Seismic Studies Likely To Be Delayed
Summary: PG&E got the go ahead from the California State Lands Commission to begin its seismic testing aimed at better understanding of faults around the Diablo Canyon Nuclear Plant in order to better prepare for an earthquake. The plan is to begin the testing in November, but that goal is undermined by the fact that nine other state and local agencies have to review the project and it is unlikely they will be finished by November, possibly forcing the studies to be delayed.
PG&E's widely-condemned seismic studies project — designed to gain more information about faults in a broad ocean area around the Diablo Canyon nuclear plant to help in preparing for earthquakes that could trigger a disaster at the plant and over surrounding areas but also is forecasted to kill many fish and other aquatic life — has been approved by the California State Lands Commission.
But the decision contains a major hidden surprise that is almost certain to spoil the decision's implementation anywhere soon.
Ecosound
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This key approval by the Commission in Sacramento on August 14 has been expected to clear the way for the seismic studies to begin in November and covering over 15 nautical miles from Monterey Bay to Santa Maria — complete with a ship towing air guns and three additional vessels operating a multibeam ecosounder for plotting sub-bottom ocean terrain.
But what hasn't been brought out is the fact — buried in the Lands Commission documents — that nine other state and local agencies must review the granting of a permit to conduct the seismic studies by PG&E before it is allowed to go forward. Some of the nine agencies apparently have the power to make recommendations that could trigger long delays in the start of the project. As a practical matter, it is highly unlikely that there is enough time for all of these agency reviews to be completed before November. (The agencies besides the Lands Commission are the California State Parks, California Department of Fish and Game, Central Coast Regional Water Quality Control Board, National Science Foundation, National Marine Fisheries Service, United States Fish and Wildlife Service, United States Army Corps of Engineers, United States Coast Guard, and San Luis Obispo Air Pollution Control District.)
The first of those nine agencies to review the Commission's action is the California Coastal Commission, which has the authority to deny a Coastal Development Permit, and that would scuttle the tests, or the Commission could modify the permit. The Commission is planning to take up the matter at its October 10-12 meeting in Oceanside, just north of San Diego. No specific date or staff report on the project has been made available yet.
The only reference the Lands Commission has made about when the seismic studies will begin was this: "If all the necessary permits are granted by state and federal agencies, the high-energy study could begin this fall." But that may be a tall order.
A PG&E spokesman said, "Under the approved State Lands Commission permit, the windows to conduct the survey are November to December of 2012, and the same time period in 2013. Should PG&E receive other needed state and federal approvals, the goal is to survey two of the identified survey tracks this year and focus on the third remaining track in 2013. During and after the first survey track, we will evaluate marine life mitigation measures to ensure their effectiveness and make any appropriate modifications. The survey time period of November through December is the time of year in which there are the fewest number of marine mammals off the Central Coast. It is also a low fish larvae period. The window for the study would also occur outside the peak gray whale migration season."
So PG&E recognizes the uncertainty surrounding whether the project will be launched as planned.
PG&E said the "technologies and methods to be used to conduct the final high-energy study were developed in consultation with experts from the National Science Foundation, Columbia University, the University of Nevada-Reno, Scripps Institute of Oceanography, and private industry. PG&E's advanced seismic research was called for by the state."
AB 1632 would also require the commission, in absence of a long-term nuclear waste storage facility, to assess the potential state and local costs and impacts associated state.
The Lands Commission has received a large number of comments about the project at Commission hearings on the permit over the past year, virtually all opposed to the project because of concern about the loss of aquatic life in the process. The Lands Commission said, "Forty-nine speakers provided comments at the Commission's public hearings in July 2012, and staff received 85 written sets of comments. In total, more than 750 individual oral and written comments were received at the hearing and via mail, email, and petition."
But other calculations estimate the comments have been made by 264 individuals and as high as 387 — and these figures may not include those who signed petitions opposing a permit for the studies. (For a list of names of individuals who made comments go to SLCA.ca.gov and SLCA.ca.gov - Division_Pages.)
The proposal to conduct three-dimensional studies of the ocean floor along the Central Coast grew out of Assembly Bill 1632, which was enacted into law in California in 2006. It directed the California Energy Commission "to assess the vulnerability of the state's operating nuclear power plants to a major disruption due to a major seismic event or plant aging, the potential impacts of such a disruption, potential impacts from the accumulation of nuclear waste at the state's existing nuclear plants, and other key policy and planning issues regarding the future role of California's existing nuclear plants." The bill did not actually require the kind of seismic studies that PG&E is pursing, a Lands Commission official noted, but its new Environmental Impact Report (EIR) said that "PG&E's advanced scientific research was called for by the state."
PG&E said it proposed the seismic studies project in response to the California Energy Commission's recommendations that advanced geophysical studies, including 3D seismic surveys, be performed near Diablo Canyon to better characterize faulting in the area.
PG&E said it "knows that these high-energy studies could impact local commercial fisheries" and has held discussions with fishing representatives. The EIR stated that "the Project would not be expected to modify habitat of special status species, cause a substantial interference with the movement of a native resident or migratory fish species, or cause a population to drop below self-sustaining levels. Therefore, the potential for the seismic survey to result in injury or mortality of adult fishes would be Less than Significant."
It also said that, "Based on information available, the effect on fish eggs and larvae are expected to be limited (only at high noise levels and in close proximity to the air guns). Combined with survey timing that would likely avoid peak larval seasons, the overall effect on planktonic resources, including juvenile fishes, would be Less than Significant."
Additional EIR statements about the impacts of the studies on aquatic life can be found at FEIR_4.04_BIOLOGICAL_RESOURCES-MARINE. (Evidence that the impacts of the testing on various categories of aquatic life is not readily available.)
PG&E said it has presented them an offer of $1.2 million as compensation. A claims process has also been established for all parties that are impacted by the project.
Two weeks ago on August 14, the California Public Utilities Commission issued a proposed decision for PG&E's seismic studies application, which authorizes PG&E to recover up to $64.25 million from state taxpayers to finance the project. The Commission reportedly has yet to approve the decision.
Although little noticed in the uproar over anticipated fish losses from the seismic studies, the bill also requires the State Energy Resources Conservation and Development Commission "to compile and assess existing scientific studies, as specified, to determine the potential vulnerability, to a major disruption due to aging or a major seismic event, of large baseload generation facilities of 1,700 megawatts or greater, including a specified analysis of the impact of a major disruption on system reliability, public safety, and the economy."
The bill would also require the commission, "in the absence of a long-term nuclear waste storage facility, to assess the potential state and local costs and impacts associated with accumulating waste at California's nuclear power plants (Diablo Canyon and San Onofre), and to further assess other key policy and planning issues affecting the future role of nuclear power plants in the state."
Storage of nuclear waste at nuclear plants and the growing shortage of space there for the waste is considered a prime vulnerability in the their continued existence. This appears to be a new involvement by the state in the issue.
The California State Lands Commission's just adopted EIR describes the PG&E seismic studies plan this way:
PG&E would perform a deep (6 to 9 miles) , high-energy seismic survey (that is, a survey involving equipment requiring energy input of greater than 2 kilojoules) with the intention of gathering additional scientific information that would help PG&E better understand the relationships and/or connections among several fault zones located in the vicinity of the Diablo Canyon Power Plant.
Based on geological studies conducted prior to installation of the Diablo Canyon plant as well as more recent studies, several faults — including the Hosgri, Los Osos, San Luis Bay, and the recently (2008) discovered Shoreline fault — are known to be in the plant's vicinity. However, their geometries and interconnections with each other are not fully understood. PG&E's geosciences staff believes conducting the additional studies that comprise the project would provide the additional scientific information necessary to improve characterizations of these fault zones and allow PG&E to refine estimates of the frequency and intensity of ground motion that is likely to occur in the area surrounding the plant. This information may be a significant step in improving estimates of the potential seismic hazard at the plant.
The areas to be covered by the project are (see map):
A. Onshore area –- Seismic survey activities would be conducted within three onshore areas, with additional staging areas on the power plant property.
— 1. South of Cambria, an area approximately 6.5 miles long and 4.5 miles wide, involving the deployment of recording devices only.
— 2. Along Morro Strand Bay sandspit (within the Morro Dunes Natural Preserve), an area approximately 5.5 miles long. This area would be subject to the deployment of recording devices only.
B. Near the power plant, an area approximately 10.5 miles long and approximately 2 miles wide. Both the use of active sources and passive recording devices is planned.
C. Nearshore area. The area immediately offshore of the power plant, approximately 18.5 km along the coast and extending up to 7.4 km offshore. Water depths within this area are up to 330 feet. This area includes a State-designated Marine Protected Area. This component would involve the use of both active sources and the installation of passive recording devices on the sea floor.
D. Marine area. This area is farther offshore of the plant, between Cambria and Guadalupe, approximately 79.6 km in length and 29.6 km offshore. Recording devices would be used.
