Concerns and Risks of PG&E's Proposed
Central Coastal California Seismic Imaging Project
by Carol Georgi and Karl Kempton
Introduction
PG&E's proposed seismic testing is expected to destroy fish stocks for an unknown length of time. The local fishing associations are negotiating for paid mitigation for destruction of the commercial fish stocks. No mitigation is planned for the local communities' losses or for the ocean ecosystem destruction.
As we discuss concerns and risks of the seismic testing, we wonder:
*Is PG&E seismic testing in the most important locations?
*How much are coastal communities expected to sacrifice?
*How much destruction of the California Central Coast's marine ecosystem is acceptable for a few more years of PG&E's nuclear power plant operation?
Nuclear energy contributes proportionally less energy each year, now estimated at about 10%, to the California state grid due to the increase of alternative energy sources.
Safety and Financial Costs
Both safety and financial costs need to be known for the continued operation of PG&E's Diablo Canyon Nuclear Power Plant (DCNPP). The plant was built directly over a geological fault line, and is located near a second fault along the coast of San Luis Obispo (SLO) County, California.
Note: PG&E found evidence of an earthquake fault within 500 feet of the Diablo Canyon nuclear power plant in 1967 but chose not to pursue it to avoid "additional speculation and possibly delay the project." (4NR.org)
PG&E is required by CA State Law AB 1632 to perform seismic imaging studies to determine the earthquake safety of DCNPP. PG&E has requested $64 million of ratepayer funding to conduct the seismic studies.
Safety and costs need to consider that nuclear power plants eventually decommission. The question is not "if," but "when." DCNPP's Unit One operation began on May 7, 1985, and the permit ends November 2, 2024. Unit Two went online March 3, 1986, and is licensed to operate through August 20, 2025. These two licenses are for about 40 years each. PG&E is applying to renew these two licenses for an additional 20 years each.
In this video, Rochelle Becker, Executive Director of the Alliance For Nuclear Responsibility, describes the steps California can take as a state to ensure reliable and affordable energy and phase out seismically shaky and aging nuclear plants.
Addressing both safety and costs concerns, the Alliance for Nuclear Responsibility has filed an opening brief in California Public Utilities Commission (CPUC) case 10-01-014, PG&E's request for $64 million of ratepayer funding to conduct seismic studies at Diablo Canyon nuclear power plant. There are eight recommendations to the CPUC in the opening brief.
PG&E's Draft Environmental Impact Report (DEIR) Seismic
PG&E's March 2012 DEIR describes the proposed seismic imaging project and its impacts.
The DEIR states that impacts to air quality, terrestrial and marine biological resources, land use and recreation will be Significant and Unavoidable even after all mitigation measures are applied.
Map 1, from DEIR showing impact of one blast: Note that this illustration from DEIR offers only one view of impact to beach areas and thus down plays the actual series of testing impacts to recreational areas. Plus, it fails to show the Santa Lucia Bank 30 miles offshore that rises to within 1300 feet of the surface.
Two Main Concerns
There are many concerns about PG&E's proposed seismic testing. This article discusses two of the main concerns regarding PG&E's plans for ocean seismic testing in San Luis Obispo County.
Concern #1
PG&E neglects the main land location near Diablo Canyon's nuclear reactor unit 1 that should be the first consideration for seismic studies. What has to be demanded is 3-d images UNDERNEATH Diablo first.
This concern is best stated in the o2-01-2012 testimonies from Dr. Douglas Hamilton and Senator Sam Blakeslee, (R-San Luis Obispo) in a proceeding at the CPUC reviewing PG&E's Diablo Canyon seismic safety studies.
The testimonies question the quality of PG&E's proposed assessment of earthquake risks to the nuclear power plant. Dr. Hamilton was part of PG&E's Diablo Canyon geosciences team from 1971 to 1988. Senator Blakeslee authored AB 1632, the legislation requiring the seismic studies.
The testimonies were filed by the A4NR. The major points of both Dr. Hamilton and Senator Blakeslee are stated in A4NR's release: "A4NR Files Testimony by Former PG&E Geologist and State Senator Disputing New Diablo Canyon Seismic Work"
Quotes from A4NR's release:
Dr. Hamilton's quotes:
1)"PG&E has failed to consider or acknowledge any seismic implication from the progressive late Quaternary uplift of the Irish Hills…This has resulted in non-recognition or non acknowledgement by PG&E of what may well be the controlling seismic hazard to the seismic safety of DCNPP (San Luis Range/"Inferred Offshore Fault").
(Note -for further explanation-- see 1-1 - SEISMIC below in Concern 2 within the response letter to Ms. DeLeon)
*The A4NR recommends The CPUC should direct PG&E to configure its onshore and offshore seismic surveys to specifically address Dr. Douglas Hamilton's testimony concerning the Diablo Cove Fault and the San Luis Range/Inferred Offshore Fault and their interaction.
2)"…nothing in the planned additional surveys, both onshore and offshore, offers any prospect for any result beyond marginal improvement to what is already known."
Senator Blakeslee's quotes:
1) "My chief concern is that at the IPRP (Independent Peer Review Panel) public meeting on February 6, 2012, members of the IPRP raised a number of questions about the most recent study plan, for which the State Lands Commission is currently preparing a draft EIR. ……… that despite these fundamental and significant questions regarding PG&E's study plan, it appears that PG&E plans to proceed with the current study plan and has made no representation that they intend to address the IPRP's questions or concerns."
*The A4NR recommends yhe CPUC should require PG&E to formally respond in writing to IPRP review comments and, where the company chooses not to accept such recommendations, PG&E should be required to document its scientific reasons for such rejection. (4NR Open Brief)
We conclude from reading the testimonies:
PG&E's non-inclusion of the Independent Peer Review Panel (IPRP) results in less quality seismic studies when the best science needs to be provided to protect the lives of the San Luis Obispo community.
Concern #2
PG&E‘s proposed mitigation and monitoring of the ocean seismic testing are grossly inadequate. If concern #1 is addressed first, perhaps the destruction of marine life and the local fishing communities may not be necessary.
Seismic surveys use many air guns that release pressurized air bubbles, creating the sound source. The ‘source level' of most air gun arrays can be 200dB or higher. It is estimated that the marine life that does not leave the testing location will be destroyed. (See: Beachapedia.org)
Testing blocks & MPA-- State Marine Protected Area-- allows no taking of any kind
Extrapolating from map 1 is an approximation of the impacts of levels one and two around the testing areas as well as and more importantly, 1) the beach and recreational areas that one would assume have to be closed —— no mention of this in the DEIR; 2) illustrates the complete devastation to the kelp bed habitats from Pismo Beach north to above Cambria within the Monterey National Marine Sanctuary.
Shock Waves of One Blast
Concern #2 is discussed in our written response to the DEIR of PG&E's Central Coastal California Seismic Imaging Project to Ms. Jennifer DeLeon, Project Manager, CA State Lands Commission.
Dear Ms. DeLeon.
This project's proposed mitigation and monitoring are inadequate. We are concerned with several topics that are unstated or under addressed in the EIR.
In most cases, the EIR downplays the potential of worse case kill off, die off, and destruction of local marine life and ecosystem balance as well as harm to humans. Even worse, the overall tone of the EIR is an understatement of the most likely outcome of the sonic blasting of the ocean. Throughout the EIR, the least amount of damage to the ocean balance is assumed as the most probable outcome of the blasting of the ocean for 7/24, 82 days.
The most glaring omission is that neither a general nor detailed description of the marine web of life can be found. We note a total lack of narrative and study related to the complex web of life. The sonic blasts will greatly impact and in many cases either scatter or destroy populations critical to the web of life-- or food chain -- thereby causing a much greater and significant number of injured and overall damage than predicted by mere sonic waves. The most glaring contradiction is that the only species of concern are threatened, endangered and commercial while at the same time admitting, though understating, the impact on the Marine Protected Areas.
A question that needs answering by PG&E is what reparation will they make and in what form for every mammal, shark, whale, otter, and other marine creature that is washed up on the shores after the seismic testing?
We recommend that PG&E buy a marine reserve for 1 square mile for every victim washed up.
Significant References not included in the EIR
1-Marco seismic forces from land masses riding on the southern microplates captured by the northern moving Pacific tectonic plate.
2-The EIR is lacking in detailed listings of marine fish in the sonic blasting area and areas adjacent that will also be negatively impacted.
3-Impact to whales, porpoise and dolphins is understated.
4-The EIR's lack of detail of context and densities and diversities of marine life associated with the area of impact that is located between two national marine sanctuaries.
5- Destruction of the commercial and recreational fishing is treated lightly as civilians killed during war.
6. The EIR does not address the impacts to the marine life within the two national marine sanctuaries.
7 — Bibliography shows lack of thorough research.
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