ML15292A546

Comment (103) of Becky Ota and Craig Shuman, on Behalf of California Department of Fish and Wildlife, on Notice of Intent to Reinitiate the Environmental Scoping Process for the Review of the Diablo Canyon Power Plant License Renewal

ML15292A546
Person / Time
Site:	Diablo Canyon
Issue date:	09/01/2015
From:	Ota B, Shuman C State of CA, Dept of Fish & Wildlife
To:	Bladey C K Rules, Announcements, and Directives Branch
References
80FR37664 00103, NRC-2009-0552
Download: ML15292A546 (7)

Text

Gallagher, CarolFrom:Sent:To:Cc:

Subject:

Attachments:

Ota, Becky@ Wildlife

<Becky.Ota@wildlife.ca.gov>

Tuesday, September 01, 2015 2:19 PMWentzel, MichaelShuman, Craig@Wildlife;

Paznokas, William@Wildlife;

Wilkins, Eric@ Wildlife; Vance,Julie@Wildlife; Bailey, Craig@Wildlife; Bahm, Sarah@Wildlife

[ExternalSender]

Diablo Canyon Power PlantNRC Scoping Diablo Canyon Power Plant__991 15_cs2.pdf

Dear Mr. Wentzel,

Please find attached the California Department of Fish and Wildlife's comments on the Notice of Intent to Reinitiate theEnvironmental Scoping Process for the Review of the Diablo Canyon Power Plant license renewal.Sincerely, BeckyBecky OtaHabitat Conservation Program Manager, Marine RegionCalifornia Department of Fish & Wildlife350 Harbor BlvdBelmont, CA 94002Office: (650) 631-6789Cell: (650) 743-7934Becky.Ota

@wildlife.ca

.govEvery Californian should conserve water. Find out how at:-71?c1'ISave OurWaterSaveOurWater.com

• Droueht.CA.gov CALIFORNIA DEPARTMENT FISH and WILDLIFESUNSI Review CompleteTemplate

= ADM -013E-RIDS= ADM-03 / -1

,f f.a! .,;lifrio il-- !I~, X UIraI i \nen .,; r -,'ae i Ar [kflhIllin D PUA D7.JO% ~ ~AttIIO-I~tLI0 0tU ,OfLIIf~

.J~%I~ .Lurl% WWFI tl.l IllJlDEPARTMENT OF FISH AND WILDLIFE CHARL TON H. BONHAM, DirectorMarine Region1933 Cliff Drive, Suite 9Santa Barbara, CA 93109www.wiidlife.ca.,qov September 1, 2015Cindy BladelyOffice of Administration Mail Stop: OWFN-12 H08U.S. Nuclear Regulatory Commission 955 Shasta AvenueWashington, D.C. 20555-0001 Michael WentzelOffice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Michael.Wentzel(bnrc..qov

Subject:

Notice of Intent to Reinitiate the Environmental Scoping Process for theReview of the Diablo Canyon Power Plant, Units I and 2, LicenseRenewal Application, Docket Nos. 50-275 and 50-323; NRC-2009-0552.

Dear Mr. Wentzel:

The California Department of Fish and Wildlife (Department) has reviewed the Notice ofIntent to Reinitiate the Environmental Scoping Process for the Review of the DiabloCanyon Power Plant (DCPP), Units 1 and 2, License Renewal Application (Project).

The Department understands that the U.S. Nuclear Regulatory Commission (NRC) isreviewing an application submitted by Pacific Gas & Electric Company (PG&E) for therenewal of the operating licenses for DCPP, Units 1 and 2 on November 23, 2009. TheNRC is restarting the scoping process for creating a Supplemental Environmental Impact Statement (SEIS) pursuant to the National Environmental Protection Act (NEPA)prior to holding hearings for the issuance of a new license.

If approved, the NRC'sissuance of renewed licenses would authorize PG&E to operate DCPP, Units 1 and 2for an additional 20 years beyond the current licensing

periods, which expire onNovember 2, 2024 and August 26, 2025 respectively.

As a trustee for the State's fish and wildlife resources under Fish and Game Codesection 1802, the Department has jurisdiction over the conservation, protection, andmanagement of fish, wildlife, and habitat necessary for biologically sustainable populations of those species.

In this capacity, the Department administers theCalifornia Endangered Species Act, the Native Plant Protection Act, and otherprovisions of the California Fish and Game Code that afford protection to the State's fishand wildlife trust resources.

Furthermore, the Department is recognized as a "TrusteeAgency" under the California Environmental Quality Act (CEQA) with regard to the fishand wildlife of the state, to designated rare or endangered native plants, and to gameConserving Cafifornia's Wild~ife Since 1870 Mr. Michael WentzelPage 2 of 6September 1, 2015refuges, ecological

reserves, and other areas administered by the department (CEQAguidelines

§15386).

As a Trustee Agency for fish and wildlife resources, theDepartment is responsible for providing biological expertise with respect to potentially significant impacts arising from project activities and means to mitigate or avoid suchimpacts.

The Department is also responsible for marine biodiversity protection underthe Marine Life Protection Act (MLPA) in coastal marine waters of California.

Biological Significance The Point Buchon area offshore of DCPP possesses a large diversity and abundance offish, invertebrate and seabirds with habitats ranging from intertidal to deep rocky reef.Six marine protected areas (MPAs) are within the source water of DCPP. The area isalso home to commercial and sport fishing communities and non-consumptive usersthat utilize the resources year round. In addition, the land surrounding the DCPP is richin biological diversity and endemic wildlife.

Pursuant to our jurisdiction, the Department has the following comments andrecommendations regarding the Project.California Endangered Species Act (CESA)CESA provides for the protection of rare, threatened, candidate, and endangered plantsand animals, and prohibits the taking of such species without authorization (Fish andGame Code Section 2050). The Department maintains a list of rare, threatened, andendangered plants and animals that can be found on the Department's web site:http://www.dfaq.

ca .aov/bio~qeodata/cnddb/pdfs/TEAnimals.pDdf.

The Department recommends including a full analysis of CESA listed species that may be in the Projectarea and potential impacts in the SEIS. Adverse impacts from the Project leading totake of CESA listed species would require take authorization from the Department according to Fish and Game Code §2081.Fully Protected SpeciesThe Department has jurisdiction over fully protected species pursuant to Fish and GameCode Sections 3511, 4700, 5050, and 5515. Fully protected species may not be takenor possessed at any time and no licenses or permits may be issued for their take exceptfor collecting these species for necessary scientific research and certain relocation situations.

Therefore "take" of any fully protected animal species is prohibited and mustbe avoided by the Project.

The Department recommends listing the fully protected species and discussing the potential impacts in the SEIS. The Department maintains alist of fully protected species that can be found on the Department's web site:httD://www.dfa

.ca.aov/wildlife/nonaame/t e SoD/fullv oro.html Mr. Michael WentzelPage 3 of 6September 1, 2015Lake or Stream Alteration Agreement (LSAA)The Department has regulatory authority with regard to activities occurring in streamsand/or lakes that could adversely affect any fish or wildlife

resource, pursuant to Fishand Game Code sections 1600 et seq. If a Project could substantially divert or obstructthe natural flow of any river, stream or lake; substantially change or use any materialfrom the bed, channel, or bank of, any river, stream, or lake; or deposit or dispose ofdebris, waste, or other material containing

crumbled, flaked, or ground pavement whereit may pass into any river, stream, or lake, notification of Lake or Streambed Alteration to the Department is required.

The entire Project site has multiple drainage features aswell as the Diablo Creek which flows approximately though the center of the Projectsite. We recommend that Project proponents consult with the Department beforecommencing activities that could impact these features and submit a Lake or StreamAlteration Notification to comply with Fish and Game Code sections 1600 et. seq. TheDepartment recommends that the SEIS inform Project proponents of this responsibility.

It is important to note that the Department is required to comply with CEQA in theissuance of an LSAA. Therefore, for efficiency in environmental compliance, werecommend that any stream disturbance(s) be described, and mitigation for thedisturbance(s) be developed as part of the environmental review process.

This wouldlikely reduce the need for the Department to require additional extensive environmental review to issue an LSAA.Water Pollution Pursuant to Fish and Game Code Section 5650, it is unlawful to deposit in, permit topass into, or place where it can pass into the "Waters of the State" any substance ormaterial deleterious to fish, plant life, or bird life, including non-native species.

TheDepartment recommends that the SEIS fully address potential pollutants to "Waters ofthe State" in the environmental analysis for the Project.

The Regional Water QualityControl Board also has jurisdiction regarding discharge and pollution to "Waters of theState" including storm water runoff into surface waters.Marine Life Protection Act and Marine Protected AreasThe State of California, through the MLPA, designated Marine Protected Areas (MPAs)in the vicinity of the Project which are regulated through Fish and Game Code Section,2850-2863 and Title 14, Section 632, CCR. MPAs in the source water for cooling theDCPP include:

the Cambria State Marine Conservation Area (SMCA), White RockSMCA, Point Buchon SMCA, Morro Bay State Marine Recreationally Managed Area(SMRMA),

the Morro Bay State Marine Reserve (SMR), and the Point Buchon SMR. Ina SMR, the take of all living marine resources is prohibited, except under a permit orspecific authorization for research, restoration or monitoring purposes.

In a SMCA, thecommercial and recreational take of living marine resources is restricted with take ofonly certain species allowed.

In a SMRMA, it is unlawful to perform any activity that, asdetermined by the designating entity or managing agency, would compromise therecreational values for which the area may be designated.

Recreational opportunities Mr. Michael WentzelPage 4 of 6September 1, 2015may be protected,

enhanced, or restricted, while preserving basic resource values ofthe area. Additional information regarding MPAs and the MLPA can be found on theDepartment's website (http://www.dfq.ca.gov/marine/mpa/).

The Department recommends including discussion of the MLPA and MPAs in the SEIS, including anypotential impacts to the MPAs from the relicensing of DCPP.Additional Recommendations The Department recommends that the SEIS include a full analysis of environmental impacts on the following topics:Entrainment and Impingement

-*The Department remains concerned about entrainment and impingement impacts from the once through cooling process at DCPP. The Department recommends analyzing continued entrainment and impingement impacts overthe life of the DCPP and potential altematives.

The analysis should include theentire source water for the DCPP.Thermal Effluent Discharge

-* The SEIS should fully analyze the impacts to marine resources by the once-through cooling water discharged from the DCPP thermal effluent discharge.

Sensitive Habitats and Essential Fish Habitat -,, The SEIS should analyze sensitive habitats such as, but not limited to, marinerocky substrate, kelp beds, and known breeding or feeding areas used by stateor federally protected species as well as areas designated Essential Fish Habitat(EFH) in the vicinity and source water of the Project.Protected Marine Resources

-* The SEIS should analyze DCPP activities that may disrupt protected marineresources such as sea turtles, marine mammals, marine fish, and native shellfish or benthic invertebrates protected under federal or state law.Recreational and Commercial Fishing -* The Department recommends that the SEIS analyze the interaction betweenrecreational and commercial fishing and the operation of the DCPP in the futureshould relicensing occur.Climate Change and Emerging Ocean Issues -* The SEIS should include an analysis of climate change in relation to both marineand terrestrial resources and how DCPP may influence the impacts of climatechange. The Department is concerned about sea level rise impacts at DCPPand recommends the SEIS include an analysis of sea level rise impacts undermultiple climate change scenarios.

In particular, the Department is interested inwhat plans are in place for sea level rise through the life of the plant and on sitestorage.

Mr. Michael WentzelPage 5 of 6September 1, 2015In addition, the Department recommends that the SEIS include analysis ofemerging ocean issues such as the increased occurrence of salps. Salps havebeen occurring in the intake cove in recent years in large numbers necessitating a pilot project that uses bubble curtains in the attempt to keep the salps fromclogging the cooling water intake. Monitoring of potential impacts from the use ofthe bubble curtains, the efficacy of the bubble curtains, and other potential solutions are still being explored.

Conclusion The Department appreciates the opportunity to review and comment on the Notice ofIntent to Reinitiate the Environmental Scoping Process for the Review of the DiabloCanyon Power Plant, Units 1 and 2, License Renewal Application.

As always,Department personnel are available to discuss our concerns, comments andrecommendations in greater detail. To arrange for discussion on marine biological resources, please contact Mr. Eric Wilkins, Environmental Scientist, Department of Fishand Wildlife, 20 Lower Ragsdale Dr. Suite 100, Monterey, CA, 93940, by e-mail atEric.Wilkins@Wildlife.ca.gov, or (831) 649-2813.

For discussions related to terrestrial biological resources, please contact Ms. Sarah Bahm, Environmental Scientist, Department of Fish and Wildlife, 1234 East Shaw Aye, Fresno, CA 93710, by e-mail atSarah.Bahm@Wildlife.ca.gov, or (559) 243-4014 x306.Sincerely, Craig Shuman, D. EnvRegional ManagerMarine RegionEc: Becky Ota, Environmental Program ManagerDepartment of Fish and WildlifeBecky.Ota(@Wildlife.ca.qov William Paznokas, Senior Environmental Scientist Supervisor Department of Fish and WildlifeWilliam .Paznokas(,Wildlife.ca

.qovEric Wilkins, Environmental Scientist Department of Fish and WildlifeEric.Wilkins(@Wildlife.ca.qiov Mr. Michael WentzelPage 6 of 6September 1, 2015Julie Vance, Environmental Program ManagerDepartment of Fish and WildlifeJulie.Vance@~Wildlife.ca..qov Craig Bailey, Senior Environmental Scientist Supervisor Department of Fish and WildlifeCraiciq.

Bailey@~Wildlife.ca~gov Sarah Bahm, Environmental Scientist Department of Fish and WildlifeSarah.Bahm(@Wildlife.ca

..qovcc: Tom LusterCalifornia Coastal Commission 45 Fremont Street #2000San Francisco, CA 94105Tom .Luster(~coastal.ca.pov Peter VonLangen Central Coast Regional Water Quality Control Board895 Aerovista Place, Suite 101San Luis Obispo, CA. 93401-7906 Peter.VonLanpen(~waterboards.ca

.qovKorie Schaeffer National Marine Fisheries Service777 Sonoma Avenue, Room 325Santa Rosa, CA95404korie.schaeffer(~noaa

.covDouglass CooperU.S. Fish and Wildlife Service2493 Portola Road, Suite BVentura, CA 93003dougjlass cooper(~fws.pov Gallagher, CarolFrom:Sent:To:Cc:

Subject:

Attachments:

Ota, Becky@ Wildlife

<Becky.Ota@wildlife.ca.gov>

Tuesday, September 01, 2015 2:19 PMWentzel, MichaelShuman, Craig@Wildlife;

Paznokas, William@Wildlife;

Wilkins, Eric@ Wildlife; Vance,Julie@Wildlife; Bailey, Craig@Wildlife; Bahm, Sarah@Wildlife

[ExternalSender]

Diablo Canyon Power PlantNRC Scoping Diablo Canyon Power Plant__991 15_cs2.pdf

Dear Mr. Wentzel,

Please find attached the California Department of Fish and Wildlife's comments on the Notice of Intent to Reinitiate theEnvironmental Scoping Process for the Review of the Diablo Canyon Power Plant license renewal.Sincerely, BeckyBecky OtaHabitat Conservation Program Manager, Marine RegionCalifornia Department of Fish & Wildlife350 Harbor BlvdBelmont, CA 94002Office: (650) 631-6789Cell: (650) 743-7934Becky.Ota

@wildlife.ca

.govEvery Californian should conserve water. Find out how at:-71?c1'ISave OurWaterSaveOurWater.com

• Droueht.CA.gov CALIFORNIA DEPARTMENT FISH and WILDLIFESUNSI Review CompleteTemplate

= ADM -013E-RIDS= ADM-03 / -1

,f f.a! .,;lifrio il-- !I~, X UIraI i \nen .,; r -,'ae i Ar [kflhIllin D PUA D7.JO% ~ ~AttIIO-I~tLI0 0tU ,OfLIIf~

.J~%I~ .Lurl% WWFI tl.l IllJlDEPARTMENT OF FISH AND WILDLIFE CHARL TON H. BONHAM, DirectorMarine Region1933 Cliff Drive, Suite 9Santa Barbara, CA 93109www.wiidlife.ca.,qov September 1, 2015Cindy BladelyOffice of Administration Mail Stop: OWFN-12 H08U.S. Nuclear Regulatory Commission 955 Shasta AvenueWashington, D.C. 20555-0001 Michael WentzelOffice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Michael.Wentzel(bnrc..qov

Subject:

Notice of Intent to Reinitiate the Environmental Scoping Process for theReview of the Diablo Canyon Power Plant, Units I and 2, LicenseRenewal Application, Docket Nos. 50-275 and 50-323; NRC-2009-0552.

Dear Mr. Wentzel:

The California Department of Fish and Wildlife (Department) has reviewed the Notice ofIntent to Reinitiate the Environmental Scoping Process for the Review of the DiabloCanyon Power Plant (DCPP), Units 1 and 2, License Renewal Application (Project).

The Department understands that the U.S. Nuclear Regulatory Commission (NRC) isreviewing an application submitted by Pacific Gas & Electric Company (PG&E) for therenewal of the operating licenses for DCPP, Units 1 and 2 on November 23, 2009. TheNRC is restarting the scoping process for creating a Supplemental Environmental Impact Statement (SEIS) pursuant to the National Environmental Protection Act (NEPA)prior to holding hearings for the issuance of a new license.

If approved, the NRC'sissuance of renewed licenses would authorize PG&E to operate DCPP, Units 1 and 2for an additional 20 years beyond the current licensing

periods, which expire onNovember 2, 2024 and August 26, 2025 respectively.

As a trustee for the State's fish and wildlife resources under Fish and Game Codesection 1802, the Department has jurisdiction over the conservation, protection, andmanagement of fish, wildlife, and habitat necessary for biologically sustainable populations of those species.

In this capacity, the Department administers theCalifornia Endangered Species Act, the Native Plant Protection Act, and otherprovisions of the California Fish and Game Code that afford protection to the State's fishand wildlife trust resources.

Furthermore, the Department is recognized as a "TrusteeAgency" under the California Environmental Quality Act (CEQA) with regard to the fishand wildlife of the state, to designated rare or endangered native plants, and to gameConserving Cafifornia's Wild~ife Since 1870 Mr. Michael WentzelPage 2 of 6September 1, 2015refuges, ecological

reserves, and other areas administered by the department (CEQAguidelines

§15386).

As a Trustee Agency for fish and wildlife resources, theDepartment is responsible for providing biological expertise with respect to potentially significant impacts arising from project activities and means to mitigate or avoid suchimpacts.

The Department is also responsible for marine biodiversity protection underthe Marine Life Protection Act (MLPA) in coastal marine waters of California.

Biological Significance The Point Buchon area offshore of DCPP possesses a large diversity and abundance offish, invertebrate and seabirds with habitats ranging from intertidal to deep rocky reef.Six marine protected areas (MPAs) are within the source water of DCPP. The area isalso home to commercial and sport fishing communities and non-consumptive usersthat utilize the resources year round. In addition, the land surrounding the DCPP is richin biological diversity and endemic wildlife.

Pursuant to our jurisdiction, the Department has the following comments andrecommendations regarding the Project.California Endangered Species Act (CESA)CESA provides for the protection of rare, threatened, candidate, and endangered plantsand animals, and prohibits the taking of such species without authorization (Fish andGame Code Section 2050). The Department maintains a list of rare, threatened, andendangered plants and animals that can be found on the Department's web site:http://www.dfaq.

ca .aov/bio~qeodata/cnddb/pdfs/TEAnimals.pDdf.

The Department recommends including a full analysis of CESA listed species that may be in the Projectarea and potential impacts in the SEIS. Adverse impacts from the Project leading totake of CESA listed species would require take authorization from the Department according to Fish and Game Code §2081.Fully Protected SpeciesThe Department has jurisdiction over fully protected species pursuant to Fish and GameCode Sections 3511, 4700, 5050, and 5515. Fully protected species may not be takenor possessed at any time and no licenses or permits may be issued for their take exceptfor collecting these species for necessary scientific research and certain relocation situations.

Therefore "take" of any fully protected animal species is prohibited and mustbe avoided by the Project.

The Department recommends listing the fully protected species and discussing the potential impacts in the SEIS. The Department maintains alist of fully protected species that can be found on the Department's web site:httD://www.dfa

.ca.aov/wildlife/nonaame/t e SoD/fullv oro.html Mr. Michael WentzelPage 3 of 6September 1, 2015Lake or Stream Alteration Agreement (LSAA)The Department has regulatory authority with regard to activities occurring in streamsand/or lakes that could adversely affect any fish or wildlife

resource, pursuant to Fishand Game Code sections 1600 et seq. If a Project could substantially divert or obstructthe natural flow of any river, stream or lake; substantially change or use any materialfrom the bed, channel, or bank of, any river, stream, or lake; or deposit or dispose ofdebris, waste, or other material containing

crumbled, flaked, or ground pavement whereit may pass into any river, stream, or lake, notification of Lake or Streambed Alteration to the Department is required.

The entire Project site has multiple drainage features aswell as the Diablo Creek which flows approximately though the center of the Projectsite. We recommend that Project proponents consult with the Department beforecommencing activities that could impact these features and submit a Lake or StreamAlteration Notification to comply with Fish and Game Code sections 1600 et. seq. TheDepartment recommends that the SEIS inform Project proponents of this responsibility.

It is important to note that the Department is required to comply with CEQA in theissuance of an LSAA. Therefore, for efficiency in environmental compliance, werecommend that any stream disturbance(s) be described, and mitigation for thedisturbance(s) be developed as part of the environmental review process.

This wouldlikely reduce the need for the Department to require additional extensive environmental review to issue an LSAA.Water Pollution Pursuant to Fish and Game Code Section 5650, it is unlawful to deposit in, permit topass into, or place where it can pass into the "Waters of the State" any substance ormaterial deleterious to fish, plant life, or bird life, including non-native species.

TheDepartment recommends that the SEIS fully address potential pollutants to "Waters ofthe State" in the environmental analysis for the Project.

The Regional Water QualityControl Board also has jurisdiction regarding discharge and pollution to "Waters of theState" including storm water runoff into surface waters.Marine Life Protection Act and Marine Protected AreasThe State of California, through the MLPA, designated Marine Protected Areas (MPAs)in the vicinity of the Project which are regulated through Fish and Game Code Section,2850-2863 and Title 14, Section 632, CCR. MPAs in the source water for cooling theDCPP include:

the Cambria State Marine Conservation Area (SMCA), White RockSMCA, Point Buchon SMCA, Morro Bay State Marine Recreationally Managed Area(SMRMA),

the Morro Bay State Marine Reserve (SMR), and the Point Buchon SMR. Ina SMR, the take of all living marine resources is prohibited, except under a permit orspecific authorization for research, restoration or monitoring purposes.

In a SMCA, thecommercial and recreational take of living marine resources is restricted with take ofonly certain species allowed.

In a SMRMA, it is unlawful to perform any activity that, asdetermined by the designating entity or managing agency, would compromise therecreational values for which the area may be designated.

Recreational opportunities Mr. Michael WentzelPage 4 of 6September 1, 2015may be protected,

enhanced, or restricted, while preserving basic resource values ofthe area. Additional information regarding MPAs and the MLPA can be found on theDepartment's website (http://www.dfq.ca.gov/marine/mpa/).

The Department recommends including discussion of the MLPA and MPAs in the SEIS, including anypotential impacts to the MPAs from the relicensing of DCPP.Additional Recommendations The Department recommends that the SEIS include a full analysis of environmental impacts on the following topics:Entrainment and Impingement

-*The Department remains concerned about entrainment and impingement impacts from the once through cooling process at DCPP. The Department recommends analyzing continued entrainment and impingement impacts overthe life of the DCPP and potential altematives.

The analysis should include theentire source water for the DCPP.Thermal Effluent Discharge

-* The SEIS should fully analyze the impacts to marine resources by the once-through cooling water discharged from the DCPP thermal effluent discharge.

Sensitive Habitats and Essential Fish Habitat -,, The SEIS should analyze sensitive habitats such as, but not limited to, marinerocky substrate, kelp beds, and known breeding or feeding areas used by stateor federally protected species as well as areas designated Essential Fish Habitat(EFH) in the vicinity and source water of the Project.Protected Marine Resources

-* The SEIS should analyze DCPP activities that may disrupt protected marineresources such as sea turtles, marine mammals, marine fish, and native shellfish or benthic invertebrates protected under federal or state law.Recreational and Commercial Fishing -* The Department recommends that the SEIS analyze the interaction betweenrecreational and commercial fishing and the operation of the DCPP in the futureshould relicensing occur.Climate Change and Emerging Ocean Issues -* The SEIS should include an analysis of climate change in relation to both marineand terrestrial resources and how DCPP may influence the impacts of climatechange. The Department is concerned about sea level rise impacts at DCPPand recommends the SEIS include an analysis of sea level rise impacts undermultiple climate change scenarios.

In particular, the Department is interested inwhat plans are in place for sea level rise through the life of the plant and on sitestorage.

Mr. Michael WentzelPage 5 of 6September 1, 2015In addition, the Department recommends that the SEIS include analysis ofemerging ocean issues such as the increased occurrence of salps. Salps havebeen occurring in the intake cove in recent years in large numbers necessitating a pilot project that uses bubble curtains in the attempt to keep the salps fromclogging the cooling water intake. Monitoring of potential impacts from the use ofthe bubble curtains, the efficacy of the bubble curtains, and other potential solutions are still being explored.

Conclusion The Department appreciates the opportunity to review and comment on the Notice ofIntent to Reinitiate the Environmental Scoping Process for the Review of the DiabloCanyon Power Plant, Units 1 and 2, License Renewal Application.

As always,Department personnel are available to discuss our concerns, comments andrecommendations in greater detail. To arrange for discussion on marine biological resources, please contact Mr. Eric Wilkins, Environmental Scientist, Department of Fishand Wildlife, 20 Lower Ragsdale Dr. Suite 100, Monterey, CA, 93940, by e-mail atEric.Wilkins@Wildlife.ca.gov, or (831) 649-2813.

For discussions related to terrestrial biological resources, please contact Ms. Sarah Bahm, Environmental Scientist, Department of Fish and Wildlife, 1234 East Shaw Aye, Fresno, CA 93710, by e-mail atSarah.Bahm@Wildlife.ca.gov, or (559) 243-4014 x306.Sincerely, Craig Shuman, D. EnvRegional ManagerMarine RegionEc: Becky Ota, Environmental Program ManagerDepartment of Fish and WildlifeBecky.Ota(@Wildlife.ca.qov William Paznokas, Senior Environmental Scientist Supervisor Department of Fish and WildlifeWilliam .Paznokas(,Wildlife.ca

.qovEric Wilkins, Environmental Scientist Department of Fish and WildlifeEric.Wilkins(@Wildlife.ca.qiov Mr. Michael WentzelPage 6 of 6September 1, 2015Julie Vance, Environmental Program ManagerDepartment of Fish and WildlifeJulie.Vance@~Wildlife.ca..qov Craig Bailey, Senior Environmental Scientist Supervisor Department of Fish and WildlifeCraiciq.

Bailey@~Wildlife.ca~gov Sarah Bahm, Environmental Scientist Department of Fish and WildlifeSarah.Bahm(@Wildlife.ca

..qovcc: Tom LusterCalifornia Coastal Commission 45 Fremont Street #2000San Francisco, CA 94105Tom .Luster(~coastal.ca.pov Peter VonLangen Central Coast Regional Water Quality Control Board895 Aerovista Place, Suite 101San Luis Obispo, CA. 93401-7906 Peter.VonLanpen(~waterboards.ca

.qovKorie Schaeffer National Marine Fisheries Service777 Sonoma Avenue, Room 325Santa Rosa, CA95404korie.schaeffer(~noaa

.covDouglass CooperU.S. Fish and Wildlife Service2493 Portola Road, Suite BVentura, CA 93003dougjlass cooper(~fws.pov