ML15251A198

Comment (21) of John Stephens on the Environmental Affects of Diablo Canyon

ML15251A198
Person / Time
Site:	Diablo Canyon
Issue date:	08/24/2015
From:	Stephens J - No Known Affiliation
To:	Wentzel M J Rules, Announcements, and Directives Branch, License Renewal Projects Branch 2
References
80FR37664 00021, NRC-2009-0552
Download: ML15251A198 (6)

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Attachments:john stephens <stephens2@earthlink.net>Monday, August 24, 2015 6:55 PMWentzel, Michael[External_Sender] Environmental affects of Diablo CanyoWHY DIABLO Canyon 's ONCE THROUGH COOLING SYSTEM SHOULDBE CONSIDERED.docxHello Michael. I'm attaching the statement that I would have liked to present at the August 5thmeeting, but ,of coarse, couldn't in 3 minutes. I srudied once through cooling at the power plantin Redondo beach, from 1974 through 1996 and this work has continued to the present5. Iknow of no better data concerning the affects of once through cooling on a fish assemblagethan our 41 year study. See Attachment. John Stephens, Emeritus professor, Occidentalcollege.......

• LJ..... 7"ICC:)2,w,,~SUNSI Review CompleteTemplate = ADM -013E-RIDS= ADM -03Add= 1i" 1 WHY DIABLO CANYON'S ONCE THROUGH COOLING SYSTEM SHOULDBE CONSIDERED "STATE OF THE ART"I am a marine biologist (an ichthyologist) retired ( 1996) after 38 yearsof teaching and research. During that time, I spent more than 20 yearsexamining the affects of once through cooling at the Redondo Beach(King Harbor) steam electric generating facility, on the adjacent fishassemblage affected by the intake and hot water discharge. Bothtemperature change and entrapment/entrainment were examined. Inthis study, we monitored monthly the volume of plankton and numberby species of fish larvae in the adjacent water column. We examined therecruitment of larval fishes to the adjacent rocky reefs and theabundance of juvenile, subadult, and adult fishes by quarterly divercounts on 5-7 transect areas. At the same time we monitored the fishassemblage in a kelp bed site, three miles to the south at Palos Verdes,with transects taken at the same depths as those in King harbor. Weconsidered this site, as a control comparison. Additionally, we followedthe fish entrapment for a number of years, including entrapment duringheat treatments. We also examined the affects of chlorination on someof these species. This field study is still going on (41st year) carried outby my replacement and has produce more than twenty papers. I havelisted a number of these papers for your interest at the end of thisstatement. In general, the fish assemblage surrounding the once throughcooling system has remained abundant and diverse, when compared tothat of the Palos Verdes kelp bed which is considered an importantnatural habitat, and the larval entrainment doesn't appear to have aneffect on the fishes of the assemblage. This, though the assemblage haschanged due to the transition from a cold PDO to a warm one, as well asdue to El Nino events, habitat destruction from storms, and breakwatermodification, etc.I have not been a strong supporter on nuclear power plantsthough I helped develop the fish return system that functioned atSONGS unit 2 before it was shut down. I am a fan of adequate electricalpower and not of carbon producing hydrocarbon plants. The U. S.electrical grid is not ready to loose California's last functioning nuclearplant, which produces abundant carbon free energy. Coastal powerplants do kill many fish larvae and a limited number of entrapped fishesbut we see no evidence of an effect upon th.e local fish assemblage.

The once through cooling system at Diablo is unique, I believe forCalifornia. Both the intake and the discharge are in the intertidal zone,not in the subtidal. A large number of intertidal fishes are small benthicspecies, rarely swimming in the water column and thus not subject toentrapment. Entrapment of fishes generally occurs at night when afishes rheotactic sense is marginal and entrapped fish are largely activeschooling nocturnal species. (Queenfish, white croakers,, anchovies etc).Further, the entrance to the intake was designed for three units andonly two were built so that the opening is relatively large and thusproduces a slower incurrent. Unfortunately, I know of no dataconcerning entrapment of fishes at Diablo or any study of entrapment atthis site. However, entrapment, even in large subtidal intakes is rarelyconsidered significant as opposed to the affects of recreational andcommercial fishing. At King Harbor, thee daily entrapment was muchless than the take by any active fishing vessel. Entrainment of planktonand larvae does kill lots of larval fishes and planktonic organisms. I haveexamined the larval fish data taken by Tenera in over ten years of meternet samples near the intake. Eleven of the top 20 larvae entrained areintertidal species. Of the 9 remaining, anchovies, white croakers andone species group of rockfish rank in the top group, anchovy larvae areabundant in most coastal inshore waters (including my work atRedondo beach), though they are more abundant during cold PDO's.Almost all of the top twenty species show considerable annualfluctuation with no obvious trend. Further, most oceanic or subtidalspecies of larvae that are taken in the intertidal would be unlikely tosurvive their settlement into this shallow highly competitiveenvironment. Remember that fishes produce huge numbers of larvae,often greater than 1,000,O00eggs/female because >99% will not survivepredation, random drift or starvation. (which is the evolutionarypressure for production of so many). The loss to intakes has not beenfound to be significant. In order to document such an effect, assemblagepopulations would have to be shown to be declining due to lack ofrecruitment caused by power plant entrainment. All fish populationshave large annual fluctuations and it is highly unlikely that any of thesefluctuations could be ascribed to entrainment as fish larvae on thePacific coast rarely return to their parental population. Suggested, nohard data has shown even a short term affect. A recent report to theCalifornia Energy Commission on the King harbor Ichthyoplankton(2008) shows that if the data is plotted from 1974 to 2008, there has been a "steady "decrease in plankton abundance, yet no correlationbetween entrainment and this decline was discovered. The majordecrease occurred in the late 19 70's when the cool PDO ended. If weignore the cool PDO data, the overall decrease disappears. No increasehas been seen since the plant went largely offline in around 2010.There has never been any long term effect demonstrated for aPacific coast fish species from open coastal larval entrainment. Thegeological and oceanographic conditions in the eastern Pacific can notbe compared to those of the Western Atlantic where the fishpopulations are often dependent on large embayments (sunken rivermouths) for some stage in the life history and required annualmigrations which increase vulnerability to entrapment or entrainment.Even there, marine entrainment has not been shown to be a long termproblem.Hot water discharge is benign for most local mobile fish specieswhich simply move to appropriate thermal conditions.. As a biologist,the thought of a discharge through the intertidal, a wonderfully richbiological habitat, seemed insane. I observed it while lecturing to theplant scientists on fish thermal preference prior to the plants initialoperation. Such a flow would certainly drive off motile organisms,including fish, and kill sedentary flora and fauna. Fishes driven fromtheir preferred habitat are certainly more vulnerable to predation. Withthe initial start up of the plant, this happened. However, only arelatively small area of intertidal is strongly affected and even the worstimpinged areas have been recolonized by tolerant species. When theplant is closed, this change should be reversed in several years. Fishesdetect water temperature and avoid those that are harmful. The warmwater rises quickly to the surface as the water deepens and is rapidlycooled, though the shallow discharge cove has certainly beensignificantly warmed. Some fishes that normally are known to becommon south of Point Conception have taken advantage of this smallarea and live here happily. Many fish larvae from the warmer southernCalifornia environment drift north of the Point Conception faunalbarrier, but few are able to survive or reproduce here. The Diablowarmer temperatures may be a harbinger of what will occur as seawater temperatures rise with global warming. What exists here today,due to once through cooling at Diablo is likely to be more prevalent inthe future. Again, at King Harbor in Southern California, a number oftropical species have been observed living in the warm discharge water including broomtail groupers, and the Cortez Chub. This appears tohave little effect upon the indigenous species and they usually disappearafter an unusually cold winter.The once through cooling system at Diablo does not show anegative affect on the local fish species and because of its' intertidalintake and discharge is highly unlikely to in the future. Any change dueto water warming should rapidly disappear once the plant is taken offline and conditions return to the then current status. Compared to theterrestrial effect of cooling towers, which also would require water forcooling, and could produce local weather changes, the present oncethrough cooling system is the system of preference.Literature of interst by Date..Terry, C. B. and J. S. Stephens, Jr. 1976. A study of the orientation of selected embiotocid fishes to depth and shifting vertical temperature gradients Bull S. CaliforniaAcad Sci75>170-183.Stephens, J. S. Jr and K. Zerba 1981. Factors affecting fish diversity on a temperatereef. Environmental Biol. Fishes 6:111-12 1.Shrode, J. B., K. Zerba, and J. SA. Stephens Jr 1982. Ecological significance oftemperature tolerance and preference in some inshore California species. Amer.Fish. Soc. 11" 1:45-5 1.Shrode, J. B., L. P. Purcell, amnd J. S. Stephens Jr. 1983. Ontogeny of thermalpreference in four species of viviparous fishes (Embiotocidae). EWnvir. Biol. Fish.9:71-76.Stephens, J. S. Jr., P. A Morris, K. Zerba, andM. S. Love 1984. Factors affecting fishdiversity on a temperate reeflI: the fish assemblage at Palos verdes Kpoint, 1974-1981. Envir. Biol. Fish. 11:259-275.Stephens, J. S. Jr, G. Jordan, P0. A. Morris,M.M. Singer, and G. McGowen 1986. Can werelate larval fish abundance to recruitment or population stability? A preliminaryanalysis of recruitment to a temperate rocky reef. CalCOFI 27: 67-83.Stephens, J. S. Jr., J. E. Hose, and M. S. Love 1988. Fish assemblages as indicators ofenvironmental change in nearshore environments. In Soule and Kleppel eds.Maroine oragnisms as indicators. Chap. 5:91-1054. Springer-Verllag Hollbrook, S.J., M. J. Kingsford, R. J. Schmitt, and J. S. Stephens Jr. 1994. Spatial andtemporal patterns in assemblages of temperate reef fishes. Amzer. Zool. 34:4563-475.Pondella, D. J. and J. S. Stephens Jr. 1994. Factors affecting the anbunfance ofjuvenile fish specieson a temperate artificial reef. Bull. Mar. Sci 55:1216-1223.Hollbrook, S. J., Schmitt, and J. S. Stephens 1997. Ecological Applications 7(4) 1997:1299-13 10.Bond, A. B., J. S. Stephens Jr., D. J. Pondella, M. J. Allen, and M. Helvey 1999. A methodfor estimating marine habitat valuesbased on fish guilds, with a comparisonbetween sites in Southern California. Bull. Mar. Sci. 64(2); 219-2432.Stephens, J. S. Jr., and D. J. Pondella I1 2002. Larval productivity on a matureartificial reef.- the ichthyoplankton of King Harbor, CA. OICES Jo. Mar. 8ci.59:51-58.Stephens, J. S. Jr., R. J. Larson, and D. J. Pondella II. (2006) Rocky reefs and kelp beds,Chapter 9: 227252 pp-in Allen, L. G., D. P. Pondella II, and M. H. Horn.eds (2006),The ecology of Marine fishes, California and adjacent waters U. C. Ptress: 660;pp.M.H.Horn and J. S. Stephens, Jr. (2006) Climate change and overexploitation,Chapter 25 :621-635 in Allen, L. G., D. J. Pondella, and M. H. Horn ibid.Pondella, D. J., J. P. Williams, and E. F. Miller (2008) The ichthyoplaNKTON OF KINGHAKRBOR, REDONDO BEACH, CALIFORNIA 1974-2008. PIERT FINAL RPT.TO THECALIFONRIAJohn S. Stephens, Jr. PhD James Irvine Professor of Environmental Biology Emeritusand founder, Director Emeritus, Vantuna Research Group, Occidental College, LosAngeles. Present address Arroyo Grande, Ca. 93420