ML103130044
"Draft Supplement" is not in the list (Request, Draft Request, Supplement, Acceptance Review, Meeting, Withholding Request, Withholding Request Acceptance, RAI, Draft RAI, Draft Response to RAI, ...) of allowed values for the "Project stage" property.
| ML103130044 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/29/2010 |
| From: | Hesser J Arizona Public Service Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 102-06272-JHH/GAM | |
| Download: ML103130044 (11) | |
Text
A M
A subsidiary of Pinnacle West Capital Corporation John H. Hesser Mail Station 7605 Palo Verde Nuclear Vice President Tel: 623-393-5553 PO Box 52034 Generating Station Nuclear Engineering Fax: 623-393-6077 Phoenix, Arizona 85072-2034 102-06272-J H H/GAM October 29, 2010 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529 and 50-530 Arizona Public Service Company's Comments on the Draft Supplemental Environmental Impact Statement Related to the License Renewal of PVNGS Units 1, 2, and 3 By letter dated August 12, 2010, the Nuclear Regulatory Commission staff notified Arizona Public Service Company (APS) of the availability of the draft plant-specific Supplement 43 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Palo Verde Nuclear Generating Station, also described as the Draft Supplemental Environmental Impact Statement (DSEIS). The notification stated that comments on the DSEIS may be submitted for staff consideration by October 29, 2010. Enclosed are APS's comments for staff consideration.
APS makes no new commitments in this letter. Should you need further information regarding this submittal, please contact Marty Eroh, Environmental Department Leader, at (623) 393-6688.
Sincerely, JHH/GAM
Enclosure:
Arizona Public Service Company Comments on the Draft Supplemental Environmental Impact Statement Related to the License Renewal of PVNGS Units 1,2, and 3 A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway ° Comanche Peak
- Diablo Canyon ° Palo Verde ° San Onofre
- South Texas
- Wolf Creek
& lyl
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Arizona Public Service Company's Comments on the Draft Supplemental Environmental Statement Related to the License Renewal of PVNGS Units 1, 2, and 3 Page 2 cc:
E. E. Collins Jr.
J. R. Hall L. K. Gibson J. H. Bashore L. M. Regner D. M. Drucker G. A. Pick NRC Region IV Regional Administrator NRC NRR Senior Project Manager NRC NRR Project Manager NRC Senior Resident Inspector (acting) for PVNGS NRC License Renewal Safety Project Manager NRC License Renewal Environmental Project Manager NRC Region IV (electronic)
ENCLOSURE Arizona Public Service Company Comments on the Draft Supplemental Environmental Impact Statement Related to the License Renewal of PVNGS Units 1, 2, and 3
Enclosure Arizona Public Service Company's Comments on the Draft Supplemental Environmental Impact Statement Related to the License Renewal of PVNGS Units 1, 2, and 3 Comment Page No. and Comment Suggested Resolution No.
SER Section Executive All of these sections discuss PVNGS use It would appear that the comparison of PVNGS groundwater
- Summary, of groundwater compared to apparently usage to Phoenix AMA groundwater usage is a more Page xiii, Line different numbers associated with the appropriate comparison than to "natural recharge." Suggest 7, and Page Phoenix Active Management Area (AMA).
revising the Executive Summary and Section 4.3.2 to match 4-2, Section In the first two cases the Draft Report the data in Table 4-11.
4.3.2, Line 22 states that PVNGS use of Groundwater is and 23, and less than 10% of the water that flows Table 4-11 on through the Phoenix AMA, but Table 4-11 Page 4-33 states that PVNGS use of groundwater is "inconsequential," i.e., less than 1% of annual demand. It appears that both of these comparisons are correct, but they could be confusing when viewed together.
It is assumed that the less than 10%
number is comparing PVNGS usage to "natural recharge" of the Phoenix AM, and the less than 1% number is comparing PVNGS Usage to the total Phoenix AMA cultural groundwater usage data.
Page 1-2, Draft states that the Scoping Process Change the date of the Scoping Process Summary Report to Section 1.3, Summary Report was issued in April, April 2010.
2 Line 10 2009 - the actual date had to have been after the Public Scoping Meetings took place on June 25, 2009.
Page 1-3 The "1" after (NRC 1996, 1999) should be Make the "1" a superscript.
3 Section 1.4, in superscript since it refers to a footnote.
Line 16 1
Enclosure Arizona Public Service Company's Comments on the Draft Supplemental Environmental Impact Statement Related to the License Renewal of PVNGS Units 1, 2, and 3 Co
.mmentmen.n Suggested Resolution, No..
` SER Section Commen Pages 1-8 Permit Dates can be up-dated / corrected.
Type 3 Reclaimed Water General Permit expiration Date and 1-9, should be changed from 6/22/2010 to 3/24/2015. The Pipeline Section 1.9, Repair & Maintenance Permit FA 20020002 Issue date should 4
Table 1-1 be changed from 8/18/2005 to 1/7/2002 and the Expiration Date should be changed from 7/31/2010 to "Not Listed." The Non-Title V Air Permit Expiration date should be changed from 7/31/2010 to 7/31/2015.
Page 2-1, On Page 2-1 the Draft states that there Change the total surface acres of water to 780 acres, and the Section 2.1, are approximately 605 surface acres of Evaporation Pond surface acres of water to 650 surface acres Line 14, and water on the site. On Page 2-29 the Draft as described in our Site Aquifer Protection Permit 100388.
Page 2-29, states that there are approximately 790 Section 2.2.1, surface acres of water, including three Lines 4 - 5.
evaporation ponds covering 660 acres.
5 The report should state that there are approximately 780 surface acres of water, including three evaporation ponds covering 650 acres. This is based on the 45 and 85 acre reservoirs and Evaporation Ponds 1, 2 and 3 being 250 acres, 220 acres, and 180 acres respectively.
Page 2-7, The Draft Report states that the Special Add the words "and cooling towers" at the end of Line 11.
Section 2.1.3, Approval Permit (Permit #7-368, Category Line 11 D18) is applicable to sludge from the PVNGS Water Reclamation Facility. For clarity, and in accordance with our Environmental Report, should add the words "and cooling towers" after "Water Reclamation Facility."
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Enclosure Arizona Public Service Company's Comments on the Draft Supplemental Environmental Impact Statement Related to the License Renewal of PVNGS Units 1, 2, and 3 Comment Page No. and Comment Suggested Resolution No.
SER Section Page 2-8 Revise the wording regarding the Remove the word "each" from line 21, and use the plural forms Section Pollution Prevention Plan for clarity, of "waste, emission, or toxic substance in line 22. Remove the 2.1.3.1 words "and newsletter" from line 28, and in line 30 and 31 7
replace "...and by implementing a P2 (Pollution Prevention) award program for their employees" with "...and by implementing an EHS Excellence award program for their employees."
Page 2-10, The Draft Report states that "Saguaros Add a statement at the end of the paragraph that states the Section 2.1.5, that are close enough to lines to pose this Saguaros can be transplanted outside of the border zone or 8
Lines 27 and risk are transplanted outside of the border trimmed.
28 zone. In addition to transplanting these Saguaros can be trimmed.
Page 2-14, The Reclaimed Water General Permit No.
Remove the sentence "It operates under a Type 3 Reclaimed Section 105317 is not for the operation of the Water General Permit (ADEQ Inventory # R1 05317)."
2.1.6.3, Line Water Reclamation facility. Permit No.
29 105317 is used to allow the discharge of Water Reclamation Pipeline water to farmers fields during certain maintenance activities. There is no specific operating permit for the Water Reclamation Facility.
Page 2-14, The Draft states that WRF-treated water Recommend removing the statement in parenthesis.
Section is also used for dust suppression at 10 2.1.6.3, Line PVNGS as required by Air Permit #
34 - 35 8600896. This permit number does not exist at Palo Verde.
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Enclosure Arizona Public Service Company's Comments on the Draft Supplemental Environmental Impact Statement Related to the License Renewal of PVNGS Units 1, 2, and 3 Comment Suggested Resolution Lines 37 and 38 of this page in the Draft Report make it sound like the Water Reclamation Pipeline is 36 miles of gravity fed pipe up to the Hassayampa Pump Station. In reality the total length of the pipeline is 36 miles, with the portion between 91st Avenue and the Hassayampa Pump station being gravity fed (first approximately 28 miles).
Clarify that the entire length of the pipeline is 36 miles, not the gravity fed portion as described in our Environmental Report.
Page 2-16, Section 2.1.7.2, Line 25 12 The Draft Report states that the Firing Range Well is used primarily for dust control. This well was never used for dust control but rather was used as a potable water source. The reference for this statement (APS-2004) does not indicate that the well was used for dust control.
The reference states that the well is an exempt well, with its primary purpose being "Industrial." However, this does not mean dust control, but rather it was used to provide drinking water to a non-public population.
Revise statement to state that Groundwater from the range well was used to provide potable water to the firing range.
Page 2-19, This section of the Draft Report is Suggest replacing "It" with "The 45-Acre Reservoir."
Section discussing both the 85 and 45 Acre 2.1.7.4, Line Reservoirs. The sentence starting at the 34 end of Line 34 states "It has a maximum depth of about 46 feet..." The "It" refers to the 45-Acre Reservoir.
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Enclosure Arizona Public Service Company's Comments on the Draft Supplemental Environmental Impact Statement Related to the License Renewal of PVNGS Units 1, 2, and 3 Comment Page No. and Comment Suggested Resolution No.
SER Section Page 2-20, The Table lists facilities regulated by our Recommend adding Sedimentation Basins 1 and 2 to Table Table 2.1.7-2 Aquifer Protection Permit - but it does not 2.1.7.2 as detailed in our Site Aquifer Protection Permit (the list the Sedimentation Basins. The main current reference for the Table).
impact of the APP regarding the 14 Sedimentation Basins is that it requires monitoring of Unauthorized (or Non-Exempt) Discharges to the Sedimentation Basins and it addresses final Closure of the Sedimentation Basins.
Page 2-21, The Draft report states that Evaporation Since Evaporation Pond #2 is currently being rebuilt, and Section Ponds #1 and #2 are both double-lined Evaporation Pond #1 will be rebuilt after Evaporation Pond #2 15 2.1.7.4, Line 7 and both have an Underdrain System.
is complete, suggest changing the wording to state that both
- 10 This is not accurate; see Site APP ponds are lined surface impoundments, and remove any Sections 5, and 6.
reference to an underdrain system for these ponds.
Page 2-21, The Draft Report states that the average Suggest removing the word "each" and replacing with "all Section annual flow rate to each pond is 3,125 evaporation ponds combined."
2.1.7.4, Line gpm (the provided reference is our site 16 Aquifer Protection Permit - APP). The 16 provided reference could be read as stating that this is the average annual flow rate to each pond, but it is meant to state that this is the estimated average annual flow to all of the evaporation ponds combined.
Page 2-22, The Draft Report appears to refer to the Suggest adding a comma between STP and Retention Tanks Section "STP Retention Tanks." These are two in lines 31 and 32, and remove "STP" between the words 17 2.1.7.4, Lines separate facilities.
"exempt" and "retention" in Line 36.
31 - 37 Page 2-22, The draft report indicates that the APP is Suggest removing the words "drinking water" in Line 39.
Section designed to protect the drinking water 18 2.1.7.4, Line aquifer in the vicinity of PVNGS. The 39 purpose of the state's aquifer protection pro ram is to protect all Aquifers.
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Enclosure Arizona Public Service Company's Comments on the Draft Supplemental Environmental Impact Statement Related to the License Renewal of PVNGS Units 1, 2, and 3 Comment Page No. and Comment Suggested Resolution No.
SER Section C
Page 2-23, The Draft Report states that the APP Suggest wording such as "The APP requires that cooling tower Section requires cooling tower sludge and WTF sludge be sampled prior to disposal, and WTF (Wastewater 2.1.7.4 Line (Wastewater Treatment Facility) sludge Treatment Facility) sludge be sampled on a twice per year 19 39 be analyzed prior to disposal in the basis."
sludge landfill. The site APP does require analysis of cooling tower sludge prior to disposal, but allows sampling of WTF sludge in place.
Page 2-26, The Draft report refers to three The downgradient wells are actually APP-9, APP-1 0, and APP-Section downgradient wells (APP-01, APP-10, 12, and they were drilled to a depth of 110 - 180 feet.
2.1.7.4, Line and APP-1 1) drilled to depths of 80 - 90 Assuming that the Draft Report is referring to these 25 - 31 feet. The correct well numbers are: APP-downgradient wells and other Aquifer Monitoring Wells when it 9, APP-1 0, and APP-1 2, and they were states that tritium has not been detected above the Arizona 20 drilled to depths of 110 - 180 feet. The Water Quality Standard of 20,000 pCi/L - it would be more report also states that tritium has not appropriate to state that Tritium has never been detected in been detected above the Arizona Water any of these wells.
Quality Standard of 20,000 pCi/L in these wells or in groundwater from other site monitoring wells.
Page 2-32, The "3" after PTE and the "4" after HAPs Change the "3" after PTE and the "4" after HAPs to superscript.
21 Section should be superscript since they refer to 2.2.2.1, Line 1 footnotes.
Page 2-32, The Draft report States that a Major In the first sentence of footnote #4, change 5 ton per year of Footnote #4 Source of HAPs is a Stationary Source any single HAP to 10 ton per year of any single HAP.
22 that emits more than 5 tons per year of any single HAP. This should state 10 tons per year of any single HAP.
Page 2-41, The draft report refers to "three large lined Change the "three large" to "two large" lined storage reservoirs.
Section 2.2.5, storage reservoirs." There are only two Line 10 storage reservoirs: the 85 and 45 Acre I Reservoirs.
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Enclosure Arizona Public Service Company's Comments on the Draft Supplemental Environmental Impact Statement Related to the License Renewal of PVNGS Units 1, 2, and 3 Comment Page No. and Comment No.
SER Section suggested Resolution Page 2-54, The Draft Report states that PVNGS Suggest revising the report to state that PVNGS provides more Section provides almost 100 ten-passenger vans.
than 100 ten-passenger vans.
2.2.8.2, Line Our Environmental report stated that we 19 have a fleet of 169 vans.
Page 2-56, The Draft Report states that height of the It would appear that these numbers are reversed. During the Section plume from the cooling towers can be cooler winter months the plume from our cooling towers is 25 2.2.8.4, Lines 1,900 feet on an average summer typically higher than on a summer morning.
20 - 22 morning and 870 feet on an average winter morning. This statement is not referenced.
Page 2-61, The Draft Report states that Maricopa Table 2.2.8.6-3 is correct, but the verbiage on page 2-61, Section County collected between $3.3 and $4.3 Section 2.2.8.6 is incorrect. The $3.3 and $4.3 billion figures 26 2.2.8.6, Line billion in property tax revenues from all are total county tax revenues. Also recommend that Table 12 PVNGS owners (see Table 2.2.8.6-3).
2.2.8.6-3 be revised by replacing "APS" in the Description of the Table, and in columns 3 and 4 with "PVNGS."
Page 4-4, The draft report states that tritium was not For clarification suggest adding the word "aquifer" between Section detected in any monitoring wells at "any" and "monitoring well" due to the shallow tritium impacted 4.3.4.1, Line PVNGS in 2008.
water that has been found around certain piping features.
11 Page 4-4, In lines 30 and 34 the acronym WRS is Change WRS to WSR.
Section used for Water Storage Reservoir instead 28 4.3.4.2, Lines of WSR.
30 - 35 Page 4-14, The Draft Report states in the second Suggest removing the second sentence of the 3V paragraph of Section 4.8.3, sentence of the paragraph that a new Section 4.8.3.
Lines 33 and criterion has been added to the NESC for 29 34 power lines with voltages exceeding 98 kV. The criterion being discussed (5 mA induced currents due to static effects) was in effect when the Palo Verde transmission lines were built.
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Enclosure Arizona Public Service Company's Comments on the Draft Supplemental Environmental Impact Statement Related to the License Renewal of PVNGS Units 1, 2, and 3 Comment Page No. and Comment Suggested Resolution No.
SER Section Comment___SuggestedResolution____
Page 5-11, The reference to the NRC's SAMA review Change the sentence to the following:
30 Section 5.3.1 should be changed from Appendix G to Lines 24 and Appendix F because Appendix F contains The NRC Staff's review is available in full in Appendix F G.
25 the SAMA review.
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