon. Operation is limited to 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per engine per calendar year.

  • Diesel Particulate Matter (DPM) for years 2018, 2019, 2020, 2021 2022, and 2023 in tons are 0.11, 0.22, 0.13, 0.17, 0.15, and 0.20, respectively.
  • Emission sources accounted for in the DPM emissions include those listed in table 3.3-9 of the ER, the 162-hp emergency diesel generator that has been removed from service (for years 2018-2022); ten (10) small diesel engines (less than 50 hp each) that are permit-exempt from the San Luis Obispo Air Pollution Control District; and twelve (12) diesel engines (less than 50 hp each) in CPE-2365-1.
  • Volatile Organic Compounds (VOC) emissions for years 2018, 2019, 2020, 2021, 2022, and 2023 in tons are 0.10, 0.16. 0.06, 0.08, 0.13, and 0.12, respectively. The VOC emissions sources for these emissions are from industrial paint and solvent use.
4) RCI FPE-1

From information gathered during the environmental site audit, the NRC staff understands that PG&E personnel have permission from the California Department of Fish and Wildlife (CDFW) to secure and collect sea otter carcasses found on the Diablo Canyon site or in surrounding marine waters. PG&E reports and turns over these carcasses to the CDFW to support the CDFWs long-term sea otter mortality monitoring program, in accordance with a CDFW letter dated September 15, 2021, that authorizes PG&E to conduct this activity.

5) RCI FPE-2

ER Section 4.6.6.4.5 states: Operation of the DCPP intake and discharge structures, sand replenishment, dredging, or in-water construction may alter black abalone habitat and subsequently influence nearshore circulation patterns. However, from information gathered during the environmental site audit, the NRC staff understands that PG&E has no plans for sand replenishment activities or in-water construction during the license renewal term.

PG&E has obtained applicable permits from the U.S. Army Corps of Engineers (USACE) to perform dredging in the intake cove in spring 2024. As part of the permitting process, the USACE considered potential impacts to federally protected ecological resources, including the black abalone. Black abalone occur on the seaward side of the intake cove breakwaters but do not occur within the intake cove itself. Therefore, measurable impacts to this species related to dredging are not anticipated. PG&E would implement appropriate best management practices and mitigation, as required by USACE permits, to minimize disturbance to the aquatic environment. All dredging would be completed within the current period of operation under the original facility operating license term. PG&E has no plans for additional dredging during the license renewal period.

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6) RCI FPE-6

From information gathered during the environmental site audit, the NRC staff understands that PG&E regularly trains its personnel and contractors performing work in areas near documented locations of federally protected species. PG&E has also implemented certain avoidance and mitigation measures related to federally protected species on the Diablo Canyon site. These include the following.

Federally Protected Birds:

PG&Es Nesting Bird Management Plan requires personnel to conduct a desktop review as part of the environmental planning process prior to initiating activities in locations that provide suitable habitat for nesting birds. A qualified biologist determines if there is potential for the activities to impact nesting birds. If there is potential to impact active nests in or near construction areas, pre-construction surveys are conducted. Nest exclusion buffers are established, as appropriate, according to species-specific exclusion buffers identified in the Nesting Bird Management Plan.

PG&E also confers with the U.S. Fish and Wildlife Service and/or California Department of Fish and Wildlife when the standard buffer cannot be observed for a nesting threatened, endangered, or fully protected species.

For federally listed birds that may occur in the Diablo Canyon action area, the standard buffer zones are as follows:

  • Hawaiian petrel: unspecified
  • Least Bells vireo: 500 feet
  • Marbled murrelet: 1,320 feet for the 90 decibels or greater measured at 50 feet. Smaller buffers may be established based on the methodology found in Estimated the Effects of Auditory and Visual Disturbance to Northern Spotted Owls and Marbled Murrelets in Northwestern California (FWS 2006)
  • Short-tailed albatross: unspecified
  • Western snowy plover: 600 feet (coastal) and 300 feet (interior)
  • Yellow-billed cuckoo: 500 feet

California Red-legged Frog Protection Measures:

  • Do not handle any frogs.
  • A biological monitor shall be present for any activities with potential to impact California red-legged frog in Diablo Creek, such as vegetation management, moving of heavy equipment or materials, or ground disturbance.
  • Work within Diablo Creek should be limited to the dry season (May through October).
  • Look for frogs when lifting materials, such as plastic or plywood, moving equipment, or storage bins.
  • Minimize standing water to the greatest extent possible.
  • Collect and remove all trash daily.

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  • Keep all hazardous materials at least 100 feet from Diablo Creek (e.g., fuel, oil, or other harmful chemicals).
  • Respond to spills, leaks, and drips immediately to protect adjacent water quality.
  • Drive slowly (5 miles per hour) on the north access road between Gate Charlie and Gate Alpha when its wet, foggy, or dark outside.

California Red-legged Frog Observation Protocol:

If any frog is found:

  • Stop work near the frog and carefully secure a buffer of at least 50 feet around the frog.
  • Call Environmental Operations.
  • Monitor the frog to ensure it will not be harmed; expand the buffer if necessary.
  • Continue monitoring until input is received, or the frog leaves the work site.
  • Work may not resume until the frog has left on its own volition or the area can be entirely isolated and protected from operations.
7) RCI GHG-1

During the environmental audits Greenhouse Gas and Climate Change breakout session and in response to GHG-1, PG&E clarified that in Section 3.3.4 of the ER the correct table number cited with respect to stationary and portable combustion sources should be table 3.3-9 not table 3.3-10.

Confirm that the following statement in the ER should read as follows: Therefore, PG&E calculated greenhouse gas (GHG) emissions on direct emission sources (stationary and portable combustion sources shown in table 3.3-9 and reported in DCPPs annual updates and air emissions statements), refrigerant used at the facility, and indirect emission sources (workforce commuting for plant activities where information was readily available).

8) RCI GHG-2

During the environmental audits Greenhouse Gas and Climate Change breakout session and in response to GHG-2, PG&E provided GHG emissions for the year 2023; informed the NRC that the GHG emissions in table 3.3-11 of the ER were incorrect, the correct values were provided; and discussed why emissions from combustion sources were relatively greater in 2018, 2022, and 2023. Confirm the following:

  • Carbon dioxide equivalent emissions in metric tons for combustion sources for the years 2018, 2019, 2010, 2021, 2022 and 2023 in metric tons are 717, 1,016, 740, 944, 1,042, and 1,153, respectively.
  • GHG emissions from combustion sources were greater in 2019 due to a series of upgrades for the main emergency generators that required additional run times; in 2022 as a result of the loss of 100 percent of freon from the Heating, Ventilation, and Air Conditioning units from two buildings; and in 2023 due to additional operation run times due to maintenance and troubleshooting of diesel generators and refrigerant leaks.
9) RCI GHG-5

During the environmental audits Greenhouse Gas and Climate Change breakout session and in response to GHG-5, PG&E stated that sulfur hexafluoride is used on-site and calculations for the quantified GHG emissions for combustion onsite sources were provided. Confirm the following:

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  • DCPP has small hermetically sealed sulfur hexafluoride breakers and since they are sealed, they were not reported as part of the GHG emissions in table 3.3-9.
  • Combustion sources accounted for GHG emissions include those listed in table 3.3-9 of the ER, the 162-hp emergency diesel generator that has been removed from service (for years 2018-2022); ten (10) small diesel engines (less than 50 hp each) that are permit-exempt from the San Luis Obispo Air Pollution Control District; twelve (12) diesel engines (less than 50 hp each) included in CPE-2365-1; and refrigerant sources.
10) RCI GW-1

In response to information need GW-1, PG&E provided information describing the relationship between inferred groundwater elevations and the locations of systems, structures, and components with a credible mechanism for the release of licensed material to groundwater.

Confirm the following statements.

  • The juxtaposition of the deep foundation basements with the inferred groundwater elevation surface indicates that no areas of the power block extend into groundwater beneath DCPP.
  • Vertical migration from inadvertent leaks and/or spills within the power block is possible through potential pathways at sumps, floor drains, underground pipes, or seismic gaps between buildings.
11) RCI GW-4

In response to information need GW-4, PG&E provided documentation of tritium sampling at DCPP in response to the Nuclear Energy Institute (NEI) Groundwater Protection Initiative that included monitoring of water collected in the French drain systems installed around the fuel handling building and the reactor containment buildings. Confirm the following statement.

  • The French drain systems were installed during plant construction to relieve potential groundwater hydrostatic pressure that might build up around the fuel handling building and reactor containment structures.
12) RCI GW-6

In response to information need GW-6, PG&E provided hourly groundwater level data from monitoring wells GW-1 and GW-2 since October 2020. Confirm the following statements.

  • No groundwater potentiometric maps of the DPCC site have been prepared since the 2012 map provided in ER figure 3.6-7.
  • Daily fluctuations in water levels in GW-1 and GW-2 are typically less than 1 inch.
  • Typical seasonal fluctuations in water levels in GW-1 and GW-2 are 1 - 2 inches.
  • The average depth to water in GW-1 and GW-2 was about 73 feet from October 2020 thru 2022.
  • The record rainfall in 2023 resulted in the water level rising at least 5 feet in GW-1 and at least 8 feet in GW-2.

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13) RCI GW-7

In response to GW-7, PG&E indicated that the 2023 Annual Radiological Environmental Report was currently in draft. Please confirm the following statement.

  • No plant-related radionuclides were detected in 2023 in wells WW2, GW-1, GW-2, 8S3, or spring location 1A2.
14) RCI HCR-2

During the environmental audit, PG&E was asked to provide citations and references for the information used to write section ER 3.8, in particular sections 3.8.1 through 3.8.5. In response, PG&E provided two documents for NRCs review: the National Register of Historic Places (NRHP) nomination form for the Rancho Canada de Los Osos y Pecho y Islay archaeological district and a 2021 archaeological report written by PG&E contractor Applied EarthWorks, Inc.

During the audit, the NRC staff also asked if archaeological reports were sent to the Tribes and/or the California Office of Historic Preservation (OHP). PG&E responded that the NRHP form had been provided to the yak titu titu yak tiłhini Northern Chumash Tribe (YTT) but in general, their requests are more specific to projects, not archaeological reports. PG&E shared that consultants provide reports to the California Historical Resources Information System Information Centers, not OHP directly. The state is currently in the process of setting up a portal where digitized records will be more accessible to consultants.

15) RCI HCR-3

During the environmental audit, the staff asked whether PG&E had any conversations with OHP regarding the license renewal and, if so, to provide all correspondence and a summary of those conversations. PG&E provided a summary of a November 8, 2023, meeting with OHP Senior State Archaeologist Brendon Greenaway to discuss the license renewal. The summary addressed updating PG&Es 1980 archaeological resources management plan (ARMP), coordination with NRC to determine whether consultation would continue from the prior license renewal application that was withdrawn in March 2018 (ML18066A937) or start fresh with the current proposed action, and confirming with NRC what roles PG&E could serve during the Section 106 consultation with their office.

During the environmental audit, staff understood the following:

  • A historic properties management plan or an update to the 1980 ARMP may be necessary, but PG&E would take lead from NRC on what is required for the license renewal.
  • NRC and PG&E staff agreed that consultation with the OHP should focus only on the current effort as NRC is considering it a new undertaking.
  • NRC would not delegate Section 106 responsibilities to PG&E. This would be communicated to OHP in NRCs follow-up call with them.
16) RCI HCR-4

During the environmental audit, as part of information need HCR-4, the staff asked PG&E to provide copies of letters sent and received from Federal and state-recognized Tribes seeking input on the current license renewal. In response, PG&E provided 26 pieces of correspondence.

Please confirm the following:

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  • PG&E sent correspondence on October 18, 2023, to the Barareno/Ventureno Band of Mission Indians (BVBMI), Coastal Band of the Chumash Nation, Northern Chumash Tribal Council, Salinan Tribe, Santa Ynez Band of Chumash Indians, Tule River Tribe, Xolon-Salinan Tribe, and the YTT discussing PG&Es intention of filing a license renewal application with NRC based on the States 2022 passing of SB 846.
  • PG&E sent correspondence on November 7, 2023, to the BVBMI, Coastal Band of the Chumash Nation, Northern Chumash Tribal Council, Salinan Tribe, Santa Ynez Band of Chumash Indians, Tule River Tribe, and the Xolon-Salinan Tribe to inform them that the license renewal application had been submitted with the NRC.
  • PG&E sent correspondence on December 20, 2023, to the BVBMI, Chumash Council of Bakersfield, Coastal Band of the Chumash Nation, Northern Chumash Tribal Council, Santa Ynez Band of Chumash Indians, Salinan Tribe, Tule River Tribe, Xolon-Salinan Tribe, and the YTT regarding NRCs acceptance of sufficiency for PG&Es license renewal application.

Additionally, confirm that in response to the correspondence above, PG&E received responses from the YTT and the Northern Chumash Tribal Council October 18, 2023 (the latter more related to the Chumash Heritage National Marine Sanctuary designation campaign).

17) RCI HCR-5

During the environmental audit, the staff asked PG&E for more information on their Confidential Cultural Resources Database (CCRD), including who had access and how sensitive cultural resources information was safeguarded. The NRC staff learned that the CCRD is PG&Es primary repository for archaeological sites, tribal cultural resources, traditional use areas, and related information. The CCRD also contains non-sensitive information related to historic built-environment resources and studies. Access to the database is restricted to PG&Es cultural resource specialists and authorized contractors who use the CRDD for environmental compliance, risk management, and resource stewardship. PG&E authorizes who has access, they define allowable uses, and defend against misuse or inadvertent disclosure of sensitive resources. A compliance bulletin was provided for NRCs review that shared more information about the CCRD.

18) RCI HCR-6

During the environmental audit, the staff asked PG&E to confirm how much of the 750-acre area of potential effects (APE) had been surveyed for cultural resources. PG&E was also asked to confirm how much of the area had been disturbed by construction and other ground-disturbing activities post-2015, when the same question was asked then. PG&E stated that the APE had been 100 percent surveyed with the exception of areas with steep slopes or localized dense vegetation. PG&E confirmed that the percentage of ground disturbance at DCPP since 2015 remained unchanged.

19) RCI HCR-8

During the environmental audit, the staff asked what steps were taken to identify any Traditional Cultural Properties (TCPs) within the APE and whether there were additional ethnographic studies conducted in the APE in addition to the 2020 John R. Johnson ethnohistory. PG&E responded that they have not commissioned a study specifically to identify TCPs, however, the 2020 Johnson ethnohistory is the only ethnographic study within the Diablo Canyon lands that focuses on the Northern Chumash people. PG&E directed NRC staff to a 2013 ethnography written by Jennifer Whiteman of the Japanese farming families that lived along Pecho in the early 1900s. A copy of that report was requested; PG&E provided the report the following day.

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20) RCI HCR-10

Please confirm that 13 documents and procedures were provided for the staffs review during the environmental audit in response to HCR-10:

  • John R. Johnson ethnohistory submitted to PG&E in 2020
  • NRHP nomination form for the Rancho Canada de Los Osos y Pecho y Islay archaeological district
  • Diablo Canyon Decommissioning Cultural Resource Inventory and Study Plan- Enright et al. 2021
  • Page and Turnbull Historic Built Environment Evaluation and report from 2022
  • The 1980 Archaeological Resources Management Plan Diablo Canyon Site
  • The Interdepartmental Administrative Procedure EV2.IDA (Rev. 5)
  • The 1982 Access Agreement between PG&E and Santa Ynez Band of Mission Indians
  • The 1987 Memorandum of Understanding (MOU) for the Treatment of Human Burials and Grave Goods and the Curation of Artifacts for Archaeological Site CA-SLO-2 on DCPP Property
  • DCPP Land Stewardship charter Cultural Resources Standard for Environmental Management (ENV-8005S)
  • ENV-8005P-01, the Cultural Resource Constraints Report Procedure
  • Cultural Resources Awareness and Response Brochure
  • Other best management practices (training, guidance, etc.)

As discussed during the audit, PG&Es records indicate that the 1987 MOU for the treatment of human remains has not been updated. Based on the discussion of inadvertent discovery plans (IDPs) for inadvertent discoveries outside of SLO-2, PG&E confirms it has two IDPs: one for state and private lands and the other for federal lands where Native American Graves Protection and Repatriation Act compliance may apply. Additionally, if human remains are encountered, the state has public resources codes that govern next steps. The path forward would include the California Native American Heritage Commission designating the Most Likely Descendant.

21) RCI HH-2

As discussed during the virtual audit, the correspondence between the plant and the State of California discussed in section 4.9.1.4 was not specific to microbiological hazards. A review of microbiological hazards to the public are not applicable at Diablo Canyon because the DCPP discharge cove connects directly to the Pacific Ocean and this area is protected by a 2,000-yard marine exclusionary area which restricts access to the discharge cove. This in turn restricts access to the public, so no response related to the microbiological hazards is expected from the State of California in this area. The communications that are provided in attachment E of the ER are related to relicensing actions in general terms.

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22) RCI HH-4

Please confirm that the transmission line Lidar scans reviewed and discussed during the audit weeks meet the requirements of the California Public Utilities Commission (CPUC) governing standards and that all in-scope transmission lines were found to have adequate clearance or compensatory measures have been put in place, as needed. As discussed during the audit weeks, these Lidar scans are performed on an annual basis to ensure compliance with PG&Es governing manual for transmission line maintenance which is designed to support compliance with CPUC General Order 165, Inspection Requirements for Electric Distribution and Transmission Facilities, as well as relevant portions of General Order 95, Rules for Overhead Electric Line Construction, and General Order 128, Rules for Construction of Underground Electric Supply and Communication Systems. In addition, please confirm that all in-scope portions of the transmission lines as shown in figure 2.2-2 and the associated text lie within the exclusion area boundary and that work conducted near high-voltage equipment falls under the sites occupational safety program.

23) RCI LV-1

As discussed during the virtual audit, Section 3.1.4 of the ER discusses planned modifications to the DCPP Independent Spent Fuel Storage Installation (ISFSI). Please confirm that construction will be confined to the existing developed ISFSI site and that there are no other areas outside of the ISFSI area that will be either temporarily or permanently disturbed. Please also confirm that the new modules will be fabricated externally and shipped to site.

24) RCI NOI-3

During the environmental audits Air Quality and Noise breakout and in response to NOI-3, PG&E stated that no noise complaints have been received related to DCPP activities since submission of the ER. Confirm that no noise complaints have been received related to DCPP activities since the ER was submitted.

25) RCI SNF-1

As discussed during the audit, please confirm that there is adequate storage capacity to store spent nuclear fuel that will be produced during the current license term up through when the renewed licenses expire using the existing ISFSI and the Unit 1 and Unit 2 spent fuel pools. Please confirm that if the dry storage capacity needs to be increased, previously disturbed land on the site is likely to be sufficient for the expansion with no significant environmental impact.

26) RCI SOC-1

Please confirm that PG&E paid approximately $29,109,244 in property taxes on behalf of DCPP in calendar year 2017 and approximately $13,943,808 in property taxes on behalf of DCPP in calendar year 2023.

27) RCI SW-1

Please confirm that DCPPs ocean water withdrawals are not currently subject to any water allocation or related permitting requirements, except that the plants current National Pollutant Discharge Elimination System (NPDES) permit imposes a discharge volume limit on Outfall 001 of 2,540 million gallons per day.

9 Additionally, please confirm that should PG&E operate DCPP past October 30, 2030, it is PG&Es expectation that DCPP would continue to operate with its once-through cooling system as it is currently configured, and any state-required environmental mitigation fees related to the Once-Through Cooling Policy would be in accordance with State of California requirements.

28) RCI SW-4

ER tables 3.6-4a and 3.6-4b provided yearly and monthly surface water withdrawal data, respectively, for years 2018 through 2022. PG&E provided similar data for 2023 in the portal.

Please confirm that the yearly and monthly surface water withdrawal data for 2023 shown below are accurate.

2023 Yearly Surface Water Withdrawal Monthly Monthly Monthly Yearly Total Maximum Average Minimum Withdrawal (MGM) 77,066 70,333 40,801 843,998 MGY Withdrawal (gpma) 1,726,389 1,606,829 914,001 2,312 MGD MGY - million gallons per year MGM - million gallons per month MGD - million gallons per day gpma - average gallons per minute for the month

2023 Monthly Surface Water Withdrawals Month Intake (MGM) Total (gpma)

January 75,143 1,683,311 February 69,608 1,726,389 March 72,677 1,628,069 April 74,580 1,726,389 May 77,066 1,726,389 June 74,580 1,726,389 July 77,066 1,726,389 August 77,066 1,726,389 September 74,427 1,722,847 October 40,801 914,001 November 55,125 1,276,042 December 75,859 1,699,350 MGM - million gallons per month gpma - average gallons per minute for the month

29) RCI SW-6

Please confirm that there have been no abnormal or reportable radioactive or nonradioactive releases to the environment since 2022.

30) RCI SW-7

Please confirm that the Pacific Ocean surface water intake nearest to DCPP is the Moss Landing Power Plant's once-through cooling water system's intake in Monterey County.

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31) RCI SW-8

Please confirm that during PG&E's discussions with the Central Coast Regional Water Quality Control Board, the Board's staff did not indicate that any changes to the DCPP's NPDES permit will be required when it is reissued.

32) RCI SW-9

Please confirm that during PG&E's discussions with the Central Coast Regional Water Quality Control Board, the Board's staff did not indicate that any changes to the DCPP's once-through cooling system were anticipated as a result of the State of California's once through cooling policy.

33) RCI SW-10

Please confirm that the following statements are accurate regarding the DCPP Intake Cove Dredging Permit Number SPL-2023-00468 and the Coastal Zone Management Act (CZMA):

  • PG&E, the permittee, is authorized to (a) dredge up to 70,000 cubic yards of accumulated sand and sediment from within a 125,000 square-foot dredge footprint at the north end of the intake cove to a depth of -38 ft mean lower low water (MLLW) and (b) place the dredged material at the USACE Nearshore Placement Area located south of the entrance to Morro Bay and west of Morro Bay State Park.
  • The authorized activities (dredging and placement of dredged material) must be completed on December 31, 2025.
  • If PG&E discovers any previously unknown historic or archeological remains while performing authorized activities, PG&E must immediately notify USACE what was found.

USACE will initiate any required Federal and State coordination.

  • PG&E must notify USACE within 10 days prior to the date of commencement and within 10 days following the end of completion of the activity.
  • The dredging permit is contingent upon the issuance of a CZMA consistency certification by the California Coastal Commission. PG&E is required to comply with the terms and conditions of the CZMA consistency certification. PG&E is required to submit the CZMA consistency certification to USACE within two weeks of receiving the certification. PG&E cannot proceed with authorized activities until USACE acknowledges that the CZMA consistency certification is acceptable.
  • The dredged material will be tested according to the provisions of Inland Testing Manual or the Ocean Disposal Manual and the USACE Regional Guidance Letter 06-02. The sampling of the dredged material will be performed according to the USACE and Environmental Protection Agency (EPA) approved Sampling and Analysis Plan (SAP). The SAP results will be approved by USACE before PG&E can perform the authorized activities.
  • PG&E will develop and implement a Dredging Quality Management (DQM) system following the National DQM system that must be certified by the DQM Support Center within one calendar year prior to PG&E performing any authorized activities.
  • PG&E will report details of any noncompliance of the permit to the USACE Regulatory Division within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
  • PG&E is required to perform pre- and post-construction bathymetric surveys taken within 30 days prior to starting dredging and within 30 calendar days of completion, respectively, of each dredging event.

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  • PG&E will perform a pre-construction survey for presence of eelgrass. Any present eelgrass will be avoided to the maximum practicable extent. A post-construction survey is also required and in the event of any loss of eelgrass, the USACE with coordinate with NMFS to mitigate the impacts following the California Eelgrass Mitigation Policy.
  • The dredging permit does not authorize PG&E to take any threatened or endangered species or to adversely modify their designated critical habitat.
  • PG&E will immediately report any event of entanglement of injury to, or killing of, any National Oceanic and Atmospheric Administration Fisheries-listed species under the Endangered Species Act to the Regulatory Office of the Los Angeles District of the USACE.
34) RCI SW-11

Please confirm that in a letter dated August 29, 1996, the California Regional Water Quality Control Board, Central Coast Division stated that the DCPP NPDES Permit No. CA0003751, per California Code of Regulations, title 23, section 2235.4 remains valid until a new permit is issued as long as PG&E complies with the requirements of the permit.

35) RCI SW-13

Please confirm that the following statements are accurate regarding the DCPP Spill Prevention, Control, and Countermeasures (SPCC) Plan, Revision 4, dated December 2023 prepared pursuant to Title 40 of the Code of Federal Regulations (40 CFR) Parts 112 and 761:

  • PG&E is required to review and evaluate the plan at least once every five years or immediately after a reportable quantity oil spill event. If more effective prevention and control technology is identified during the review, the plan will be amended. If a change in facility design, construction, operation, or maintenance occurs that may significantly affect the facilitys potential for offsite discharge of oil to navigable waters, the plan will be amended within six months.
  • Currently, PG&E is not planning to implement DCPP facility modifications related to SPCC improvements.
  • PG&E uses an integrated response to hazardous materials spills at DCPP. The integrated response includes written procedures, administrative controls, training of all site personnel, site-wide coordination, trained and dedicated hazardous materials response team, strategically placed, and quarterly inventoried emergency spill kits, and emergency response agreements with outside hazardous materials response organizations.
36) RCI SW-14

Please confirm that the Storm Water Pollution Prevention Plan for the DCPP will be updated when a new Industrial General Permit (Order No. 2014-0057-DWQ) is issued by the State of California State Water Resources Control Board, and that PG&E expects that the new Industrial General Permit will be issued in the 2024-2025 timeframe.

37) RCI SW-15

Please confirm that the watershed sanitary survey and report described in item 10 of PG&E Diablo Canyon Domestic Water Supply Permit for Public Water System No. 4000589 is no longer required and has been replaced with an annual report submitted to the San Luis Obispo County Health Department. Additionally, please place the latest annual report on the portal for review.

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38) RCI SW-20

Please confirm the following statements about the Receiving Water Monitoring Program (RWMP):

  • The monitoring includes seawater temperature and biological data. Monitoring data are collected at intertidal and subtidal stations located in South Diablo Cove, North Diablo Cove, South Diablo Point, Fields Cove, South Control, and North Control areas. Water temperatures are recorded every 20 minutes. Intertidal horizontal band transects are surveyed four times per year for algae, seagrass, invertebrates, and substrate. Intertidal vertical band transects are surveyed four times per year for fishes. Subtidal benthic stations are surveyed four times per year for algae, invertebrates, ad substrate. Subtidal fish are surveyed four times per year. Habitat-forming kelp survey is performed annually.
39) RCI TER-1

From information gathered during the environmental audit, please confirm the characteristics of each meteorological (MET) tower as follows: 1) primary MET tower is guyed, is 76 m above ground level, and is lighted with a blinking red light at the top, 2) the backup MET tower is 61 m, is lighted with a blinking red light at the top and has no bird diverters installed on the guy lines.

40) RCI TER-2

Please confirm as stated during the environmental audit that U.S. Fish and Wildlife Services has not yet issued a new Special Use Utility Permit (SPUT). Also please confirm as stated during the audit that PG&E continues to operate under the conditions of previous SPUT permit.

41) RCI TER-4

From information gathered during the environmental audit, please confirm that there have been no known bat mortalities at the DCPP site and that there are no known bat maternity roosts within the DCPP site.

42) RCI WM-1

As discussed during the audit, please confirm that there are no proposed changes or upgrades to the effluent control program planned for the license renewal term.

43) RCI WM-2

As discussed during the audit, please confirm that there are no other types of waste stored in the area designated for mixed waste storage and that there are no proposed changes to the mixed waste storage program during the license renewal term.

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44) RCI WM-3

Please confirm that there are no proposed changes or upgrades to the solid waste processing system program being considered for the license renewal term. Please confirm that there is adequate storage between the ISFSI, low-level waste storage capacity, and spent fuel pools to safely store the greater-than-Class C waste likely to be generated during the license renewal term, accounting for the needed capacity for the spent nuclear fuel generated through the period of extended operation.

45) RCI WM-4

As discussed during the audit, please confirm there have been no reportable oil spills triggering 40 CFR 110 since the ER was written.

46) RCI WM-5

As discussed during the audit, please confirm that there have been no reportable unplanned releases of radioactive materials since the ER was written.

47) RCI WM-6

As discussed during the audit, please confirm that there have been no reportable inadvertent releases or spills of nonradioactive contaminants requiring notification since the ER was written.

48) RCI WM-9

As discussed during the audit, please confirm that PG&E currently uses Clean Harbors, Pacific Petroleum, and Safety Kleen for shipping its hazardous and non-hazardous wastes and that the following is a list of the facilities utilized for treatment, storage, and/or disposal of these wastes:

Chemical Waste Management Kettleman Hills Facility, Clean Harbors Aragonite, Clean Harbors San Jose, Clean Harbors Grassy Mountain, Clean Harbors Buttonwillow, Safety Kleen Newark, Emerald Services, and Thermo Fluids.

14 DIABLO CANYON POWER PLANT UNITS 1 AND 2 LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW REQUESTS FOR ADDITIONAL INFORMATION

1) RAI GEN-1

REQUIREMENT: Title 10 of the Code of Federal Regulations (10 CFR) Part 51.53(c)(iv) requires that environmental reports contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware.

ISSUE: Table B-2 of the draft Supplemental Environmental Impact Statement, Operating Permits and Other Requirements, will list the permits and licenses issued by Federal, State, and local authorities for activities at Diablo Canyon, as identified in table 9.1-1 in appendix E of the Diablo Canyon Environmental Report (ER), dated November 7, 2023 (Agencywide Documents Access and Management System ML23311A154). As part of preparing the site-specific environmental impact statement, the staff must consider whether there have been any changes to operating permits or other requirements.

REQUEST: Please provide any relevant updates to table 9.1-1 that have transpired since the ER dated November 7, 2023. If any permits have expired since submitting the license renewal (LR) application to the U.S. Nuclear Regulatory Commission (NRC), please provide the status of those permits and/or renewals.

2) RAI AQU-1

REQUIREMENT: 10 CFR 51.53(c)(3)(ii)(B) requires that if plant uses a once-through cooling or cooling pond heat dissipation system, the license renewal applicant submit a copy of current Clean Water Act 316(b) determinations and, if necessary, a 316(a) variance in accordance with 40 CFR Part 125, or equivalent State permits and supporting documentation.

ISSUE: The NRC staff requires copies of supporting documentation related to Clean Water Act 316(a) concerning thermal effluents and Clean Water Act 316(b) concerning impingement and entrainment to independently review these issues and assess impacts on aquatic resources during the proposed license renewal term.

REQUEST: Please provide the following documents:

a) Superior Court of the State of California, County of San Luis Obispo. 2021. Consent Judgement, Case No. 211CV-0111. People of the State of California, ex rel. California Regional Water Quality Control Board, Central Coast Region v. Pacific Gas and Electric Company. February 25, 2021. 12 p.

b) Teneral Environmental. 2016. Pacific Gas and Electric Company, Diablo Canyon Power Plant, Cooling Water Entrainment Study: July 2008-June 2009. Prepared for Pacific Gas

& Electric Company. ESLO2015-016.3. November 29, 2016. 194 p.

3) RAI FPE-5

REQUIREMENT: 10 CFR 51.53(c)(3)(ii)(E) requires that the ER assess the impact of LR on threatened and endangered species in accordance with Federal laws protecting wildlife, including the Endangered Species Act and Marine Mammal Protection Act.

Enclosure 2 ISSUE: The NRC staff requires copies of supporting documentation related to compliance with these statutes to independently review these issues and assess impacts on federally protected ecological resources during the proposed license renewal term.

REQUEST: Please provide the following documents, which are cited or discussed in the ER.

a) Pacific Gas & Electric Company. 2019. Marine Mammal Stranding Report for May 14, 2019. 2 pg. (FPE-5) b) Pacific Gas & Electric Company. 2019. Marine Mammal Stranding Report for June 3, 2019. 2 pg. (FPE-5) c) Pacific Gas & Electric Company. 2020. Marine Mammal Stranding Report for January 30, 2020. 2 pg. (FPE-5) d) Terra Verde Environmental Consulting, Inc. 2020. California Red-legged Frog (Rana draytonii) Survey Report, Diablo Canyon Power Plant Decommissioning Project.

Prepared for Pacific Gas and Electric, Diablo Canyon Power Plant. August 2020. 134 p.

(FPE-9) e) Stopper Environmental Services. 2022. California Tiger Salamander Aquatic Survey Results, Toms Pond (APN: 076-011-030), San Luis Obispo County, California.

Submitted to U.S. Fish and Wildlife Service and California Department of Fish & Wildlife.

June 2022. 16 p. (FPE-9) f) Pacific Gas & Electric Company. 2019. 2018 Annual Sea Turtle Report for Diablo Canyon Power Plant (DCPP). January 30, 2019. 6 p. (FPE-15) g) Pacific Gas & Electric Company. 2020. 2019 Annual Sea Turtle Report for Diablo Canyon Power Plant (DCPP). January 30, 2020. 14 p. (FPE-15) h) Pacific Gas & Electric Company. 2021. 2020 Annual Sea Turtle Report for Diablo Canyon Power Plant (DCPP). January 28, 2021. 6 p. (FPE-15) i) Pacific Gas & Electric Company. 2022. 2021 Annual Sea Turtle Report for Diablo Canyon Power Plant (DCPP). January 31, 2022. 5 p. (FPE-15) j) Pacific Gas & Electric Company. 2023. 2022 Annual Sea Turtle Report for Diablo Canyon Power Plant (DCPP). January 26, 2023. 5 p. (FPE-15)

4) RAI GW-10

REQUIREMENT: 10 CFR 51.53(c)(2) requires that the ER describe in detail the affected environment around the plant. 10 CFR 51.53(c)(3)(ii)(P) requires that an applicant include a description of any groundwater protection program used for the surveillance of piping and components containing radioactive liquids for which a pathway to groundwater may exist.

ISSUE: As part of its response to information needs GW-1, GW-3, GW-8, and GW-10, PG&E referred to the most recent site conceptual model report, provided for NRC staffs review as DCPP SCM ERM Report 8_04_2014.pdf in response to GW-10. The site conceptual model is one of the components of a groundwater protection program conforming to the Industry Groundwater Protection Initiative (NEI 07-07, Rev. 1) followed at DCPP (ER Section 3.6.2.4).

The site conceptual model report provided for staffs review contains information required by the staff to complete its analysis of the potential environmental impacts of radionuclides released to groundwater.

16 REQUEST: Provide a copy of Diablo Canyon Power Plant Site Conceptual Model (SCM)

Report dated July 30, 2014.

5) RAI SW-3

REQUIREMENT: 10 CFR 51.53(c)(3)(iv) requires that environmental reports contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware.

ISSUE: ER figures 3.6-4 and 3.6-5 plot average monthly discharge and average monthly intake temperatures, respectively, for years 2018 through 2022. Similar data for 2023 is available now.

REQUEST: Please update ER figures 3.6-4 and 3.6-5 to include 2023 average monthly discharge and average monthly intake temperatures, respectively.

6) RAI SW-12

REQUIREMENT: 10 CFR 51.45(b) requires that the ER include environmental considerations including the impact of the proposed action on the environment, any unavoidable adverse environmental effects, and any irreversible and irretrievable commitment of resources.

ISSUE: ER Figure 2.2-1 provides the water balance diagram for the DCPP; however, the notes at the bottom of this figure are not legible.

REQUEST: Please provide a clear, legible version of ER figure 2.2-1, Water Balance Diagram.

7) RAI TER-2

REQUIREMENT: 10 CFR 51.53(c)(iv) requires that environmental reports contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware.

ISSUE: As part of the information needs provided to PG&E, TER-2 asked for a summary of bird mortality and nesting reports at the Diablo Canyon site from 2013-2023. PG&E provided the summary and in TER-3 provided individual reports from 2013-2023, along with a January 2024 report.

REQUEST: Please provide the summary of bird mortality and nesting for 2013-January 2024.

Please provide a statement that there were no bird mortality or nesting reports for 2016, 2018, or 2019.

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