Marine SanctuariesDecember 2011
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Diablo Canyon Nuclear Power Plant  Needlessly Kills Marine Life 
and Harms the Local Fishing Industry

by Carol Georgi and Karl Kempton, former Energy Planner for San Luis Obispo County
and Lead Author of
"Proposed Central Coast National Marine Sanctuary, 1990"
Updated from our November, 2010 Marine Sanctuary Article

The billions of marine life killed by Once Through Cooling (OTC) in PG&E's Diablo Canyon Nuclear Power Plant (DCNPP) is staggering and represents  threats to commercial and sport fisheries, near shore ocean ecosystems, local fishing industries, and coastal economies. Change is necessary at DCNPP for the health of California coastal waters and communities in San Luis Obispo County.  PG&E's  Diablo Canyon nuclear power plant has been using OTC since 1985, plans to use OTC until 2024, and perhaps indefinitely. Our research has not found any mitigation by PG&E to the local fishing community nor for the marine ecosystems.

Agreement and Statement by Pacific Gas and Electric (PG&E) to the State of California

• PG&E's original application to the Public Utilities Commission of the State of California dated July 7, 1967, in the agreement, item 7  (State of California Application no. 49051)  states: "In the event critical problems relating to aquatic or recreational uses occur after and as a result of installation, Pacific agrees to continue its cooperative investigations with the objective of modifying operation or design to eliminate these problems. In the event that adverse effects accrue to aquatic life or recreation uses due to plant construction or operation, Pacific will provide reasonable mitigation for the losses incurred, provided such mitigation will not interfere with the construction or operation of the plant unless otherwise agreed."

• In 2006, PG&E admitted that it wants to move away from once through cooling: 'When we have the option of doing away with a once-through cooling system, we will do do it" (AR2269: 18-19, July 31, 2006, CEQA Public Scoping Meeting TRanscript.), as reported by Jack Mc Curdy in his November, 2011 SLO Coast Journal Article. 


Mitigation of damage to marine life caused by Once Through Cooling (OTC)  

When DCNPP began operation, sufficient data was already available pointing to the destruction of incredible numbers of larvae. The information was established at San Onofre Nuclear Generating Station (SONGS) where a large 'sand bar' of dead sea life formed. 

Deborah Schoch reported in the Los Angeles Times, October 26, 1995:

"When Scientists concluded SONGS was destroying massive numbers of fish and kelp, plant operators were required to undertake a plan to reduce damage to marine life.......The plan was forged four years ago in response to a long-term scientific study that found the nuclear plant had caused a 60% reduction in the area covered by a nearby kelp bed. The 1989 study also said that the plant's cooling system sucks up and kills 21 to 57 tons of fish and 4 billion eggs and larvae each year."  http://articles.latimes.com/1995-10-26/local/me-61441_1_san-onofre 

However, we are not aware of any mitigation by DCNPP to reduce their damage to marine life or assist the local fishing communities.


PG&E Withholds and Skiews Data at DCNPP

Linda Gunter of the Nuclear Information and Resource Service reported on February 22, 2001: 


"In perhaps the most egregious example, the California utility, Pacific Gas & Electric (PG&E), for many years, provided state water authorities with skewed data that omitted known marine damage by its Diablo Canyon reactors. PG&E claimed that the plant's intake and discharge of billions of gallons of seawater a day did little harm to the surrounding marine community. In reality, the plant's operation had devastated marine ecosystems for miles up and down the coast and was responsible for the near obliteration of already threatened black and red abalone populations in the area. Finally threatened with legal action by regulators, PG&E nevertheless managed to undermine the state's cease-and-desist order by promising to outspend the authorities on legal appeals, effectively tying up any lawsuit in litigation for years. State authorities backed down from stopping the damaging thermal discharge and agreed to a settlement that includes a cash amount of just $4.5 million and other half-measures that will allow the PG&E and Diablo Canyon to continue its business-as-usual practices to the detriment of the marine environment." <http://www.nirs.org/press/02-22-2001/1>

An example of poor regulatory oversight leading to possible corruption was found at the PG&E Diablo Canyon power plant in the spring of 2000, as documented by a quote from San Luis Obispo's Mothers for Peace article, Pacific Gas & Electric (PG&E), for many years, provided state water authorities with skewed data on its Diablo Canyon nuclear power station. The data showed that the plant's intake of billions of gallons of water a day did very little harm to surrounding marine life. PG&E's conclusions were based on the unscientific formula that the amount of sea life drawn into the system at the intake port could be accurately measured by the amount of small fish and other organisms at the outflow of the cooling system.

In the spring of 2000, Diablo Canyon's operators were discovered to have withheld information from environmental regulators for two decades revealing the true effect of the reactor's hot water discharges into the coastal waters off Diablo Cove and miles beyond. The concealed data included infrared images indicating more extensive thermal plume impact zones than previously admitted and time-series photographs showing the progressive deterioration of biologically important marine habitat in coastal waters around the reactor. The damage was catastrophic to the indigenous marine life community, including the near obliteration of the already threatened black and red abalone populations. The concealed findings also revealed up to a 90 percent destruction of many varieties of sea life as they passed through Diablo Canyon's cooling system. These findings had never been reported to state or federal agencies.
From Water Quality Control Policy on the Use of Coastal and Estuarine Waters for Power Plant Cooling, State Water Resources Control Board, California, Environmental Protection Agency.


Once Through Cooling Destroys Marine Life

Diablo Canyon Power Plant's OTC system impacts fish larvae 47 miles along the shore and in nearshore waters as far as 2 miles out. As shown in Core Area 5, the kelp forest along the Pecho Coast is of great significance as well as the inner waters of the adjacent Morro Bay National Estuary waters where the now rare eel grass provides shelter for fish nurseries. The direct and indirect destruction reaches south into Core Area 3 and north into Core Area 6. Our San Luis Obisbo (SLO) County coast line is about 109 miles in length. This means almost half our SLO County nearshore waters are negatively impacted by PG&E's nuclear power plant. (See 2010/Nov)

Area 4

Area 5

Area 6


How OTC Destroys Marine Life

Drawn from roughly 93 square miles, about 2.5 billion gallons of seawater a day are processed  through the DCNPP Once Through Cooling system. This OTC system began operation at DCNPP in May, 1985.

Impingement - The killing of larger organisms such as fish, shrimp, crabs, jellyfish, and sea turtles by pinning them against screens covering the intake when the strong suction of seawater and marine life are brought into the OTC system. One estimate for DCNPP is 700-800 pounds of fish and crabs each year. (Diablo Canyon and PG&E Deal)

Entrainment - The killing of small marine life such as fish larvae and eggs when they are sucked into and drawn through the OTC system with the water. They die by combined effects of temperature, pressure, biocide residual and turbulence and then are expelled back to the aquatic environment in the effluent. The estimate for DCNPP is more than 1.5 billion larvae each year.  (Diablo Canyon and PG&E Deal)

Thermal effects. "Cooling water is typically 20 degrees warmer when it is discharged from Diablo Canyon’s cooling system. This influx of warm water alters the ecosystem of the discharge cove. Kelp, other forms of algae and small fish, particularly in the shallow areas along the shore of the cove, are the most heavily impacted."   (Diablo Canyon and PG&E Deal)

Read more: Diablo canyon and PG&3 Deal 2)


 Cooling water intake structures cause adverse environmental impact by pulling large numbers of fish and shellfish or their eggs into a power plant's or factory's cooling system. There, the organisms may be killed or injured by heat, physical stress, or by chemicals used to clean the cooling system. Larger organisms may be killed or injured when they are trapped against screens at the front of an intake structure.

Impingement kills marine life and is also a threat to the safe operation of a nuclear power plant. For example, in 2008, a large quantity of jellyfish became impinged and the power plant had to be manually shut down.

As reported by San Luis Obispo's Mothers for Peace, "Two nuclear power plants in California, Diablo Canyon and San Onofre,continue to degrade coastal waters indefinitely. The Federal Clean Water Act requires that cooling water intake structures minimize the environmental impacts to aquatic organisms due to impingement on intake screens and the killing of eggs and larvae as they pass through the cooling water systems. But Pacific Gas & Electric Company (PG&E) admits in its License Renewal Application that "For all regulatory and assessment purposes, entrainment losses caused by Diablo Canyon Nuclear Power Plant (DCNPP) are considered 100 percent of all organisms withdrawn from the Pacific Ocean with the intake flow under all conditions. Annual entrainment of larval fish is estimated to range between 1.48 and 1.77 billion."  

According to the California State Waterboard, as reported by San Luis Obispo's Mothers for Peace: "Diablo Canyon entrainment impacts an average source water coastline length of 74 kilometers (46 miles) out to 3 kilometers (2 miles) offshore, an area of roughly 93 square miles, for nine taxa of rocky reef fish. These rocky reef fish included smoothhead sculpin, monkeyface prickleback, clinid kelpfishes, blackeye goby, cabezon, snubnose sculpin, painted greenling, Kelp/Gopher/Black-and-Yellow (KGB) Rockfish Complex, and blue rockfish. In that 93 square mile source water area, an average estimated proportional mortality of 10.8 percent was calculated for these rocky reef taxa. The rocky reef fish species with the largest calculated coastline impact was the smoothhead sculpin, having an estimated proportional mortality of 11.4 percent over 120 kilometers (75 miles) of coastline during a 1997-98 sampling period. (Water Quality Control Policy on the Use of Coastal and Estuarine Waters for Power Plant Cooling, State Water Resources Control Board, California Environmental Protection Agency, at 30,) 

Copper Rockfish
Copper Rockfish

Kelp Rockfish
Kelp Rockfish

Monkeyfish Eel
Monkeyfish Eel

Kelp Rockfish
Rockfish

Cabezon
Cabezon

Further reports of studies are noted by  San Luis Obispo's Mothers for Peace, the California State Waterboard stated In its 2000 Staff Report


EPA and The Clean Water Act

"Although responsible for enforcing compliance with intake and discharge permits at reactors under the terms of the Clean Water Act, the EPA has largely failed to establish national performance standards," said Paul Gunter, Director of the Reactor Watchdog Project at NIRS and a report author. "When faced with the opportunity to enforce "best available technology" standards, the EPA has buckled to industry pressure and left the marine environment to pay the price." (See: NIRS.org)

Similarly, state water and wildlife authorities fall prey to nuclear industry pressure tactics and falsifications. In numerous incidents, nuclear utilities have falsified data and concealed and withheld information from environmental regulators that would have revealed the true extent of the environmental damages wrought by their reactor operations. "The nuclear industry plans to roll back environmental protections to create a new bottom line," said Linda Gunter, SECC Communications Director, and one of the report's authors. "The industry cries poverty when asked to install less destructive systems and again when told to mitigate the environmental damage," continued Gunter. "While nuclear utilities advertise themselves as environmentally friendly, in reality they are sacrificing the marine environment and its inhabitants on the altar of company profits." (See: NIRS.org )


California wants to preserve and restore the near shore marine environment

 Once Through Cooling Water Policy statement from the California State Water Resources Board:

The State Water Quality Control Board (SWQCB) passed a resolution in October 2010, which sets forth its policy for phasing out power plants that use OTC.

The Policy establishes technology-based standards to implement federal Clean Water Act section 316(b) and reduce the harmful effects associated with cooling water intake structures on marine and estuarine life. The Policy applies to the 19 existing power plants (including two nuclear plants) that currently have the ability to withdraw over 15 billion gallons per day from the State’s coastal and estuarine waters using a single-pass system, also known as once-through cooling (OTC). Closed-cycle wet cooling has been selected as Best Technology Available (BTA). Permittees must either reduce intake flow and velocity (Track 1) or reduce impacts to aquatic life comparably by other means (Track 2).

The Policy is implemented through an adaptive management strategy by which the standards can be achieved without disrupting the critical needs of the State’s electrical generation and transmission system. A Statewide Advisory Committee on Cooling Water Intake Structures (SACCWIS) has been established to review implementation plans and schedules and provide recommendations to the State Water Board at least annually. The State Water Board will consider SACCWIS’s recommendations and make modifications to the Policy, as appropriate. The permittees’ NPDES permits will be reissued or modified to conform with the Policy.

For more information see California’s Power Plant Once-Through Cooling Regulation

Thermal discharges - cooling water intake structures for DCNPP are implemented through NPDES permits. 

As authorized by the Clean Water Act, the National Pollutant Discharge Elimination System (NPDES) permit program controls water pollution by regulating point sources that discharge pollutants into waters of the United States. In California, the NPDES permit is authorized by the State Water Resources Control Board (SWRCB). (See SWRCB - Water_Issues)

Review Committee for Nuclear Fueled Power Plants

NPDES permits are in process for the two nuclear-fuled power plants in California ( DCNPP and SONGS ) for OTC. 

A special review committee for nuclear-fueled power plants was formed to oversee special studies the two power plants are required to perform. These studies will investigate ability, alternatives, and cost for each power plant to meet the policy requirements. ( See  SWRCB - Water Issues)

Permitting of Affected Power Plants - Diablo Canyon Nuclear Power Plant

The NPDES permit application for DCNPP, as well as letters, and Once-Through Cooling Special Studies and Interim Requirements Response are available on California's SWRCB website. (See Water Boards / Diablo Canyon)

Conclusion

California is working to ban OTC statewide due to the destruction caused to marine life and water quality. The California SWQCB is addressing OTC directly for each of the 19 power plants. The special studies of how to deal with OTC issues at the two nuclear plants will be completed for public comment in October 2013, with the Board's final decision after that. If an alternative is chosen, San Onofre is Required to be in compliance by 2022 and Diablo by 2024. Will these power plants follow state law, or will they file court cases to fight to continue using OTC? Subsequent articles will be written as this story develops.

The billions of marine life killed by OTC in PG&E's Diablo Plant is staggering and represents  threats to commercial and sport fisheries, near shore ocean ecosystems, local fishing industries, and coastal economies. Change is necessary at DCNPP for the health of California coastal waters and communities in San Luis Obispo County.

Newer cooling technology can replace the out-dated Once Through Cooling system used by DCNPP. However, instead of planning to replace  OTC, PG&E seems to want us to believe that their production of electricity for the CA electric grid is so important, they can go ahead and use OTC indefinitely. Continuing to rely on PG&E's outdated cooling system continues the degradation of aquatic life. Must we accept the marine life and ecosystem loss and the financial losses to the local tourism and the fishing communities? Or can we move to sustainable alternative energy sources? Please view the video posted on this link from California Coastkeeper Alliance.

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Underwater photos are by Terry Lilley with Sue Sloan doing the lighting.
Banner Image of Otter & Pup by Cleve Nash
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